IJnited States      Office of Air Quality       EPA-450/3-82-022
Environmental-Protection  Planning and Standards     September 1982
Agency        Research Triangle Park NC 27711
Air	,	
Revisions to
Continuous Emission
Monitoring Systems-
Performance
Specifications 2 and 3-
Summary of Comments
and Responses

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                                   EPA-450/3-82-022
                 Revisions to
 Continuous Emission Monitoring Systems
    Performance Specifications 2 and 3
(Proposed January 26, 1981, 46 FR 8352)
  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

                    September 1982

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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, N.C. 27711; or, for a fee, from 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	   3


Chapter 3.  SUMMARY OF COMMENTS AND RESPONSES	   6
            Table 1.   List of Acronyms Used in Summary of
                      Comments and Responses 	    2
            Table 2.   List of Commenters	73
                              m

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                                 Chapter 1
                               INTRODUCTION
     On January 26, 1981, the U.S. Environmental Protection Agency (EPA)
published in the Federal Register (46 FR 8352) revised "Performance
Specification 2 - Specifications and Test Procedures for S02 and
NO  Continuous Emission Monitoring Systems in Stationary Sources,"
  J\
and "Performance Specification 3 - Specifications and Test Procedures
for Og and ^ Continuous Emission Monitoring Systems in Stationary
Sources."  These revised specifications were proposed under the
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 specifications,
a public hearing was scheduled for February 19, 1981, beginning at
9:00 a.m.  The hearing, however, was not held because no one requested
to speak.  The public comment period was from January 26, 1981, to
March 27, 1981.
    Twelve comment letters on the proposed revisions to the
performance specifications (PSrs) were received from industry,  Federal
agencies, State air pollution control  agencies, trade associations, and
State air pollution control  agencies,  trade associations, and equipment
manufacturers.   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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            TABLE 1.  LIST OF ACRONYMS USED







CD  - Calibration Drift





CEMS- Continuous Emission Monitoring System





NSPS- New Source Performance Standards





PS  - Performance Specification





PST - Performance Specification Test





QA  - Quality Assurance





RA  - Relative Accuracy





RM  - Reference Method





SIP - State Implementation Plan

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                                  CHAPTER 2
                      SUMMARY OF CHANGES SINCE PROPOSAL
      1.   Section 60.13(c)(2)(ii).   The revision proposed for this
 subparagraph is no longer under consideration.
      2.   Section 60.13(d).   The limit of the mandatory adjustment
 of the zero and span drifts was changed from the applicable
 specification to twice the  applicable specification.   The requirement
 to quantify and record the  amount  of excess  zero and  span drift was
 changed  to  require the quantifying and recording only when specified.
      3.   Section 1.1.   (Note:   All  sections  refer to  PS  2,  unless otherwise
 specified.)   A  second  paragraph was  added  to explain  that performance
 specification (PS)  is  not designed  to  evaluate  the  installed continuous
 emission monitoring  system  (CEMS) over an  extended  period of time nor does
 it  identify  specific calibration techniques  and  other  auxiliary  procedures
 to  assess the CEMS  performance.  This  paragraph  also reminds the  source
 owner or operator of his/her responsibility  to  properly  calibrate, maintain,
 and operate  the  CEMS.  This paragraph  was  also added to  PS 3.
     4.  Section 3.  Parts of Section  3.1, 3.1.1, and  3.2  have been
 amended to address  locations at  inlets  to  control devices.
     5.  Section 3.1.  The last sentence in  the  first  paragraph was
 revised to read, "If the cause of failure  to meet the RA test is determined
 to be the measurement location and a satisfactory correction technique
cannot be established, the Administrator may require the CEMS to be
relocated."   The RA stands for relative accuracy.

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     6.  Section 3.2.  For stacks greater than 2.4 meters, the use
of the 0.4, 1.2, and 2.0 meter points was limited to those cases
where pollutant stratification is not expected and prohibited after
wet scrubbers or at points where two streams with different pollutant
concentrations are combined.
     For those cases where the pollutant concentration changes are
due solely to diluent leakages (e.g., air heater leakages) and pollutants
and diluents are simultaneously measured at the same location, the
option of using a half-diameter in lieu of two equivalent diameters is
allowed.
     7.  Section 4.1.  The limits of the recorder high level  was
changed from 90 to 100 percent of the span value to a value between
1.5 times the pollutant concentration corresponding to the emission
standard level and the span value.   The option of using a value
between 50 and 100 percent of the high-level value was allowed
provided the data recorder full-scale requirements are met.  The
zero and high-level points for the determination of calibration drifts
were changed from "0 to 50" to "0 to 20" and from "80 to 100" to
"50 to 100" of the high-level value.
     Inlets to scrubbers were also addressed.
     8.  For SOg emission standards between 130 and 86 ng/J (0.30
and 0.20 Ib/million Btu), the RA specification was changed to 15 percent;
and below 86 ng/J (0.2 Ib/million Btu), the RA specification  was changed
to 20 percent of the emission standard.

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     9.  Sections 5.2 and 5.3.  The minimum acceptable operational
condition was changed from 50 percent "capacity" to 50 percent
"of normal load."
     10.  Section 5.3.  This section was changed to allow the RA
test to be conducted during the calibration drift (CD) test period.
     11.  Section 6.  The third paragraph concerning the use of
incremental addition procedure was deleted.  The first paragraph
was revised to allow other CD procedures as long as the CD can be
determined.
     12.  Section 7.1.2.  The sentence, "A test run for grab samples
must be made up of at least three separate measurements," was added.
     13.  Section 7.2.2.  For those cases where the pollutant
concentration is varying with time over the run, the arithmetic
average of the CEMS value recorded at the time of each grab sample
is being allowed.
     14.  Section 7.3.  The second sentence was deleted, and a
revised sentence was placed under Section 7.1.2.

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                                 CHAPTER  3
                  SUMMARY  OF  PUBLIC  COMMENTS  AND  RESPONSES
 Commenter  VI-D-1
      1.1   Comment:   Section  4.1.   (Note:  All  sections  refer  to  PS  2,
 unless  otherwise  noted.)   Setting the  span at  the  expected  range of
 operation  would be more appropriate.
           Response:  The  span  level must be  chosen so that  the majority
 of  the  measurements  will  be  accomplished at  about midscale  and
 still allow the calculation  of a monthly emission average or  control
 device  percent reduction  average.  To  obtain the latter, it is best to
 select  a high span level;  however, the CEMS would become less accurate
 at the  low levels.   If the span level  is too low, then data would be
 lost when the emissions exceed the recorder full  scale.   To allow some
 compromises, Section 4.1  has been revised to allow spans to be set at
 50 to 100 percent of recorder full scale as long as a high-level  value
 is read between 90 and 100 percent of the data-recorder full scale.  The
 high-level value is  selected between 1.5 times the emission standard
 level and the span (which  is generally 1.5 to 2.5 times the expected
emissions).
     1.2  Comment:  Section 3.2.   In large diameter stacks there would be
no significant difference in results obtained from three sample points
compared to a single-point sample.  A more representative sample  could be
drawn from a single point, or points nearer the centroid of the stack.
          Response:   The use of three test points was based on
"Magnitude of S02, NO,  C02 and 02 Stratification  in Power Plant Ducts"

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 (EPA-600/2-75-053, September  1975) and  "Sampling  Location  for  Gaseous
 Pollutant Monitoring  in  Coal-Fired Power  Plants"  [Source Evaluation
 Society Newsletter 4(2), May  1979].  A  single point  located  1  meter or
 more from the  stack wall could be -11 percent off from  the average
 emission rate, and a  single point at the  centroid could be +9  percent
 off.  The use  of three points allows measurements to within  +3 percent
 of the average.
     1.3  Comment:  The  proposed revisions to Appendix  B are in the
 best interest  of all  involved in continuous monitoring.  I am  certain
 the revisions will result in a marked improvement of monitoring programs.
          Response:   None required.
 Commenter VI-D-2
     2.1  Comment:  The proposed revisions will have profound  effects
 on State implementation plans (SIP) across the country and,  in particular,
 on SIP that include provisions for use of CEMS data for demonstration
 of compliance with emission regulations.  Yet it  is difficult  to fully
 evaluate the impact of the revisions since EPA has given no opportunity
 to review either the  CEMS guidelines or Appendix  E.  We feel  very strongly
 that no revisions should be made until those documents are proposed and
 reviewed.
     Although, for the most part, it appears that the proposed revisions
might be appropriate for CEMS's installed to indicate proper operation and
maintenance of pollution control  equipment, EPA must realize that SIP

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refer to the Federal regulations when specifying requirements for
compliance monitoring.  With no mandatory design or installation
specifications and precious few mandatory performance specifications,
review of proposals to install a CEMS for compliance monitoring could
not be effective.  It is doubtful that expenditures of the magnitude
involved in installing a CEMS could be justified without prior indication
of the ability of the CEMS to provide accurate data.  Sources and
control  agencies would be at the mercy of manufacturers'  claims.
Sources could be tempted to purchase inexpensive, poorly engineered
systems, which would have a very low probability of passing the
certification tests.  If the system is installed and fails
certification, it is likely that the source would claim economic
hardship rather than replace or relocate the system.  Thus, if the
design,  installation and most of the performance specifications are to
published as guidelines only, EPA should undertake a program to certify
equivalent systems (analysis and sample interface) as is  done for ambient
monitors.  If EPA is unwilling to provide this assurance  of probable
ability of systems to provide accurate data, all  specifications should
remain mandatory for CEMS's used for compliance monitoring.
     Response:   The primary objectives of the CEMS PS's are evaluation of
data accuracy and representativeness.   To accomplish these objectives, EPA
feels that the three specifications, which include the limits of
inaccuracy and drift, listed under Section 4 of PS 2 and  Section  2 of
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  PS 3 are the essential requirements; i.e., the OEMS must be accurate,
  must not drift,  and must provide a means for determining drift.
       The proposed PS's are not designed to evaluate the installed CEMS
  performance over an extended period of time nor are they designed to
  evaluate adequacy of quality assurance (QA)  procedures.   For  that matter,
  neither  are the  present PS's.   The performance  specification  test (PST)
  procedure determines  the acceptability of  the RA along  with the monitoring
  location  and the  acceptability  of  the  drift  for  7 consecutive days.   At
  this time,  the only means  for evaluating CEMS's  for extended periods  of
  time is a provision in Section  60.13(c), which allows the Administrator
 under Section 114 to require the owner or operator of the affected
 facility to conduct additional CEMS performance evaluations.
      At the present time, QA procedures are being formulated to determine
 whether a CEMS  produces acceptable data (i.e.,  with  the  desired RA) on a
 day-to-day basis  so that the data can be used for continual  compliance
 purposes.  As was mentioned in the preamble,  EPA plans to publish  such
 procedures at a later date to determine precision and accuracy.
      The  CEMS guidelines were available in  draft form in a separate
 document  and have  been  available upon request since  the  time of proposal
 of  the PS's  for review.   As was  mentioned in  the  preamble, the CEMS
 guidelines are to  assist  vendors, purchasers, and operators of CEMS's with
 supplementary equipment and performance specifications,  and are essentially
 the specifications proposed on October 10, 1979.   The CEMS guidelines are
not mandatory and  are intended to aid in the selection of a CEMS.

