United States Office of Air Quality EPA-450/3-82-027
Environmental Protection Planning and Standards November 1983
Agency Research Triangle Park NC 27711
_
vvEPA Revisions to
Method 3,
Appendix A of 40
CFR Part 60 -
Summary of
Comments and
Responses
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EPA-450/3-82-027
Revisions to Method 3, Appendix A
of 40 CFR Part 60 -
(Proposed September 7, 1982, 47 FR 39204)
Summary of Comments and Responses
Emission Measurement Branch
Emission Standards and Engineering Division
U.S. ENVIROMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
November 1983
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This report has been reviewed by the Emission Standards and Engineering Division of the Off ice of Air Quality Plannin
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended t
constitute endorsement or recommendation for use. Copies of this report are available through the Library Service
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711;or,forafee,fror
the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
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TABLE OF CONTENTS
Page
Chapter 1. Introduction 1
Chapter 2. Summary of Changes Since Proposal 2
Chapter 3. Summary of Comments and Responses 3
Table 1. List of Commenters 39
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Chapter 1
Introduction
On September 7, 1982, the U.S. Environmental Protection Agency
(EPA) published in the Federal Register (47 FR 39204) "Revisions to
Method 3, Appendix A of 40 CFR Part 60." These revisions were proposed
under authority of Sections 111, 114, and 301 (a) of the Clean Air Act
as amended.
Public comments were solicited at the time of proposal. To
provide interested persons the opportunity for oral presentation of
data, views, or arguments concerning the proposed revisions, a public
hearing was scheduled for November 8, 1982. The hearing, however, was
not held because no one requested to speak. The public comment period
was from September 7, 1982, to November 8, 1982.
Seventeen comment letters on the proposed revisions were received
from industry, State air pollution control agencies, trade
associations, and testing consultants. The comments that were
submitted, along with EPA's responses, are summarized in this document.
The summary of comments and responses serves as a basis for the
revisions that have been made to the test methods between proposal
and promulgation.
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Chapter 2
Summary of Changes Since Proposal
1. The F0 check is made an optional procedure instead of a
s
mandatory one.
2. Sections 4.1.5 and 4.2.7. These paragraphs are revised to
replace the words "Citation 5 in the Bibliography" with "Section 4.4"
so that the quality control procedures are identified specifically.
3. Section 4.4. The heading is changed to "Quality Control
Procedures" to indicate the optional nature of the procedures.
4. Section 4.4.1. Changes are made to this section to explain
the use and applicability of the F0 method.
5. Sections 4.4.1.1 and 4.4.1.2. These paragraphs are added to
explain the F0 calculation procedures and to account for high CO
concentrations and for mixed fuels.
6. Section 4.4.1. The table of F0 values is changed to a range
of values for each fuel type and is used in place of the +5 percent
acceptance limit in the proposed revisions.
7. The requirement for an ambient air check of the Orsat is
deleted.
8. Method 19, Table 19.1. The value for Fc for wood bark is
corrected.
9. Method 19, Section 5.2.2. The equations for fuel factors
are corrected.
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Chapter 3
SUMMARY OF COMMENTS AND RESPONSES
Commenter IV-D-1
1.1 Comment: Sections 4.1.5 and 4.2.7. The proposed change from
running analyses for either C0£ or 03 to running analyses for both
C02 and Og is acceptable as this is the procedure the company has
been following.
Response: No response is necessary.
1.2 Comment: Section 4.4.1. Data validation or verifying that
the fuel factor is +5 of the established value is primarily a check on
the chemicals in the Orsat analyzer used in determining the C02
concentration, and can be readily incorporated into company procedures.
Response: No response is necessary.
1.3 Comment: Section 4.4.2. Checking Orsat chemicals for
detecting Q£ by analyzing ambient air is a standard procedure before
each use. The proposed requirement to add a post check is a good
quality assurance (QA) check which can be easily implemented.
Response: No response is necessary.
1.4 Comment: Section 4.4.3. The reference to "above criterion"
should be replaced with a specific: reference citing the appropriate
section or sections. Clarification is also needed as to what "sampling
and analysis and quality assurance check" is to be repeated when
criterion is not met. It is unclear whether this section applies to
just the test of the gas sampling or the complete run,.
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Response: The criterion of+5 percent is increased and is
replaced with a table of acceptable F0 ranges for each fuel type. The
promulgated version of the revisions does not contain a requirement for
retesting if the check limits are not met, but recommends that the
problem be investigated and suggests some typical areas for
investigation.
Commenter IV-D-2
2.1 Comment: When the Orsat apparatus is used to determine the
gas composition, it is typical to analyze the gas for oxygen, carbon
dioxide, and carbon monoxide in order to provide data for the molecular
weight of the gas, emission rate correction factor or the excess air
ratio. Thus, no additional effort is required by this revision. The
calculation of the F0-factor is easily done with the Orsat results.
Response: No response is necessary.
2.2 Comment: The analysis of a sample of ambient air after the
analysis of the source gas sample will add 15 to 30 minutes to the
compliance test, but will provide credibility to the data. If the
proper air composition data are obtained, it will show that the
absorbing solutions are not exhausted. Without this ambient air
sample, the results of the final runs of source gas are assumed
correct. This has been inferred in the past, if the three analysis
runs on each sample of source gas gives essentially identical results.
As the absorber solutions become depleted, they will absorb less gas
and the results on the individual components would decrease on each
run.
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Response: It is not necessarily true that partially deplet
absorbing solutions will lead to lower or incorrect measurement of ga
component concentrations, but more passes will be necessary to achiev-
complete absorption. Analysis is easier and, thus, more likely to be
accurate with fresh absorbing solutions.
Comtnenter IV-D-3
3.1 Comment: Calculating the F0 factor seems worthwhile.
However, it would be more convenient to state the acceptable range of
F0 values for a given fuel rather than state, "... +5" (I assume
percent) "of the established value. . ."
Response: An F0 table is included in the promulgation
version that lists the acceptable range for each F0 factor. The rangi
are generally greater than +_5 percent and are more representative of
actual ranges experienced in field tests.
3.2 Comment: The F0 procedure here does not provide for those
cases where multiple fuels are burned. It is not at all unusual to
see boilers at furniture factories in North Carolina which burn wood
and oil simultaneously.
Response: The calculation of the F0 factor for mixed fuels
included in the final procedure.
