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PS-11
Particulate Matter CEMS
' Application: HWC MACT
| Revised PS:
'S 0.85 Correlation Coefficient;
v ฑ10% CI; ฑ25% Tolerance
v Acid QA/QC Procedures to Appendix F
| FR notice - December 30,1997
| FY 99 promulgation
| Contact: Dan Bivins (919) 541-5244
Appendix F - Procedure 2
PMCEMS QA
Daily Calibration Drift Assessments
Quarterly Response Calibration Audits
(performance test comparisons)
Quarterly Absolute Calibration Audits (reference
materials comparisons)
Extractive Sampling Volume Audit
Out-of-Control Criteria for QC Checks
FR notice - December 30,1997
FY 99 promulgation
Contact: Tom Logan (919) 541-2S80
PS-15
FTIR CEMS
Applicability: General, Validated at Portland
Cement Facility
Certification Options
V Spike with Single Analyzer
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I
a,
\
-
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Method 322
GFC/IR for HC1
Application: Portland Cement Plants
Heated Line/350 F Filter/GFCIR
Proposed: March 24, 1998 with Portland
Cement MACT
FY 99 Promulgation
Contact: Terry Harrison (919)
541-5233
DRAFT METHOD
Acetonitrile
Applicability: Gaseous and Particulate
Emissions
Isokinetic Sampling w/multicomponent
Train
GC/FID Analyses
Validated at HWI
Category C Method: To Be Proposed
Contact: Gene Riley (919) 541-5239
\
Test Methods and Regulatory
Revisions
Reformatted Methods per EMMC
Corrections/Updates
Proposed: August 27, 1997
FY 99 promulgation
Contact: Foston Curtis (919) 541-1063
I
Draft Method
Hydrogen Cyanide
Applicability: Gas Phase Emissions
Isokinetic Sampling w/multicomponent
Train
1C Analysis
Validated in Laboratory
Category C Method: To Be Proposed
Contact: Gene Riley (919) 541-5239
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Draft (Method 317)
Phenol and Cresol Emissions
Applicability: High levels (>20 ppm) of
Phenol and Listed Cresols
Isokinetic Sampling w/multicomponent
Train
LPLC and GC/MS Analyses
Category C Method: To Be Proposed
Contact: Gene Riley (919) 541-5239
EMC Technical Assistance
Sources
| Internet/World Wide Web
V http://www.epa.gov/ttn/emc
V TTN Help Desk (919) 541-5384
i EMC Hot-line "The Source" (919) 541-0200
Technical information - auto-fax
Order audit materials
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HIGHLIGHTS OF EMISSION TEST METHOD
DEVELOPMENT ACTIVITIES FOR 1998
Environmental Protection Agency
Office of Air Quality Planning and Standards
Below are highlight items involving emission test method publication, evaluation,
validation, and other Emission Measurement Center (EMC) activities during the past twelve
months. An EMC contact name is provided for each activity.
OAQPS METHODS 1 TO 99 - NEW SOURCE PERFORMANCE STANDARDS (NSPS)
METHODS:
40 CFR Part 60, Appendix A (Emission measurement methods applied to new source
performance standards)
Method 5i - This Agency developed and validated method is specifically for
determination of low level particulate matter (PM) emissions from facilities performing
calibrations or calibration audits of particulate matter continuous emission monitoring systems
(PM CEMS) as specified in the regulations. The method uses a small, light weight filter holder
and includes procedures for taring and weighing the entire filter holder assembly. The method
is effective for filter loadings up to 45 mg/dscm, above this level the vacuum drawn by the
sampling train will exceed the maximum vacuum allowed under Method 5. The method has been
validated at hazardous waste incinerators and will likely be proposed with the predictive emission
monitoring system (PEMS) performance specification with the hazardous waste incinerator
MACT rule. The draft method was published with the Federal Register on December 30, 1997
with an OSW Notice of Data Availability. Response to comments have been prepared and the
method is scheduled for promulgation in FY 99. (Dan Bivins 919/541-5244)
Method 14A - The EMC worked with the Aluminum Association on a less costly
alternative to Method 14 in combination with Methods ISA and 13B for total fluoride emissions
from primary aluminum plants. The alternative uses a series of eight or more in-situ "Alcan
cassettes" containing a series of untreated and sodium formate treated membrane filters as the
primary collection mechanism in lieu of the manifold sampling apparatus described in Method
14 and subsequent collection of the sample following Method 13A or B procedures. Sample
recovery includes a water wash of the nozzle combined with recovery of the filters. Sample
preparation includes addition of CaO and evaporation and charring of the filters (and nozzle
wash) followed by addition of NaOH and ashing of the filters. Analytical finish is with an
automated colorimetric procedure employing five calibration standards with a correlation
coefficient of at least 0.99 and a successful analysis of a check standard with recovery between
95 and 105 percent of the known value. An alternative analytical finish employs specific ion
electrode with prior distillation of the sample, or the use of TSIAB IV buffer (TSIAB II for low
level fluoride concentrations). Five calibration standards with a correlation coefficient of at least
0.99 ( 0.97 when 0.01-0.48 ug/ml standards) are required and a successful analysis of a check
standard with recovery between 95 and 105 percent of the known value. The method was
1
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promulgated with the Primary Aluminum MACT standards on October 7, 1997. (Terry Harrison
919/541-5233)
Method 23 - Method 23 is an isomer-specific procedure for the measurement of
polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans in air emissions. Revisions
to Method 23 were proposed in the Federal Register on May 31, 1995. These revisions correct
and clarify the sample analysis procedures and eliminate the requirement for the methylene
chloride rinse during sample recovery while retaining the Toluene sample rinse. Comments
indicate there is a need for an option to include the methylene chloride rinse for combination
trains requiring sample splits for analytical separations. The method is being revised and is
scheduled for promulgation in FY 99. (Gary MeAlister 919/541-1062)
40 CFR Part 60, Appendix B (Performance specifications for continuous opacity and gaseous
monitoring systems - COMS and CEMS)
Performance Specification 1 - EPA conducted on-site evaluations of continuous opacity
monitoring systems (COMS) manufacturers to review the design criteria and the performance
procedures as applied according to Performance Specification 1. One result of these field audits
is revision of Performance Specification 1 to clarify testing responsibilities, reporting
requirements, and certain performance evaluation procedures. The revisions were proposed in
the Federal Register on November 25, 1994. Since that time, an ASTM subcommittee of
instruments manufacturers and vendors developed revised procedures for the instrument
manufacturer's design verification testing and certification requirements. This resulted in the
publication of ASTM D6216. These procedures have been incorporated into a revised
performance specification to be issued as a supplemental proposal in FY 99. (Solomon Ricks
919/541-5242)
Performance Specification 11 - This performance specification for the certification of
PM CEMS was proposed in April 1996 with the Hazardous Waste Combustor (HWC) MACT
standard. Field demonstration work since that time has produced data to support the use of PM
CEMS but with revised performance criteria. The revisions include a new confidence interval,
a tolerance interval, and a correlation coefficient. The December 30, 1997, Notice of Data
Availability published by OSW included the revised PS-11. Response to comments have been
prepared and the method is scheduled for promulgation in FY 99. (Dan Bivins 919/541-5244)
Performance Specification 15 - This performance specification is for certifying fourier
transform infrared (FTIR) CEMS for HAPs absorbed by IR. The performance specification is
a result of field validation work the EMC performed at a Portland cement facility. The procedure
allows several certification options: 1) calibration gas spiking of single analyzer during the
sampling mode, 2) side-by-side comparison of two analyzers, and 3) relative accuracy testing of
the CEMS with a reference method. The performance specification was proposed in the Federal
Register on August 7, 1997 with the methods and regulatory revisions correction package.
Response to comments have been prepared and the method is scheduled for promulgation in FY
99. (Tom Logan 919/541-2580 or Rima Dishakjian 415/744-2260)
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40 CFR Part 60. Appendix F (Quality Assurance Procedures for CEMS)
Procedure 2 - The December 30, 1997, Federal Register. Notice of Data Availability
(NODA) included a new Procedure 2 of Appendix F to address quality assurance procedures and
criteria for PM CEMS. The procedure includes daily calibration drift assessments and quarterly
response calibration audits (comparisons with performance test results) or quarterly absolute
calibration audits (comparisons with audit reference materials). The procedure also addresses
particular procedures (a sample volume audit) for extractive sampling PM CEMS. The procedure
describes out-of-control criteria for each of the different checks and minimum data availability
requirements. (Tom Logan 919/541-2580)
OAQPS METHODS 201 TO 299 - STATE IMPLEMENTATION PLANS (SIPS)
METHODS:
40 CFR Part 51, Appendix M (Test methods scheduled for State Implementation Plans)
Methods 203A, B, and C - These field test methods describe application of Method 9
(40 CFR Part 60, Appendix A) procedures for visible emissions observers to use in determining
compliance with averaging times other than 6 minutes, time exception standards, and
instantaneous emission standards. The methods also address visible emission sources other than
the traditional stack emission point including sources of fugitive emissions. The methods were
proposed on November 22, 1993. The public comments have been summarized and responses
prepared; promulgation is scheduled for FY 99. (Frederick Thompson 919/541-2707)
Methods 204 and 204A-F (7 methods) - This series of sampling and analysis procedures
address the measurement of capture efficiency for collection devices applied to printing and
coating operations using inks and coatings with organic solvents; one of the procedures addresses
construction of the temporary total enclosure (TTE) used to isolate the collection hood for testing.
Methods 204 and 204A-F were proposed on August 7, 1995. An Agency decision made
following proposal with industry input resulted in a option to allow the industry to apply
alternative methods that meet specified data quality objectives (DQO). A February 1995
guideline document "Guidelines for Determining Capture Efficiency" specifying application of
this DQO option is available on the Technology Transfer Network (TTN). Promulgation of
Methods 204 and 204A-F in the Federal Register was completed on June 16, 1997. (Candace
Sorrell 919/541-1064)
Method 207 - This method is an impinger-based sampling and analysis procedure for the
following isocyanates: methyl isocyanate, methylene diphenyl diisocyanate, hexamethylene 1,6-
diisocyanate, and 2,4-toluene diisocyanate. These compounds are found in the emissions from
flexible foam manufacturers, automobile paint spray booths, and the pressed board industry. The
method is proposed to be added to Appendix M of part 51 to provide a method for state and
local agencies to apply in regulations to measure these pollutants. The proposed method
appeared in the Federal Register on December 8, 1997. 30, 1997 with an OSW Notice of Data
Availability. Response to comments have been prepared and the method is scheduled for
promulgation in FY 99. (Frank Wilshire 919/541-2785 or Gary MeAlister 919/541-1062)
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OAQPS METHODS 301 TO 399 - MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY (MACT) METHODS:
40 CFR Part 63, Appendix A (Methods for the National Emission Standards for Hazardous Air
Pollutants [NESHAP] for Source Categories requiring application of maximum achievable control
technology or MACT)
Method 301 - This field validation protocol was promulgated as Method 301 with the
Early Reduction regulations on December 29, 1992. The purpose of this method is to provide
a framework and performance criteria that can be use in validating emission test data (and
methods) when no EPA method is available or when proposing an alternative to an existing EPA
test method. Comments and questions from the user community have prompted preparation of
technical revisions and clarification to this method. The clarifications or corrections will be in
four primary areas: appropriate procedures for validating instrumental test methods, applicability
of ruggedness testing procedures to similar sources, applicability of correction factors for other
sources, and evaluation of alternatives to existing reference methods. Proposal of these revisions
will follow a peer review process planned for FY 99. (Gary McAlister 919/541-1062)
Methods 306, 306A, and 306B - These methods were promulgated January 1995 along
with the regulation for chromium emissions from hard and decorative chromium electroplating
facilities. The methods have been reformatted according to EMMC guidelines requiring
consistency between method formats within the agency. The revised and reformatted methods
were proposed in the Federal Register on August 7, 1997 under revisions/corrections. The EMC
has made minor corrections and revisions to update and clarify the sampling and analytical
procedures with the purpose of publishing a notice of change and update in the Federal Register
in FY99. (Gene Riley (919) 541-5239)
Method 308 - This method for determining methanol emissions was proposed with
MACT standards for the pulp and paper industry on December 17, 1993, and appeared on the
Clean Air Act Amendments Bulletin Board of the TTN. The method is based on manual
sampling utilizing distilled water and silica gel for sample collection and direct injection gas
chromatography for analysis. The method was promulgated in the Federal Register on November
14, 1997. (Gary McAlister 919/541-1062)
Methods 310A, B, and C - These test methods are adapted from test methods submitted
to the EPA by DSM Copolymer, Uniroyal Chemical, and Exxon. These companies are involved
in the manufacture of EPDM rubber. The basic principle of DSM Copolymer's methods involve
heating a sample in a sealed bottle with an internal standard and analyzing the vapor by gas
chromatography. Uniroyal Chemical extracts residual hexane contained in wet pieces of EPDM
polymer with methyl isobutyl ketone (MIBK). The extract is then analyzed by gas
chromatography. Exxon's principle involves dissolving an EPDM crumb rubber sample in
toluene to which heptane has been added as an internal standard. Acetone is then added to the
solution to precipitate the crumb, and the supernatant is then analyzed for hexane and diene by
gas chromatography using a flame ionization detector (FID). These methods were promulgated
on March 17, 1997. (Solomon Ricks 919/541-5242)
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Methods 312 A, B, and C - These test methods are adapted from test methods submitted
to the EPA by Goodyear Tire and Rubber Company, Ameripol Synpol Corporation, and DSM
Copolymer. The basic principle of the Goodyear method is to coagulate the SBR latex sample
with an ethyl alcohol solution containing a specific amount of alpha-methyl styrene as the
internal standard, and analyzing the extract to determine styrene concentration using a gas
chrpmatography with a FID. Ameripol Synpol coagulates the latex sample in propanol which
contains alpha-methyl styrene as the internal standard. The extract is then analyzed by a gas
chromatography to determine the residual styrene from the latex. DSM Copolymer utilizes a
packed column gas chromatography with a FID to determine the concentration of residual styrene
in the latex samples. These methods were promulgated on March 17, 1997. (Solomon Ricks
919/541-5242)
Methods 313A and B - These test methods are adapted from test methods submitted to
the EPA by the American Synthetic Rubber Corporation (ASRC) and the Goodyear Tire and
Rubber Company. The basic principle of the ASRC method involves placing the wet crumb
sample into a sealed vial mounted on a head space sampler which heats the vial to a specified
temperature for a specific time and then injects a known volume of vapor into a capillary gas
chromatography. The method determines residual toluene and styrene in the stripper crumb
derived from solution polymerization processes that utilize toluene as the polymerization solvent.