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      The EPA agrees that it is doubtful  that the owner or operator
 of an affected facility would install  a  CEMS without prior indication
 of the ability of the CEMS to provide  accurate  data.   Most sources
 ask for references to determine the monitor's past  performance  and
 require some form of guarantee that the  CEMS would  pass  the  PST.
 The Agency feels  that this is a better approach  than  instituting  a
 costly certification program  or mandating  the present  PS's.
      2.2  Comment:   Section 60.13(d).  The wording  requiring
 quantification  of excess drift is unnecessary since Section 60.7(d)
 requires maintenance of the calibration  data in  the 2-year file.   If
 the  intent  was  to require  reporting  of excess drift, that has not
 been  accomplished.
          Response:  Although  Section 60.7(d) requires maintenance
 of the calibration data in the 2-year file, these data may not
 provide  the means to quantify  excess drift.  For example, not all
 CEMS's have strip charts.  Some use computer printouts and may give
 only  the adjusted output.  The intent was not to require reporting
 of excess drift on a regular basis,  but that the data should be
 available upon request.
     2.3  Comment:  Appendix B.  The only performance specifications
that could be eliminated without jeopardizing the evaluation  of a  CEMS
are the 2-hour zero and span drifts.  These specifications do not
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 relate  to  normal,  daily system  operation.   All  other design,  installation,
 and  performance  specifications  should  be  retained  as mandatory  requirements,
           Response:  We agree that  the 2-hour  zero and  span drifts
 are  not  usually  checked during  the  normal,  daily system operation.
 We also  feel  that  response  time and calibration error fall in this
 same category and  these instrument  checks  should not be made
 mandatory.  The  CD test is  also a form of  calibration
 error determination and would be redundant  if  the  calibration error
 test is  retained.
      2.4   Comment:  One general requirement which  we feel should be
 added for  a CEMS used to determine  compliance with emission regulations
 is a  periodic three-point calibration  check.  The  present requirement
 for  a daily two-point (zero and 80-100 percent of  full  scale) check
would not necessarily identify  problems with the calibration system
 (gas or cell) or the linearity  of analyzer response.  The monitor could
 be adjusted to read the expected upscale value regardless of whether
 the  system waS, in fact, operating  properly.  Addition  of the extra
upscale point would provide a check of both the linearity of analyzer
response and the integrity of the calibration gas  or cell.
          Response:  The use of a periodic three-point calibration
check is to evaluate the CEMS on a long-term basis.  Such checks
properly belong in the QA procedures.
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      2.5  Comment:   (a)   We agree that the sample acquisition point
 for RA RM testing need not be adjacent to the monitor sample
 acquisition point.   In fact,  the RM point should be located so as
 to be acceptable for new source performance standards (NSPS) compliance
 testing.
           Comment:   (b)   We agree with the relaxation of the RA
 specification when  actual source emissions at normal  process
 operating capacity  are less than 50 percent of the standard.  However,
 we would caution against extending this concept to the point where
 monitoring results  would be used only as a pass/fail  indication with
 respect to emission regulations.   The purpose of these requirements
 should not be confused with alternative types of performance regulations,
 such as sulfur in fuel,  which try to achieve a general  nonquantitative
 level  of emissions.
           Response:  None required.
 Cotnmenter VI-D-3
      3.1  Comment:   Section 7.2.2.  When NOV concentrations are not
                                            A
 linear with time, the RM average cannot be expected to agree with the
.integrated CEMS record over the set of three grab samples.   It is
 our suggestion that the  three grab samples be taken simultaneously
 (within a 3-minute  period) if possible.  If for some reason it is
 desirable to spread out  the grab samples beyond the 3-minute period
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 (up  to  21  minutes),  we suggest  that the  average RM values  be compared
 to the  average  CEMS  values  recorded at the  time of each  grab sample.
           Response:   Section  7.2.2  has been revised to allow the use
 of the  arithmetic  average of  the  CEMS values recorded at the time of
 each grab  sample.
      3.2   Comment:   Section 7.3.  This section  appears inconsistent
 with Section  7.1.2,  which requires  a 21-minute  maximum for  each  set
 of grab samples.
           Response:   This section has been  revised  to make  it  consistent
 with  Section  7.1.2.   The second sentence should  have been placed  under
 Section 7.1.2 with the word "set" changed to  "run."  The intent was
 that  three Method 7  grab samples constitute  a test  "run."  The word
 "set" refers  to all  necessary RM tests; e.g., Method 7 and Method  3
would constitute a set.
 Commenter VI-D-4
      4.1  Comment:   A review of these specifications shows them to be
 significantly improved over the existing specifications.   The following
changes have  been made:
     a.  Calibration Error and Zero Drift requirements have been
combined with the CD specifications.  This would reduce the amount of
effort required for completing the test.
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      b.  The CEMS Response Time requirement has been eliminated.
      c.  Reference Method Measurement Location and Traverse Points
 are clearly specified.
      d.  The 1-week conditioning period prior to starting the
 PS test has been eliminated.
           Response:   None required.
      4.2  Comment:   Section 4.1.   One should be allowed to use a
 span gas concentration of 50  to 100  percent span.   This would provide
 more flexibility to  the operator without  any significant loss in
 accuracy.
          Response:   See Response  1.1.
     4.3  Comment:   Section 5.3.   There is  a typing error.  The  second
 sentence should  read:   "To meet the  specifications, the  RA must  be
 equal to or less  than  20 percent of  the mean value of the RM  test data
 in terms of the  units  of the emission standard or 10 percent  of  the
 applicable standard, whichever is  greater."
          Response:  This section  has been  corrected.
     4.4  Comment:  Section 6.  It is not clear if the reference gases
during these tests would be introduced into the analyzer or through the
entire CEMS.  Since gas cells or optical filters are allowed,  it would
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indicate that the  intent here  is to consider the drift of the analyzer
alone.
          Response:  The intent is to determine the CD according to
the written procedure of the source owner or operator.  The
acceptability of the procedure will be determined under the QA
procedure.
Commenter VI-D-5
     5.1  Comment:  These regulations will apply to all sources
subject to PS 2 and 3, including some sources subject to Appendix P
of 40 CFR Part 51.  We are concerned that these proposed revisions
may result in additional expenditures to the systems installed at
our facilities, without resulting in any improvement in the accuracy,
reliability or enforcement capability of those instruments.   We have
now completed installing and modifying our opacity, nitric oxide,
and diluent monitors, an effort which began in 1976, and has cost
approximately $9 million.  It is our estimate that these revised
specifications could require the expenditure of an additional
$300,000 for testing, and increase maintenance costs from about
$20,000/year/monitor to $30,000/year/monitor.   Other users could face
more severe relocation or replacement costs.   In other words,  we
strongly disagree with EPA's statement that
          ".  .  .  existing CEMS that met the specifications of
          the current PS 2  and 3 also meet the requirements
          of these revised  specifications,  and therefore,  do not
          require retesting."
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      We believe that these specifications  could  require  replacement or
 testing,  depending  on responsible  agency's interpretation,  of many of
 the emission  monitors installed  since October  of 1975.   We,  therefore,
 still  urge  EPA to exclude  existing monitoring  installations  from  the
 proposed  revisions  with  the following language:
          "Existing monitoring installations shall be excluded
          from these revisions unless the  responsible agency
          demonstrates by  testing  the inadequacy of the  installation
          location,  opacity calibration, or RA."
     As we  urged in  our  December 7, 1979,  submittal application of
 these changes  to existing  systems  should be excluded.  While  the  intent
 is  reasonable,  it could  be  misinterpreted  by many local agencies.
 Specifically,  RM location  requirements,  system accuracy requirements
 and other key  areas  have changed.  It is clear that a system which
meets the existing PS might  be properly located  but still require
 retesting due  to RM  requirement changes.   It might also fail a
+20 percent system error.
          Response:   The intent of the cited statement was to let
agencies know  that they should not require retesting of all  existing
monitors under the revised PSrs.   Existing GEMS's cannot be  exempted
from being retested  because  it would be contrary to 60.13(c); however,
the PSvs have been amended to prevent CEMS's from being relocated to the
case where a satisfactory correction technique cannot be established.
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     5.2  Comment:  We appreciate your consideration of our December 7,
1979, comments on this subject and note that many significant
improvements have been made.  We still have two major concerns with this
recently revised proposal:
     a.  Section 3.2.  The RM measurement,location requirements should
exclude the "two equivalent diameter requirement" when:  (1)  pollutant
concentration changes are due solely to diluent leakage, and (2)
diluents and pollutants are simultaneously measured at the same location.
This allows practical siting of RM locations in large ducts, and will
not affect the accuracy of the method.
     b.  Section 4.2.  In over 300 RA tests conducted throughout our
system of 29 GEMS's, we have often found calibration errors in excess
of +2.5 percent of span, but RA results have been well  within +20
percent of the RM.   While we use 2.5 percent for testing, it is overly
restrictive for normal operation.   In fact, it is often counterproductive,
requiring much more adjustment and maintenance time with no resulting
improvement in RA,  but with significantly reduced reliability.
     In order to provide a practical and workable rule, you should
change this requirement to +_5 percent before readjustment is required in
normal  operation, or change paragraph 60.13(d)  to refer to 24-hour
zero and span drifts of twice the  amount referenced in  this paragraph.
          Response:   Section 3.2 and Paragraph  60.13(d) have been
revised to incorporate the suggestions.
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      5.3  Comment:   The EPA states  that these  PS's,  although related
 to QA,  should be evaluated on  the basis of their  adequacy in evaluating
 the GEMS's after their initial  installation.   One initial  test  is
 completely inadequate  to demonstrate  any suitability beyond  the test
 period.   Our  experience indicates most  problems occur after  this  initial
 test, even with  good maintenance.   Hence,  the  proposed PST cannot
 adequately evaluate  a  CEMS without  a  continuing long-term (6 months  or
 more) test.   If  EPA  wishes to  identify  such long-term testing as QA,
 then  it  should be integral  to  the PST for most currently  available
 monitors.
      In  any case, we again suggest  that  the best  course of action for
 EPA is to  continue to  review these  PS's while developing a QA program
 and gathering statistically significant data on a wide range  of
 analyzers.  Then, revised  PS's and  a workable QA package could be
 promulgated simultaneously.  Such a course of action would preclude
 equipment modifications and retesting at this time which may  prove to
 be unnecessary or counterproductive.
          Response:   We agree that one initial  test is completely
 inadequate to demonstrate any suitability beyond the test period.
The initial PST is to demonstrate the CEMS adequacy at the time
of the initial installation or soon  thereafter.  The QA procedure is
to evaluate CEMSrs on a long-term basis; therefore, we do not feel
that the QA procedure should be an integral part of the PST.   However,
users have the option of requiring an evaluation over a longer period
of time.
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      The  EPA will  continue to review the PS's while developing a QA
 procedure;  however,  the determination of acceptable QA programs will  be
 left  to the user.
      5.4   Comment:   Section 2.1.4.   Change title to "Data Aquisition
 System."   The recorder is  usually only a small  part of a cost effective
 data  system.
           Response:   The definition  includes  data aquisition;  therefore,
 a change  need not  be made.
      5.5   Comment:   Section 3.1.   The first sentence allows  correction
 of CEMS data  ".  .  .  so  as  to  be  representative  of the total  emissions
 of the affected  facility."  We agree  with  this  statement.  However,
 Section 3.1 also states, "If  the  cause of  failure to meet  the  RA test
 is determined  to be  the measurement  location, the CEMS may be  required
 to be relocated."  We believe that this  sentence  should  be deleted and
 that data correction  should be allowed in  all cases  where  RA results
 can be applied to generate  a  correction  factor.   This correction  factor
 would then  be  checked and modified during  periodic QA testing  at  the
 facility.
          Response:  The cited statement was  intended to take  care of
those cases where a practical solution for  correcting the  data cannot
be reached.  The statement  has been revised to read, "If the cause of
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failure to meet the RA test is determined to be the measurement location
and a satisfactory correction technique cannot be established, the
Administrator may require the CEMS to be relocated."
     5.6  Comment:  Section 3.2.  We recommend inserting "at least"
in front of "three traverse points" in the minimum requirements.  In
large ducts, 6, 9, or more may be needed.  Allowance of added points
as needed should be explicitly stated.
          Response:  More than three points are allowed.  Note the
phrase, "minimum requirements."
     5.7  Comment:  Section 3.2.  The point location should also be
revised.  Since "measurement line" is not defined, we assume it extends
from stack wall to stack wall.  For stacks with large diameters (e.g.,
5 meters), there is no guarantee that the samples will  be
representative of facility emissions.  We recommend deleting this sentence
and retaining the 16.7, 50, and 83.3 percent of measurement line unless
another configuration can be shown to be representative.
          Response:  The measurement line is defined earlier in the
paragraph.  Note that the second criterion is an option, not a mandatory
requirement.  It is true that for large (also for small) stacks, there
is no guarantee that the samples taken with the second criterion will be
representative of the emissions and that the first criterion of 16.7,
50.0, and 83.3 points offers a better chance, if there is stratification.
The second criterion was based on practicality for those cases where
                                    2Q