3.3 Comment: Performing an Orsat measurement on ambient air
appears to be a waste of time, effort, and Orsat 02 reagent. It
proves nothing about the accuracy of results for stack gas. In the c
where the 02 reagent becomes exhausted during the performance on
air, it has not shown that it was exhausted, previously. I think that
the requirement for three repetitions of the Orsat method on a given
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gas sample gives about as good proof as you are going to get that the
method is performed correctly and that the Orsat reagents are
sufficiently active.
Response: The purpose of the analysis of the air sample is
to check the equipment, the analyzer, and the technique to measure
accurately a known concentration. The chemical strength of the
absorbing soluticn is checked in another section of the method
(Section 4.2.5). The Agency agrees that obtaining an accurate
measurement of Q£ for an air sample does not assure that measurements
in other ranges or of other components are accurate; however, an
inaccurate measurement of the 03 concentration in air is an indication
of a serious problem in the equipment or the technique that should be
investigated before accepting the results.
3.4 Comment: While you are out to change things, why not say
something about 03 meters (fuel cell or paramagnetic detector types)?
Response: The scope of these revisions does not include
02 meters.
3.5 Comment: Aside from good Orsat technique, the most
important thing for accurate results is a leak free sampling setup. A
leak check from probe tip to sample bag before and after sampling
seems worthwhile.
Response: In Method 3, Sections 4.1.2, 4.1.5, 4.2.2,
and 4.2.7 describe mandatory leak-check procedures for sampling
equipment. Section 5 describes the leak-check procedure for
Orsat analyzer equipment. No additional leak-check procedures are
required.
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Commenter IV-D-4
4.1 Comment: The proposed revisions to Method 3 contained
in Appendix A of 40 CFR Part 60, are questionable as to their quality
assurance benefit. Method 3 presently requires that an individual
analysis not differ by more than 0.3 Ib/lb-mole from the mean of the
required minimum of three analyses. While the procedure does not
necessarily document the accuracy of the results, it does document the
precision of the analysis.
Response: The precision check of the molecular weight
determination is not part of these revisions. In addition, the
molecular weight check is really insensitive to Orsat errors and does
little to indicate the accuracy of the 02 or 002 measurements.
4.2 Comment: My interpretation of the intent of the proposed
revisions is to certify the absorbing reagents are not; depleted during
the analysis by a comparison to ambient air. Any depletion of an
absorbing reagent should be obvious when comparing the results to the
prior analysis and become even more obvious with the next analysis.
There is also the chance the absorbing solution may become depleted on
the ambient air analysis, thus making the stack gas analysis results
questionable. If a procedure change must be made to ensure the
accuracy of the results, it would require an ambient air analysis
prior to the stack gas analysis and an ambient air analysis after the
stack gas analysis to bracket the data. This procedure would only
serve to enhance the chance of absorbing reagent depletion during the
stack gas analyses or the final ambient analysis. The presently
required quality assurance procedure seems adequate.
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Response: See Response 3.3.
4.3 Comment: The use of a fuel factor, F0, for verification
of ±5 percent of the established value is also questionable. The fuel
factor does not allow for combinations of fuels.
Responses: See Response 3.2.
4.4 Comment: The F0 values can vary with the ultimate analysis
of the fuel. Does the _+5 percent tolerance allow for experimental
error such that the summation of the experimental error and the
expected variance in the F0 for a particular fuel type does not exceed
5 percent? EPA publication EPA 450/2-79-006 reports maximum deviations
(percent) from the midpoint F0 factors for bituminous coal and oil as
being 4.5 percent and 4.1 percent, respectively.
Response: See Response 3.1.
4.5 Comment: An inspection of the fuel factor formula indicates a
conservative bias in respect to the percent excess air used in a
facility, A 0.1 percent difference by volume in the analysis of either
C0£ or 02 generates a greater deviation from the "established F0
value" with an increase in excess air. It is obvious that the greater
the excess air, the more the probability the resultant calculated F0
will exceed the _+5 percent. It is not uncommon for wood-fired boilers
to use 500 percent excess air. A ±0.3 percent difference by volume in
analysis would generate a ±5 percent difference in F0. Orsat analysis
required accuracy is ±0.3 percent difference by volume.
Response: See Response 3.1. In addition, this comment shows
the need for greater assurance of Orsat accuracy at higher excess air
conditions in order to obtain accurate measurement of emission rates.
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4.6 Comment: It is thought the proposed revisions would not
enhance the presently established quality assurance procedures and
should not be incorporated into Method 3.
Response: The Agency disagrees with this comment that the
F0 calculation is not a good indicator of the accuracy of Orsat
measurements. However, there are several difficulties in the
application of the F0 procedure as. a requirement that have led the
Agency to revise the proposed required calculation to a recommended
procedure in the promulgated version. These difficulties include:
(1) problems with sources determining a suitable F0 value for mixed
fuels because the ratio of fuel combustion rates is not always easily
or accurately determined; (2) suitable F0 values are not readily
available for all fuels such as vegetable wastes or organic chemical
wastes; (3) the F0 procedure would not apply to all tests with the
Orsat, only to those on sources burning organic fuels, making the
requirement unequally applied; and (4) rejection of a test run or set
of runs because of an errant F0 check is severe in many cases as the
solution to the problem can be found without retesting.
Commenter IV-D-5
5.1 Comment: Better clarification is needed to indicate that
the revision only applies when determining emission correction factors
or excess air for combustion sources. The supplemental information
section states that these revisions would apply to all sources subject
to standards of performance specifying the use of Metnod 3 for Q£ and
C02-
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Response: These revisions are located only in Section 4 of
the method which applies to excess air correction and emission rate
calculations.
5.2 Comment: Section 4.4.1 states that one must "verify that
the fuel factor, F0, is within j^5 of the established value . . . ."
This appears to be a large variation, considering the range of values
suggested in the published table, and we suspect a typographical error
was made in this "+_5" value. If this is an error, two likely
possibilities exist, "_+5" or "+5 percent". If the Agency intended a
5 percent variation limit for the F0 factor, then this range is too
restrictive. Absolute errors of only 0.2 percent in values of both
the Q£ and C02 readings can result in a 5 percent variation in the
fuel factor, F0.
Response: See Response 3.1.