The Goodyear method uses the principle of dissolving the polymer sample in chloroform and
coagulating the cement with an isopropyl alcohol solution containing a specific amount of alpha-
methyl styrene as the internal standard. The extract of this coagulation is then injected into a gas
chromatography and separated into individual components. These methods were promulgated
on March 17, 1997. (Solomon Ricks 919/541-5242)
Method 315 - The EMC worked with the Aluminum Association to develop this
consensus method. Particulate matter and methylene chloride extractable matter (MCEM) are
withdrawn isokinetically from the source. PM is collected on a glass fiber filter maintained at
a temperature in the range of 120 ฑ 14ฐC (248 ฑ 25ฐF) or such other temperature as specified by
an applicable subpart of the standards and approved by the Administrator for a particular
application. The PM mass, which includes any material that condenses on the probe and is
subsequently removed by an acetone rinse or on the filter at or above the filtration temperature,
is determined gravimetrically after removal of uncombined water. (Because MCEM is the
pollutant of concern for the MACT, analytical procedures different from Method 5 for PM
weighing as well as more restrictive acetone and methylene chloride blank requirements are
included.) MCEM is then determined by adding a methylene chloride rinse of the probe and
filter holder, extracting the condensible hydrocarbons collected in the impinger water, adding an
acetone rinse followed by a methylene chloride rinse of the sampling train components after the
filter and before the silica gel impinger, and determining residue gravimetrically after evaporating
the solvents. The method was promulgated in the Federal Register on October 7, 1997. (Terry
Harrison 919/541-5233)
Method 316 - The manual testing method for measuring Formaldehyde emission
concentrations is based on sample collection in water with a acidic pararosaniline analytical
finish. The method was developed by the mineral wool manufacturing industry and has been
validated for use for the mineral wool and fiberglass manufacturing MACT. The method was
proposed in the Federal Register on March 31, 1997. The public comments have been
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summarized and responses prepared; promulgation is scheduled for FY 99. (Gary McAlister
919/541-1062 or Rima Dishakjian 415/744-2260)
Method 318 - This fourier transform infrared (FTIR) based method is designed
specifically for the analysis of phenol, formaldehyde, CO, carbonyl sulfide, and methanol
emission concentrations from manufacturing processes using phenolic resins, primarily the
mineral wool and fiberglass industries. The Agency conducted method validation testing at the
industry categories and measured the target pollutants. The validation tests included an extractive
sampling technique, appropriate QA/QC, and standardized data reduction procedures. The
method was proposed in the Federal Register on March 31, 1997. Response to comments have
been prepared and the method is scheduled for promulgation in FY 99. (Tom Logan 919/541-
2580 or Rima Dishakjian 415/744-2260)
Method 320 - This method is a generic, self-validating, extractive sampling procedure
applying fourier transform infrared (FTIR) analytical technology. The Agency developed method
can be applied to measuring concentrations of any pollutant responsive in the IR range and for
any source category provided specific performance and quality assurance criteria are met. The
method includes options for validating results based on whether tests are conducted for
compliance purposes or for screening. The validation requirements are consistent with Method
301 and include self-validation procedures such as spiking and appropriate calculations. The
draft method was published in the Federal Register on March 24, 1998 along with the Portland
cement MACT rule. The method is being revised according to comments and is scheduled for
promulgation in FY 99. (Tom Logan 919/541-2580 or Rima Dishakjian 415/744-2260)
Method 321 - This fourier transform infrared (FTIR) based method is specific for
determining compliance for HC1 emissions from Portland cement plants. The industry developed
and validated system uses a heated sample line and a filter maintained at 350ฐF to control
ammonium chloride formation. The draft method was published in the Federal Register on
March 24, 1998 along with the Portland cement MACT rule. The method is being revised
according to comments and is scheduled for promulgation in FY 99. (Tom Logan 919/541-2580
or Rima Dishakjian 415/744-2260)
Method 322 - Gas filter correlation infrared spectroscopy is applied in this method for
measuring HC1 emissions from Portland cement plants. The industry developed and validated
test method uses a heated sample line and a filter maintained at 350ฐF to control ammonium
chloride formation. The draft method was published in the Federal Register on March 24, 1998
along with the Portland cement MACT rule. The method is being revised according to comments
and is scheduled for promulgation in FY 99. (Terry Harrison 919/541-5233)
Methods and Regulatory Revisions and Corrections Package - The EMC has
summarized minor methods corrections and revisions and similar revisions for new source
performance standards with the purpose of publishing a notice of changes and updates in the
Federal Register. In the process of making these changes, the EMC decided to reformat the
methods to be consistent with the EPA guidelines prepared by the Environmental Monitoring
Management Council (EMMC) for all environmental methods. The revised and reformatted Part
60 and Part 61 methods were proposed in the Federal Register on August 7, 1997 under
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revisions/corrections. Comments have been summarized and the methods are being revised and
are scheduled for promulgation in FY 99. (Foston Curtis 919/541-1063)
Other Test Method Development Activities - Methods and procedures under
development and at various levels of validation. These methods are listed by the pollutant of
interest and a contact name is provided for each.
Acetonitrile - Gaseous and particulate emissions are withdrawn isokinetically and
collected in a multi component sampling train. The collection train consist of a heated probe
and filter, a condenser/sorbent module, and impingers. The acetonitrile is absorbed on
Carboxen-1000 contained within the module. The sample is recovered by rinsing the train
components with 1:1 methylene chloride/methanol. The target analyte is extracted from the filter
and Carboxen-1000 and analyzed by gas chromatography with flame ionization detector
(GC/FID). Particulate acetonitrile is extracted from the filter and combined with the probe rinse
for analysis by GC FID. Gaseous acetonitrile is extracted from the Carboxen-1000 with 70 ml
of methylene chloride and analyzed by GC/FID. The draft method has been validated at a
hazardous waste incinerator. (Gene Riley 919/541-5239)
Hydrogen Cyanide - The draft method is applicable to the collection and analysis of
hydrogen cyanide (HCN) in the gas phase. Gaseous and particulate emissions are withdrawn
isokinetically and collected in a multi component sampling train. The primary components of
the sampling train include a heated probe and filter, and impingers; two impingers containing
0.1N sodium hydroxide (NaOH). The hydrogen cyanide reacts with the NaOH to form cyanide
ion. The performance of the method depends on maintaining a high pH (> 12) in the impingers.
As a result, the pH in the impingers must be routinely monitored throughout the duration of
sampling. The sampling train is recovered in four fractions: 1) the nozzle, probe and front half
rinse; 2) the filter; 3) Pb acetate impinger (optional); and 4) impingers 2, 3, & 4 contents.
Particulate cyanide salts retained on the filter are not usually analyzed. Filters can be recovered
in 0.1 N sodium hydroxide and the sodium hydroxide extracts analyzed by ion chromatography.
Retention of hydrogen cyanide on the filter depends upon the amount and nature of the
particulate material present in the source. The cyanide ion retained in the impinger alkaline
solution is analyzed by ion chromatography (1C). The method has been validated for hydrogen
cyanide in the laboratory and is believed to be applicable to processes where hydrogen cyanide
might be emitted. (Gene Riley 919/541-5239)
Phenol - The draft method (also known as Method 317) is applicable to the collection and
analysis of high levels (>20 ppmv in the gas phase or associated with particulate) of phenol and
certain cresols. Gaseous and particulate emissions are withdrawn isokinetically and collected in
a multi-component sampling train. The primary components of the sampling train include a
heated probe and filter, and impingers; two impingers containing 2 N sodium hydroxide (NaOH).
Phenol and cresols react with the NaOH to form the corresponding sodium salts. The sampling
train is recovered in three fractions: 1) the nozzle, probe, front half rinse; 2) the filter; and 3) the
impingers. Filters are extracted with methylene chloride using Method 3541. The extract is
analyzed by gas chromatography/mass spectrometry (GC/MS) using Method 8270. Retention of
phenol and cresols on the filter depends upon the amount and nature of the particulate material
present in the source. An aliquot of the impinger fraction is pH adjusted and is adjusted to a
known volume (25 ml). An aliquot may be first concentrated using a rotary evaporator and then
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the pH adjusted to obtain lower detection limits. The pH adjusted sample is analyzed by high
performance liquid chromatography (HPLC). The method has been validated for three target
analytes at a fiberglass manufacturing facility and is believed to be applicable to processes where
phenols and cresols are emitted. (Tom Ward 919/541-3788 or Gene Riley 919/541-5239)
Performance Based Measurement Systems (PBMS) - In an effort to implement the
President's program for reinventing government and reforming regulatory policy, EPA has been
trying to remove barriers by using new measurement and monitoring techniques. One possible
barrier is the requirement to use specific measurement methods and/or technologies in complying
with the Agency's stationary source air pollution regulations. The Agency has adopted the PBMS
approach in removing this barrier. The PBMS approach defines the measurement needs and/or
data quality objectives (DQOs) for regulations. The proposed approach introduces flexibility into
data gathering and defines criteria for selecting appropriate methods to meet those needs. The
goal is to de-emphasize the historical Agency reliance on specific, prescribed procedures except
where such procedures are required by legislation or for method-defined parameters. Over the
past seven months, the EMC has assessed the regulatory structure of 40 CFR 60, 61, and 63 to
determine specific PBMS measurement requirements for data qualification. Regulations that
depend on test methods that yield method-defined parameters (i.e., the regulation or the method
inherently precludes alternatives, save a rewriting of the regulation and the method) were
disqualified. Only the analytical portion of the test methods are being considered for PBMS at
this time. Approximately 25 test methods have been identified as candidates for establishing
performance criteria (i.e, through data quality objectives (DQOs) or measurement quality
objectives (MQOs)). Implementation will be through revisions in a federal register package
scheduled to be proposed in FY 99. Performance criteria could potentially be established for up
to 56 other test methods. Final decisions regarding the process and changes to be made are
expected in FY 99. (Lara Autry 919/541-5544)
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Stationary Source Compliance Audit
Program (SSCAP)
Lara Autry
of Air
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
THE STATIONARY SOURCE COMPLIANCE
AUDIT PROGRAM
Lara P. Autry
On November 15, 1990, the Clean Air Act (CAA) was amended and a list of 189
compounds that are considered to be Hazardous Air Pollutants (HAPs) was included. These
pollutants are to be regulated through the development of Toxics Methods, which include
Maximum Achievable Control Technology (MACT) Standards, and New Source Performance
Standards (NSPS).
In support of these Federal regulations, audit materials are developed, validated, and
provided to State and local agencies to ensure high quality source emissions compliance data.
These performance evaluation samples have traditionally been requested from the Stationary
Source Compliance Test Coordinator of the Environmental Protection Agency's (EPA's)
National Exposure Research Laboratory by the regulatory agency for whom the compliance test is
being conducted.
As of January 1, 1998, the Stationary Source Compliance Audit Program (SSCAP) was
taken over by the EPA's Emission Measurement Center and many changes instituted. These
modifications to the program provide a more effective and efficient way to implement the
performance evaluations.
The objectives of this presentation are to provide a little background of the SSCAP,
information regarding how to obtain audit samples, sample availability, and general details of the
database being developed to run the program throughout all the EPA Regional Offices and States.
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STATIONARY SOURCE
COMPLIANCE :
AUDIT PROGRAM
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Method 315: Under Development
CONTACTS
p EMC QA Team Members-; . * . - .
. Lara Autryr (919) 541 -5544' *. : '
- .'Terry Harrfeon:;(9f.9)'541'-5233x*^ /
. Gary McAlisten (919)54t-1062 i/; %-
. Wad^Peele: (9T9)'541^945;;" ,~l; '. ;
' .Wed Thompson:, (dl-9) 541-2/07 ' ,\ /
p Fax Number: (9i9).541-ip397/;"^ ^
p ,E-maih last.first@epamail.epalgG.v . '
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Presentation 2
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Presentation 2
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Fine Particulate Measurements
- Filterable and Condensible Particulate
Tom Logan
of Air
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
SOURCE PM FINE PROJECT
Tom Logan
This talk will describe on-going method development to measure fine particulate matter (FPM)
emission. Primary FPM will be measured by a cyclone train using PM10 and PM2 5 micron size cut
cyclones. Measurement options for FPM precursors will also be discussed.
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SOURCE
PM FINE PROJECT
PRIMARY PM
FINE PM PRECURSORS
NEW METHOD
20lb
Based on Method 20la -PM 10 using a cyclone
train
Solid Phase PM separated into both PM 10 &
PM2.5
Draft now available on internet
PRIMARY PM FINE
Measured at Stack Temperature and
Composition
Filterable PM-New 201 b
FINE PM PRECURSORS
MATERIAL WHICH PASSES PRIMARY PM
FILTER
Relates source pollutant contribution to
ambient air concentrations
Complex to quantify; many components
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FINE PM PRECURSORS CONT.
How and what components to quantify
Complexity of measurement procedure
Costs, both equipment and for field tests
FINE PM PRECURSORS
MEASUREMENT OPTIONS
Condensable Method - M202
FTIR to measure acid gases and C-H
stretch for organics
Dilution train to measure compounds by
ambient air denuder technique
FINE PM PRECURSORS CONT.
Source Components :
SO2 NH3
NO HCI
SOB HF
NO2 Organics
FY 99 ACTIVITIES
Conduct Field evaluation of primary & Fine PM
Precursors methods
CFR proposal for Primary PM Fine Method
-M20lb
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SCHEDULE FY99
Draft Method 201 b
Initiate WA for FPMP
Complete Lit Review
Complete Lab Studies
Draft EMC Proposal M 201 b
Complete SOPs for FPMP
Approved QAPP & Test Plan
Complete Field Test
Draft Field Test Report
9/98
10/98
12/98
2/99
3/99
4/99
4/99
6/99
7/991
FUGITIVE PM
FROM ROADS, FIELDS, PILES, ETC
Manual Sampling, using tower based
samplers for spatial resolution
Optical Systems, LIDAR etc
SCHEDULE CONTFYOO
Method 201 b Proposal to DC
EMC Proposal FPMP
FR Publication M201 b Proposal
2nd PM Method Proposal to DC
FR for FPMP Proposal
FR M201 b Promulgation
FR FPMP Promulgation
8/99
11/99
12/99
3/00
8/00
8/00
8/01
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Presentation 3
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Pcesentation 3
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Performance-Based Measurement
System
Lara Autry
of Air
Source Testing in the New
Regulatory World Workshop
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Performance Based Measurement System
98-WA69.02
Lara P. Autry
Statistician, Environmental Protection Agency,
Emission Measurement Center (MD-19), Research Triangle Park, North Carolina 27711
ABSTRACT
The Environmental Monitoring Management Council (EMMC) has defined Performance Based
Measurement System (PBMS) as "A set of processes wherein the data quality needs, mandates
or limitations of a program or project are specified and serve as criteria for selecting appropriate
methods to meet those needs in a cost-effective manner." Under such a system, the
Environmental Protection Agency (EPA) will specify what question(s) is .to be answered by
measurement or what decision(s) is to be supported by the data and what level of uncertainty is
acceptable. The EPA would specify performance criteria and data producers will be required to
demonstrate that their proposed measurement system (i.e., methods, sample handling procedures)
meets these specific performance criteria. Data producers will be required to document
performance and certify they have used appropriate quality assurance and quality control
procedures.