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stratification is not expected.  The text has been revised to make
this clear.
     5.8  Comment:  Section 4.1.  This paragraph is confusing as
written.  We assume that it suggests setting both data system
equipment and the CEMS analyzer spans with a 90-100 percent of
                                                i
full-scale value.  While this is normal for highly linear data system
equipment, it may be ill-advised for the analyzers.  In that case,
the span level should be permitted at other than 90-100 percent
without requiring Administrator approval.  A span level near the
regulation limit (about 50 percent of full-scale) is suggested.  Some
light absorption [e.g., nondispersive infrared analysis (NDIR)]
detectors have nonlinear outputs that are not as effective near full
scale as the response curve flattens out.
          Response:   See Response 1..1.
     5.9  Comment:  Section 4.2.  While it appears that a source
may adjust its CEMS as needed during the performance testing to
meet the +2.5 percent criteria (Re:   Paragraph 6) this is not
immediately clear.  We suggest adding the phrase "allow daily
(more often if specified) adjustment, if necessary."
          Response:   The CEMS is not to be adjusted unless it is
part of the normal operating procedure.   Section 6 has been revised
to reflect this.
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     5.10  Comment:  Section 4.3.  By including potential stratification
effects within the RM test as well as pollutant and diluent errors
within the +20 percent you have effectively made a +30-50 percent
requirement much more severe.  While we successfully use such a standard
on our sources, it is not clear that this is economically reasonable
or technologically feasible.  In any case, we suggest that this be
demonstrated - on a variety of sources - before forcing utilities into
an overly expensive and time consuming program which may never work as
intended.
          Response:  Many CEMS have met the +20 percent criterion for
combined pollutant-diluent systems.  If a CEMS is not capable of meeting
this requirement during the initial PST, it would certainly be a poor
candidate for a long-term reliable operation.  See also Response 8.3.
     5.11  Comment:  Section 5.2.  Load or capacity should be allowed
to vary over the full range that it does in normal operation, including
nearly full loads, but not limited to 50 percent.  If loads of less than
50 percent are typical of unit operation, it is important to test at
50 percent load.   Large errors may often be introduced by negative duct
pressures, different temperatures, etc., at low loads.  Further, the
50 percent restriction places an unreasonable burden on existing units.
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          Response:  This section has been revised to  50 percent
of normal operation.
     5.12  Comment:  Section 5.3.   It is not essential to hold
the RA test period until after completion of the CD test.  This
should be up to the source, based on experience with the monitors
under test and scheduling needs.
          Response:  The section has been revised to allow RA
testing during the CD test period.
     5.13  Comment:  Section 6.0.  The incremental addition
procedure should not be tied to 80-95 percent of span, but rather
to an appropriate incremental cell which will provide  the most
meaningful demonstration of the analyzer's operation.  The value
will  depend on stack concentrations and the shape of the Beer's
law curve for the given analyzer.
          Response:  The third paragraph has been deleted.   Since
this  case is mentioned in Section 4.1, it is not necessary to
make mention of it again.
     5.14  Comment:  Section 7.1.  In our 3 years of RM testing, we
have  found that it is relatively simple to pass existing PST's at one
load  or boiler condition - but that in our boilers,  where loads and
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fuels vary widely, the RM tests need to be done over the full range
of operating conditions.  We suggest that the tests be made over a
representative set of conditions and a long period of time, e.g.,
several months.
          Response:  This is one option that we have decided not
to mandate because of cost considerations.  To write the PS's so
as to cover all source conditions would require the most stringent
approach, which can be costly and may be unnecessary for some or
the majority of the sources.  However, the sources, understanding
their peculiar problems, may choose to use the more stringent
procedures to ensure the specified RA requirement.
     5.15  Comment:  Section 7.1.  If the source operating
conditions vary significantly with time, the calculated emission rate
may have no relationship to the actual emission rate unless pollutant
and diluent measurements are taken simultaneously.  We recommend
requiring simultaneous measurements unless the source operator can
show that time/pollutant variations are insignificant.
      x
          Response:  See Response 3.1.
Commenter VI-D-6
     6.1  Comment:  The proposed rules are certainly consistent in that
the only method of detennining the acceptability of a given instrument
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 is  with  respect to the RM's.   Unfortunately,  during  the last 5 years
 we  have  not  seen any advancement in  the  accuracy,  repeatability,
 reliability  or  cost associated with  the  RM's.   In  the  same  period,
 we  have  seen substantial  improvements  in our  gas measuring  instruments
 to  the point where, in many cases, they  are a much better criteria  for
 establishing emissions than are the  RMfs.
     At  the  current time  and  under the proposed specifications, there
 is  no criteria  which either qualify  or motivate the  stack sampler
 to  do an  adequate  job.  We recognize that  there have been interlab
 comparison studies  which  have  attempted  to evaluate  RM  accuracy, but
 how valid is the data  so  obtained when the intent  is known,  as
 opposed to running  a  stack sampling  exercise  in the  field with
 sometimes poorly trained  personnel and under  trying, demanding and
 adverse conditions?  Since EPA  has established  the RMrs, it  seems
 that they have  been  very  wary of quantifying  inherent errors or
 attempting to provide  quality checks to  ensure  that  inadequate RM
 data are not used in any  of the required test evaluations.    In particular,
 RM  7 has been nearly universally proclaimed by  stack samplers and
 users alike  as  a very  imprecise method.  Further,  the American Society
 for Testing and Materials (ASTM) describes several  biases and
 interferences for this method which are never mentioned in  the EPA
descriptions.  At the current time, we believe  that RM 7
may exhibit a substantial negative interference due to chlorides
which are present in the outlet of wet scrubber type flue gas
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desulfurization systems.  Reference Method 6 is certainly better than
Method 7, but still is not ideal and their consistency is, in no way,
comparable to National Bureau of Standards (NBS) reference materials.
     At a minimum, under the above conditions, the RM should be verified
using a traceable NBS gas, and only that RM which meets the blind
gas sample check should be acceptable for verifying an instrument.
All manual stack sampling reference data should be qualified during
each test using blind gas samples.   If the errors are believed to be
consistent during a given run, the RM data should be corrected according
to the error observed in the blind sample.  Further acceptance criteria
should be established in terms of the uniformity of individual data
points established in a given run.
          Response:  The commenter's primary contention is that NBS
reference gases are better checks for accuracy than the RM's on the
basis that RMfs are "fickle."  It is true that the RM's can give
erroneous results when the procedure is not properly executed.  This is
also true of a CEMS.   The Agency is presently in the process of
including QA procedures into Methods 2 through 8 to ensure high
probability of obtaining valid data.
     The Agency considered for Methods 6 and 7 a periodical  check against
a known gas cylinder concentration.   At this time,  however,  we
feel that qualifying testers at each test in the use
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 of the RM's against blind gas samples would be costly.  We feel that
 the option to use such a procedure should be left to the vendor and
 the user.
      We see no reason why the RM should be verified time-after-time
 against traceable NBS gases.  The methods have been established as
 RM's and have been proven to provide accurate data, when properly
 executed.  It would seem prudent to inquire into the tester's
 experience and secure testers with an established reputation of
 providing accurate and precise results to run a stack sampling exercise
 in the field  under trying,  demanding,  and adverse conditions.   If the
 RM's  are properly conducted and  the quality control  procedures in
 the methods are  carefully followed, the results will  be accurate
 measures of emissions.
      We  agree  that Method 7 is less precise than  Method 6.   The
 imprecision of these methods has  been  considered  when  the +20  percent
 criterion was  established.
      Method 7  does not mention the  chloride interference mentioned  in
 the ASTM method  since high  concentrations  of  chlorides  were  not expected
 in  nitric acid and power  plants.  About  a  1:1 ratio of  chloride to  NO
                                                                      A
 is  required before there  is  any appreciable reduction in concentration. '
      6.2   Comment:  Because  of the  ability  to calibrate  these  instruments
dynamically, i.e., at stack  temperature  and pressure, using either  direct
or traceable NBS reference gases, instruments can be made accurate, and
measurements very  repeatable.  Using the criteria you have proposed, one
would be forced to throw away  the only consistent and accurate  standard which
we have and attempt to design  instruments to meet a fickle RM — this is
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 certainly not in the best interests of regulator,  vendor, or user.   The
 reason I  say that you have essentially outlawed traceable gases in
 your proposal is that in the event that an instrument fails the RA
 (RM correlation) test,  the users'  most promising approach
 is to reset the calibration so that it is  supposedly equal  to the
 past RM data and run the test again.   This does not achieve the desired
 results of consistent,  accurate calibration.
      For  those instruments whose calibration  can be validly checked
 using direct or traceable NBS gases,  the testing with respect to existing
 RMTs is a  redundant  and an unnecessary,  costly  exercise.   It may be
 reasonable to use RM's  sometimes to evaluate  the potential  stratification
 effects on the CEMS,  but the NBS gases  should be an acceptable  measurement
 qualifying media.  Certainly not all  instruments can  be validly checked
 with NBS gases under dynamic stack  conditions,  but  those  which  can,
 should  be  permitted  to  be operated  with  certification criteria  which  are
 relevant to the capabilities of such  instruments.   We strongly  recommend
•that the EPA should  investigate the capabilities of such  instrumentation
 and  determine if the desired accuracy and  consistency can be  obtained
 with less  costly testing  procedures.
           Response:   We would  tend  to agree that the  capability
 to dynamically calibrate  instruments is  a  plus  in instrument
 design.  However,  calibration  gases are  not identical  in  composition
 as the  stack effluent being  monitored.   In addition,  in several
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 cases, when differences were found between the OEMS and the RMrs,
 the cause was traced to an incorrect moisture correction, moisture
 interference, or a plugged filter, i.e., dynamic calibration, by
 itself, is not sufficient to ensure accurate results.
      The use of direct or NBS reference gases is not prohibited.
 The PS merely allows greater flexibility of meeting the RA
 requirement.   For example, there are users of instruments who
 obtain accurate results by using gas cylinders that are analyzed
 by the RM's.   The use of such cylinders is less  costly than  NBS
 reference  gases.
      Presetting the calibration is not improper  if improper  calibration
 is determined  to  be the cause for the  difference  between  the  CEMS  and
 the RMrs;  however,  resetting  the calibration  based  on  erroneous  RM
 results would  not be  prudent.
     We agree  that  for  those  instruments whose calibration can be
 validly checked using direct  or traceable  NBS gases  in  lieu of
 the RM's would  be a redundant,  unnecessary, and costly  exercise.
 However, how does one determine what "constitutes" a "valid" check?
 As  mentioned earlier, several cases showed that the use of NBS
 calibration gases by itself is  insufficient to check the accuracy
 of  a CEMS.   All CEMS operators should establish and demonstrate that
 their procedure is adequate to  "validly" check the CEMS.  After the
demonstration,, one can apply for an alternative procedure under
Section 60.13(1) of 40 CFR Part 60.
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     6.3  Comment:   In several places in your proposed values, you
have reiterated the  RA criteria in terms of +20 percent of the
mean reference value or +10 percent of the applicable standard,
whichever is greater.  This specification is to include the pollutant
and diluent monitor, as well as the ppm to Ib/MBtu converter and
recorder.  We certainly agree that we should continue to push for more
accuracy as long as  it is not unduly costly, but this specification is
overly demanding, considering that the RMrs are far from absolute
and that there certainly is less intrinsic value associated well
under basic requirements.
     If the proposed criteria are promulgated,  it will  certainly
encourage any informed operator to operate as near the  emission limit
as possible during RA testing to ensure an error window of 20 percent.
At emission levels of one-half the emission standard,  the +10 percent
of standard becomes effective and remains the effective criteria as
emission levels approach zero.   This penalizes  the conscientious operator
and substantially increases the cost of certification.
          Response:   The relative error criterion of +20 percent of
the mean RM value is not a proposed revision,  but is the promulgated
requirement.   The +JO percent of the applicable standard is the proposed
revision.   This criterion was included to alleviate—not penalize—the
"conscientious operator."  Let us assume that the standard is 500 ppm
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 and the source is operating at an emission level  of 100 ppm.   If the
 +.20 percent criterion is used, the CEMS must operate within +20 ppm.
 However,  with  the +10 percent of standard criterion, the CEMS must
 operate within +_50 ppm or +50 percent of the RM mean value.
      6.4   Comment:   It is important to note that  an increasing number of
 scrubber  applications provide emission levels of  15-50 ppm S02 to meet
 the 70 or 90 percent removal  criteria.   Considering the fact  that,
 typically,  these  instruments  are scaled for span  values of 300 to 750,
 these  readings are  a very small  percentage of full  scale (2  percent  to
 16  percent), the  error allowance in terms of ppm,  not percent of reading,
 is  very important.   As  a  result,  I  would  propose  that the  two-tiered
 accuracy  criteria be eliminated.  We  would suggest  that for a scrubber
 inlet monitor,  the  recommended +20  percent of the emission  limit be
 applied to  the  actual  inlet concentration  or  RM value.   For an cutlet
 monitor,  the recommended  +20  percent  of the emission  limit be applied
 to  the  product  of the  inlet concentration  multiplied  by the required
 removal efficiency.
     I  firmly  believe  that your  proposed  criteria,  as  compared to the one
 recommended above,  are overly  demanding and will only  cost the user more
 in terms of repeat  testing and will not provide any  improvement  in
overall instrument  accuracy.  We favor  treatment of the system as a
whole, but allowances must be  sufficient to provide adequate margins
 for the RM's, each  instrument  (diluent and  pollutant), and associated
hardware.   Your proposed +_10 percent of the emission standard
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 does not leave sufficient margins under any, except the most ideal,
 conditions.
           Response:   We agree that high span values would cause higher
 relative inaccuracies at the low concentrations.   However,  the use of
 a standard +20 percent of the emission standard would penalize
 instruments used on  the scrubber inlet,  especially if the emission
 standard is low in comparison to the  inlet  concentration.   In  addition,
 instead  of encouraging any improvement in overall  instrument accuracy,
 the  suggested  criterion,  which  increases the allowable  inaccuracy,  would
 seem to  encourage  greater inaccuracy.  To improve  the  instrument  accuracy
 at low levels,  it  would  be better  to  simply  allow  lower  span gases
 to be used.  To  avoid  retesting, the  CEMS should be reliable and
without  any biases; and competent  testers should be used.
     For the second recommendation, the correct emission  limit  should
 be the product of  the  inlet concentration multiplied by  the allowed
 removal  inefficiency—not  required removal  efficiency.
     6.5  Comment:  Another factor needs to  be clarified  in this general
RA area.  A scrubber operator may be  required to meet a 70 or
90 percent S02 removal efficiency as well as a gross 0.6 to 1.2 Ib/MBtu
ceiling.  In terms of your proposed +10 percent of the emission standard
or our recommended +20 percent of the emission standard, specifically
what is the emission  standard for an inlet  and outlet S0? scrubber
monitor?
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          Response:  The criterion is +20 percent of the RM mean value
or +JO percent of the emission standard, whichever is greater.
Therefore, at the inlet of the scrubber, the +10 percent of the emission
standard criterion would not be expected to be used, but the +20
percent of the RM mean value would be used.  For the outlet, the emission
standards are defined by the regulations.  See Subpart Da, Section 60.42a.
For example, for sources under 60.43a(a), the emission standard is
1.20 Ib/million Btu, or 10 percent of the potential combustion
concentration, or 0.60 Ib/million Btu, or 30 percent of the potential
combustion concentration.
     6.6  Comment:  In terms of determining scrubber efficiency, it is
extremely important that the inlet and outlet monitors be referenced to
a common stable reference.  Again, the only consistent standard of which
we are aware is an NBS gas.  Without a common reference, the inlet and
outlet monitors could be mi sealibrated by up to +20 percent of
reading, which could result in up to a 15 percent error in scrubber
efficiency, indicating 55 percent removal when the actual removal is
70 percent.
          Response:  We agree that the inlet and outlet monitors should
be referenced to a common stable reference.  Of course, we feel that
at present the RM is that reference.  In calculating the maximum
error that could result from mi sealibration, the commenter erroneously
assumed that the monitor can be miscalibrated by +20 percent.  Such
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 a monitor would not pass the RA test,  unless the RM gave very precise
 numbers, an unlikely event.   A more reasonable  maximum bias  is about
 +10 percent.   Instead of seeing a  possible maximum error of  +15
 percent at the 70 percent level, one would see  about +7 percent at
 the 70 percent reduction level  and +2  percent at the 90 percent
 reduction level.
      6.7  Comment:   In  paragraph 60.13, you have required operators
 of CEMS to check  the zero and span drift  at least  once  daily --  and  to
 readjust the  zero and span whenever the 24-hour  zero and span  drift
 exceeds the limits  of the applicable performance specifications.
 Since  there are no  criteria  for what constitutes a check of  zero and  span
 and  since  operators  do  not wish to  readjust  anything  any more  often  than
 absolutely  necessary, the  aggressive instrument  manufacturer or user would
 design  this check to  include  as little of  the overall measurement system as
 possible.   In fact,  by  using  a relay to switch the drive signal input to the
 final  current driver, one  could ensure that  the  zero  and span  checks
 would  be stable and  that  the  instrument would virtually never
 need readjustment, at least as-so far as "zero/span" drift values
 are concerned.  Obviously, this situation  is not consistent
with the basic intent of the  specification and must be corrected.  We
would suggest that the following statement be added in 60.13(d):  "The
 zero and span drift check must, at a minimum, include all the active
 components  used or referenced in the normal stack gas measurement cycle,
 except  that predictable effects, such as stack temperature compensation,
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 which would otherwise cause the zero and span values to vary,  can be
 checked  independently.   The zero and span drift check values  shall
 normally remain  invariant from day-to-day if the instrument does  not
 exhibit  any drift."   This statement would ensure that zero  and span
 drift values provide  a  valid indication  of the stability of the
 measurement system.
           Response:   The basic approach  of the PS's  is  to state what
 is  expected of the CEMS and the manner  in which the  specifications
 are to be  evaluated.  This  was done to allow greater flexibility  in
 the design  and selection of the instruments  and to allow for innovative
 technology.
      The first criterion, the  RA, is  checked  with the applicable  RM's.
 The second  criterion, the calibration drift  at  the zero  and span  levels,
 is left up  to the manufacturers  and the  users.   If the manufacturer
 designs an  instrument to  include, as you  indicate, as little of the
 overall measurement system  as  possible and if  the user accepts  his
 design, the  user is responsible  for the quality of the data.  The
 Administrator, under Section 60.13(c), can require the owner or operator
 of the affected facility  to  conduct additional  CEMS evaluations.  For
 those sources that must continually comply with the emission standards,
 the QA procedure will  most  likely involve periodical' RA checks.  These
RA checks will ascertain the adequacy of the drift check procedures.
 If the manufacturer does not properly design his instrument to operate
reliably and the user accepts such instruments, the user in  the long
run can be subjected to costly repairs and tests.
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     We agree  that  instruments should be designed  so that  the  zero
and span calibration checks include all the active components;  however,
we cannot say  that  this requirement is absolutely  necessary for all
designs.  The  guideline will be revised to include these points.
     6.8  Comment:  Section 6.  The effects of automatic calibration
and correction do not appear to be anticipated in  this proposal.  In
one of our typical  automated CEMSrs, the zero and  span check values from
all instruments are individaully recognized and the appropriate zero
and span calibration correction can be applied to all succeeding data
until the next calibration cycle.   In this case, no readjustment of
zero and span  should be necessary until the correction exceeds the
manufacturer's recommendation.  This means that no zero or span drift
would be seen  in the final reported emission values.
     Your proposal  to eliminate the potential advantages of automatic
calibration correction eliminates one of the more cost-effective tools
with which the instrument designer has to work — digital electronics.
We recommend that automatic correction be allowed, but with
qualification.  When automatic correction is allowed, the automatic
correction should be monitored and the drift in correction should not
exceed three times  the normal  drift allowance, provided that the
corrected output is less than one-third the normal drift allowance.
          Response:   We are not disallowing auto correction.   All  we are
asking is how much  is the correction.
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      6.9   Comment:   I  would  like  to  point  out  that  qualification  of
 the  zero  and  span  drift  integrity has  been included and  is  existing  for
 opacity monitors --  but  not  gas analyzers.   In  60.13(d),  it  states that,
 "Such  procedures shall provide a  system check of  the analyzer  internal
 optical surfaces and all  electronic  circuitry,  including  the lamp and
 photodetector assembly."   Unfortunately, the intent of this  statement
 is admirable,  but  1t is  openly violated by at least one model  of
 transmissometer which  has  been "certified"  in some  applications and
 tacitly approved by  the  EPA.  This fact is  primarily important from  the
 fact that  EPA must establish a reasonable  floor for instrument
 performance and apply  it uniformly or  the market will become distorted
 by less expensive imitations which can get  by and will be purchased on
 a strictly cost-selection criteria.  The eventual outcome of such actions
 is an unhappy user and data of less real integrity  than that specified.
          Response:  The specification in 60.13(d)  for opacity monitors
 is given because there is no easily applied RM for  transmissometers.
 Manufacturers of different instruments can request  a determination if
 certain procedures meet the intent of the regulations in principle.
 Approval  of such procedures,  however, does not "certify"  the instrument
 nor does  it mean that the instrument will  continuously operate  with  or
without loss in integrity.
     6.10  Comment:  The  argument with respect to whether the
 span calibration check  should be  done near mid-scale, 50  percent
                                   37