5.3 Comment: It is very easy to exceed +0.2 percent using the
Orsat analyzer. We suggest reviewing EPA's June 1982 quality assurance
audit for Orsat analysis of 02 and C02. According to this audit,
less than 20 percent of the participants could expect to meet the 5
percent limit based on accurate 02 and C02 measurements. Only with
off-setting inaccuracies in the 02 and C02 determinations (one high
and one low) could more than 20 percent of the participants expect to
meet the 5 percent limit.
Meeting this limit by compensating errors will not assure good
quality data. On the contrary, it will provide a false sense of security
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that the data is reliable, when in fact it will be in error to the
extent of the error made in the 02 or C02 gas concentration measurement.
Response: The Agency feels that the F0 factor calculation is
an important indicator of just the problem the commenter mentions.
Inaccurate measurement of 02 or CC)2 concentration will be indicated by
the F0 calculation. Other problems, such as leaks, are addressed in
other sections of the method. The Agency reviewed the audit results
mentioned by the commenter and determined most of the problems
encountered in obtaining accurate analyses were a result of leaks.
This indicates more of a problem with obtaining a representative audit
sample rather than an inherent analysis or field testing problem.
5.4 Comment: The revision should recognize and emphasize the fact
that some sources will not have the same F0 factors that are
calculated from the fuel type. For example, the F0 factor on a glass
melting furnace firing gas is on the order of 1.3, not 1.75. This
much lower value results from large volumes of C02 liberated from the
glass batch during melting. Batch composition changes will result in
variable F0 factors.
Response: The intent of the revision was not to cover
all industry sources, but to apply where excess air or emission rate
correction calculations are required. We agree glass manufacturing
is an example of a source for which the F0 factor is not applicable.
5.5 Comment: A simplified technique should be utilized to
estimate a comparative F0 value when a mixture of fuels is utilized,
e.g., oil and gas.
Response: See Response 3.2
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Commenter IV-D-6
6.1 Comment: I agree with these proposed revisions and consider
them to be necessary parts of professional sampling procedure.
Response: No response is necessary.
6.2 Comment: However, the other proposed revision—assuring that
the gas analysis results agree with the limits specified for the fuel,
using the F0 factor procedure—cannot be unilaterally applied to all
industries regulated by 40 CFR Part 60. According to the proposed
revision, the F0 factor for Portland cement plants, using a bituminous
coal fuel source, should be 1.140. Method 3 gas analysis data of our
wet process Portland cement plants' stack gases, indicate an average
F0 of about 0.70. The disparity in the F0 factors arises from the
assumption that all C02 in the stack gas is generated from fuel
combustion. In Portland cement production, C02 is generated from
the raw materials. In the calcination process of cement production,
calcium carbonate (limestone) is converted to calcium oxide (lime) and
carbon dioxide. While we would expect C02 concentrations of 12.5
percent to 13 percent from the fuel combustion, we experience C02
concentrations of approximately 20 percent to 21 percent from the
fuel combustion and the calcination process. The FQ factor is only
meaningful for industries which do not, during their production
processes, affect the C02:02 ratio.
Response: This is true and the revisions note for which
industries the checks can be applied. The promulgation version will
contain more explanation about applicability. See Response 5.4.
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Commenter IV-D-7
7.1 Comment: The authors are not clear as to the specific
objectives for modifying the QA procedures for Methods 3, 4 and 5.
Confusion is furthered by not addressing the problems associated with
the proposed methods, and more important, not addressing why current
QA procedures are not fully enforced.
Response: The promulgation version addresses the issues
with the proposed revisions raised by the commenters. Addressing
the reason current QA procedures are not enforced, is not within the
scope of this revision.
7.2 Comment: EPA suggested, but not mandatory, QA handbook and
QA source survey are not mentioned at all.
Response: The intent of these revisions is to include
quality control procedures not already included in the method that
would enhance data quality. The references mentioned by the
commenter are available from other sources.
7.3 Comment: Stating that "little additional effort is required"
is entirely subjective and dependent on a large number of factors.
Potentially, great effort could be required to satisfy these proposed
requirements, when equivalent alternatives are available.
Response: If the measured quality control checks do not fall
within the specified limits, there is indication of some serious error
in the sampling or analysis. Time should be given to finding the
source of the error and resolving the data. The promulgation version
makes the revisions optional, thus, the time required to perform or
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not perform the procedures is left to the tester; however, the quality
control checks are recommended as being beneficial to the tester.
7.4 Comment: Using an F factor as a comparison tool exposes one
to all the inherent problems and complications. As Roger Shigehara,
et al, observed in "Validating Orsat Analysis Data from
Fossil-Fuel-Fired Units," the method does not apply to sources that
remove C02 (such as wet scrubbers) or 03, add 02 and N2 in proportions
different from air, or add CC>2. The likely potential of incomplete
combustion and its resulting CO are not addressed.
Response: The promuglation version clarifies the
applicability of the procedures and discusses the variations of
equations to accommodate alternate fuels, incomplete combustion, and
mixed fuels.
7.5 Comment: When testing sources utilizing fuels with
unpublished F factors, the Orsat data apparently must be validated (or
invalidated) upon completion of the fuel analysis - long after the
test program is completed. When using an F factor based on fuel sample
analysis, the Orsat data will be compared to data (fuel analysis) with
possibly less quality assurance than its own, effectively defeating
the purpose. When sampling for Method 3 is simultaneous with other
emission parameters, are all parameters to be resampled if the Orsat
data are invalidated? Air leakage in the system, inevitable to some
degree, could invalidate the test program even though their sampling
and analysis were entirely valid. Unlike isokinetic calculations,
there is no acceptance criteria for calculated adjustments (bias
against the source).
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Response: The revised procedures are Intended to be used
on-site at the time of the test or in order to verify the quality of
the Orsat data. It is not the intent to require the tester to perform
a fuel analysis in order to complete the quality control check. See
also Response 3.1.
7.6 Comment: An alternative QA method is the use of
standardized composite gases in portable pressure cylinders. These
cylinders, already used for the EPA QA source audit survey, have the
capability of being used in the laboratory or field, pre- or post-test.
In addition, they can be used for molecular weight determination quality
assurance, along with sources witn unpublished or "complicated"
F factors. In each case, analytical verification is immediate, enabling
the sampler to verify or void the data on site.
Response: QA cylinders are an acceptable option; although,
use of cylinders requires an extra sampling and analysis test which is
avoided by the F0 factor calculations. In addition, leaky sample lines
from audit cylinders would result in unacceptable analysis results
while, in fact, test results may be acceptable. See also Responses
4.1 and 5.4.