The system will apply to physical, chemical, and biological measurements conducted either in
laboratories or in the field. The adoption of a PBMS approach represents a fundamental shift
from the traditional process(es) that the EPA has used to approve new or alternative measurement
methods, to a new approach that imposes legal accountability for the achievement of specific data
quality objectives, without prescribing the particular procedures, techniques, or instrumentation
for achieving such objectives. Exceptions will be needed for method defined parameters for
which the method defines the property (e.g., Toxicity Characteristic Leaching Procedure mobility,
ambient and stationary source particulate matter) or for situations where it would be impractical
or cost prohibitive to define the property except by using a reference method (e.g., where a stable
reference standard cannot be prepared).
The objectives of this paper are to provide an understanding of what PBMS is and what it is
intended to achieve. Some of the implementation efforts within the Office of Air and Radiation
(OAR) will be provided as an example of the change to current practices.
INTRODUCTION
The Environmental Protection Agency (EPA) is actively working to implement the President's
program for reinventing government and reforming regulatory policy. As part of this program,
EPA has been working at breaking down barriers to using new measurement and monitoring
techniques. One possible barrier is the requirement to use specific measurement methods or
technologies in complying with some of the Agency's regulations. EPA's Environmental
Monitoring Management Council (EMMC), members of the regulated community, and Congress
agree that EPA should consider changing the way it specifies measurement/monitoring
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requirements in regulations and permits. There is acceptance for Agency-wide use of a
performance based measurement system (PBMS).
The PBMS is "performance based" in that it emphasizes the cost-effective "matching" of the
performance characteristics of a measurement method to defined measurement needs or data
quality objectives (DQOs) of the applications. It de-emphasizes the historical Agency reliance
on specific, prescribed procedures except where such procedures are required for method-defined
parameters or by legislation. PBMS will address the perception that prescribed measurement
methods within Agency programs:
discourage the proposal, development, and advancement of cost-effective, alternative
approaches, including new measurement technologies;
discourage the modification of methods that could improve the performance of those
methods for particularly challenging measurement scenarios; and
constitute an unnecessary burden on those who provide similar data to multiple Agency
programs and must conform to the various program-specific method mandates when a
common measurement approach is available that will satisfy these multiple needs with
significant cost savings.
The prescriptive method approach inhibits the use of more recent, better, cheaper, or faster
methods. Many EPA methods incorporated a series of rigid, prescriptive steps, however,
designed to control the quality of analytical results and to allow data users consistent results to
evaluate. The PBMS system is designed to provide measurement flexibility and will facilitate
the introduction and approval of new methods.
Under the PBMS, data producers will be required to demonstrate and document that any method
(including the Agency's designated reference methods) selected are appropriate for their intended
application. They will also be required to certify that appropriate quality assurance and quality
control (QA/QC) procedures are used during both the initial demonstration and the application
of the method. Although method-defined parameters and sampling are removed from
consideration for PBMS at this time, the PBMS will apply to physical, chemical, and biological
measurements obtained in laboratories as well as those made in the field.
DEFINITION AND GOALS
The EMMC PBMS work group defines PBMS as "A set of processes wherein the data quality
needs, mandates or limitations of a program or project are specified and serve as criteria for
selecting appropriate methods to meet those needs in a cost-effective manner." Under PBMS,
the EPA must specify what question(s) is to be answered by a measurement or what decision(s)
is to be supported by the data and what level of uncertainty is acceptable. The EPA will specify
performance criteria, through data quality objectives (DQOs) and/or measurement quality
objectives (MQOs), and data producers will be required to demonstrate that their proposed
measurement system (i.e., methods, instruments) meets these specific EPA performance criteria.
The EMMC PBMS work group set the following goals for the EPA PBMS approach to
regulatory development:
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1. Provide a simple, straightforward way for the regulatory community to respond to specific
measurement needs with reliable, cost-effective, methods.
2. Emphasize project or application-specific method performance needs rather than requiring
that specific measurement technologies be used in order to avoid costly measurement
overkill.
3. Encourage the use, by the scientific community, of professional judgement in modifying
or developing alternatives to established Agency methods.
4. Employ a consistent way to express methods performance criteria that is independent of
the type of method or technology. This includes articulating measurement needs in
qualitative and quantitative terms.
5. Foster new technology development and continuous improvement in the measurement
community to give the Agency feedback on new monitoring approach successes as well
as failures. This will expand the EPA's knowledge of new or modified approaches and
will enable EPA to assist others by helping to disseminate this information to the wider
monitoring community.
The adoption of a PBMS approach represents a fundamental shift from the traditional process(es)
that the EPA has used to approve new or alternative measurement methods. This new approach
imposes legal accountability for the achievement of specific DQOs or MQOs, without prescribing
the particular procedures, techniques, or instrumentation for achieving such objectives. In some
cases, a PBMS approach will not be acceptable. Exceptions will be needed for method-defined
parameters for which the method defines the property (e.g., ambient and stationary source
paniculate matter) or for situations where it will be impractical or cost prohibitive to define the
property except by using an Agency designated reference method (e.g., where a stable reference
standard cannot be prepared).
PERFORMANCE CRITERIA
PBMS criteria are values for critical data quality elements that reflect a specific project need or
regulatory requirement. EPA has often used reference methods to identify these data quality
elements, such as bias, precision, sensitivity, selectivity, detection limit and effective range either
because of regulatory requirements or because they most readily or easily meet general program
goals.
Since the data generally are used for environmental decision making, it is critical that the quality
of the measurements be known. Historically, EPA has evaluated and validated the performance
of its methods in a variety of matrices. Under the PBMS approach, validation will be conducted
with the actual samples being analyzed. This may result in a higher degree of confidence in the
reported data quality.
DQOs or MQOs address only a portion (i.e., method/laboratory performance) of the information
that a regulator or regulated person would need to evaluate in making measurement based
decisions. Indicators of extra-laboratory variability, such as replicated field samples, will need
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to be considered in the most generic approach to environmental measurements. The results of
a matrix spike of compounds detected or of interest in that specific material are also valuable in
creating confidence in the validity of reported results.
Data Quality Objectives (DQOs)
EPA recommends the use of a seven step DQO process to convert a decision maker's data needs
into an optimized study design that balances those needs against resources. The seven steps that
make up this process include: State the Problem; Identify the Decision; Identify the Inputs to the
Decision; Define the Study Boundaries; Develop a Decision Rule; Specify Tolerable Limits on
Decision Errors; and Optimize the Design. Although the DQO process seems to be a series of
linear steps in practice, it is iterative because information gained from each step may influence
prior steps. The following are descriptions of each of these seven steps and a more detailed
description can be found in EPA QA/G-4: Guidance for the Data Quality Objectives Process.
Step 1: State the Problem - Concisely define the problem to describe the issues to be studied.
Outputs from this step should include a concise description of the problem, a list of the
planning team members that identifies the decision maker, a summary of available
resources, and any deadlines for the study.
Step 2: Identify the Decision - Define the decision statement that the study will attempt to
resolve. The activities in this stage are to identify the principal study question, define the
alternative actions that could result from resolution of the principal study question, and
the decision statement that links the principal study question to possible actions that will
solve the problem.
Step 3: Identify Inputs to the Decision - Identify the information that needs to be learned and the
measurements that need to be taken to resolve the decision statement. The natural outputs
to this step include: identification of the information that will be required to resolve the
decision statement; determination of the sources for each item of information identified;
identification of the information that is needed to establish the action level; and
confirmation that appropriate analytical methods exist to provide the necessary data.
Step 4: Define the Study Boundaries - Specify the conditions to which decisions will apply and
within the spatial and temporal boundaries which the data should be collected. Products
from this stage include: specification of the characteristics that define that population of
interest; definition of the geographic area within which all decisions must apply; when
necessary, division of the population into strata that have relatively homogeneous
characteristics; determination of the time frame to which the decision applies;
determination of when to collect data; definition of the scale of decision making; and
identification of any practical constraints on data collection.
Step 5: Develop a Decision Rule - Define the parameter of interest, specify the action level, and
integrate previous DQO outputs into a single statement that describes a logical basis for
choosing among alternative actions. Specific outputs to this step are the statistical
parameter that characterizes the population, the action level, and an "if...then..." statement
that defines the conditions that would cause the decision maker to choose among
alternative actions.
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Step 6: Specify Limits on Decision Errors - Specify the decision maker's tolerance limits on
decision error rates based on a consideration of the consequences of making an incorrect
decision. Products in this stage include: determination of the possible range of the
parameter of interest; identification of the decision errors and choice of the null
hypothesis; specification of a range of possible parameter values where the consequences
of decision errors are relatively minor; and assigned probability for the occurrence of
decision errors.
Step 7: Optimize the Design - The purpose of this step is to identify a resource-effective data
collection design for generating data that are expected to satisfy the DQOs. Activities
that are involved in this step are as follows: review the DQO outputs and existing
environmental data; develop general data collection design alternatives; formulate the
mathematical expressions needed to solve the design problems for each design alternative;
select the optimal sample size that satisfies the DQOs and document the operational
details and theoretical assumptions of the selected design in the sampling and analysis
plan.
There are often tradeoffs made between data confidence and cost. If both field error and
measurement method performance are known, decision makers can determine the various
consequences of the false positive and false negative errors they are willing to tolerate. Field
error can be estimated, which for these purposes shall be defined as the total of the errors
associated with sampling derived from preexisting data or from data obtained in a pilot study
conducted under real-world conditions. The performance of the selected or alternative
measurement methods can be evaluated to determine whether or not any particular method is
appropriate for the given measurement scenario. With these pieces of information, an optimal
sampling and analysis design can then be developed using the DQO process.
Measurement Quality Objectives (MQOs)
If field error is defined and a study design is selected, user can calculate the amount of bias and
imprecision that they will accept in their measurement methods. These characteristics (bias and
precision) are critical measurement quality objectives (MQOs) and are among the most important
performance criteria for method selection. Where multiple approaches can meet performance
criteria, then such factors as cost and operational ease may also become important in method
selection.
Some measurements required of the regulated community by the Agency are already
"performance based" (e.g., measurement of hazardous waste characteristics for the Resource
Conservation and Recovery Act) in that the data producer has the responsibility to select samples
and determine the nature and extent of testing using their knowledge of the waste and Agency
guidance. The guidance clarifies what the Agency wants, but the final decisions are the
responsibility of the data producer. This responsibility includes making decisions based on
measurement results that include the effects of material heterogeneity, the appropriateness of the
sample(s), and effects of sample shipment and handling, as well as the variability arising from
laboratory or field measurement methods.
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MONITORING
Regulators have observed that even under highly regulated and inspected EPA programs, data
producers often do not follow prescribed methods as they are written. In compliance programs
that allow alternative test procedures (ATPs) or methods, however, users must obtain written
permission from the state and concurrence from the EPA Regional Administrator (for wastewater
methods) or a designee of the EPA Administrator ( for drinking water and air methods) to use
an ATP. Regulators base approval on whether an alternative procedure or method is substantially
equivalent to a prescribed method. Unfortunately, the approval process is time consuming,
cumbersome, and costly; as a result, users have submitted few requests.
EPA is aware that advances in analytical technology are progressing rapidly and there is great
potential to improve the Agency's ability to monitor compliance and new contaminants not
amenable to existing methods. Recognizing the problems and potential benefits, the Agency is
considering PBMS to allow the regulated community to use new or emerging technologies to
meet mandated monitoring requirements.
When EPA proposes to regulate contaminants under the PBMS, EPA would identify the analyte-
or program-specific measurement needs and express these as performance criteria. Most, but not
all, of EPA's compliance monitoring programs prescribe measurement methods by federal or
states statutes. Under the PBMS, emphasis would then be on how to document data quality
rather than on gathering data. Personnel performing measurements would be responsible for
demonstrating method performance and the organizations would be responsible for certifying
performance and for maintaining the prescribed data records that support their conclusions.
In those compliance monitoring programs that allow some limited analytical flexibility, EPA has
a few safeguards in place. Sometimes the prescribed methods allow different preparation steps
(extractions, cleanup) and instrumentation procedures (chromatography conditions and detectors),
but only specify that laboratories verify precision and bias performance criteria at high
concentrations. PBMS offers analytical flexibility, but it incorporates critical performance criteria
to assure analytical performance.
IMPLEMENTING PBMS FOR OAR
Due to the fundamental differences that exist between the Agency's Program Offices, each office
is developing an implementation plan to focus on the individual program needs.
Structure of OAR
The Office of Air and Radiation (OAR) includes: the Office of Air Quality Planning and
Standards (OAQPS), the Office of Mobile Sources (QMS), the Office of Radiation and Indoor
Air (ORIA), and the Office of Atmospheric Programs (OAP). There are four offices within OAR
and combined they represent a total of seven programs that will be affected by PBMS. The
OAQPS houses the Ambient Air and the Stationary Source Programs. In the OMS, there are
essentially two different programs: Fuels, and Engines and Vehicles. For the OAP, the Acid Rain
Program is the only program of concern. Finally, the ORIA has both the Indoor Air and
Radiation Programs.
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Process for Implementation
OAR plans to apply PBMS only to the analytical portion of the methods at this time. There are
two principle reasons for this approach, (1) the sampling component of air methods is essentially
method-defined (e.g., the sampling approach defines the results) and (2) the lack of reference
materials that could assess the entire sampling approach. This is consistent with the approach
being taken by the Office of Solid Waste (OSWER) for the air emission test methods. In the
future, this decision may be reassessed.
