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 ------- 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 ------- 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 Page Chapter 1. INTRODUCTION Chapter 2. SUMMARY OF CHANGES SINCE PROPOSAL. . . . Chapter 3. SUMMARY OF PUBLIC COMMENTS AND RESPONSES Table 1. LIST OF COMMENTERS ------- 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. ------- 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. ------- 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 ------- 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 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. ------- 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. ------- 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 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 ------- 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 KEY WORDS AND DOCUMENT ANALYSIS b.IDENTIFIERS/OPEN ENDEDTERMS ii. DISTRIBUTION STATEMENT Release Unlimited HA Fu,,,, 2220-1 (R.y. 4.77) PREV.OUS EDIT, ON 19. SECURITY CLASS (This Report? Unclassified 20. SECURITY CLASS (This pa?t~ Unclassified 13B 21. NO. OF PAGES 10 22. PRICE ------- DATE DUE ------- |