Commenter IV-D-8
8.1 Comment: Revision to Method 3 should be delayed to allow
more time to evaluate how adequate the EPA F0 factors are for fuels.
Specifically, combination fuels including a solid fuel should be
exempted.
Response: F0 factors for mixed fuels can be calculated with
a good degree of tolerance. Fuel ratios accurate to within +25 percent
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can be used to determine an expected F0 factor that still allows
reasonable (+5 percent) measurement imprecision in meeting the quality
control check. A procedure for establishing an expected F0 factor
for mixed fuels is included in the promulgated revisions. There
remains some problems within industry in accurate measurement in fuel
combustion rates and in determination of suitable F factors for unusual
fuels, such as vegetable wastes and wood materials, that make
determination of the fuel ratio-based F0 factor to within even +25
percent a difficult task. This issue is discussed in the applicability
section of the revisions.
Commenter IV-D-9
9.1 Comment: Coal, gas, liquid and sometimes lignite fuels can
achieve the +5 percent of the established values, but only if a wet
scrubber is not involved. When a wet scrubber is used on a source as
a control device, the Orsat results are normally +_6 to +_10 percent
from the established values.
Response: The results included by this commenter reflect
a lower than expected C02 concentration. (Calculated F0 values are
greater than theoretical.) This is a possible situation if C02 is
actually removed by the scrubber liquor. Dissolution of C02 in aqueous
solutions used in most power plant S02 scrubbers is inhibited by the
acidic condition of the slurry and probably does not occur in
significant quantities. The data supplied by the commenter show that
only 3 of the 12 tests on scrubbed exhaust gases result in FQ values
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outside of the ranges listed in the table in the revisions. For each
of the three results, there is a duplicate test result that falls within
the recommended limits. This indicates that some C0£ dissolution may
have occurred, but the emission rate results should not be
significantly affected. Scrubber:; which use aqueous solutions that
are not acidic, such as water or basic slurries, can dissolve some COg
thus affecting the results. Test results from such scrubbers should
be reviewed with this possibility considered.
9.2 Comment: When a combination of fuels are used, such as
oil and bark, the comparison to tne established values is inappropriate
because generally the amount of each type of fuel burned is not known
until well after the field testing is completed. Also, there are
significant variations in the barks and woods burned.
Response: See Response 8.1.
9.3 Comment: In plants that the process produces or consumes
carbon dioxide or oxygen, such as lead smelters, lime kilns, sulfur
recovery units, and cement kilns, no valid comparison can be made to
the established values.
Response: Except for sulfur recovery plants in this list
of industries, the F0 factor quality control check would not apply
as Orsat measurements are not necessary. For sulfur recovery units
(kraft pulp mills, refineries, etc.) the F0 factor check is not easily
applied because of C02 evolution..
9.4 Comment: Many fuels, such as lignite, vary widely in quality
and burning characteristics. Although it is allowed to determine F0
from ultimate analysis of the fuel, these fuel samples taken during
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the testing cannot be analyzed until well after the completion of the
field tests. This makes it difficult to repeat the Orsat analysis.
Response: See Response 7.5.
9.5 Comment: Ambient air should always be run in the Orsat
analyzer before using, and the criterion set in this section is good.
However, I have taken Orsat samples on plants at altitudes of over
8UUO feet and some allowances may have to be made for high altitude
samples.
Response: The Agency is not aware of a significant problem
with high altitude measurements.
•
9.6 Comment: To arbitrarily reject Orsat samples on the basis
of the two criteria specified actually borders on the ridiculous. It
would certainly be a Utopian world if all fuels and processes performed
to within _+5 percent of a specified number. Unfortunately, my 1U
years of sampling sources has provided a much different perspective.
Response: See Responses 4.6,
9.7 Comment: Based on the analyses of over 150 individual
source samples on fossil fuel-fired steam generators, it seems that a
much better criterion for validating or invalidating Orsat samples is
to put them in the perspective in which they are used, which is to
calculate the emission rate from a source. For several years now, we
have calculated the emission rate from such sources by three different
methods: using the F factor, using the Fc factor and using process
heat input data. The first method utilizes the oxygen content from
the Orsat analysis, the second method utilizes the carbon dioxide
content from the Orsat analysis, and the third method does not utilize
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either of the analyses. By comparing the emission rate calculations
from these three methods, errors in Orsat analyses can be readily
detected. However, if the source is well in or well out of compliance
with the applicable standard, any error in the Orsat analyses may be
insignificant.
Attached to these comments are several examples of where the Orsat
analysis does not meet the criterion set forth in Section 4.4.1, yet
the calculated emission rates are very close and do not affect the
determination of compliance and noncompliance. The presented data are
typical and not intended to be all inclusive. More data are available,
if desired.
Therefore, possibly a more useable and representative criterion
would be to evaluate the emission rate calculations and to establish a
criterion that the calculated emissions using the F factor and the Fc
factor should be within +20 percent of each other. This would consider
the impact of the Orsat analysis in all the calculations.
As an alternate, since the +5 percent appears to be too restrictive
for all sources, the data suggest a criterion of _+10 percent would
cover virtually all types of sources and fuels.
Response: The Agency agrees that the level of emissions in
relation to the compliance level should be considered in determining
acceptance because of poor Orsat data. Also, the use of F factor and
Fc factor comparisons is very similar to F0 checks resulting in
similar comparisons. See also Response 3.1.
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Commenter IV-D-10
10.1 Comment: The F0 is a valid quality assurance factor for
for judging the accuracy of a gas composition analysis provided that
the combustion/gas stream under test does not include a generator or
an absorber of carbon dioxide between the combustor and the point of
measurement. Examples of such includes kilns that add C02 and wet
scrubbers that remove C02. If C02 is added or removed from the
combustion gas prior to sample gas collection, the F0 of the gas
analysis will deviate from the value characteristic for the given fuel
type.
Response: See Response 9.1.
10.2 Comment: The F0 is not a valid quality assurance factor if it
is calculated using the equation that has appeared in most
publications, when the combustion process under test is incomplete and
considerable concentrations of methane and carbon monoxide exist.
Equations to calculate F0 should be revised to account for these
conditions and the proposed regulation amended to alert the user which
source types justify the additional effort required to analyze for
these products of incomplete combustion.
Response: See Response 7.4.