Each regulation and measurement method was evaluated to determine if it was a candidate to be
part of a performance based system (i.e., a measurement that was not method-defined). Once the
yes/ho decision was made for including a regulation or measurement method in PBMS, a rank
was assigned to each regulation and method to indicate the difficulty anticipated, if these
regulations or methods are changed, for converting existing regulatory or methods text in the
Code of Federal Regulations to be compatible with a PBMS.
Three programs within OAR already have a PBMS-type structure with the exception of a
preapproval process. OAR is retaining this PBMS structure and does not plan to eliminate these
up-front approval processes.
PBMS implementation for existing regulations could occur in two ways: by amending regulatory
language or by amending reference measurement methods. These changes will come in the form
of DQOs, MQOs, or a combination of the two. These could be developed according to the
hierarchy on the tables for each program following the schedules that appear within each
program's section of the implementation plan. Performance criteria will potentially be developed
for each method or regulation identified for PBMS candidacy by consulting those environmental
scientists within the Agency who are responsible for those methods/regulations being changed.
Unfortunately, the resources are not available; therefore, procedures to allow PBMS in the future
are being focused upon.
CONCLUSIONS
Currently, most methods incorporate a series of rigid, prescriptive steps designed to control the
quality of analytical results and to allow data users to evaluate those results. While the value for
such rigid specifications is debatable, they currently apply nonetheless, to a significant segment
of compliance monitoring. The PBMS system would provide measurement flexibility (e.g., to
overcome such analytical problems as matrix interferences or to meet the measurement
requirement of programs more cost effectively) and would facilitate the introduction and approval
of new methods.
This paper has summarized the goals of the proposed PBMS system and laid out generic
guidelines on what PBMS will entail. There is much to be done in the way of communication
and training for the EPA's staff, Regional and State staff, regulated entities, and the measurement
community. The Agency is currently preparing a coordinated PBMS communication and training
plan for all the program offices to meet this need together. Specifics of each programs
implementation plans for PBMS will have to be obtained from the individual program offices.
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REFERENCES
1. U.S. Environmental Protection Agency, 1994a. Guidance for the Data Quality
Objective Process (EPA QA/G-4). EPA/600/R-96/055. Office of Research and
Development.
2. Autry, Lara P. Data Quality Assessment: A Tool for Data Analysis; AWMA
90th Annual Meeting & Exhibition. 97-A945.01. March 1997.
3. Environmental Monitoring Measurement Council Performance Based Measurement
System Work group. Performance-Based Measurement System. July 13, 1996.
4. The Office of Air and Radiation Performance Based Measurement System
Draft Implementation Plan. January 29, 1998.
. 8
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MRFORM^NCE BASEp
MEASUREMENT SYSTEMS
OiFICE OF AIR AND
RADIATION
199B
Performance Baised Measurement System (PBMS);
A set of processes wherein the data quality needs,
mandates or limitations of a program or project are
specified and serve as criteria for selecting
appropriate methods to meet those needs in a
cost-effective manner.
Define (PBMS)
Background
Goals of PBMS
OAR's Structure
OAR Implementation Plan Status
OAR Regulatory Evaluation
Summary^ Future
PBMS wp shift Agency's approach from requiring
Specific procedures for measurement to specifying
performance criteria for selecting a suitable
measurement method
In May 199งy EMMC Policy Council endorsed
Agency-wide adoption of PBMS approach
InMay 1997, Fred Hansen charged EPA Programs:
1 Develop Implementation Plans by 9/30/97
Implement PBMS by 9/30/98
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HOW DID WE GET TO PBMS? i 5
Laboratory and instrument vendor outcry about
Agency's prescription of rigidly defined methods ,;
EMMC Work Group formed to define and develop
basic principles for PBMS
Threat of 1996 Congressional bill to force PBMS I
' ' ' * * '- '' '
. . .
Fred Hansen met with instrument vendors in
March 1997."' : ;' .. - '-: . . r.:^' ';'...
GOALS GE PBMS (continued) 1 *
Provide a consistent way to express method
performance criteria independent of the type, of I
method or technology.
Foster new technology development and
continuousjmprovement in measurement 4
methodology.
Encourage feedback on successes as well as failures
O -'..--
to expand and disseminate knowledge of new or
modified approach under real world conditions.
tiOALSOEPBMS
Provide a simple, straightforward way for the
regulated community to respond to specific
measurement needs with reliable, cost-effective,
.it; methods.
s? Emphasize project-specific method performance
needs rather than specific technologies to avoid
.costly measurement overkill.
Encourage use of professional judgment in
modifying or developing alternatives to established
Agency methods.
Office of AirlQuality Planning and Standards
4 Stationary Source Program
Ambient Monitoring Program
Office of Atmospheric Programs
Acid Rain Program
Office of Mobile Sources
Engines and Vehicles Programs
Fuels Program
Office of Radiation and Indoor Air
Radiation Program
Indoor Air Program
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IMPLEMENTATION PLAN
Initial Draft Plan completed September 30, 1997
Final Draft Plan completed for review February 16,
1998
Management review completed March 5, 1998
OECA review and concurrence completed April
22, 1998
Final Plan completed May 29, 1998
Transmitted^tp Fred Hansen and the EMMC Policy
Council July 15, 1998
SCOPE OF PBMS
. Sampling
Sampling Preparation Analytical
Method-
Defined
Method-
Defined
Current Alternative Method
Approval Process
Method-
Defined
PBMS
OAR Regulatory Evaluation
Measurement Requirements and Methods
Eliminated from PBMS Consideration:
Method-defined
Required Only Sampling
Published by Consensus Standard Setting Body
Policy Considerations
j PBMS Compatible Measurement Requirements and
Methods Raflfced-Regai'dmg Difficulty in Making
Regulatory Changes
OAR HIGHLIGHTS
Retention of up-front approval process:
Ambient Monitoring Program
Acid Rain Program
Engine and Vehicle Programs
Performance criteria established in future
rulemaking:
Stationary Source Program
Radiation Program
Fuels Program
Indoor Air Program
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STATIONARY SOURCE PROGRAM
For parts 60, 61, and 63, realistic revisions could
be made to 83 Subparts or approximately 23
Methods
Revision Package for:
-I Rules referencing existing Test Methods: '
Specify existing Test Method as an option
Specify performance criteria (DQOs/MQOs) as an
-; alternative option " .; : ;
-"! : * ' . i -7* ฐ -"'' ' :
New Test Methods.
Specify performance criteria (DQOs/MQOs)
FUELS PROGRAM ซ i
PBMS-type option already offered in many fuels
regulations
Retention of approval for existing fuels regulations
(i.e., not generally accepted to be a part of a PBMS
approach)
PBMS-type option for current and future
rulemakinp began March 1996 for Reformulated
. o o
Gasoline Rulemaking
RADIATION PROGRAM
ซ PBMS Approach Employed in Majority of Existing
Measurement Activities
Performance Criteria (DQOs/MQOs) need to be
ป ^Established for 3 Test Methods
Performance Criteria will be Specified in Future
Regulations/Test Methods
Ilp>OOR:AIR PROGRAM
^Existing HAP regulations do not apply to Indoor
Air Quahty Measurements
Guidance Documents do not require any revisions
-Performance criteria (DQOs/MQOs) will be
specified in future regulations
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SUMMARY/FUTURE
Modification of Methods:
Stationary Source Program Target May 2000, if not
later
Racliation Program Target Mav 2000-,-if not sooner
Communication Effort -- NOW
Training Modules -- Summer 1999???
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Presentation 4
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Presentation 4
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Instrumental Methods:
Review of Current Projects and Guidance
- Reference Test Methods
- Portable Emission Analyzers
Bill Grimley
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
INSTRUMENTAL METHODS: CURRENT PROJECTS AND GUIDANCE
Bill Grimley, EMC
The objective of this presentation is to familiarize participants with current projects within the
EMC concerning instrumental methods for 02, CO2, CO, S02, and NOX. Issues to be addressed
include method application by data objectives, method to method consistency, and available
technical guidance. Members of the audience are encouraged to describe their perspectives of
these issues so that EMC can refocus its work in this area to best meet State and regional needs.
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Instrumental Methods:
Current Projects and Guidance
Bill Grimley, EMC, MD-19, RTF, NC 27711
(919)541-1065 fax-1039
email: grimley.william@epa.gov
Reference Methods
Current Project:
Repropose revisions
3A, 6C, 7E, 10,20
Resolve technical difficulties
Achieve consistency across methods
Current Projects & Guidance
Reference Methods
3A.6C.7E. 10,20
Instrumental Methods
[O2. CO.CO2. SO2. NOx]
nttp://www/epa.Qov/ttn/emc
Conditional Methods
CTM-022. CTM-030
Preliminary Methods
| future: NOx by UV; ?)
Reference Methods
Guidance documents
ALT-004 [ 3A, 6C ]
ALT-007 [ 3A, 6C, 7E, 10, 20 ]
ALT-013[7E]
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Conditional Methods
Electrochemical
analyzer
CTM-022
NO, NO2, NOx
CTM-030
NOx, CO, O2
Preliminary Methods
near future: NOx by UV [?]
idea: methods for "periodic monitoring"
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Presentation 5
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VOC Methods Application, Guidance
- Method 25 versus 25A/25B versus 18
- Capture Efficiency Guidance
- Reporting VOCs
Gary Me A lister
Candace Sorrell
Mike Pjetraj
Source Testing in the New
Regulatory World Workshop
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- Method 25 versus 25A/25B versus 18
Gary McAlister
of Air
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
METHOD 25 VERSUS 2SA VERSUS 18
Gary McAIister
The three test methods that are commonly used to measure volatile organic compounds are
Methods 25, 25 A, and 18. The methods are compared on the basis of what they measure and
how they collect and analyze their samples. Then, their relative advantages and disadvantages
are discussed. Based on this discussion, some general guidelines for their use are presented.
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How Do Methods 25,
25A, and 18 differ?
Gary McAlister
US EPA
Meeting Objectives
Background
Method 25 - Measures Total Voc
Method 25A - Measures Total
Hydrocarbons (THC)
Method 18 - Measures Individual Organic
Compounds
. --?:,
Background (continued)
m Method 25
& Samples Are Time Integrated
^ Analysis Is Completed Off Site
M Method 25A
& Sampling Is Continuous
^ Analysis Is Done On Site
H Method 18
^ Samples Can Be Time Integrated or
Semi-continuous
4 An^l,y,si,fป Can,,,Ba,On Sitp off site
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-----
Background (continued)
& Method 25 - All Compounds Are
Converted To Methane Before Measuring
With An FID
IB Method 25A - All Compounds Are
Measured Directly, As A Whole, With An
FID
m Method 18 - Each Compound Is
Separated And Measured Individually
With An FID
_.
Advantaci6S And
^^Vl V Cil I ^ClVf vO ^
Disadvantages
Method 25A
m Advantages
^ Very Good Precision
& Real Time Analysis
^ Relatively Low detection Limit
m Disadvantages
^ Does Not Respond Equally To All VOC
^ Requires A Separate Measurement Of
Methane To Convert THC to VOC
Arlwontonac Anrl
_ ;
Disadvantages
Method 25
0 Advantages
^ Measures Only VOC (Excludes Methane)
A Responds Equally To All VOC
M Disadvantages
& Potential Positive Bias That May Vary
According To Source Category
^ Relatively Poor Precision
Advantages And
Disadvantages
Method 18
Advantages
& Good Precision
^ Low Detection Limits
j^ Can Exclude Methane
Disadvantages
A Measures Individual Organic Compounds
Not Total VOC
& Requires Calibration Standards For All
Measured Compounds
-------
* .
>t- ";
General Guidance
11 Use Method 25 For Unknown Mixtures
With Concentrations Greater Than
50 PPM
m Use Method 25A For Unknown Mixtures
With Concentrations Less Than 50 PPM
-
Summary
None Of The Existing Methods For
Measuring VOC's Are Perfect
Because Their Problems Can Be Source
Specific, We May Have To Approve
Alternative Methods For Some Sources
We Must Continue To Improve The
Existing Methods
General Guidance (continued)
Use Any Of the Methods For Known
Mixtures With The Following Conditions
A Method 25 Should only Be Used For
Concentrations Greater Than 50 PPM
A Method 25A Should Be Calibrated With the
Known Mixture Or The Results
Mathematically Corrected for Varying
Response Factors
& Method 18 Must Be Calibrated For Each Of
The Compounds In The Mixture
-------
- Capture Efficiency Guidance
Candace Sorrell
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
CAPTURE EFFICIENCY GUIDANCE
Candace Sorrell
In February 1995, EPA issued new guidance on capture efficiency (CE) testing. This guidance
recommended the use of permanent total enclosure (PTE) and temporary total enclosure (TTE)
protocols instead of a traditional liquid/gas mass balance determination. The traditional
liquid/ gas mass balance often resulted in very poor precision and CE values in excess of
100 percent. This presentation will summarize what is contained in the guidance document
entitled "Guidelines for Determining Capture Efficiency." The requirements are for conducting a
capture efficiency test using a PTE and TTE. This will include a general overview of the criteria
which need to be met in order for the enclosure to qualify as a TTE or PTE. In addition to the
enclosure procedures, the presentation will discuss the statistical requirements, data quality
objective (DQO) or the lower confidence limit (LCL) approach, which must be met if a source
decides to conduct a traditional liquid/gas material balance.
-------
Capture Efficiency
,Testing
TTE Criteria
' Any NDO shall be at least 4 equivalent opening
diameters from each VOC-emitting point
Total area of all NDO's shall not exceed 5
percent of the surface area of the enclosure
(walls, floor and ceiling)
Average face velocity through all NDO's shaj
be at least 200 ft/min.
Purpose
Discuss requirements for conducting a capture
efficiency test using a temporary total enclosure
(TTE)
Discuss statistical requirements to meet the
data quality objective (DQO) and lower
confidence limit (LCL) approach
TTE Criteria
' All access doors and windows whose areas are
not included as NDO's and are not included in
the calculation of face velocity shall be closed
during routine operation of the process
' Any exhaust point from the TTE shall be at least
4 equivalent duct or hood diameters from each
NDO.
