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
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