10.3 Comment: The F0 only elucidates errors in Orsat analyses
that result from independently derived biases in the analysis of C02
or 02. The F0 factor does not reflect errors caused by dilution of the
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collected sample with air during or after sample collection. Thus, a
leaky bag may cause significant error in the Orsat analysis even though
the F0 obtained for the analysis agrees well with the published
value.
Response: This is true. There are other quality control
and quality assurance checks within the method which address leak
problems.
10.4 Comment: The use of ambient air as a calibration gas has
value and has been used in our laboratory for years. However, only
rarely does the oxygen content approach 20.9 percent in combustion
samples. Moreover, the use of ambient air as a calibration gas
provides no check on the C02 in nitrogen standard gas with very
good success. The sample is taken from the cylinder into an evacuated
bag and then drawn into the Orsat analyzer buret. This standard is
stable and lasts about 2 years when careful withdrawal techniques are
emp 1 oy ed.
Response: See Response 7.6.
10.5 Comment: The volumetric absorption procedure referred to
as an Orsat analysis is an old and time-consuming procedure which if
properly performed by an experienced technician gives accurate
results. The tedious nature of the analysis, however, renders
shortcuts attractive to the busy analyst. Our laboratory has routinely
performed gas composition analyses on noncompliance tests by gas
chromatography with a thermal conductivity detector and a dual loop
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gas sampling valve. We have performed numerous comparisons between
the Orsat, GC and electrochemical results (Teledyne Model 320P oxygen
analyzer at room temperature in the lab with the gas samples
temperature equilibrated for several hours) and found excellent
agreement between all three methods. For this reason, we strongly
recommend that GC/TCD be allowed as an alternate to the Orsat method
with the same sample quality assurance criteria. The 2.5 minute
analysis time for C02, 0£, and N£ and 3.5 minutes for C02, 03,
N£, CH4 and CO allows the analyst to repeat an analysis several
times, if he has any doubts about its validity and can provide data on
methane and carbon monoxide, the existence of which are often
overlooked (wood-fired boilers, cupolas, etc.) by inexperienced
personnel.
Response: Alternative instrument procedures are not within
the scope of these revisions.
Commenter IV-D-11
11.1 Comment: In Section 4.4.1, delete the sentence: "Using the
following procedure, verify that the fuel factor, F0, is within _+5 of
the established value (i.e., either the average value found in the
table below or the value calculated from the ultimate analyses results
of representative fuel samples following the procedures in 40 CFR
Part 60, Appendix A, Method 19)." Replace it with: "Using the
following procedure, determine whether the fuel factor, F0, lies
within the established ranges (i.e., either the average value found in
22
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the table below or the value calculated from the ultimate analyses
results of representative fuel samples following the procedures in 40
CFR Part 60, Appendix A, Method 19)."
Delete the F0 factor table. Replace it with:
Fuel type FQ range
Coal:
Anthracite and Lignite 1.016 - 1.130
Bituminous 1.083 - 1.230
Oil:
Distillate 1.260 - 1.413
Residual 1.210 - 1.370
Gas:
Natural „ 1.600 -• 1.836
Propane 1.434 -- 1.586
Butane „ 1.405 -• 1.553
Wood 0.997 - 1.120
Wood bark 1.003 •• 1.130
Response: Using ranges instead of percentages is a practical
approach that the Agency has adopted in the final package. The ranges
stated in the comment were revised slightly before the final table was
prepared.
11.2 Comment: In Section 4.4.2, delete the sentence: "At the
completion of each test series (e.g., set of three test runs), analyze
a sample of the ambient air with the Orsat." Replace it with: "When
the calculated F0 does not lie within the specified range or when the
fuel does not have a specified F0 value, analyze a sample of the
ambient air with the Orsat."
Response: This is a good suggestion, and it is included in
the promulgated version of the revisions as a suggestion.
23
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11.3 Comment: In Section 4.4.3, delete the sentence: "If either
of the above criteria is not met, repeat the sampling and analysis and
the quality assurance check." Replace it with: "If the calculated F0
does not lie within the specified range and the 02 value of the
ambient air analysis is not 20.9^ 0.3 percent, repair the Orsat and
reanalyze the sample. If the calculated F0 still does not lie within
the specified range and the 03 value of the ambient air analysis is
not 20.9 _+ 0.3 percent, repeat the sampling and analysis and the
quality assurance check."
Response: This is a good check for an integrated bag sample,
but would not be appropriate for a grab sample. Resampling for a grab
sample is necessary. In any case, such procedures will be left to the
discretion of the tester and not be required in the method.
11.4 Comment: Our comments, if adopted, also would assure that
"the quality of compliance data will improve," the stated objective of
the proposed revisions. In addition, by only requiring F0 to fall
within the specified range for validation of the measured C02 and 02,
additional field time and expense required for the ambient air analysis
would be eliminated. Further, the analyses of ambient air where the
02 value is not 20.9 _+ 0.3 percent do not necessarily invalidate the
results of previous flue gas analyses. Since the analysis of one
ambient gas sample is the equivalent of 2 to 5 typical flue gas
analyses, the 02 absorbent may deplete before completing the ambient
air analyses. However, the Orsat analyzer may have been working
properly during previous flue gas analyses (as validated by the F0
value check). Also, failure of the ambient air analysis to fall within
24
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the specified range simply indicates that a problem with the Orsat
exists. Previously analyzed flue gas samples whose F0 did not fall
within the specified F0 range should be reanalyzed after repairing
the Orsat or using another Orsat.
Since the F0 values presented in the proposed revisions are based
on the carbon-to-hydrogen ratio of each fuel type and the stoichiometry
of combustion, _+5 percent of these proposed values may not represent
the ranges actually measured for each fuel. We feel our proposed ranges
of F0 values better represent the range for each fuel type typically
encountered in stack testing. After the direct involvement of Entropy
personnel in the original development of F factor and F0 values, we
have used the relationship between C02 and Q£ percentages versus fuel
type as internal checks for all our Orsat data collected at combustion
sources. Our proposed ranges are based on our internal check of 1,000 -
2,000 Method 3 test runs per year for the last 5 years.
Section 4.4.3 as published in the proposed revision does not assure
the quality of compliance data; rather, it has more potential to require
additional sampling and analyses by the tester due to factors beyond
the tester's control. If the F0 value lies outside the specified range
but the analytical criteria as set forth in Method 3 are met and the
ambient air check is valid, then the data must be accepted as accurate.