-------
TEMPORARY TOTAL ENCLOSURE
FUGITIVE EMISSIONS
Alternative Capture
Efficiency Approaches
Data Quality Objective (DQO)
Lower Confidence Limit (LCL)
How To Determine Capture Efficiency
FUGITIVE EMISSIONS (F)
Input (L) -
Capfui od (G)
CE= ^ or L'F
G + F
Data Quality Objective
Purpose - Allow sources to use alternative
capture efficiency procedures (i.e., non-TTE)
while ensuring reasonable precision
DQO is + 5% at a 95% confidence limit,
which means that 95 percent of the time the
actual CE value will be within 5 percent of the
mean measured value (assuming the test
method is unbiased)
-------
Data Quality Objective (cont)
Individual CE values greater than 105 percent
are invalid and cannot be used to calculate
average CE and DQO
Source must have at least 3 valid test runs to
use the DQO approach
Lower Confidence Limit
Purpose - To provide sources, who may be
performing much better than their applicable
regulatory requirement, a screening option by
which they can demonstrate compliance (i.e.,
can use less precise method and less test runs
while still assured of correctly demonstrating
compliance)
The lower confidence limit (80 percent,
2-sided) must be greater than or equal
to the applicable CE regulatory
requirement.
^maiy'
How To Calculate DQO
a
* 0.975 S
Lower Confidence Limit (cont)
Individual CE values greater than 105 percent
are invalid and cannot be used to calculate
average CE and LCL
Source must have at least 3 valid test runs to
use the LCL approach
If the data does not meet the DQO and
the average CE, using all valid test runs, /
is above 100 percent then the test
sequence is considered invalid.
-------
Lower Confidence Limit (cont)
If facility's L.CL is below the standard then the
facility must conduct more test runs to show
compliance (LCL or DQO) or non compliance
(DQO).
Additional DQO and LCL
Testing Criteria
Each test run shall be at least 20 minutes long
and shall not exceed 24 hours.
All test runs must be separate and independent.
Composite liquid samples are not permitted to
obtain an "average composition" for the test
run.
How to Calculate LCL
LC =x
avg
0.90 S
n
Additional DQO and LCL
Testing Criteria (cont)
Individual CE results and average CE results
cannot be truncated (i.e., 105 percent cannot
be reported as 100+ percent)
All test run data meeting the prior criteria must
be used in the calculations unless the source
can identify testing or analytical error
-------
Contact Information
EMC Home Page - http://www.epa.gov/ttn/emc
- Methods 204 - 204F are under "Test Methods"
-Guidance document is under "Instructional Material"
then click on "Guideline Documents"
Candace Sorrell
- sorrell.candace@epamail.epa.gov
- (919)541-1064
-------
- Reporting VOCs
Mike Pjetraj
of Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
VOC Emissions
Influence of VOC Measurement and Reporting Methods on Regulatory Policy and Emissions
Estimations
Michael Pjetraj
Individual pollutant emissions from a wide variety of industrial processes are measured by a limited
number of source sampling methods. Volatile Organic Compounds (VOCs) present a particularly
unique testing dilemma since there are a large number of different compounds defined as VOCs. The
process of accurately and consistently measuring the quantity of total VOCs emitted is a concern to
both industry and regulatory agencies.
The most commonly used methods for quantifying VOCs in gas streams are in the Code of Federal
Regulations (40 CFR 60) Appendix A, Methods 18, 25, and 25 A. Each method has advantages and
disadvantages relative to the other methods. The choice of measurement and reporting techniques
depends on the purpose that the data will serve. Due to differing analytical limitations for each of the
VOC test methods, all sources may not be able to use the same test method and data manipulation
procedures.
-------
VOC Methods Application &
Guidance:
Reporting VOCs
Presented by:
Michael Pjetraj
North Carolina
Division of Air Quality
michael_pjetraj@ncair.net
Reporting VOCs
Major Measurement Techniques for VOCs:
25, 25a, 18, 24, and other specific methods
Generally "stack testing" is performed using
25aorl8
VOCs - Methods 25 & 25a
Methods 25 & 25a are in 40 CFR 60
Appendix A
The methods were created in order to
determine the removal efficiency of a
control device
VOCs - Methods 25 & 25a
Typically once a method is promulgated
(and sometimes before it is) the method will
be used for a variety of purposes.
Including functions that it was not designed
to perform.
VOCs - Methods 25 & 25a
1. Applicability and Principle
Direct measurement of an effluent with a
flame ionization detector (FID) analyzer
may be appropriate with prior
characterization of the gas stream and
knowledge that the detector responds
predictably to the organic compounds in the
stream.
VOCs - Methods 25 & 25a
The method specifically states that it may
not be applicable to the determination of a
mass emission rate
-------
VOCs - Methods 25 & 25a
The FID can be applied to the determination
of the mass concentration of the total
molecular structure of the organic emissions
under any of the following limited
conditions:
VOCs - Methods 25 & 25a
(1) Where only one compound is known to
exist;
(2) when the organic compounds consist of
only hydrogen and carbon;
VOCs - Methods 25 & 25a
(3) where the relative percentages of the
compounds are known or can be ,
determined, and the FID responses to the
compounds are known;
(4) where a consistent mixture of the
compounds exists before and after emission
control and only the relative concentrations
are to be assessed; or
VOCs - Methods 25 & 25a
(5) where the FID can be calibrated against
mass standards of the compounds emitted
(solvent emissions, for example).
VOCs - Methods 25 & 25a
Case Study:
Emissions testing was performed and
submitted in support of a permit application
Gas Stream consisted of ~ 100 VOCs
Total VOCs per 25a = 2.5 Ib/hr as carbon
1 speciated compound per a compound
specific test was emitted at 5 Ib/hr
VOCs-Methods 25 & 25a
Example:
Using the MW of carbon for mass emission
rate
Consider Propylene Glycol
(CH3CH(OH)CH2OH)
Molecular Weight is 76.10
The carbon weighted MW is 76.1/3=25.4.
-------
VOCs - Methods 25 & 25a
Example (cont.)
Assume: Concentration = lOOppm
QsdoflOO.OOOdscfm
Ib/hr 'as carbon'= 18.7 Ib/hr.
Using the MW normalized for carbon we
get Ib/hr 'as VOC'=39.57 Ib/hr.
An error in excess of 100% due only to
MW.
VOCs - Methods 25 & 25a
We have identified a major concern with the
reporting of VOCs when using methods 25
&25a
Molecular Weight adjustment
Every organic will weigh more than just
carbon
VOCs - Methods 25 & 25a
The other error specific to Method 25a is
called the "response factor"
The Flame lonization Detector (FID) used
in Method 25a does not get a 1:1 response
with all organics
Reporting VOCs - Method 18
Method 18 measures specific VOCs
Requires knowledge of the pollutant gas
stream
Can only measure VOCs for which the GC
has been calibrated
Reporting VOCs - Method 18
Difficulties:
Sources claim that they only need to
measure "total VOCs" - not speciated
What to do with a "soup" of VOCs?
Reporting VOCs
VOC reporting survey sent to 28 state
agencies
15 states responded
7 states require 'as VOC'
6 states require 'as carbon, methane or
propane'
2 states were unclear
-------
Reporting VOCs
NC DAQ forwarded the survey along with
other information to Region IV.
11/17/97 EPA Region IV issued policy
stating that Method 25 & 25a results must
be converted to an 'as VOC' basis.
-------
Presentation 6
-------
-------
MACT Rule Development
- Role of EMC in MACT Development
MACT And Other Air Toxic Emission Standards
- MACT Test Methods Rule Format
- MACT Monitoring For Compliance
8/77 Lamason
Susan Wyatt
Jim Szykman
Sally Mitoff
Source Testing in the New
Regulatory World Workshop
-------
- Role of EMC in MACT Development
8/77 La mason
of Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT RULE DEVELOPMENT
(Role of EMC with MACT)
Bill Lamason
-------
- MACT And Other Air Toxic Emission Standards
Susan Wyatt
ot Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
STATUS
MACT RULE AND OTHER AIR TOXIC EMISSION STANDARDS
Susan R. Wyatt
Section 112 of the Clean Air Act requires promulgation of maximum achievable control
technology (MACT) standards on a staggered schedule to be completed by the year 2000. All of
the 2 and 4 year rules and many of the 7 year rules have now been published. The source
categories for which rules have been completed and those for which rulemakings are still
underway are presented. Efforts to list additional source categories for regulation through the
urban area source and 112(c)(6) programs will also be described.
-------
STATUS - MACT and
OTHER AIR TOXIC
EMISSION STANDARDS
November 3, 1998
Susan R. Wyatt
SECTION 112(d) MAXIMUM ACHIEVABLE
CONTROL TECHNOLOGY (MACT)
STANDARDS
- New sources, best controlled similar source
-Existing sources, average emission limitation
achieved by best performing 12%
Major sources equal 10 tons of any 1 HAP or
25 tons combination of HAPs
Section 129 Combustion Standards
-Municipal Waste Combustion (12/95)
- Hospital\Medical\lnfectious Waste Incineration
(9/15/97)
- Promulgate by November 2000:
Industrial/Commercial Waste Incinerators
Other Solid Waste Incinerators
MACT SOURCE CATEGORIES
i 189 Hazardous Air Pollutants Listed in CAA
(Now 188)
i 1 74 Source Categories Listed by EPA
i Source Categories Divided into Bins:
BIN
2 year
4 year
7 year
10 year
STATUTORY
DATE
11/15/92
11/15/94
11/15/97
11/15/00
SOURCE
CATEGORIES
6
39
42
87
\
-------
2 & 4 YEAR MACT COMPLETED
2 Year MACT:
- 2 standards promulgated (covering 6 source
categories)
4 Year MACT:
- 19 standards promulgated (covering 40
source categories)
7 YEAR MACT STANDARDS
(Status as of 10/10/98)
MACT Standards source Categories
Acrylic/Modacrylic Fibers IGMACT)
Tetrahydrobenzaldehyde
Chlorine Manufacturer
Chromium Chemicals Manufacturer
EAF: Stainless & Non-Stainless Steel 12)
Ferroalloys Production
Flexible Polyurethane Foam Production
Mineral Wool
Nylon 6 Production
Proposed
09/16/98
08/1 5/97
11/99
-
-
07/23/98
12/O9/96
04/29/97
-
Promulgate
(Projected)
05/1 5/99
05/01/98
11/2000
delisted 5/17/96
delisted 5/1 7/96
04/28/99
09/15/98
09/30/98
delisted
7 YEAR MACT (as of 10/10/98)
16 standards proposed (covering 25 source
categories)
5 standards promulgated (covering 5 source
categories
All will be promulgated by May 1 5, 1999
(hammer date) except for two which will be
completed by October 1999
7 YEAR MACT STANDARDS
(Status as of 10/1
MACT Standards Source Categories
Oil & Natural Gas Production
Pesticide Active Ingredient Production
Petroleum Refineries-Catalytic Cracking, Catalytic
Reforming & Sulfer Plant units
Pharmaceuticals Productions
Polycarbonates Production (GMACT)
Polyether Polvols Production
Aminot Phenolic III
Portland Cement Manufacturing
Publicly Owned Treatment Works (POTW)
0/98)
Proposed
11/24/97
10/27/97
08/25/98
03/20/97
09/16/98
08/1 5/97
09/30/98
03/O9/98
O8/O7/98
(CONT'D)
i
Promulgate
(Projected)
04/23/99
03/30/99
05/01/99
07/30/98
05/1 5/99 ;
02/14/99
05/1 5/99
05/1 7/99
05/01/99 Z^ZZ'
-------
7 YEAR MACT STANDARDS (CONT'D)
Status as of 10/10/98)
MACT standards Source Categories
Primary Aluminum
Primary Copper
Primary Lead Smelting
Pulp & Paper (non-combust) MACT I
Pulp & Paper Combustion MACT II
Pulp & Paper Inon-chem) MACT III
Reinforced Plastic Composites Production
Secondary Aluminum Production
Steel Pickling
Proposed
08/22/96
04/09/98
04/10/98
12/17/93
11/14/97
02/29/96
10/99
12/09/98
08/28/97
Promulgate
(Projected)
09/1 9/97
01/30/99
12/14/98
11/14/97
03/31/99
11/14/97
11/2000
03/29/99
12/17/98
2 YEAR MACT STANDARDS
. MACT STANDARD SOURCE CATEGORIES
Dry Cleaning
Commercial & Industrial
drycleaning
Hazardous Organic
NESHAPS (HON)
Promulgation Date
Compliance Dates
09/22/93
04/22/94
1 2/20/93
10/24/94
*See website http://www.epa.gov/ttn/uatw
7 YEAR MACT STANDARDS (CONT'D)
(As of 10/10/98)
MACT Standards Source Categones Proposed
Wood Treatment
Wool Fiberglass 02/25/97
Acetal Resins Production (GMACT) 10/98
Promulgate
(Projected)
delisted 5/17/96
06/98
05/99
4 YEAR MACT
i
STANDARDS i
Title Promulgation Compliance
Date Dates
Aerospace Industry 09/01/95 09/01/98
Asbestos (delisted) 11/30/95 11/30/95 ;
Chrome Electroplating 01/25/95 01/25/96 decor ;
01/25/97 others .
