United States      Office of Air Quality       EPA-450/3-82-Q18
Environmental Protection  Planning and Standards     Julv'1983
Agency        Research Triangle Park NC 27711
for Continuous
Monitoring of Total
Reduced Sulfur
Emissions -
of Comments
and Responses

  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
                  Office of Air, Noise, and Radiation
               Office of Air Quality Planning and Standards
               Research Triangle Park, North Carolina 27711
                       July 1983

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.

                           TABLE OF CONTENTS

Chapter 1.  INTRODUCTION 	



            Table 1.  LIST OF COMMENTERS 	

                                 CHAPTER 1


     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


     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.

                                CHAPTER  2


     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.

                                CHAPTER 3


                       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

 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.

      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


     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.

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


     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


     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.

     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.

                      Table 1.  LIST OF COMMENTERS

                          Docket Number A-8G-57

Document Number                                Commenter/Affiliation

    IV-D-1                               Ashok K.  Jain, Engineering Project
                                         National Council of the Paper
                                           Industry for Air and Stream
                                         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
                                         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
                                         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

                                      TECHNICAL REPORT DATA
                               fflease read Instructions on the reverse before completing)
    Performance Specifications for Continuous  Monitoring of
       Total Reduced Sulfur Emissions
    Summary of Comments  and Responses
    Emission Standards  and  Engineering Division
 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.
    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
                                                                1. CONTRACT/GRANT NO.
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
       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
                                 KEY WORDS AND DOCUMENT ANALYSIS
                                                b.IDENTIFIERS/OPEN ENDEDTERMS

    Release  Unlimited
 HA Fu,,,, 2220-1 (R.y. 4.77)   PREV.OUS EDIT, ON
19. SECURITY CLASS (This Report?
                                                20. SECURITY CLASS (This pa?t~
                                                                         21. NO. OF PAGES
                                                                        22. PRICE