In such cases, the tester's only responsibility should be the notation
in the test report of F0 values outside the specified range. F0 values
can fall outside the specified range due to numerous factors which the
tester has no control over. Several examples are:
25
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a. Combustion of mixed fuels.
b. Use of specially treated fuels which have atypical carbon-to-
hydrogen ratios.
c. Oxygen or carbon dioxide enrichment of either the combustion
s
or flue gases.
d. Control equipment prior to the test location which
preferentially removes either oxygen or carbon dioxide from the flue
gases.
Response: See Responses 3.3, 4.6, and 7.3.
Commenter IV-D-12
12.1 Comment: Verification that the fuel factor, F0, is within
_+5 percent of the listed value or that calculated from ultimate
analyses of fuel samples poses a significant problem for combination
fuel boilers, especially those common in the pulp and paper industry.
Determination of F0 for a boiler burning wood fuel and fossil fuel
(oil, gas, or coal) would require extremely accurate monitoring of
respective fuel flows. This is not practical, especially for the wood
and coal fuel components.
Response: See Response 8.1.
12.2 Comment: We expect that the quality assurance intent can be
achieved by following the proposal for checking the Orsat analyzer with
ambient air at the completion of each test series to ensure the
measured Q£ value is 20.9_+ 0.3 percent.
Response: No response is necessary.
26
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12.3 Comment: Although this method revision is for combustion
sources, we have a concern that it could be applied to lime kiln
sources. Because of high C0£ release rates in the calcining process,
calculation of F0 factors will not be within_+5 percent of the listed
values.
Response: See Responses 5.4 and 6.1.
Commenter IV-D-13
13.1 Comment: We are attempting to obtain actual field test
data from several member companies in order to ensure that the proposed
regulations are compatible with the actual performance of Methods 3,
4, and 5. Due to the long lead time required in collecting data, we
have not been able to obtain and analyze significant amounts of data.
We, therefore, request you to grant an additional comment period of 30
days to enable the completion of the data gathering arid analysis effort
presently underway.
Response: The Agency feels that there are sufficient data to
make the changes to the promulgated version that have been made. No
extension of the comment period is necessary.
13.2 Comment: It should be clearly stated that the procedures
outlined in Section 4.4.1 are applicable only to those sources which
have their emission standards written as ng/J or lbs/106 Btu. Section
4.4.1 cannot be applied when the emission standard is specified either
as g/SDCM (kraft recovery furnace, lime kiln) or as g/kg feed (smelt
dissolving tank vent).
27
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Response: The procedure is applicable for organic and fossil
fuel combustion sources and require Orsat measurement for 63 correction
or excess air determination. The form of the emission standard does not
really matter.
13.3 Comment: Section 4.4.1 specifies that the fuel factor, F0,
should be within _+5 of the established value. We assume that this was
intended to be _+5 percent.
Response: This is correct.
13.4 Comment: It has not been explained as to how the values
of F0 presented in Section 4.4.1 were derived. A review of Method
19, Appendix A of 40 CFR Part 60 provides a possible means of
calculating F0 by equating the emission estimates using the
oxygen-based F^ factor with the emission estimates using the carbon
dioxide based Fc factor.
When the values of F^ and Fc tabulated in Method 19 are used, the
following values of F0 are obtained. It is suspected that the proposed
values of F0 are in error.
Fuel Type Fn, Proposed Fn, Calculated
Coal
Anthracite 1.070 1.072
Bituminous 1.140 1.136
Lignite 1.076 1.079
Oil 1.346 1.353
Gas
Natural 1.749 1.750
Propane 1.510 1.530
Butane 1.479 1.456
Wood 1.050 1.055
Wood bark 1.056 1.085
28
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Response: The calculation of F0 from Fd and Fc values is
included in the promulgated version and is true for a specific fuel
analysis. The numbers proposed represent midpoint values of many
analyses. The wood bark value for Fc in Method 19 is incorrect and
s
has been corrected in the promulgated revisions.
13.5 Comment: The procedure for calculating F0 for combination
fuels has not been specified, and should be clearly outlined.
Response: See Response 8.1.
13.6 Comment: There are very limited data on the accuracy of
Orsat 62 and C02 measurements. According to Reference 4 cited in
reference Method 3, the use of Orsat data "to convert particulate
catches to such reference conditions as 12 percent C02 and 50 percent
excess air may introduce sizeable errors in the corrected particulate
loading." We suggest that any Method 3 quality assurance requirement
should take into consideration any published Orsat performance data
and any data generated by EPA quality assurance audits for Orsat
analyses for 02 and C02-
Response: The criteria in the proposal represent what can be
achieved with good sampling and analysis techniques. Data in QA audit
reports include errors through testers' mistakes and miscalculations.
These factors should be eliminated by a good quality control program.
13.7 Comment: The concept of a fixed error limit (5 percent) to
the estimated value of F0 imposes varying limits of accuracy on 02
and C02 measurements as a function of excess air. This can be
illustrated by the following example. Consider a source utilizing a
fuel with a theoretical F0 of 1.093.
29
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At very low excess air (4 percent 02), an absolute error of 0.41
percent is allowed in the measurement of 02 and C02 to stay within
5 percent of theoretical F0. However, if the excess air increased
to a high level (15 percent 02), the allowed absolute error would be
reduced to 0.14 percent.
The objective of a QA step in Method 3 should be to achieve best
02 and C02 data and not to specify method performance based upon source
operating conditions, since these are unrelated. It is thus obvious
that the use of F0 as a quality assurance check on Method 3 is not
valid and should be reconsidered.
Response: The objective of a quality control procedure is
to provide the means to indicate that the measured data are
acceptably accurate. It is true that greater accuracy in the Orsat
results is required to meet the F0 check at higher excess air, but
better accuracy is desired under these conditions because 02-corrected
emission rates are more sensitive to Orsat errors at high excess air
than at low excess air.
13.8 Comment: Based upon the limited data provided to NCASI by
member mills, F0 values for bark boilers and combination wood
waste-fossil fuel boilers are substantially different from theoretical
values. These differences may be from nonuniform F0 factors for bark
and wood samples derived from different species, and inability to
accurately estimate heat input rate from bark and wood waste. It is
30
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common to estimate heat input rate from bark by making daily bark
consumption estimates and using an average bark Btu content.