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 or full  scale,  90 percent,  is  somewhat  mundane.   From  a  technical
 standpoint,  the closer  the  check  is  to  full-scale,  the better
 will  be  the  check of the  real  span drift  component  as  opposed  to
 zero  drift.   From the practical viewpoint, the span check material
 is relatively difficult (costly)  to  manufacture to  a specific  value.
 Since the  desired effect  is to ensure accuracy in the  vicinity of
 the emission  standard,  we would suggest that the span  check be
 performed  at  a  value  which  is a minimum of 1.5 times the emission
 1imit.
           Response:   See Response 1.1.
      6.11  Comment:  In  PS 2, paragraph 6, you have specifically
allowed a  single-point  incremental addition type check of
instrument drift.  It is very easy to prove that it takes two
points, at a minimum, to define a linear calibration function.
Normally, .these two criteria are defined as gain and offset, which
correspond to EPA's typical  span and zero parameters,  respectively.
By using only a one-point definition of a calibration  function,
you have made it impossible to predict the performance of the
instrument at any other point on the calibration  "curve."  We
strongly recommend that a  single-point drift  check only be  allowed
if the user can show that either the zero/offset  or gain/span
characteristic is stable (non-variable)  and predictable for that
individual  instrument.  It should  be noted that all  gas analyzers
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can be designed to incorporate a zero and span check.  In some designs,
it is more expensive than others, but this should be a required
characteristic if the EPA really desires a consistent specification
which will ensure a reasonable degree of accuracy.  We would recommend
that the EPA consider the experience of Pacific Gas and Electric in
San Francisco in their attempt to obtain reasonable performance from
their across-stack gas analyzers.  It is our understanding that the
rotating zero pipe has been necessary to accurately define the
performance of such systems.  A paper was presented on the subject at
the 1979 APCA Show by Bob Webb of Pacific Gas and Electric.
          Response:  We agree that a single-point drift check should be
allowed only if the user or manufacturer can show that either the
zero/offset or gain/span characteristic is stable and predictable for
that individual instrument.  In the case in point, the vendor did exactly
that.  It is our understanding that the one-point check was sufficient to
determine calibration drift.
     6.12  Comment:  It is not clear what the allowable zero and span
drift are without adjustment, considering that the PS 2
criteria  involve statistical means and confidence
intervals.  These data are not readily available on a day-to-day basis.
                                     39