Coke Ovens 10/27/93 11/15/93
Commercial Sterilizers 12/06/94 12/06/97 j
Website: http://www.epa.gov/ttn/uatw
-------
4 YEAR MACT STANDARDS
Title
Degrease Organic
Cleaners (Halogenated)
Industrial Cooling
Towers
Magnetic Tape
Marine Vessels
Offsite Waste Treament
Promulgation
Date
1 2/02/94
09/08/94
12/15/94
09/19/95
07/01/96
(CONT'D)
Compliance
Dates
12/02/97
03/08/96
12/15/96
09/19/99
07/01/99
4 YEAR MACT STANDARDS (CONT'D)
Title Promulgation Compliance
Date Dates
POLYMERS & Resins II 03/08/95 03/03/98
Epoxy Resins Production
Non-Nylon Polamides Production
Polymers & Resins IV 09/12/96 03/12/97
Acrylonitrile-Butadiene-Styrene
MethytMethacrylate-Acrylorutrile
Methyl Methacrylate-Butadiene
Polystyrene
Styrene Acrylonitrile
Polyethylene Tetephthalate
|
"V,
4 YEAR MACT STANDARDS (CONT'D)
Title
Petroleum Refineries
Printing/Publishing
Polymers & Resins I
Butyl Rubber
Epichlorohydrin Elastomers
Ethylene Propylene Rubber
Hvpalon (TM) Production
Neoprene Production
Nitrile Butadiene Rubber
Polybutadiene Rubber
Polysuttide Rubber
Styrene-Butadiene Rubber & Latex
Promulgation
Date
08/18/95
05/30/96
09/05/96
Compliance
Dates
08/18/98
05/30/99
03/05/97
4 YEAR
Title
Secondary Lead
Smelters
Shipbuilding MACT
Stage 1 Gasoline
Distribution
Wood Furniture
MACT STANDARDS
Promulgation
Date
06/23/95
12/15/95
12/14/94
12/07/95
(CONT'D)
Compliance
Dates
06/23/97
12/16/97
12/15/97
11/21/97
-------
10 YEAR MACT
Have initiated work on majority of source
categories
Statutory deadline of 11/15/2000
Most standards are well underway
- Data has been gathered on majority of source
categories
-Analysis nearly complete for many
-Already working with stakeholders
OTHER PROJECTS:
Architectural/Industrial Manufacturing (AIM)
Consumer Products
Automobile Refinishing
SOCMI Wastewater NSPS
NOx NSPS Revisions
10-YEAR RULE CATEGORIES
Alumina Processing
Ammonium Suit ate
Asphalt Concrete
Asphalt Roofing & Processing
Asphalt/Coal Tar Application
Auto & Light Duty Truck (coating)
Baker's Yeast
Boat Manufacturing
Carbon Black
. Carbonvt Sulfide
Cellulose
Chlorine Production
Clay Products
Coke Ovens: pushing, quanching
Cyanide Chemicals
Dry Cleaning (petrol
Engine Test Facilities
Ethylene Processes
Rex Poly Foam Fabrication Oper
Friction Products
Fumed Silica Production
Hydrogen Chloride
Integrated Iron & Steel
Iron & Steel Foundries
Large Applicances
Leather Tanning & Finishing
Lime
Metal Can
Metal Coil
Metal Furniture
Misc Metal Parts
Municipal landfills
Misc Organic NESHAP
Non-Clay Refractories
Organic Liquid Distrib
Paint Stripping
Paper & Other Webs
Plastic Parts & Products
Plywood/Particle Board
Polyvinyt Chloride & Copolvmers
Primary Magnesium
Reinforced nasties
Rocket Engine Test Firing
Painting, Coating & Dying of Fabrics
Rubber Tire
Semiconductor
Industrial Boilers
Institutional/Commercial Boilers
Process Heaters
Internal Combustion Engines
Stationary Turbines
Sewage Sludge
Site Remediation
Spandex
Taconite Iron Ore
Uranium Hexaflouride
Vegetable Oil
. wood Building
112(c)(6) STANDARDS
- 7 Pollutants (Alkylated Lead Compounds,
POM, Hexachlorobenzene (HCB), Mercury,
PCBs (2,3,7,8-TCDD - Dixion), 2,3,7,8-TCDF
- Furans) combined as TEQ (Toxic Equivalents)
-Adds 2 new categories to MACT List
Open Burning of Scrap Tires
Gasoline Distribution Aviation Fuel
-Adds area sources for some categories
already addressed by MACT
-------
112(k) URBAN AREA SOURCE PROGRAM
- Draft Strategy Published - 09/14/98
- Final Strategy Required - 06/18/99
-Adds 34 new Area Source Categories
TURNING ATTENTION TO ADDITONAL
STANDARDS:
-112(c)(6) - 7 Pollutants
- 11 2(k) Urban Area Source program
- Residual Risk - MACT Categories
SUMMARY AND QUESTIONS
I
-------
- MACT Test Methods Rule Format
Jim Szykman
fc of Air o
*<8^=*Fsซ$ซ8.
'- ^,ปA
and
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT RULE DEVELOPMENT
(MACT Test Methods Rule Format)
James Szykman
-------
- MACT Monitoring For Compliance
Sally Mitoff
of Air
Source Testing 'in the New
Regulatory World Workshop
-------
Continuous Compliance Monitoring
for MACT
Structure of Current Regulations
Ideas for Future Standard Format
-------
Language in Current Regulations
Compliance Provisions - Monitoring to demonstrate
continuous compliance.
"...The monitoring required to demonstrate
continuous compliance with the emission
limitations is identified in this section..."
Monitoring requirements.
"...operate...within these parameters to ensure
continued compliance with the standard..."
Continuous Monitoring.
"...Operation...in a manner exceeding or going below
the operating parameter value...shall constitute a
violation of the emission standard..."
-------
Language in Current Regulations
Parameter Monitoring Levels and Excursions.
(1) Establishment of parameter monitoring levels.
"...operate control devices such that the
monitored parameters remain... [within the
range].. .established"
(2) Compliance determinations.
"The parameter monitoring data...shall be used
to determine compliance for the monitored
control or recovery devices."
Standards.
"...Operate...within parameters identified in the
initial performance test."
-------
Identify Different Types of CMS Data
I. CEMS * Direct Emission Measurement
II. CPMS * Direct / Strong Correlation
between
Operating Parameter and Emission Level
III. CPMS * Operating Parameter
Correlated with Emissions
-------
Standard Format
I. CEMS * Direct Emission Measurement
Standard = Emission Limit
Continuing Compliance with Standard
determined by CEMS
II. CPMS * Strong/Direct Correlation
Standard = Emission Limit
CPMS determines Continuing
Compliance with Emission Limit
III. CPMS * Correlated
Standard #1 = Emission Limit
Standard #2 = Operating Limit
CPMS determines Continuing
Compliance with Operating Limit
-------
Presentation 7
-------
-------
MACT Test Methods Review
Methods 306, 306A, & 306B for Chrome Plating
- FTIR Methods
Gene Riley
Rima Dishakjian
Source Testing in the New
Regulatory World Workshop
-------
- Methods 306, 306A, & 306B for Chrome Plating
Gene Riley
_ of Air ft.
<ฃ&&***ฃ&,
v*/;
v^nr^1
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
REVIEW OF CHROME PLATER EMISSION TEST METHODS
Peter Grohse, Research Triangle Institute; Gene Riley, USEPA
EPA Methods 306, 306A, and 306B along with the CARB Method 425 are designated in 40 CFR
Part 63 Subpart N - National Emission Standards for Chromium Emissions From Hard and
Decorative Chromium Electroplating and Chromium Anodizing Tanks as test methods that EPA
has approved for demonstrating source compliance.
EPA Methods 306, 306A, and 306B have recently been revised to incorporate the new
EPA/EMMC1 format that is required in codifying future analytical monitoring methods. While
revising EPA Methods 306 and 306A entitled, "Determination of Chromium Emissions from
Decorative and Hard Chromium Electro-plating and Chromium Anodizing Operations, sampling
and analytical guidance was added to clarify and update the technical procedures.
California Air Resources Board (CARB) Method 425 entitled "Determination of Total Chromium
in Hexavalent Chromium Emissions from Stationery Sources" that measures hexavalent and/or
total chromium was also modified recently by CARB.
The revised methods have been peer-reviewed by EPA analytical staff experienced in inorganic
chemistry and/or related procedures associated with the measurement of total and/or hexavalent
chromium (Cr+6). The primary objectives of the peer review were to (1) perform quality
assurance/ quality control (QA/QC) evaluations of EPA Methods 306 and CARB Method 425
analytical differences, defects, and similarities; (2) summarize the findings of the review; and (3)
provide detailed recommendations for corrections, modifications, and improvements.
This report provides a detailed summary of the evaluation as well as an overview of the
measurement techniques and specific differences that exist between the EPA 306 and CARB
425 methods. Comments and recommendations regarding the individual test methods are also
included.
EPA/EMMC - EPA/Environmental Monitoring Management Council
-------
MACT TEST METHODS
CHROMIUM EMISSIONS
Gene Riley, EMC, OAQPS
(919) 541-5239
Riley.Gene@EPA.GOV
CHROMIUM REGULATION
i40CFRPart63SubpartN
* Hard & Decorative Chromium Electroplating
ป Chromium Anodizing Tanks
REFORMATTING METHODS 306,
306A and 306B
Environmental Monitoring Management Council
(EMMC) Format
Methods Revised
ป Additional Guidance, Clarification, Detail
* Additional QA/QC Information
* EMMC Format
' Promulgation Expected: FY 99
ELECTROPLATING MACT
i Implementation Schedule
ป Promulgation January 1995
Compliance January 1997
* Extension July 1997
-------
CHROMIUM EMISSION TEST
METHODS
^Method 306
* Isokinetic Sampling
Method 306A
* Constant Sampling Rate / Proportional Time
' Applicability
* Total Chromium Emissions
* Hexavalent Chromium Emissions
METHODS 306, 306A, CARB 425
SAMPLE COLLECTION
Total Chromium Option
*On-Site Filtering - not required
*pH >8.5 NaOH / >8.0 NaHCOS - not required
Store / Ship @ 4 C - not required
Sample Holding Time - 60 days
CHROMIUM EMISSION TEST
METHODS CONT
California Air Resources Board Method (CARB
425)
> Applicability
* Total Chromium Emissions
* Hexavalent Chromium Emissions
METHODS 306, 306A, CARB 425
SAMPLE COLLECTION CONT
ป Hexavalent Chromium Option
*On-Site Filtering - not required
*pH >8.5 NaOH / >8.0 NaHCOS - check/verify
* Store / Ship @4C-yes
* Sample Holding Time - analyze within 14 days
-------
METHODS 306, 306A, GARB 425
Total Chromium Analyses Options
* Inductively Coupled Plasma Emission
Spectrometry (ICP)*
* Graphite Furnace Atomic Absorption
Spectrometry (GFAAS)
Hexavalent Chromium Option
* Ion Chromatography w/ Post Column Reaction
(IC/PCR)
ANALYTICAL CRITERIA CONT
GFAAS Analysis
* Measures Total Chromium Only
* Used to Measure Chromium Concentrations 1 ug
Cr/L to 35 ug Cr/L
* QA Highly Dependent Upon Analyst Skill
* Requires Sample Digestion
* Analysis Time ~ four minutes / sample
* Usually Requires Matrix Compensation
* Prone to Spectral/Background Interferences
ANALYTICAL CRITERIA
i ICP Analysis
ป Measures Total Chromium Only
* Used to Measure High Chromium Concentrations
>35 ug Cr/L
* Wide Range Linearity (5 orders magnitude)
* Reasonably Sensitive (~5 ug Cr/L)
* No Digestion Required
ป Rapid Analysis (two minutes / sample)
ป Associated Problems w/Alkaline Matrices
* Spectral and Background Interferences
ANALYTICAL CRITERIA CONT
1C / PCR Analysis
* Measures Trivalent / Hexavalent Chromium
* Can Measure Low Cr+6 Concentrations in Alkaline
Solution <0.05 ug Cr+6/L
ป Sample Filtration Maybe Required to Prevent
Plugging of Injection System
* Extremely Reliable for Cr+6
* No Sample Digestion
* Analysis Time >5 minutes / sample
ป No Significant Interferences
-------
ANALYTICAL QA / QC
DISCREPANCIES
Total Cr vrs Cr+6 Measurements (same sample)
Total Chromium Analysis
* Matrix Correction Compensation Error for ICP or
GFAAS
* Total Cr may be biased low (up to 15 %)
Cr+6 Analysis (IC/PCR)
ป Not Prone to Matrix Effect/Suppression
CHROMIUM SURFACE TENSION
METHOD
Method 306B
ป Surface Tension Measurements
Sources
* Decorative Chromium Plating Operations
* Chromium Anodizing Operations
ป Continuous Chromium Plating
METHODS 306 & 306AIN-STACK
SENSITIVITY
ปICP Analysis (Total Cr)
* 0.0014 to 0.0021 mg Cr/DSCM
GFAAS Analysis (Total Cr)
* 0.00029 mg Cr/DSCM
IC/PCR Analysis (Cr+6)
* 0.000015 mgCr+6/DSCM
METHOD 306B
SURFACE TENSION
Applicability
* Surface Tension Measurement of Chromium
Plating Tanks Using Fume Suppressants
ซ Measurement Devices
* Stalagmometer (produces higher reading)
*Tensiometer
* Other Approved Equivalent Methods
-------
METHOD 306B CONT
i Measurement Frequency (progressive system)
* Initial Startup to 40 Hours; once per 4 hours
*40 Hours to 80 Hours; once per 8 hours
*80 Hours to 1st Exceedence; once per 40 hours
* Exceedence; return to once per 4 hours
CONTINUOUS COMPLIANCE
MONITORING
> Specific to Type of Emission Control Device:
ป Composite Mesh-Pad System
* Packed-Bed Scrubber System
Packed-Bed Scrubber/Mesh-Pad System
ป Fiber-Bed Mist Eliminator
ป Other Approved Systems
METHOD 306B CONT
* Surface Tension Measurements
* Compliance Limit; 45 dynes per centimeter
ปAlternate Limit; value established during
Performance Test
CONTINUOUS COMPLIANCE
MONITORING CONT
Site-Specific Monitoring Parameters Established
During Performance Test
* Pressure Drop Across APC System; (ฑ 1 inch
water column of demonstrated pressure drop)
* Velocity Pressure at Common APC Inlet;
(ฑ 10 percent of demonstrated velocity pressure)
-------
REVIEW OF CHROME PLATER EMISSION TEST METHODS
Peter Grohse, Research Triangle Institute; Gene Riley, USEPA
1.0 INTRODUCTION
EPA Methods 306, 306A, and 306B along with the CARB Method 425 are designated in
40 CFR Part 63 Subpart N - National Emission Standards for Chromium Emissions From Hard
and Decorative Chromium Electroplating and Chromium Anodizing Tanks regulation as test
methods that EPA has approved for demonstrating source compliance.
EPA Methods 306, 306A, and 306B have recently been revised to incorporate the new
EPA/EMMC1 format that is required in codifying future analytical monitoring methods. While
revising EPA Method 306 entitled, "Determination of Chromium Emissions from Decorative and
Hard Chromium Electro-plating and Chromium Anodizing Operations - Isokinetic Method"
sampling and analytical guidance was added to clarify and update the technical procedures.
California Air Resources Board (CARB) Method 425 entitled "Determination of Total
Chromium in Hexavalent Chromium Emissions from Stationery Sources" that measures
hexavalent and/or total chromium was also modified recently by CARB.
The revised methods have been peer-reviewed by EPA analytical staff experienced in
inorganic chemistry and/or related procedures associated with the measurement of total and/or
hexavalent chromium (Cr+6). The primary objectives of the peer review were to (1) perform a
quality assurance/ quality control (QA/QC) review of EPA Method 306 and CARB Method 425
analytical differences, defects, and similarities; (2) summarize the findings of the review; and (3)
provide detailed recommendations for corrections, modifications, and improvements.
