United States Office of Air Quality EPA-450/3-82-Q18
Environmental Protection Planning and Standards Julv'1983
Agency Research Triangle Park NC 27711
Air
Performance
Specifications
for Continuous
Monitoring of Total
Reduced Sulfur
Emissions -
Summary
of Comments
and Responses
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EPA-450/3-82-018
Performance Specifications for Continuous
Monitoring of Total Reduced Sulfur Emissions
(Proposed July 20, 1981, 46 FR 37287)
Summary of Comments
and Responses
Emission Measurement Branch
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
July 1983
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This report has been reviewed by the Emission Standards and Engineering Division of the Office of
Air Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or
commercial products is not intended to constitute endorsement or recommendation for use. Copies
of this report are available through the Library Services Office (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park, IM.C. 27711, or from National Technical Information
Services, 5285 Port Royal Road, Springfield. Virginia. 221 61.
.*• L-;:ncy.
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TABLE OF CONTENTS
Page
Chapter 1. INTRODUCTION
Chapter 2. SUMMARY OF CHANGES SINCE PROPOSAL. . . .
Chapter 3. SUMMARY OF PUBLIC COMMENTS AND RESPONSES
Table 1. LIST OF COMMENTERS
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CHAPTER 1
INTRODUCTION
On July 20, 1981, the U.S. Environmental Protection Agency (EPA)
published Performance Specification 5, "Specifications and Test
Procedures for TRS Continuous Emission Monitoring Systems in Stationar;
Sources," in the Federal Register (46 FR 37287). The performance
specification (PS) is to be used for evaluating the acceptability of
total reduced sulfur (TRS) continuous monitors as specified in the
applicable regulations. The specification was proposed under the
authority of Sections 111, 114, and 301(a) of the Clean Air Act, as
amended.
X
Public comments were solicited at the time of proposal. An
invitation to request a public hearing was issued to provide intereste<
persons the opportunity for oral presentation of data, views, or argumi
concerning the proposed PS, but no person desired to make an oral
presentation. The public comment period was from July 20, 1981,
to September 20, 1981.
Letters concerning issues relative to the proposed PS were receivi
from six commenters. A detailed discussion of these comments and
responses is summarized in this document. The summary of comments
and responses serves as the basis for the revisions which have been mai
to the PS between proposal and promulgation.
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CHAPTER 2
SUMMARY 0? CHANGES SINCE PROPOSAL
1. Section 1.1. Sources shall be allowed 1 year after the
promulgation date to install and operate monitors.
2. Section 2.1. The detector span level has been widened to
allow a setting between 1.5 times the pollutant concentration
corresponding to the emission standard level and the span value.
3. Section 2.2. The allowable detector calibration drift has
been changed to 5 percent for 6 out of 7 test days.
4. Section 3.2. For Method 16A, a sample is collected for
at least 1 hour.
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CHAPTER 3
SUMMARY OF COMMENTS AND RESPONSES
PERFORMANCE SPECIFICATION 5
1. Commenters D-l, D-3, D-5
Comment: We request an additional 30 to 180-day comment
period to- enable affected sources to complete data gathering and analysis
efforts that are now underway. This will allow us to evaluate 0- monitors
and to determine the impact of this regulation on currently used monitors.
Response: Additional time has been given to complete this data
gathering effort. The comment period will not be extended; however,
subsequent data submitted to the Agency will be considered in revising
the proposed PS.
2. Commenters D-l, D-2, D-A, D-5
Comment: The National Council for Air and Stream Improvement
technical document used to establish the calibration drift (CD) does
not support the proposed not-to-exceed 3 percent specification.
This document deals primarily with the Barton titration system, which
according to the proposed 3 percent limit, would not pass. A
specification which is based upon not-to-exceed criteria but does
not take into account the distribution of the population around the mean
is not technically sound. We feel the 3 percent limit is too stringent
and suggest a larger number be chosen or a value based on a 24-hour
arithmetic mean plus the 95 percent confidence interval. Since the high
level drift calculation includes the zero drift, the CD should be defined
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separately for high- and low-level drift. A low drift of 3 percent and
a high-level drift of 5 percent span can be supported by available data.
Response: The CD limit has been changed from not exceeding 3 percent
to not exceeding 5 percent for 6 out of 7 test days. This value is
supported by the background technical document as well as data submitted
by sources on currently used monitors. The Agency does not feel the
specifying of a separate low-level test is warranted.
3. Commenters D-l, D-2, D-4, D-5
Comment: Sources should be allowed to install monitors 1 year to
18 months after promulgation, instead of proposal. It is not appropriate
nor reasonable to require the installation of expensive equipment before
publication of the final atandard. This additional time is needed to
survey available monitors, since it appears the Barton system may not pass
the CD test.
Response: Sources will be allowed 1 year beyond the promulgation date
to purchase, install, and operate monitors. This time seems reasonable since
operators had the opportunity to review available monitors during the
period between proposal and promulgation. The corrected CD requirement
does not preclude use of the Barton system.
4. Commenter D-l
Comment: Since most commercially available systems provide little
flexibility in adjusting the detectsr span, the span level should be
from 70 to 120 percent of span value instead of 90 to 100 percent. The
70 percent level would be much higher than most standards.
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Response: The allowable span level has been widened to a level
/
between 1.5 times the concentration of the applicable emission standard
and the specified span value of 30 ppm.
5. Commenters D-2, D-3
Comment: In Section 2.2, the applicability of the CD is unclear.