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          Response:  Section 4.2 specifies the allowable zero and span
drifts.  The specification criteria do not involve statistical means
and confidence intervals.
     5.13  Comment:  It appears from this and previous proposals that
the EPA has assumed all devices are equally inadequate, not capable of
being easily checked with a high degree of integrity or predictability,
and have settled on a rigorous correlation with RM's as the only
method of determining compliance with basic accuracy requirements.  This
means that all measurement techniques, even those including the highest
degree of built-in verification means, must also comply with the most
costly means of verification (RM testing) which are really only relevant
to the instruments with the least capability.  In the interests of
our economy and the often-suggested high cost of environmental monitoring,
we sincerely believe that it is necessary for EPA to consider lower cost
means for certification of instruments with greater capabilities for
verification.  From another viewpoint, it may be much more desirable
for a user to purchase more instrumentation verification capability on
the front end to reduce future certification, maintenance and QA costs.
Additionally, it is certainly much more inexpensive to purchase and use
traceable calibration gases than to become involved in repeat testing
according to RMKs 6 or 7.
     At the current time and under the proposed rules, there is no incen-
tive to evaluate this trade off, since all devices are assumed to be
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marginal and certification costs are the same high value for all devices.
For example, all across-the-stack devices could be equipped with rotating
zero pipe facilities to provide zero and span checks with a high degree
of integrity.  Without this calibration means, one is justified in
mandating rigorous RM testing in order to ensure accurate results.   Another
example involves the use of NBS traceable zero and span check reference
materials.  With nontraceable materials, one is left with a high degree
of suspicion regarding the meaning and integrity of such calibration checks.
With traceable references, the calibration checks can provide much higher
real calibration accuracy.  A third example involves the potential  validity
of a dynamic calibration check, using NBS traceable gases at stack
temperature and pressure.  Without this means, a high degree of RM testing
may be necessary to ensure valid results.  With this capability, the use
of traceable gases can provide a higher degree of integrity than will  ever
be achieved with wet-chemistry, operator-dependent, RMrs.   We would welcome
the opportunity to discuss the above options with the EPA in more detail.
We would like to make it clear that we believe that we can ensure a
higher degree of accuracy and substantially lower certification costs
(50 percent) if the EPA will  consider certification means which are more
proportionate to the inherent built-in or installed capabilities of the
instrument.
          Response:  The Agency has not assumed that all  devices
are equally inadequate.   If this was true,  then EPA would not have
required the use of CEMS for monitoring purposes or for continual
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compliance  purposes.  The Agency  has concluded that  the best means  of
checking  the  instrument for accuracy is the RM tests.  This, however,
do.es not  preclude alternative and cheaper means to be used for checking
RA.  Those  measurement techniques with "the highest  degree of built-in
verification  means" would be more likely to be approved than those  with
the lesser  capabilities.  And EPA will consider lower cost means for
certifying  instruments if it is adequately demonstrated that such
procedures  will provide the proper evaluation.  The  QA procedures
can be used for these demonstrations.
     The  EPA  encourages users to consider those GEMS's that can easily verify
the accuracy, which would reduce future certification and QA costs, in
addition  to its demonstrated reliability and cost of maintenance.
     We agree that the use of traceable calibration gases is less
expensive than to become involved in repeat testing using RM's 6 and 7.
However,  it should first be established that the traceable calibration
gases are sufficient to insure the required accuracy.  See Response 6.2.
     As was mentioned in the preamble to Subpart Da,  EPA will  be proposing
QA procedures to require the determination of precision and accuracy of
the CEMS.   These procedures should provide the incentive to obtain reliable
instruments.
     6.14  Comment:   We believe your proposal  is weak in one other area,
which is necessary to ensure accuracy measurement at emission  levels
other than the one encountered during RA testing.   This is the area
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of linearity, or nonlinearity, as the case may be.  We would
recommend that the linearity or nonlinearity should be documented
by the equipment manufacturer at the factory.  We would recommend that
if the manufacturer represents an instrument as having a linear
calibration curve, that a test similar to your existing RA test be
performed, except that that data should be evaluated in terms of its
deviation from a straight line.  For such linear instruments, the
maximum deviation should not exceed +3 percent of span.  For nonlinear
calibration curves, the vendor should demonstrate that the published
nonlinear curve is accurate to within +3 percent of span for that
individual instrument.   The NBS traceable materials should be required
for this test.  The calibration may exclude temperature compensation
if such can be shown not to affect the linearity or nonlinearity of
the system.  The manufacturer should thus provide, in essence, a
certificate of calibration.  Further, the manufacturers'  maintenance
procedures should be directed toward verifying or maintaining the
given calibration function.
          Response:  The Agency agrees that linearity or nonlinearity
should be established and periodically verified.   However, EPA is
leaving the option of whether to have such procedures or certifications
to the user.
     6.15  Comment:  We definitely believe that these proposed regulations
and revisions should not be applied retroactively.  It may be reasonable
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 to make them effective for instrumentation purchased after the date of
 the proposal,  but certainly not broadly retroactive.   The basic
 reason  for this  concern is the  revised  RM  certification  testing
 which could require changing the installation  site  in  some circumstances,
 and the tighter  accuracy specifications which  are inherent with the
 proposed consideration of pollutant  and diluent monitor,  ppm  to
 Ib/MBtu conversion,  and recorder,  as a  system  which  must  fall  within  the
 same error band  as  previously allowed for  just the pollutant  monitor.
 There are  substantial  changes which  become even more significant when
 considered in  light  of the  potential  errors and costs  associated with
 the  RM  testing.   It  may be  reasonable to mandate updating  to  this
 specification within 5  years after date of the initial certification.
           Response:  See Responses 5.1  and 8.3.
     6.16  Comment:  Section 2.6.  The  validity of the "established
 reference  value"  is  totally undefined, as  discussed previously.  Such
 values  can be estabished to provide minimum measurable or visible drift,
or to provide a valid check of the operation of the entire measurement
 system.
          Response:  This is the reason that RA tests are conducted with
RM's.  See also Response 6.7.
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     6.17  Comment:  Section 2.1.4  The last sentence needs to be
expanded as follows:  "The data recorder may include automatic data
reduction and correction capabilities."
          Response:  Automatic data reduction does not preclude
correction capabilities.  The suggested addition need not be
made.
     6.18  Comment:  Section 4.1.  The single-point calibration
drift determining technique is wholly unsatisfactory, as previously
discussed, unless the operator can show that the offset or gain of
the system is nonvariable.  There is a noticeable inconsistency
here in that you have tacitly allowed single-point calibration checks
without qualification and are, at the same time, specifying overly
tight limits on the range of allowable zero and span limits.   If
checking is not possible at zero and span, the lower value should be
between 0 and 33 percent of full scale, and the upper between 66 and
100 percent.
          Response:  See Responses 6.11 and 1.1.
     6.19  Comment:  Section 5.2.  There should be no restriction
for plant operating capacity as proposed.   It may be reasonable to
require that the plant operate at more than 50 percent capacity for
at least 3 days out of 7, but certainly not all the time.
          Response:  See Response 5.11.
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      6.20   Comment:  Section  5.3.   (a)  The CD and RA  tests  should
be allowed  to  be conducted  simultaneously to reduce costs,   (b)  One
test  failure does not generally  invalidate the results of  the other.
(c)   The last  sentence could  be  somewhat restrictive depending on
the meaning of the word, "demonstrated."  We prefer that the last
half  of the sentence be modified to state, "... unless the zero
and span calibration check  values are shown to be unaffected."  If
one part of the system fails, the RA testing should be allowed to be
completed for  the remaining available data, as long as no more than
one major system component  has failed,  (d)  We would propose that
for diluent/pollutant measuring systems, the error criteria be
tightened up by Mfi. or 0.707, compared to the combined system tests.
Thus, an individual  diluent monitor could be certified at 0.707 times
20 or 14.14 percent error allowance, as could the pollutant monitor
alone.
          Response:   (a)   See Response 5.12.   (b)  It is true that
one test failure does not generally invalidate the results of the other.
This depends on the system,   (c)  As mentioned earlier (see
Response 6.2),  the suggested modification is not sufficient to
ascertain whether adjustments made to one channel does not affect the
others.  This also includes failure of major components.   The degree
of restrictiveness of the word "demonstrated"  depends on the particular
CEMS.   (d)   See Response 8.3.
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      6.21   Comment:   Section  7.1.   It is  very important that if the
 plant operating  conditions,  such as load,  fuel  and  excess  air,  are
 not  reasonably constant (+10-20  percent)  during the RM tests,  and
 that the diluent,  pollutant and  moisture  are  determined as  near
 simultaneous  as  possible.
           Response:   See  Response  3.1.
      6.22   Comment:   Section  7.3.   We support the note in  this
 paragraph.
           Response:   None required.
      6.23   Comment:   Section  3.2 of PS 3.  We question  the  accuracy
 of Method  3 in its basic form.  In particular,  this  is  an area where
 a dynamic  calibration check,  using NBS traceable gases, should
 be allowed  in lieu of Method  3, if the diluent  analyzer is  tested
 alone per  the tighter-suggested RA error allowance  (14.14 percent).
           Response:  See Responses 6.1, 6.2, and 8.3.
 Commenter V1-0-8
     8.1  Comment:   These comments on the proposed 'revisions are
 submitted on behalf of the Utility Air Regulatory Group (UARG).  The UARG
 is composed of the Edison Electric Institute, the National  Rural Electric
 Cooperative Association, and 85 individual electric utilities.   A list
 of UARG's members is enclosed as Enclosure 1.
     The UARG filed comments on the October 10, 1979, proposed revisions
 in December, 1979.   Our review of the reproposed PS's indicates that the
Agency has responded to several of the earlier UARG comments.
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     We would like to suggest certain additional changes which appear
necessary as a result of the changes which the Agency has made since the
earlier proposal.  The UARG comments are discussed in some detail in
Enclosure 2.  I would like to take the opportunity to briefly summarize
in this letter some of the more important comments.
     Continuous monitoring technology is a developing science.
The problems with monitor accuracy and reliability have been well
documented by both UARG and the Agency.   Given the state-of-the-art
of monitoring technology, it is critical that any PS's be flexible
enough to allow sources to respond to unanticipated problems and
special circumstances.  We, therefore, applaud the increased
flexibility which the Agency has introduced in the reproposed PS's.
At the same time, however, we encourage  the Agency to issue at an
early date the monitoring guidelines referred to in the January 26,  1981,
Federal Register publication, in order to provide vendors,  purchasers,
and operators of continuous monitors with supplementary equipment and
performance specifications.  While we agree that the state-of-the-art is
not adequate to incorporate more specific guidelines in regulatory language,
more detailed guidelines would be helpful as a starting point for continued
discussions among the Agency, monitor users, and monitor vendors.
     While we agree with the general approach taken in the  reproposed
revisions to Appendix B, we have a variety of concerns with particular
aspects of this reproposal.  These concerns are listed briefly in the
following comments.
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           Response:   The CEMS guideline document was available on
 January  26,  1981.   However,  based on  the comments received during the
 comment  period  of  this  rulemaking,  the  document  will  be  revised and
 republished  as  soon  as  possible.
      8.2   Comment:   The reproposed  PSTs address  only the location of
 outlet monitor  systems.   For sources  with pollution  control  technology,
 an  inlet  as  well as  an  outlet monitoring system  may  be required.   The
 Agency, therefore, must revise these  reproposed  PS's  in  order  to
 account for  questions concerning  location  and  testing of inlet  monitor
 systems,  and propose these specifications  for  public comment.
           Response:  The  text  has been  revised to address  inlets  to
 control devices.  However, we  do not  feel  it is  necessary  to propose
 these specifications for  public comments as the  same principles apply
 as to obtaining representative samples.   In addition, the  revisions
 should not pose any problems.
     8.3   Comment:   The problems with continuous monitor accuracy are
well documented.  In spite of  these well-known problems,  the reproposed
 specifications require that both pollutant and diluent monitors in
combination meet the +20 percent accuracy requirement, even though the
existing PS's only require the pollutant monitor to meet  these accuracy
problems.   In addition,  the reproposed specifications eliminate the
10 percent location error allowed in the October 1979 proposal.  We
do not understand the basis for this departure from the  existing PS's
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 and earlier proposal.  In light of the well-known problems with monitor
 accuracy, the Agency should allow +10 percent error for monitor location,
 as well as an error for diluent monitors.
           Response:  In the October 6, 1975, PS's, only the individual
 pollutant monitors were required to meet the specified RA.  No accuracy
 requirement was placed on the diluent monitors.   This was an error on
 EPA's part.   At that time, EPA felt that the zero and span checks  were
 sufficient to  ensure that the concentrations obtained by the monitor
 would have yielded results within  +0.5 percent 02 or C02.   However,
 experience has shown that this was not the  case.
      The combined  accuracy requirement is more restrictive.   However,
 as  mentioned in  the preamble,  this  requirement is  not  unattainable.
 The Agency has reviewed a  number of RA tests where the combined systems
 were checked.  Of  the 24  tests  that were  reviewed, 13  improved its RA
 and 11  got worse.   But only two would  have failed as a result of the
 combined specification and five would  have passed while failing the
 pollutant  monitor  RA.  The point is that  CEMS's are capable of meeting the
 combined specification.
     Some  monitors which presently meet the existing RA specifications
may not be capable of complying with the proposed accuracy specification.
However, this could be a result of monitor deterioration or lack of
maintenance.   If a CEMS cannot be corrected outside of full system
replacement,  the system is probably so inaccurate that it serves no
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useful purpose and would be advisable to have it replaced; the remedy
is not to increase the relative error specification.
     The +10 percent criterion used in the definition of stratification
was not an allowance for error.  The entire context of Section 4 of the
October 5, 1975, specification (40 FR 46250) is that the sampling location
should be representative of the emissions.  Section 4.1 states, "For
sampling locations where effluent gases are ... nonstratified, a point
or path of average emissions may be monitored."  Section 3.2 of the
October 10, 1979, proposal (44 FR 58602) states, "The tester may ...
conduct the stratification check ... to select the point, points, or
path of average gas concentration."
     3.4  Comment:  The Federal Register proposal states that "some
commenters erroneously assumed that QA procedures were an integral  part
of the specifications."  The Agency, therefore,  concludes that it is
unnecessary to issue QA procedures before finalization of the PS's.  The
UARG remains convinced that until  we understand the procedures which are
required to maintain monitor accuracy over time, application of detailed
PS's at the time of monitor installation provides no guarantee of continued
monitor accuracy.  We understand that there is little data at this
point on which the Agency could base the development of QA procedures.
The Agency, however, should recognize the seriousness of this issue in
any PS's it issues.
          Response:   The PS's are  not designed to evaluate the CEMS over
a long period of time.   Neither are they designed to establish the  adequacy
of QA procedures that are to insure valid short-term and long-term
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 monitoring data.  The PS's merely specify what is expected of the
 instrument, e.g. in PS 2,  the calibration curve should remain stable
 and the measurements should be accurate within +20 percent when
 compared to the RM's.   The PST provides the  check necessary to
 determine whether the  CEMS is within  the requirements  at  the time
 of the  initial  installation.   The QA  procedures are intended to
 demonstrate that the CEMS  is  properly maintained.   Because EPA
 recognizes  that neither the PST nor the PS's guarantee continued  monitor
 accuracy,  EPA is developing the QA procedures  to  evaluate  the CEMS
 over  longer periods  of'time.   If  the  user desires  to include an
 evaluation  of the  CEMS over a  long period of time  along with  the  initial
 PST or  to  institute  other  procedures, he  may choose to do  so.  He may
 also  choose  to  include procedures  to  insure that the selected  sample
 point(s) remain  representative, or unbiased, with  respect  to  total
 emissions.
      8.5  Comment:  The UARG  is concerned with  how the location procedures
 specified in the reproposed specifications will affect new units.  While
 the application  of these procedures to existing units is possible since
 testing can  be done, a new  unit will  need adequate time to test monitor
 locations after  the unit starts up.  Industry experience indicates that
monitor installation and the testing  required to establish a proper  '
 location can take 1 year or more after the initial startup and debugging.
The PS's should deal with this concern,  and other regulations may require
modification as a result of these proposed procedures.
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          Response:  Taking a year or more to establish a suitable
location is unusual.  However, if delays in meeting the present
requirements are justifiable, Section 60.13(1) may be used to establish
alternative requirements.
     8.6  Comment:  The reproposal does not specify that the drift test
procedures, and the results of the drift test must be approved prior to
the RA test.  If the Agency reviews apparently successful calibration
drift tests after the completion of RA tests; and, if upon such review,
the Agency determines that the procedural requirements and specifications
of the drift test was not achieved, sources may be required to repeat
both the drift and accuracy tests.  To help avoid this type of situation,
we recommend that sources be given the discretion of having the
procedures and results of the drift tests evaluated and approved by
the applicable agency before initiation of RA testing.  The timing for
such approval should be decided by the source, since they will be taking
the liability for having to reconduct all tests if it is later found
that the drift test was failed.
          Response:  The PS's do not prohibit such discretion.
     8.7  Comment:  The CD test is based on a single measurement of
a calibration gas or gas cell each day.  Since the imprecision of any
one measurement could cause a monitor to fail the drift specification,
it is recommended that calibration medium(s) be analyzed three
times each day by the subject monitor and that the results of the
three analyses be averaged and compared to the reference value of the