This report provides a detailed summary of the evaluation as well as an overview of the
measurement techniques and specific differences that exist between the EPA 306.and CARB
425 methods. Comments and recommendations regarding the individual test methods are also
summarized.
2.0 OVERVIEW OF MEASUREMENT METHODOLOGY
EPA Method 306 provides three (3) analytical techniques for the measurement of the
wide-range of chromium emissions found at hard chromium electro-plating and anodizing
sources. These techniques are inductively coupled plasma emission spectrometry (ICP),
graphite furnace atomic absorption spectrometry (GFAAS), and ion chromatography with post
-------
column reaction (IC/PCR). The ICP and GFAAS analytical methods are applicable for the
measurement of total chromium only. The IC/PCR analytical method is applicable for the
measurement of speciated (trivalent and hexavalent) chromium emissions.
CARS Method 425, allows the analyst to use either the GFAAS or IC/PCR technique but
does not provide for the use of the ICP technique. Instead, the analyst has, as an option, the
use of a manual colorimetric technique that uses the same color reaction as the IC/PCR
determination, but with significantly less sensitivity. However, EPA only allows the use of the
manual colorimetric approach with certain limitations.
Since it is expected that chromium emissions from the chrome plating sources will be
almost exclusively hexavalent chromium (Cr+6), the first two analytical methods are referenced
for the more routine analytical measurements. In the event that chromium speciation is
required, IC/PCR is provided for determination of hexavalent chromium. Relative strengths and
weaknesses for the three referenced techniques are discussed in the following sections.
2.1 Inductively Coupled Plasma Emission Spectrometry (ICP)
Inductively coupled plasma emission spectrometry is a single or multi-element emission
technique that has become routine over the last fifteen years. The method has a wide range of
linearity (up to 5 orders of magnitude) and is reasonably sensitive; a chromium detection limit of
<5 ^g Cr/L to 30 ^g Cr/L can usually be obtained, depending on the emission source. EPA has
designated that this technique be used to measure only high chromium concentrations >35 ^g
Cr/L when demonstrating compliance . The ICP determination is probably the most rapid of the
three techniques, allowing the analyst to perform a sample measurement in about two minutes.
The method is especially rapid since no sample preparation (digestion) is required.
The most recent improvements include the use of an "axial" torch which provides
approximately a tenfold improvement in sensitivity over the more traditional radial torch design.
With the axial design, the analytical signal for the chromium is enhanced, however, the analytical
signals for the interfering species are similarly enhanced. For the difficult sample matrix (high
dissolved solids) associated with the Method 306 alkaline medium, this may present as many
difficulties as advantages. ICP techniques possess a number of interferences that are worthy of
note:
Spectral interferences due to iron, manganese, and uranium are possible. Generally
speaking, these interferences can be corrected through the use of an alternate wavelength or by
automated interfering element corrections provided by the instrument software. If it can be
-------
verified that these species do not exist at significant concentrations in the sample, it is
suggested that these correction techniques not be used since they tend to result in some
degradation of the detection limit.
Background interference due to a matrix mismatch between samples and standards may
be encountered and corrected. However, the background interference correction may not be
needed since the method requires that a alkaline sampling medium be used in the calibration
standard preparation. For these alkaline samples, perhaps the most significant interferences
are physical, which can be attributed to a high dissolved solids content in the sample. There
tends to be an accumulation of solid material from the alkaline salt at the end of the plasma
torch (axial or radial) which severely compromises the analytical results, as well as greatly
decreases the lifetime of the torch. Sophisticated ICP sample introduction techniques such as
the ultrasonic nebulizer are not recommended since they concentrate the high solids matrix in
addition to concentrating the Cr analyte prior to injection into the plasma.
2.2 Graphite Furnace Atomic Absorption Spectrometry (GFAAS)
This technique allows the analyst to accurately determine Cr concentrations in the
impinger samples that are <35 /^g Cr/mL This technique has been used reliably for more than
20 years by analytical laboratories. Chromium concentrations that are <1 ppb^ug/L) can be
detected with this technique. Quality measurements are, however, highly dependent on the skill
of the analyst, although less so with the improved furnace designs and computer controls
provided with instrumentation during the last 15 years. The GFAAS technique is not ideally
suited to the 306 and 425 Methods' alkaline samples, but with reasonable care, quality data can
be obtained. The GFAAS technique is not as rapid as the ICP procedure; with analysis times
ranging up to four minutes.
The sample is digested in nitric acid (HNO3) prior to measurement and sample intensity
is compared to that of calibration standards prepared in HNO3. This is the only procedure of the
three techniques that requires a significant sample preparation operation. In normal laboratory
operation, the calibration standards do not contain the alkaline reagent. Therefore, the signal of
the sample may be suppressed with respect to that of the less complex standard matrix, thereby
requiring the need for some type of matrix compensation technique. This may be accomplished
by (1) adjusting the furnace conditions; (2) adding alkaline reagent to the standards to match the
matrix of the sample; or (3) resorting to the method of standard additions (MSA). Frequently the
first approach is all that is required. Also graphite furnace tubes differ considerably in quality
which tends to affect both the instrument performance as well as the analytical strategy
-------
employed with the matrix correction issues.
GFAAS is particularly prone to spectral interferences due to smoke resulting from the
dissolved solids in the sample. Due to the severity of the sample matrix, a background
correction system may be necessary, such as the Zeeman correction system. Many
instruments manufactured within the last fifteen years apply this technique automatically for
sample measurements. Another acceptable system uses the Smith-Hieftje correction. Methods
that employed the Deuterium background correction are generally not considered effective in
this analytical application.
Dedicated GFAAS instrumentation produced in the last 15 years are normally equipped
with autosampling features. Sample volumes ranging from <5,uL to 50yuL and sometimes up to
100>L are pipetted accurately and with excellent precision. This repetition is essential to quality
GFAAS measurements. Early techniques requiring manual sample pipetting into the furnace
were greatly dependent on the technique of the analyst. Consequently, duplicate injections were
required for reliable results. This is no longer the case with current autosampling systems.
The alkaline medium encountered during these measurements produces considerable
degradation of the graphite parts resulting in much shorter graphite tube and contact ring
lifetime; 10%-30% of normal duration. It is for this reason that matrix matching of the standards
with samples should be a last resort since this will result in additional analyses of solutions
containing highly dissolved solids.
2.3 Ion Chromatography with Post Column Reaction (IC/PCR)
This technique is probably the most sensitive of the three instrumental methods and is
certainly the most specific with respect to hexavalent chromium measurements. Current
instrumentation allows the chemist to detect Cr+6 levels of <0.05 /^g/L in the alkaline solution.
Early approaches employed the use of a pre-concentrator column packed with the same ion
exchange resin used in the analytical column. With improved detector design and superior
materials of construction (Teflon instead of stainless steel), detection limits have dropped
significantly and the need for the pre-concentration approach is only required with older
instrumentation. While no significant sample preparation is required for this technique, filtration
of the sample may be necessary to prevent clogging of the sample injection system. The actual
measurement time for each sample is probably the longest for the three methods - greater than
5 minutes per sample.
IC/PCR is an extremely reliable technique for the determination of the hexavalent Cr
species in the presence of the trivalent form of Cr (Cr*3). The technique has, for all practical
-------
purposes, no significant interferences. The hexavalent chromium ion is isolated on the analytical
column and further specificity is provided through the reaction of the Cr+6 ion with the color
agent, diphenycarbazide. The colorimetric measurement is made at the 540 nm wavelength.
The likelihood of a species both co-eluting with the Cr+6 ion and reacting to form a sensitive color
complex at the 540 nm wavelength is remote.
This method is perhaps more robust than ICP or GFAAS in handling the alkaline medium
and does not experience the hardware deterioration to which the previously described methods
are prone.
Early systems did require some skills in assembly of the analytical system. "Homemade"
systems can now be constructed from HPLC pumps, a sampling valve, and an analytical
column, with the only major purchase being the spectrophotometer (colorimeter) detector. Such
systems can cost <$10,000. Complete systems, however, are now available commercially that
include an autosampler, the analytical system and a data acquisition system.
3.0 QUALITY CONTROL AND QUALITY ASSURANCE CONSIDERATIONS
Quality control activities differ slightly between the measurement methods, not so much
due to the instrumentation but rather due to the sample preparation techniques that precede the
measurement. Methods 306 and 425 address, to varying degrees, accuracy and precision
issues for all the measurement techniques. Quality control requirements for each method and
measurement technique are indicated in Table 1. Included in Table 1 are QA/QC criteria for the
original Method 306 and for the revised Method 306.
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Table 1. Quality Control Acceptance Criteria USEPA Method 306a and CARB Method 425
QC Activity
No. Calibration Stds
Linearity"'6
Calib. Ref. Std.
Calibration Blank
Contin. Check Std.f
Contin. Check Blk.
Field Reagent Blk.
Spikes (Meas.)
Spikes (Prep)
Duplicate Injections
Duplicates (Prep.)
Post Run Calibr.?
(No.ofStds)
ICP Spectrometry
M306
3+blk
ฑ7%
ฑ10%
<3XDL
ฑ10%
<3XDL
<3XDL
ฑ10%
ฑ10%
No
M306b
3+blk
r>0.999
ฑ10%
<3XDL
ฑ10%
<3XDL
<3XDL
ฑ10%
ฑ10%
No
GFAA Spectrometry
M306
3+blk
ฑ7%
ฑ10%
<3XDL
ฑ10%
<3XDL
<3XDL
+25%
ฑ10%
No
M306b
3+blk
r>0.999
ฑ10%
<3XDL
ฑ10%
<3XDL
<3XDL
ฑ10%
+25%
+20%
No
M425
c
g
Ion Chromatography/PCR
M306
3+blk
ฑ7%
+5%
<3XDL
ฑ10%
<3XDL
<3XDL
ฑ5%
ฑ5%
3Std +
Blk1
M306b
3+blk
r^O.999
ฑ10%
<3XDL
ฑ10%
<3XDL
<3XDL
+10%
+10%
3Std +
Blkh
M425
4-6 +blk
ฑ10%
ฑ5%
4-6 Std
+ Blkj
a. Method 306
b. Recommended Revisions
c. No acceptance criteria listed
d. Agreement of measured with expected for each calibration point
e. r = correlation coefficient derived from regression equation
f. Frequency every 10 samples unless noted otherwise
g. Frequency every 15 samples
h. ฑ10% agreement with original calibration curve
i. ฑ5% agreement with original calibration curve
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3.1 Analytical Accuracy
Method accuracy is assessed through the use of spikes and standard reference
materials (SRMs). Analytical accuracy is assessed for both the measurement phase and for the
overall analytical method. In this way, the analyst can pinpoint the source of any potential errors.
Accuracy is expressed as percent of recovery based on "True" or expected value. In the case of
the ICP or IC/PCR techniques, measurement recovery and overall method recovery are
essentially one and the same, since there is no sample digestion procedure employed. For
GFAAS there is a distinct sample digestion step involved and recovery values will reflect errors
in both the digestion and the analytical measurement steps. In addition, it is critical that the
accuracy of the calibration standards be established immediately following the calibration
procedure (prior to measurement of field samples). The analytical measurement accuracy is
assessed through the use of spikes that are added to the sample immediately prior to its
measurement. Poor recoveries indicate that species/substances within the sample matrix are
interfering with the excitation process of the chromium species in the plasma. Common ways to
compensate for this effect is through one or more of the following approaches:
1) optimization of instrument conditions
2) matrix-matching of standards with samples (not always possible)
3) implementation of a Method of Standard Additions (MSA) technique
4) addition of an internal standard to samples and standards
The latter approach is not particularly feasible with the GFAAS and IC/PCR techniques
but could be used with the ICP determination. This approach requires extensive knowledge of
the spectroscopy operation and should not be considered routine laboratory operation. Method
306 notes the use of the first three approaches for ICP measurements. Standards (calibration
and QC) should be prepared in the alkaline reagent of choice and matrix interferences should
therefore be minimal.
Methods 306 and 425 address GFAAS calibration in essentially the same manner, that is,
strict matrix matching is not necessarily required. Standards and digested samples both contain
1 percent HNO3 but only the field samples contain the alkaline reagent. It is implied that careful
adjustment of instrument conditions will compensate for matrix differences. While this is true in
many cases, matrix compensation can be dependent on the quality of the particular lot of
graphite parts in the furnace. Both methods refer to the option of the MSA approach for matrix
compensation..
-------
Some laboratories have reported discrepancies between Method 306 for total Cr and
hexavalent Cr measurements for the same source sample. This is quite possible if matrix
corrections for the total Cr determination by either ICP or GFAAS are not carefully performed.
While the total Cr determination can be within Method 306 specifications, the total Cr result may
still be biased low with respect to the Cr+6 result by as much as 15 percent since Cr+6
determinations using IC/PCR are not particularly prone to matrix effect/suppression. The same
phenomenon can occur with GFAAS total Cr determinations.
The source solution used to prepare the calibration standards as well as the accuracy of
the preparation procedure itself should be assessed through the use of calibration reference
standards (also known as Initial Calibration Verification {ICV} standards in many reference
methods). This solution must be prepared from an entirely different source (commercial or
otherwise) and is analyzed immediately following the calibration. Usually, either 5 percent or 10
percent agreement with expected values are considered acceptable. This approach should be
used for all analytical techniques.
On a related topic, accuracy can be compromised if there is instrumental drift over the
course of the analysis. Drift may be assessed by analyzing a standard or sample of known
concentration at specific intervals during a sample analysis run. Normally, the drift may be
considered excessive if the measured value of the standard used differs from the expected
value by more than 10 percent. Drift check standards are also known as Continuing Calibration
Verification (CCV) standards.
Accuracy can be affected if there is a drift in the "zero" point of the calibration curve.
This usually is caused by some contamination in the calibration blank and is assessed
immediately following calibration (otherwise known as the Initial Calibration Blank or ICB) as well
as throughout the analysis run (otherwise known as the Continuing Calibration Blank). In
addition, proper adjustment of sample "washout" times between samples may be verified
through the periodic analysis of the calibration blank.
3.2 Analytical Precision
As with accuracy, both measurement and overall method precision must be determined.
Measurement precision is determined through the use of replicate injections of the sample
solution. Overall analytical method precision is determined by processing two portions of the
sample through the entire laboratory (preparation and analysis) procedure. It is expected that
the overall method position will require a wider acceptance criteria since it involves several
additional steps, each of which contribute a certain error to the determination.