It is, therefore, recommended that the proposed QA procedure
should not be applied to wood waste and combination boilers.
Response: See Response 8.1.
Commenter IV-D-14
14.1 Comment: Orsat equipment is a familiar technology that has
been in use for many years. The audit of the Orsat equipment appears
reasonable; in fact, the procedures outlined in the proposed rules are
part of standard operating procedure for many of our members. However,
newer technologies than Orsat equipment, specifically electronic flue
gas analyzers, offer greater ease of measurement and greater accuracy.
Electronic flue gas analyzers may well prove to be less expensive to
use than Orsat equipment over the long run, with substantially improved
accuracy, and precision. American Public Power Association (APPA)
therefore, recommends that EPA allow the use of approved electronic
flue gas analyzers at the discretion of the owner as an alternative to
Orsat equipment.
Response: The scope of these revisions does not include 03
meters. Alternative procedures can be submitted to the Agency for
review provided comparison data between the alternative and the
reference method are included as well as a detailed procedure
description of the alternative.
31
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14.2 Comment: The second concern relates to the requirement that
all testing and calibration be performed in the field. Conditions for
accurate analytic results may be best served by allowing calibrations
to be run at ground level under laboratory conditions. Recalibration
using "ambient" air up in the stack may not be accurate because 62
levels may be skewed by the presence of higher carbon monoxide and
carbon dioxide levels, as well as perhaps other gaseous components.
Thus, the audit of the Orsat equipment using stack "ambient" air may
not be completely accurate. APPA, therefore, recommends that multiple
sampling runs be allowed with the check for Orsat equipment accuracy
on ambient D£ levels to be run at ground level under laboratory
conditions. Should EPA be able to verify that there is no difference
in "ambient" 03 levels drawn from the stack or at ground level, APPA
withdraws this recommendation.
Response: -The Agency feels that ambient air Q£ values will
be within narrow limits at any outdoor or well-ventilated location.
However, the ambient air check of the Orsat analyzer is no longer a
requirement of the method, only a recommendation.
14.3 Comment: In the Federal Register (FR 47:39204-39205,
September 7, 1982) listing for these proposed regulations at the bottom
of page 39205, it is proposed that the owner "verify that the fuel
factor, F0, is within j^5 of the established value" of the F0 values
32
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shown in the accompanying table. This value appears to be a typographical
error. APPA assumes the correct value would be ±5 percent of the F0
values shown in the table. APPA recommends this value be clarified in
the final rules.
Response: See Response 3.1 and 13.3.
Commenter; IV-D-15
15.1 Comment: This division agrees that this is an excellent
quality assurance tool. However, this division comments that if the
quality assurance procedures outlined in Section 4.4 and the accuracy
requirements set forth in Method 3 can be met by a procedure other
than sample collection in a bag and analysis by an Orsat that this
procedure could be utilized as an alternate to Method 3. Specifically
this division considers that the continuous collection of gas samples
at each point of the parti oil ate traverse and the continuous analysis
of these samples for oxygen, carbon dioxide, and carbon monoxide with
electronic analyzers utilizing a weighted average of the results
obtained to determine the F factor for heat input would be an
acceptable alternate to Method 3. This assumes that the quality
assurance procedures stated in Section 4.4 are met, the accuracy
requirements of Method 3 are met, acceptable calibration procedures
for the instruments are implemented, and that documentation of the
calibration of the instruments both prior to and after the collection
of the sample is presented in the test report.
Response: See Response 14.1.
33
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Commenter IV-D-16
16.1 Comment: The proposal gives no hard data in support of
revision. The only justification for imposing this additional
analytical burden is a brief reference in the summary section of the
proposal which states that "(t)he current regulation includes only
limited quality assurance requirements and, as a result of this
proposed regulation, the quality of compliance data will improve."
Such an unsupported statement is inadequate as the basis for revising
any rule, but especially one as well established as Method 3.
Furthermore, we do not agree with it and believe that existing quality
assurance procedures under Section 4 of Method 3 are sufficient.
We would urge EPA to withdraw this proposal pending the
presentation of hard supporting data and the opportunity for public
review and comment concerning the supporting data base. Moreover, we
would strongly recommend that field data, rather than laboratory data,
be used to support any changes.
Response: The Agency has received a mandate to provide
quality assurance and quality control procedures to the test methods in
an effort to assess and assure data accuracy and precision for all
compliance tests. The Agency feels the quality control procedures in
the promulgated revisions are adequately supported and are achievable.
16.2 Comment: The proposed language under Section 4.4.1 calls for
verification" . . . that the fuel factor, FQ, isj»;5 of the established
34
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value ..." EPA has advised us that this should have read "+5
percent," however, and that is the meaning upon which the following
discussion is premised.
EPA proposes to require that field determinations of F0 agree
within_+5 percent of the established value before a test run can be
accepted. This seems an unworkable standard with respect to the
combination fuel boilers so prevalent in the pulp and paper industry.
We do not believe combination fuel boilers can meet the_+5 percent F0
criterion because of inherent difficulties in the accurate measurement
and precise control of fuel feed rates, and the variability in fuel
quality, especially when burning wood and bark. With respect to
variability in fuel quality, for example, the moisture content of bark
can vary from less than 40 percent: to more than 70 percent, and the
BTU content of natural gas can vary by _+5 percent.
Our data are too limited at this point to conclusively establish
how much the _+5 percent F0 criterion would have to be relaxed to become
reasonably attainable for combination fuel boilers. It does strongly
suggest, however, that the criterion would have to be increased to at
least_+10 percent F0 to be reasonable. The very best solution is probably
to exempt all combination fuel boilers from meeting the F0 test, should
one be imposed, and we recommend this course of action should this
proposal become effective.
Response: See Responses 8.1 and 3.1.
35
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16.3 Comment: The proposed revision does not speak to how the
"established" F0 should be calculated for combination fuel boilers
burning more than one fuel at a given time. We recommend that EPA
clarify the exact procedure for dealing with the calculation of the
"established" F0 for combination boilers should such boilers
ultimately fall under these requirements.
Response: See Response 8.1.
16.4 Comment: The "established" F0 fuel factors listed in the
table under proposed Section 4.4.1 are not in good agreement with the
F0 fuel factors we have calculated from the fundamental values of Fd
and Fc given in §60.45(f)(4). We recommend that EPA recheck these
"established" F0 values.
Response: See Response 13.4.