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calibration medium to determine CD.  This repetition of analysis should
minimize the possibility of imprecision causing drift test failure.
         Response:  The imprecision is considered in the CD specification;
therefore, averages need not be used.
     8.8  Comment:  The drift specification, 2.5 percent of the span
value is an absolute specification, i.e., 25 ppm drift is 2.5 percent of
1000 ppm span and 12.5 ppm is 2.5 percent of 500 ppm, etc.   The absolute
specification may be adequate for detecting a parallel  shift of the
calibration curves away from the initial, or accepted,  calibration curve.
However, if the slope of the calibration curve changes  or "drifts,"
the absolute drift specification may be inadequate to quantify the
actual  drift at the calibration or span range.   For example, when the
slope of the calibration curve changes by 2.5 percent,  the  CD will  show
a 25 ppm change at the 1000 ppm level, 22.5 ppm at the  900  ppm level,
20 ppm at 800 ppm, and 17.5 ppm at 700 ppm.   As seen here,  determination
of compliance with an absolute drift specification can  vary when
differing calibration values are used for the drift test.   We suggest
that in order to more accurately assess CD,  the drift specification
should be expressed relative to the value of the calibration gas or gas
cell.
          Response:   The CD value does not vary with the calibration
values.  The "span value" is fixed and specified in an  applicable subpart
of the regulations.
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     8.9   Comment:   The  calibration  error  specification  is  important
 in evaluating monitor  performance  at sources  that  exhibit variable
 pollutant  concentrations.  Although  the  RA test  is useful in
 evaluating monitor  performance at  any one  concentration  level,  the
 calibration error test is  the only means of evaluating the  calibration
 response of monitors over  the full measurement range.  Therefore, the
 calibration error specification should be  included in the reproposed
 specifications.
           Response:  The primary criterion  of the  PS is  the RA  test
 using RM's.  When purchasing a CEMS,  the user may  choose to include a
 calibration error specification.
 Commenter  VI-0-9
     9.1   Comment:  Section 60.13(b).  I concur with the Agency that it
 is not necessary to'write a regulation that would  require a pretest to
 a test.
           Response:   None required.
     9.2   Comment:  Section 60.13(c)(2)(ii).  I feel that the "+20
 percent with a confidence level  of 95 percent" should be referenced
to an applicable standard,  since it is unlikely that any monitoring
equipment would be able to  maintain this error at the minimum
detectablility of the monitoring equipment.
          Response:   The  PS includes a +10 percent of emission standard
criterion  to account for  errors  at the minimum detectability of the CEMS,
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     9.3  Comment:  Section 60.13(d).  The requirement for daily zero
and span drift is unnecessary since the regulation already requires the
operator to follow the manufacturer's recommendation and also minimum
standards are specified in Appendix B.
          Response:  The requirement for daily zero and span drift is
for long-term basis.  However, Appendix B does not address the long-term
issue.  Although the regulation requires the operator to follow the
manufacturer's recommendation, this paragraph sets the minimum
requirement.
     9.4  Comment:  Section 60.13(d).  I do not believe the EPA has any
basis for determining the optical surface of opacity monitors must be
cleaned once the zero compensation exceeds 4 percent opacity.  This
requirement does not allow the manufacturer any flexibility.   The optical
surface should be cleaned as per the manufacturer's recommendation.
          Response:  The 4 percent is thought to be the minimum percent
opacity needed to assure proper quality of data.  This specification guides
the manufacturer's recommendation as to how often it should be cleaned.
Commenter VI-D-10
     10.1  Comment:  The proposed revisions to Section 60.13 of the
General Provisions make this section consistent with the proposed revisions
to Appendix B.  We have no comment with respect to these proposed revisions.
          Response:  None required.
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     10.2  Comment:  We support the proposed  revision which would
allow for the complete evaluation of S0? and  NO  GEMS's after  they  have
                                       ^       /\
been installed at operating facilities.  The  proposed PS tests should,
therefore, be less costly to perform relative to current PS requirements.
          Response:  None required.
Commenter VI-0-12
     12.1  Comment:  We are a member company  in the UARG and wholeheartedly
support the comments on this subject submitted by them.  Therefore, our
comments will be in addition to those filed by UARG.
          Response:  None required.
     12.2  Comment:  Although this latest proposal is drastically
different from previous EPA proposals and has the potential to shift
the bulk of the burden to prove the accuracy and reliability of
CEMS from the vendor to the user, we are generally in favor of this
approach.  But we do have reservations.
          Response:  None required.
     12.3  Comment:  Prudent specifications of conditions and requirements
in user purchase agreements may effectively swing this burden of proof
back to the vendor.  However, it remains to be seen if the vendors will
attempt to meet instrument specifications included as part of a purchase
agreement if those specifications are not required by regulations.   In
fact, our experience to date with conditional  purchase agreements has
been less than promising.   The vendors were reluctant to agree to this
procedure even when we had the previous proposal  (October 10,  1979) and
an EPA sponsored research project to back us up.   This reinforces the
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position that the EPA should issue the guidelines covering monitor
specifications and test procedures that were discussed in the preamble
in a timely manner.  At least then, the vendors and users will have an
official definitive document on which to base these conditional agreements.
          Response:  See Response 8.1.
     12.4  Comment:  Even though we are in general agreement with the.
overall content of the proposal, we would like to point out a few
specific points that need further clarification before the proposal is
promulgated.   These comments follow.
     a.  The proposal is apparently not intended for sources subject
to Subpart Da requirements or those sources required to have S0« scrubbers,
since it precludes locating an S02 scrubber inlet CEMS and determining its
RA.   If the EPA intends for this proposal to be applicable to sources
subject to scrubber installations, then more effort should be extended
in meeting that objective.  Unless another proposal is forthcoming that
will cover these sources, we recommend that the EPA rewrite this proposal
to incorporate inlet CEMS testing.
     b.  The determination of the CEMS RA contains a number of possible
errors that must be combined into one final accuracy number.  The sources
of these possible errors are the inaccuracies associated with the CEMS
location, the inaccuracies associated with the pollutant monitor, the
inaccuracies associated with the diluent monitor, and the inaccuracies
associated with the RM.
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     By allowing more leeway in choosing a CEMS location, the EPA has
increased the possibility of it being more accessible than previous
proposals would dictate.   No effort is to be made to determine if the
flow is stratified or not, and no provision is provided for this
purpose.  Therefore, the +10 percent location error allowed by the
last proposal (October 10, 1979) must be incorporated in the CEMS RA
determination.  If stratification does exist, this error could be
significant.
     Also, the pollutant monitor and the diluent combined monitor are
now considered the CEMS and are subjected to the RA determination as
such.  The previous proposal (October 10, 1979) allowed 20 percent
for the pollutant monitor alone; therefore, the EPA must have already
recognized some limits in pollutant monitor accuracies.
     Finally, the RM, itself, may cause other errors of differing
values depending on technique, familiarity, and other nondefinitive
problems.  Though considered accurate in itself and since it is a
RM, there can still be a number of possible errors.
     We doubt that the CEMS can be depended upon to meet the accuracy
requirement of +20 percent when it must incorporate them all into one
accuracy number.  We also question whether the CEMS should be subjected
to this sum total of possible errors in determining their accuracy.   We
recommend, at the least,  requiring a separate accuracy determination
for the pollutant monitor and one for the diluent monitor.
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          Response:  See Responses 0.1 and 8.2.   In addition,  the
PS does not  prohibit stratification checks.  This option  is  left to
the user.  The October 1979 proposal included the diluent monitor
as part of the CEMS (see Section 5.1).
Commenter VI-D-13
     13.1  Comment:  Section 5.2.  We strongly oppose the "more than
50 percent capacity" provision because it would make it impossible
for certain  units to comply.  Such units are those that were overdesigned
by more than 100 percent for future considerations.   We suggest that
calibration  tests be conducted while the affected facility is operating
at 50 percent of its normal load.
          Response:  See Response 5.11.
     13.2  Comment:  Section 4.1.  We anticipate difficulties in
complying with this provision because span gas suppliers often provide
span gas which is only within +10 percent of what we have requested.
For this reason, we suggest a span level  of 80 to 100 percent.
          Response:  See Response 1.1.
     13.3  Comment:  Proposed regulations delete the current requirements
to offset the zero setting by at least 10 percent of the span during  '
calibration tests (Sections 6.2.1 and 6.2.2 of the existing PS 2).   We
support the deletion for the following reasons.   First,  some monitors
can be offset by only up to 5 percent.   Second,  offset of the zero  setting
invalidates span settings and causes a nonlinear relationship between
the two settings.
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          Response:   None required.
     13.4  Comment:   Section 60.13(d).  The proposed quantification
and recording requirements for zero and span drift create unnecessary
paperwork.  Such an investigation can be conducted as the need arises
on an informal basis.
          Response:   The recording is not a proposal but is presently
required under Section 60.7(d).  The section has been revised to
quantify the amount of excess zero and span drift, when specified.
     13.5  Comment:   In general, we are in agreement with the proposed
concept to simplify and improve procedures for determining pollutant
concentrations and for evaluating continuous monitoring systems.
          Response:   None required.
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                        COMMENTS ON OTHER VIEWS
     The preamble of the January 26, 1981,  proposed rules,  under
"Request for Comments on Other Views,"  stated:   "A number of
suggestions were received which were not incorporated in these
revisions.  Because they represent differing views, EPA requests
comments on them to determine what course of action should be taken
in the final rulemaking."  The following are the comments that were
received and EPA's responses.
1.  Mandatory Conditioning Periods
     a.  VI-D-2.  Although we believe that a conditioning period is
beneficial for identification of operational problems prior to
committing funds and personnel to a test program, we see no need to
include a conditioning period as a mandatory requirement.
     b.  VI-D-5.  While we agree with the suggestion of a conditioning
period with the length determined by the anticipated use of the CEMS,
we do not feel it should be mandatory.   Conditioning periods would
tend to reduce the need for variances if the CEMS goes  "unreliable"
immediately after an RA test  is conducted 1 day after startup,  but
are not necessary for those who have a great deal of experience in
a particular application.
     c.   VI-D-6.  Eliminating  the  7-day conditioning period leaves
the burn-in requirements to  the operator and equipment  manufacturer
to define.  This  allows more  flexibility, a possible reduction  in  cost,
and  should  not  have  a significant  effect on the  integrity  of  the tests.
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     d.  VI-D-10.  Provisions of Section 60.8 require that NSPS
testing be conducted within 60 days after the date when full
production is achieved.  Under these circumstances, a requirement
for CEMS's to be installed and operational 60-90 days prior to NSPS
compliance testing could actually conflict with activities
associated with bringing the unit up to full capability.  Therefore,
we urge that CEMS installation and operation 60-90 days prior to
NSPS compliance testing not be required.
     e.  VI-D-11.  Due to the high cost of certifying a CEMS, a
source will want to insure that the system is functioning properly
prior to arranging or initiating a compliance certification test.
We recommend that EPA suggest that source adopt a 30-day conditioning
period before initiating a performance test.  By incorporating a
longer preliminary period, there should be a greater chance of a
CEMS passing the performance test.  The longer conditioning period
would also allow plant maintenance personnel an opportunity to
become familiar with the system under actual field conditions.  We
believe that these benefits clearly outweigh having a fixed
conditioning period established by regulation and recommend the
mandatory 7-day conditioning period be excluded.
     f.  VI-D-13.  While we do not see a necessity for a separate
conditioning requirement for operation and compliance purposes,  we
strongly recommend that the mandatory conditioning period requirement
be retained and perhaps even made longer.   Retention and expansion
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of the mandatory conditioning period  is  important and needed  because
of persistent plugging problems.  A conditioning period requirement
will provide additional impetus for vendors to supply reliable
systems and will help insure that approved systems will continue to
operate satisfactorily.
     Response:  Five of the six commenters felt that the conditioning
periods were beneficial but should not be made mandatory.  Therefore,
the requirements and verification of operational status have  been
left to be determined between the manufacturer and the source owner
or operator.
2.  Mandatory 3-Day RA
     a.  VI-D-11.  We disagree with the view that RA tests should be
spread over 3 days instead of 1.  Considering that most stack sampling
consultants base their fees on time spent in the field plus expenses,
we believe that the requirement to extend the sampling time is
unreasonable.  We assume that by extending the sampling over 3 days,
the objective would be to obtain data that would be more representative
of actual source emissions.  The objective of the RA tests is to insure
that the pollutant concentration, measured by an appropriate RM, is
statistically similar to pollutant measurements obtained from the CEMS.
We see no benefit in extending the sampling period.   However, if the
objective is to vary the pollutant emission concentration, other means
should be employed.
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     Response:  The objective of the RA tests as mentioned by the
commenter is correct.  Therefore, the specification was not changed
to mandate a 3-day RA.  The present specifications allow the RA
tests to be conducted over a minimum of 4.5 hours.  However, no
maximum is set.  Therefore, the 3-day option is open to the source
owner or operator, should he desire to extend the test period.
3.  Concurrent NSPS and PS Tests
     a.  VI-D-2.  We agree that NSPS compliance tests and CEMS
performance tests should be conducted simultaneously in a manner
so as to be acceptable as NSPS compliance tests.
     b.  VI-D-5.  Source operators should be given the option of
conducting CEMS PS tests and NSPS tests concurrently.  However, we
disagree with the suggestion to mandate concurrent testing.
     c.  VI-D-6.  The option to combine tests should be left open
to the operator, but the tests are sometimes performed under different
test conditions.
     d.  VI-D-13.  Use of results from a concurrent test would save
resources.  For this reason, we support integration of the concurrent
test provision in the final regulation.
          Response:  Two commenters felt that simultaneous NSPS
and PS tests should be mandated; two commenters felt that they should
not be.  The proposed specifications allow simultaneous testing.   If
simultaneous testing is economically advantageous, source owners or
operators would naturally do it without being regulated.   Mandating
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simultaneous testing could increase costs, e.g., if the CEMS breaks
down during the PST, both tests would have to be halted.   However,
leaving the option as is, the performance testing could proceed
and the PST conducted at a later date.
4.  CEMS Calibration Checks
     a.  VI-0-2.  Failure to periodically introduce calibration gases
as close to the point of sample acquisition as possible could result
in inaccurate data due to deterioration of the sample transport
system.  If the calibration checks are not conducted in this manner
during performance testing, the CEMS may still meet the required
RA but be subject to an unidentified leakage in the sample transport
system which could vary with time and ambient conditions.  Our
experience with sources that have installed extractive CEMSrs indicates
that the requirement to introduce the calibration gases at the probe
is not unduly burdensome and does not result in a significantly higher
cost than for introduction at the analyzer.
     b.  VI-D-5.  We agree with the concept of checking the entire
CEMS starting at  the probe for extractive systems.  However, this type
of check is difficult to  implement and can yield misleading results.
If the system runs  at negative pressure,  the calibration cylinder
pressure must be  adjusted to properly balance the system pressure to
normal operating  conditions.   If the cylinder regulator pressure  is
too high,  leaks will not  show  up because  the  system will be pressurized.
For systems that  have a  sample pump near  the  probe, the need for  a
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daily check  is minimized  because a  small  leak on a  positive  pressure
system will  not affect analyzer response.   If diluent measurement  is
done simultaneously, leaks may be corrected for twice.
     Sample  losses due to adsorption or absorption  will be minimal
if proper materials are used, again minimizing the  need for  a daily
system check.
     Most calibration gases purchased in  aluminum cylinders  will not
change concentration significantly over periods much longer  than
6 months.  Only an initial calibration gas calibration check should
be required  provided the source operator  uses certified gases in
followup QA/RA tests.
     c.   VI-D-6.  We concur with the opinion that zero and span
gases should be introduced at the stack in extractive systems to
verify the entire measurement system integrity.
     d.   VI-D-13.   We agree with the EPA analysis that the RA test
would validate the CEMS regardless of the location for introducing
calibration gases into the system.   We are opposed, however, to a
requirement which specifies the location at which calibration gases
are introduced.   A requirement to introduce calibration gases at a
probe located at the stack wall  would require either long  calibration
gas supply lines or would require another person  since monitors are
usually  located  at some distances away from the  probe.   This is
unnecessary.
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          Response:  The EPA reconsidered requiring the introduction
of calibration gas mixtures at the probe at the stack wall, but
determined that such a requirement would be inconsistent with the
basis for the reproposal,  i.e., comparisons against the RMrs determines
the GEMS's acceptability.   However, EPA agrees that checking the whole
system including the interface is desirable and, with proper demonstration,
could replace the comparisons against the RM's.  Mention of its
desirability will be made in the guideline document.
5.  Performance Specifications
     a.  VI-D-2.  The comments on audit and data recovery are very apropos
and should serve to illustrate to EPA that QA procedures are an integral
part of these specifications.  It is naive not to recognize that QA
specifications do govern CEMS design and evaluation and more naive not
to account for all operational requirements before selection and
installation of CEMS.
     b.  VI-D-5.  For very low emission rates, the RA requirement
of 10 percent of the applicable standard is within our CEMS sensitivity.
However, an alternative to consider is to allow RA within 5 percent CEMS
full-scale for low emission rates.
     c.  VI-D-6.  We concur with decreasing value of the accuracy of
emissions as they approach zero.  We believe the external check is
extremely desirable if one is to ensure valid measurement data.  The
minimum data recovery specification is certainly desirable from a
user's standpoint, however, vendors will raise the associated costs
                                   63