Is it for the entire system, the instrumental part, or just the detector?
Response: Section 2.2 has been clarified by stating the applicability
of the CD to the detector.
6. Commenter D-2
Comment: The preamble to the proposed specifications state the
procurement costs of monitors at $15,000 to $30,000. Actual cost estimates
place the figures around $50,000 to $100,000.
Response: Current manufacturer's estimates place the procurement and
installation costs between $20,000 and $80,000.
7. Commenter D-2
Comment: To eliminate confusion, it should be explicitly stated,
either in the preamble or rule, that instrument response time is not being
specified.
Response: The preamble will state that no response time is specified.
8. Commenter D-2
Comment: The relative accuracy (RA) language of the proposed
specifications contradicts that used in the guideline document. The
guideline document should be corrected to state that the RA shall be no
greater than 20 percent of the mean value of the reference method (RM),
or 10 percent of the applicable standard, whichever is greater, not less.
Response: This error in the guideline document has been corrected.
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9. Commenter D-6
Comment: Paragraph 60.13(b) of the regulations should be modified
to clarify the operational period and verification of the operational
status. We also suggest the following addition to 60.13(b)(l): "...
requirements in Appendix B after the monitoring system has been in place
and operated in a normal stabilized mode for a period of at least 1
/
month."
Response: Section 60.13(b) is being revised along with
PS 2 and 3 to state the following: "All continuous monitoring systems
and monitoring devices shall be installed and operational prior to
conducting performance tests under 60.8. Verification of operational
status shall, as a minimum, include completion of the manufacturer's
written requirements or recommendations for installation, operation,
and calibration of the device."
10. Commenter D-6
Comment: The proposed PS 5 refers to several paragraphs in PS 2.
Since PS 5 refers to PS 2 in such depth, we suggest PS 5 be rewritten
in the format of PS 2. Specifically, we recommend the following
changes for uniformity.
a. Section 1, Applicability and Principle, should be changed to
Principle and Applicability. Sections 1.1 and 1.2 should be changed
accordingly.
b. Section 2.1, Instrument Zero and Span, should be listed as
Section 3.2, Span.
c. Section 2.2, Calibration Drift, should be listed as Section
3.6, Calibration Drift.
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d. Section 2.3, GEMS Relative Accuracy, should be listed as
Section 3.3, Accuracy (Relative).
e. Section 3, Relative Accuracy Test Procedure, should be listed
as Section 6,0, Performance Specification Test Procedures.
Response: The proposed PS 5 is based upon a revised PS 2 (proposed
January 26, 1981). It appears the above comments are based upon the
original PS 2 and not the revised version. The proposed PS 5 reflects
the noted uniformity to revised PS 2.
11. Commenter D-6
Comment: Paragraph 3.1, Sampling Strategy for RM Tests, which refers
to PS 2, Sections 7.1, 7.2, 7.3, and 7^.5, should be changed to reflect
only 7.1 and 7.2. The PS 2 has no Sections 7.3 and 7.5.
Response: See response to Comment 10.
12, Commenter D-6
Comment: An alternative procedure to performing analysis of the
calibration gases by RM tests should be included. One alternative is
to use EPA Protocol 1 gases.
Response: Protocol 1 gases are available for criteria pollutants
only. For H-S, a standard reference material gas certified by the
National Bureau of Standards (NBS) is needed. Since NBS does not now
have a standard reference H2S cylinder gas and probably will not in the
near future, the analysis of calibration gas shall be by RM test.
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Table 1. LIST OF COMMENTERS
Docket Number A-8G-57
Document Number Commenter/Affiliation
IV-D-1 Ashok K. Jain, Engineering Project
Manager
National Council of the Paper
Industry for Air and Stream
Improvement
Southern Regional Center
Post Office Box 14483
Gainesville, Florida 32604
IV-D-2 T.C. Owen, Corporate Director
Union Camp Corporation
Post Office Box 1391
Savannah, Georgia 31402
IV-D-3 Edward 0. Clem, Environmental Affairs
Director
Champion International Corporation
One Champion Plaza
Stamford, Connecticut 06921
IV-D-4 E.F. Button, Director, Environmental
Control and Compliance
. ITT Rayonier, Inc.
1177 Summer Street
Stamford, Connecticut 06904
IV-D-5 James E. Walther, Supervisor, Air
and Noise Programs
Crown Zellerbach Environmental
Services
904 N.W. Drake Street
Camas, Washington 98607
IV-D-6 Bill Stewart, Executive Director
Texas Air Control Board
6330 Highway 290 East
Austin, Texas 78723
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1 REPORT NO.
TECHNICAL REPORT DATA
fflease read Instructions on the reverse before completing)
EPA-450/3-82-Q18
4 TITLE AND SUBTITLE
2.
Performance Specifications for Continuous Monitoring of
Total Reduced Sulfur Emissions
Summary of Comments and Responses
AUTHOR(S)
Emission Standards and Engineering Division
PERFORMING ORGANIZATION NAME AND ADDRESS"
Emission Measurement Branch (MD-19)
Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
July 1983
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
12 SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards (MD-10)
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
SUPPLEMENTARY NOTES
1. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
thl ™ Jocument Besses the public comments submitted after proposal
£ fE Aformance specification in the Federal Register. Changes made to
a< th! h^S "f 3 ITUlt °f-these co^ntFl?e-TncTu^d—This document serves
as the basis for the revisions which have been made to the performance
specification between proposal and promulgation perTormance
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