16.5 Comment: Finally, with respect to the F0 test, the
proposal does not make it clear that this criterion is inappropriate
for sources, such as kraft pulp mill recovery boilers, which have flue
gas concentration-based emission standards. In these instances, and
for good causes, there are not "established" F, Fc or FQ fuel factors.
For example, the black liquor fired as fuel in a recovery boiler is
very variable in composition and fuel value, and cannot be
characterized with single valued fuel factors. We urge EPA to exempt
from the F0 test any source which has emission standards cast as
flue gas concentrations.
Response: See Response 9.3 and 13.2.
36
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Commenter IV-D-17
17.1 Comment: Instead of merely assuring agreement of Orsat
results within j;5 percent of established F0 factors, a fuel analysis
of the fuel to be utilized should be obtained prior to testing and
Orsat results compared with a theoretical combustion analysis of the
fuel. The Orsat results should be withings percent of the theoretical
02 and C02 determined from the fuel analysis as well as the
established F0 factor. Comparison of Orsat results with the
theoretical analysis is easier and more specific for a given fuel than
in comparison with the F0 factor.
Response: The commenter's approach is often impractical for
many types of fuels as obtaining a representative sample is very
difficult or methods do not exist. The procedure is flexible enough
to allow comparisons with the F0 table of ranges in almost all cases.
See also Response 7.5.
17.2 Comment: Instead of merely checking the Orsat with ambient
air, it would be better to check it with a calibration gas of similar
composition to that being tested (C02 and 02 in N2). By merely
checking the Orsat with ambient air, the C02 absorption chemical is
not checked. This procedure is more tedious and expensive than
checking the Orsat with ambient air.
Response: See Response 7.6.
17.3 Comment: In Section 4.4.1, page 39205, the following
statement is made, "Using the following procedures verify that the
37
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fuel factor, F0, is within ^5 of the established value . . .". My
question is - is the number _+5, _+0.5 or _+5 percent?
Response: See Response 13.3
17.4 Comment: The value of F0 for oil is given in the table
to be 1.345. Our calculations indicate that this value is only true
for light oil. If so, what about residual oil?
Response: The promulgated revisions include a table with a
range of acceptable F0 values. The range for oil should include most
oils used as fuel.
38
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TABLE 1. List of Commenters
Document Number Commenter
IV-D-1 . From R.A. Reckart, Vice President
Fossil and Hydro Production,
Northeast Utilities to Docket
Number A-82-05. Subject: Comments
on proposal of revisions to Methods
3, 4, and 5.
IV-D-2 From C.D. Malloch, Regulatory
Management Director, Air,
Environmental Policy Staff,
Monsanto Co. to Docket Number
A-82-05. Subject: Comments on
proposal of revisions to Method 3.
IV-D-3 From Robert E. Wcoten, Jr., Source
Test Engineer, North Carolina
Department of Natural Resources and
Community Development to Docket
Number A-82-05. Subject: Comments
on proposal of revisions to
Method 3.
IV-D-4 From Jerry W. Powell, Environmental
Programs Chemist, Texasgulf
Chemicals Company to Docket Number
A-82-04 (moved to A-83-05).
Subject: Comments on proposed
revisions to Method 3.
IY-D-5 From Richard H. Russell,
Supervisor, Environmental
Testing, Owens-Illinois, Inc. to
Docket Number A-82-05. Subject:
Comments on proposed revisions to
Methods 3, 4, and 5.
IV-D-6 From Dale S. Harmon, Sr.
Environmental Engineer, Texas
Industries, Inc. to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Method 3.
39
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TABLE 1. List of Commenters
(Continued)
Document Number Commenter
IV-D-7 From Randall J. Richert,
Environmental Scientist,
Southwestern Laboratories, Inc.
to Docket Number A-82-05.
Subject: Comments on proposed
revisions to Methods 3, 4, and 5.
IV'D~8 From James E. Walther, Supervisor,
Air and Noise Programs, Crown
Zellerback to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Methods 3,
4, and 5.
IV-D-9 From Bill J. Mullins, Jr.,
President, Mull ins Environmental
Testing Company, Inc. to Docket
Number A-82-05. Subject: Comments
on proposed revisions to Methods 3
and 5.
IY'D"10 From Perry Lonnes, President,
Interpoll, Inc. to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Method 3.
IV-D-11 From Bruce G. Hawks, Supervisor
Quality Assurance Source Sampling
Division., Entropy
Environmentalists to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Method 3.
IV'D'12 From Danny B. Sjolseth, Section
Manager, Air Technology Research
and Development to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Methods 3,
4, and 5.
40
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TABLE 1. Li st of Commenters
(Continued)
Document Number Commenter
IY-D-13 From Ashok Jain, Engineering
Projects Research Manager, National
Council for Air and Stream
Improvement, Inc. to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Methods 3,
4, and 5.
IV-D-14 From Michael K. Bergman, Staff
Scientist, American Public Power
Association to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Method 3.
IV-D-15 From Harold E. Hodges, Director,
Tennessee Air Pollution Control
Division, Tennessee Department of
Public Health to Docket Number
A-82-05. Subject: Comments on
proposed revisions to Methods 3, 4,
and 5.
IV-D-16 From S.L. Estes, Specialist, Air and
Water Resources, Union Camp Corp.
to Roger Shigehara. Subject:
Comments on proposed revisions to
Methods 3,4, and 5. .
IV-D-17 From W.H. Axtman, Executive
Director, American Boiler
Manufacturers Association to Roger
Shigehara. Subject: Comments on
proposed revisions to Methods 3, 4,
5, and 7A.
41
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
4. TITLE AND SUBTITLE
Revisions to Method 3 of Appendix A of 40 CFR Part 60,
Summary of Comments and Responses
7. AUTHOR(S)
Emission Standards and Engineering Division
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Measurement Branch (P1D-19)
Emission Standards and Engineering Divisior
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
-.,. SUPPLEMENTARY NOTES
ti ABSTRACT
This document addresses the public comments submi
to Method 3 in the Federal Register. Changes made as
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
November 1983
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11, CONTRACT/GRANT NO,
13.TYPEOF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA 200/04
tted after proposal of the. revisions
the result of these comments are
included. This document serves as a basis for the changes made in the revisions to
Method 3 between proposal and promulgation.
'< KEY WORDS AND DOCUMENT ANALYSIS
> DESCRIPTORS b.lDENTIF
1
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