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to cover their risks.   It would help differentiate reliable from
unreliable equipment and vendors.
     d.  VI-D-13.  We oppose a minimum data recovery specification
of at least 18 hours in at least 22 out of 30 days for two reasons.
First, it would mean that a minimum of 30 days is needed to complete
a source test.  This is a long test by itself.  Second, there would be
less time to comply with the "within the 60 days after achieving the
maximum production" provision.
     The fixed percentage specification for determining RA, +10 percent
of the applicable standard, is inherently biased against the sources
combusting relatively clean fuels.  Hence, we recommend a use of a
sliding scale which relaxes the subject specification for sources having
to meet low emission standards.
          Response:  These comments have to do with evaluating the
reliability of the CEMS over a long-term basis.   See Responses 2.1,
5.3, and 5.14.
     Concerning the sliding scale which relaxes  the required accuracy
when emission standards are low, EPA agrees that the RM variability needs
to be considered.   At present, the only low emission standard is for
S02 (Subpart Da).   Therefore, Section 4.3 has been revised to allow
greater relative errors at these levels.
6.  Separate vs.  Combined Units of Measurement
     a.   VI-D-5.   We agree that all units should be recorded,  but only
the regulated quantity needs to be reported.
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      b.   VI-D-6.  We  recommend  this  from  the  standpoint  of  backup.   If
 the  ppm  to  Ib/MBtu  conversion fails, one  would  have a  backup  position with
 a  recording of raw  data.
          Response:   Since the  recording  of separate units  is viewed as
 backup in nature, this option should be left  to the owner or  operator.
 If it is  advantageous, then this would become normal procedure without
 being regulated.
 7.  The RA Terminology
     a.  VI-D-5.  The term "relative accuracy" is defined accurately
 in the definitions, so we would leave the term the same  even  though
 the commenter is accurate in stating that an RA test determines the
 relative error between the reference test and the CEMS.
     b.   VI-D-6.  This is somewhat academic in that error and accuracy
are often used interchangeably.   The +20 percent requirement is
obviously an error allowance.
          Response:   Both comments are correct.   Since a change could
cause confusion, the use of the terminology will not be changed.
8.  Outlier Rejection Technique
     a.   VI-0-2.  In order to allow an agency to assess the true results
of RA testing, results for all  tests conducted should be required to
be submitted, along with reasons for requesting  deletion of any data.
The Agency, should make the final decision as to  deletion of data and
 should use the results for all  acceptable tests  in calculating the
RA of the CEMS.
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     b.  VI-D-5.  We agree  that  the  tester  should  be  allowed  to
reject up to three samples  in determining RA tests  results.   While
it  is probably true that  the tester  will throw out  the  three  tests
that increases his RA, he will also  have the discretion to throw
out results that do not appear reasonable.
     c.  VI-D-6.  We highly recommend this.  Specific stack samples
are often obviously faulty or erroneous.  A stack  sampler should  be
able to take extra samples to allow  for an occasional mistake.  This
will, in effect, reduce the risks and costs of performing Method  6
or 7.  Any one sample should be  able to be eliminated without specific
justification.  Elimination of more  than one sample value should  be
left to the subjective analysis  of the data by the user.
     d.   VI-D-11.   We recommend  that statistical techniques be used
to reject outliers, rather than  an arbitrary decision on the  part
of the tester.  However, test results that are outliers because of
testing difficulties or source operating conditions should be rejected
without being subjected to statistical techniques.
          Response:  The Agency  originally decided that a data set
of a minimum of nine samples was sufficient to evaluate the CEMS.
Statistical  techniques for outliers within the set of nine were
investigated,  but were found to be too restrictive because of the
small  sample size.   The proposed technique does not allow any
rejection of data  from the set of nine,  but allows the replacement
of up to three samples by other samples.   Since the evaluation involves
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a comparison of two methods, EPA feels that the proposed procedure is
satisfactory for rejecting outliers.
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                      TABLE 2.  LIST OF COMMENTERS
                         Docket No. OAQPS-79-4

