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
                                  m

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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
                                   5

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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
                                   1U

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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.
                                   19

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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
                                  20

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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
                                   21

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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.
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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
j
HI DISTRIBUTION STATEMENT 19.SECUR
Release unlimited Unclas
20. SECUR
Unclas
ERS/OPEN ENDED TERMS C. COSAT1 Field/Group

TY CLASS (This Repon) 21 . NO. OF PAGES
sified 42
1TY CLASS (This page) 22. PRICE
sified

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