Docket item no.                             Commenter/Aff111atlon

   VI-D-1                     Joe Francis, Environmental Specialist
                              State of Nebraska Department of
                                Environmental Control
                              Mail Box 94877 Statehouse Station
                              Lincoln, NE 68509

   VI-D-2                     James K. Hambright, Director
                              Bureau of Air Quality Control
                              State of Pennsylvania
                              P.O. Box 2063
                              Harrisburg, PA 17120

   VI-D-3                     Richard H. Russell, Environmental Sampling
                                Supervisor
                              Owens-Illinois, Inc.
                              P.O. Box 1035
                              Toledo, OH 43666

   VI-D-4                     Russell 0. Blosser, Technical  Director
                              NCASI
                              260 Madison Avenue
                              New York, NY 10016

   VI-D-5                     David J. Williamson
                              Pacific Gas and Electric Company
                              P.O. Box 7442
                              San Francisco, CA 94106

   VI-D-6                     Gerald F. McGowan, Vice President,
                                Engineering
                              Lear Siegler, Inc.
                              74 Iverness Drive East
                              Englewood, CO 80112

   VI-D-8                     F. William Browne!! for Utility Air
                                Regulatory Group
                              Hunton and Williams
                              1919 Pennsylvania Avenue, N.W.
                              Washington, D.C. 20036

   VI-D-9                     J.L. Bechthold, Manager
                              Regulatory Compliance and Services
                              Northern States Power Company
                              414 Nicollet Mall
                              Minneapolis, MN 55401
                                  73

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                      TABLE 2.   LIST OF COMMENTERS
                               (Continued)

                         Docket No.  OAQPS-79-4
Docket item no.                                Commenter/Affiliation

   VI-D-10                    Mark P.  Steinberg,  Superintendent
                              Air Quality Division Environmental
                                Department
                              Wisconsin Electric  Power Company
                              231 W.  Michigan
                              Milwaukee, WI  53201

   VI-D-11                    F.W.  Chapman,  Jr.,  Manager
                              Environmental  and Energy Conservation
                              515 South Flower Street
                              Los Angeles,  CA 90051

   VI-D-12                    Morris  L. Brehmer,  Executive Manager
                              Environmental  Services
                              Virginia Electric and  Power Company
                              Richmond, VA 23261

   VI-D-13                    J.G.  Holmes,  Director
                              Environmental  Planning
                              TOSCO Corporation
                              10100 Santa Monica  Blvd.
                              Los Angeles,  CA 90067
                                  74

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                                      TECHNICAL REPORT DATA
                              (flcase read Instructions on the reverse before completing)
      EPA-450/3-82-022
                                                               3. RECIPIENT'S ACCESSION NO.
  Revisions  to Continuous  Emission Monitoring Systems
  Performance Specifications  2 and 3 - Summary of Comments
  and Responses
               5. REPORT DATE
                  September  1982
               6. PERFORMING ORGANIZATION CODE
  Emission Measurement Branch
                                                               8. PERFORMING ORGANIZATION REPORT NO.
                           VIE AND ADDRESS
  Emission Standards and Engineering Division
  Office of Air  Quality Planning  and Standards
  U.S. Environmental Protection Agency
  Research TRiangle Park, NC  27711
                                                               10. PROGRAM ELEMENT NO.
               11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
  Director, Office of Air Quality  Planning and Standards
  Office of Air,  Noise, and Radiation
  U.S.  Environmental  Protection Agency
  Research Triangle  Park, NC  27711
               13. TYPE OF REPORT AND PERIOD COVERED
               t4. SPONSORING AGENCY CODE
                 EPA/200/04
 This  document contains  introductory material regarding  the proposed revisions
 (January 26, 1981, 46 FR  8352) to Performance Specifications 2Pand 3    The changes

            edre                          "1th  the  "' Deceived and 9
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.IDENTIFIERS/OPEN ENDED TERMS  fc!  COSATI Field/G
                                                                               13 B
Unlimited
19. SECURITY CLASS (ThisReport)
 Unclassified
                                                20. SECURITY CLASS (This page)

                                                 Unclassified
21. NO. OF PAGES

    80
                            22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE 75

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