-------
The ICP and IC/PCR techniques require duplicate "injections" of the same sample since
no sample preparation technique is required. Unlike the other methods, duplicate digestions of
the same sample are performed when using the GFAAS determination. Both Method 306 and
CARB 425 are consistent on these QC requirements.
3.3 Interference Checks
Interference checks are used primarily with the ICP measurement. A variety of spectral
interferences due to interfering elements are possible with this technique. This phenomenon
may be assessed through the analysis of known standards containing the expected interfering
element(s) and measuring the "false" analyte (Cr) signal attributable to the interfering element.
The interference may be corrected by implementing the instrument software.
Interferences exist for the other techniques also. Normally, spectral interferences are
encountered with GFAAS but are usually corrected with the instrumental background correction
systems.
With IC/PCR, a co-eluting species could theoretically complex with the diphenylcarbazide
reagent causing a chromatographic interference but this likelihood is small. Occasionally peaks
may appear in the vicinity of the chromate peak that are of uncertain identity. The analyst must
then re-inject the sample that has been spiked with additional Cr. If the combined peak is of a
satisfactory shape (no doublets, etc.) then the original peak may be assumed to be Cr and the
system may be undergoing drift which would require a subsequent corrective action. If,
however, multiple peaks are observed, and clearly resolved, and the proper retention time is
observed for the Cr spike, then the system is considered to be operating properly.
3.4 Calibration and Linearity
Both Method 306 and CARB 425 specify a minimum of three (3) calibration standards
and a calibration blank for all of the approved analytical techniques. Method 425 actually
requires 4 to 6 standards and a blank for the IC/PCR technique. This method does not,
however, specify the number of standards for the GFAAS measurement. Acceptance for
linearity is usually expressed in terms of a linear regression expression of the calibration curve
but there is no mention of this in either Method. Method 306 does address linearity issues by
specifying a percent agreement of the measured standard with the expected value. The revised
Method 306 does specify a correlation coefficient "r" criteria for linearity acceptance.
3.5 Analytical Detection Limits (Limit of Detection - LOD)
-------
Analytical detection limits are ordinarily determined through the measurement of replicate
aliquots of a sample or standard with an analyte concentration near the expected LOD.
Replicate measurements of a laboratory or field blank are also accepted by some agencies. For
samples containing a difficult matrix, it is important that a low concentrated solution contain a
representative amount of the matrix solution. It is also critical that all applicable
digestion/extraction steps be implemented in the preparation of each LOD replicate. For
example, each replicate would require a separate digestion for the GFAA determination of total
Cr.
4.0 COMPARISON OF EPA METHOD 306 AND CARB METHOD 425 MEASUREMENT
METHODS
While both methods approve the use of the GFAAS and IC/PCR techniques, they differ
in the techniques used for measuring higher concentrations of Cr emissions (>35 /ug Cr/L).
Method 306 specifies the ICP technique, and assumes that the hexavalent Cr species are the
predominant form of Cr being emitted from the chrome plating facilities.
Method 425 is designated for a less specific application, namely, any stationary source.
Therefore, CARB approves the use of a classical manual colorimetric technique, which provides
a reasonable measure of compound specificity. This latter technique, incidentally, is
considerably more prone to interferences from other chemical species than the IC/PCR
technique.
While the Methods are similar in their treatment of the measurement techniques, there
are some differences in their approach to the quality control / quality assurance issues. These
are outlined in Table 1. Method 306 provides significantly more QA/QC acceptance criteria for
the analytical data than does Method 425. Although the GFAAS QC procedures are covered in
some detail in Method 425, no QC acceptance criteria are provided. Greater detail is provided
for the IC/PCR measurement, but still is far less than that described in Method 306.
Method 425 provides the analyst with a detailed detection limit calculation (3.4.1) that is
consistent with the overall approach to the "Pre-Test Protocol" designed to ensure that a
sufficient sample volume is collected. However, the calculations are based on what appears to
be a faulty premise. The method describes a calculation based on the standard deviation of the
mean of at least four replicates of a standard concentration near the mid-point of the curve
(Section 3.4.1). The method should have specified a calibration curve constructed near the
lower end of the calibration curve, not the curve used for actual field sample analysis.
Alternatively, CARB could have specified the analysis of a low standard/sample (one that is
-------
approximately 5-10 times the expected LOD) and changed the term smid to read s,ovtf. In a
contradictory statement, however, Method 425 also mentions the use of at least four "lab blanks"
for the determination of the LOD (Section 17.1.1). Method 306 quotes LODs from SW-846
measurement methods without specifying calculations/procedures. An attempt has been made
to clarify this issue in the Method 306 revision.
In the revised version of Method 306, an attempt has been made to provide criteria for all
of the QC operations. In addition, a brief reference to the detection limit calculation is provided.
5.0 SUMMARY
In this evaluation, a comparison of QA/QC issues covered in the USEPA Method 306
and CARB Method 425 was conducted. As a result of this comparison, revisions were made to
Method 306 in an attempt to clarify a clear set of QC data acceptance criteria. In some cases
this involved "relaxing" certain data quality requirements and activities in order to make them
somewhat more consistent with other EPA reference methods. Also, in some cases, QC criteria
were provided where none had previously existed. The linearity acceptance was changed to
reflect a "traditional" approach that acknowledges differences in accuracy as one approaches
the detection limit. Finally, a number of changes were made to the method that reflect more
current, updated methodology for all three of the techniques - ICP, GFAAS, and IC/PCR.
This report attempts to summarize issues related to the techniques themselves,
including advances in recent years and data quality issues that are specific to each particular
measurement approach.
Environmental Monitoring Management Council (EMMC)
-------
- FTIR Methods
Rima Dishakjian
of Air
and
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
FTIR METHODS
Rim a Dishakjian
The Emission Measurement Center (EMC), in response to the requirements in Title III of the Clean
Air Act Amendments of 1990, has been utilizing extractive Fourier Transform Infrared Spectroscopy
(FTIR) for data gathering and compliance purposes. The FTIR technique is useful as a screening tool
for sources where the emissions are relatively unknown, in that FTIR can identify more than 100 of
the 189 Hazardous Air Pollutants (HAPs) listed in Title III. The technique is useful since it can
simultaneously analyze for multiple compounds. The EMC has developed this technique and has
utilized it to gather data and to determine compliance in several Maximum Achievable Control
Technology (MACT) standards. Two FTIR techniques, a generic test method and Performance
Specifications for FTIR as CEMS, have been proposed. These two techniques are self-validating,
in that they can be used at any source category as long as the validation requirements in the methods
are met.
-------
EXTRACTIVE FTIR
TEST METHODS
(STACKS)
COMPLIANCE
CONTINUOUS MONITORNG
WHAT IS FTIR?
FOURIER TRANSFORM INFRARED
SPECTROSCOPY
DETECTS COMPOUNDS WHICH
ABSORB IN THE INFRARED REGION
CAN DETECT -104 HAZARDOUS AIR
POLLUTANTS (HAPs)
EACH COMPOUND HAS UNIQUE
SIGNATURE (ID UNKNOWNS)
EXTRACTIVE FTIR
PROJECTS
METHOD 320 - GENERIC FTIR TEST
METHOD
PS-15 GENERIC PERFORMANCE
SPECIFICATIONS FOR FTIR CEMs
METHOD 318 PROPOSED WITH
MINERAL WOOL MACT
FTIR PROTOCOL AVAILABLE SINCE
FALL 94
WHAT IS FTIR
(CONT'D)?
CAN MEASURE MULTIPLE
COMPOUNDS SIMULTANEOUSLY
DATA CAN BE STORED AND
REANALYZED IN THE FUTURE
EXTRACTIVE FTIR: EXTRACT SLIP OF
STACK GAS, SAMPLE CONDITION
(OPT), ANALYZE IN GAS CELL
-------
TEST METHOD 320
PROPOSED TEST METHOD 320, 40
CFR PART 63, APPENDIX A
TO BE PROMULGATED WITH CEMENT
MACT
CAN BE APPLIED TO ANY SOURCE
CATEGORY
SCREENING OPTION
' USED WHEN SOURCE HAS NOT BEEN
CHARACTERIZED
USE SEVERAL SAMPLING SYSTEMS
(HOT/WET, DILUTION, CONDENSOR)
' SCREEN FOR COMPOUNDS IN
SPECTRAL LIBRARY (FOR HAPs)
' WILL MAINLY BE USED FOR MAJOR
SOURCE DETERMINATION
METHOD 320 SUMMARY
SCREENING OPTION
VALIDATION REQUIREMENT
SELF-VALIDATION REQUIREMENT
VALIDATION SECTION
MUST BE DONE FOR EACH NEW
SOURCE CATEGORY
METHOD 301-TYPE VALIDATION
DYNAMIC SPIKING WITH SINGLE
OR DUAL FTIR INSTRUMENT
-------
SELF-VALIDATING
SECTION
' ROUTINE QA PROCEDURE FOR
SIMILAR SOURCES
SPIKING OF 1-2 TARGET COMPOUNDS
CHOOSE TOUGHEST COMPOUND(S)
TO SAMPLE
MUST SHOW GOOD RECOVERY
(70-130 PERCENT)
OTHER FTIR METHODS
FTIR PROTOCOL - PROCEDURE FOR
PREPARING SPECTRA, ANALYZING
SAMPLES, ETC
METHOD 318 - SPECIFIC TO MINERAL
WOOL AND WOOL FIBERGLASS
SOURCES
METHOD 321 - HCL METHOD SPECIFIC
TO CEMENT FACILITIES
PERFORMANCE
SPECIFICATION 15
PS 15, 40 CFR PART 60, APPENDIX B
PROPOSED IN METHODS COMPILATION
PACKAGE
PROMULGATION FALL 98
NOT SOURCE-SPECIFIC
ALLOWS SEVERAL OPTIONS FOR
CERTIFICATION: SPIKING WITH SINGLE
ANALYZER, COMPARING 2 ANALYZERS,
COMPARISON TO REFERENCE METHOD
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Presentation 8
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8
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Approval of Alternative Test Methods
and Monitoring
- Alternative Methods Policy and
Approval Process
- Examples of Recent Alternative Approvals
- Method 301 Revisions, Guidance
- Method Precision Evaluation (PQL)
- Environmental Technology Verification
Robin Sega//
Terry Harrison
Gary McAlister
Robert Fuerst
Source Testing in the New
Regulatory World Workshop
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Alternative Methods Policy and
Approval Process
Robin Sega//
of Air
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
Approval of Alternative Test Methods and Monitoring
Robin R. Segall
This presentation will provide background as well as the latest Agency policy and procedures
regarding approval of alternatives to Federally-required test methods and monitoring. In
particular, it will address the latest policy on delegation of the authority to approve test methods
and monitoring to state and local agencies, procedures for requesting alternatives, criteria for
approving alternatives, and identification of resources for review of approvals made in the past.
The presentation will also discuss the interface of alternative method/monitoring approval process
with the Performance Based Measurement System, Title V permitting, the Environmental
Technology Verification Program, and approval state air toxics rules and methods under Part 63,
Subpart E.
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Approval of Alternative
Test Methods and
Monitoring
Background, continued
Four presentations in this session address various
aspects related to approval of alternatives
Policy and process - Robin Segall
* Examples of recent approvals - Terry Harrison
Update on Method 301 - Gary McAlister
Environmental Technology Verification Project - Bob
Fuerst
Background
"Federal air regulations typically specify
performance test methods and
monitoring
"Specific sources, or sometimes a certain
segment of the regulated industry, need
or want to use alternatives to the
required test methods or monitoring
Presentation Overview
'Regulations and policies governing authority for
approval and delegation of that authority
Approval process
"Criteria for approval
Related processes
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Relevant Regulations
Part 60 NSPS
'Part 61 NESHAP
Part 63 NESHAP for Source Categories
Part 51 SIP Requirements
Test Method vs. Monitoring
"Section 63.2 defines a test method as a
"validated procedure for sampling, preparing,
and analyzing for air pollutant specified in a
relevant standard as the performance test
procedure."
"In some cases, such as Subpart Da of Part 60,
the performance test method is a continuous
monitoring procedure.
Relevant Regulations, continued
Sections 60.8(b), 6U3(h), and 63.7(f) of the General
Provisions to these parts codify the Administrator's
authority to approve alternative test methods
Sections 60.13(1), 61.14(g), and 63.8(f) of the General
Provisions codify the Administrator's authority to
approve alternative monitoring
Section 51.212 of Part 51 codifies the Administrator's
authority to approve alternative test methods for SIPs
Delegation Policy
"Administrator's authority is delegated internally
(w/in EPA) according to the Delegations Manual
(Delegations 7-1 19 and 7-121)
"Policy regarding delegation to states is handled
through policy memos
Latest policy in 7/10/98 memo from John Seitz
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Major, Intermediate, and Minor
Changes to Test Methods
'Minor Alternative or Change
> Site-specific
No effect on stringency of standard
No national significance
* Made to accommodate site-specific constraints
Major, Intermediate, and Minor
Changes to Test Methods, continued
"Major Alternative or Change
Modification involves unproven technology
and/or is an entirely new method
May be site-specific, but will usually set a
national precedent
Major, Intermediate, and Minor
Changes to Test Methods, continued
"Intermediate Alternative or Change (New
Category)
> Modification involves proven technology
* Site-specific, but could have national significance
- Has potential to decrease stringency of
applicable standard
Existing Internal Delegations
Test Methods Monitoring
Major
Changes
Minor
Changes
OAQPS
Regions
Regions
Regions
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Plan for Internal Delegations
Major
Changes
Intermediate
Changes
Minor
Changes
Test Methods Monitoring
OAQPS
Regions
Regions
Regions
Regions
Regions
Conditions of New Part 63 Policy
on Delegation to States
"Delegation is at discretion of Region
"Delegated authority (Region or State)
must provide OAQPS Emission
Measurement Center with copies of all
approved intermediate changes to test
methods or monitoring
New Policy on Delegation to
States for Part 63
Major
Changes
Intermediate
Changes
Minor
Changes
Test Methods Monitoring
No
Yes
Yes
No
Yes
Yes
Other Conditions of Delegations
"States must report minor changes to
Regions
'Delegated authority (State or Region)
should report monitoring changes to
OECA for inclusion in Applicability
Determination Index (ADI)
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Alternative Test Method/
Monitoring Approval Process
"Major and Intermediate Changes
I. Determination of delegated authority
2. Letter request (including supporting
information) to delegated authority with copies
to appropriate organizations (state, Region)
3. Acknowledgment of request (EMC now sends a
. letter). . . . .
Alternative Test Method/
Monitoring Approval Process,
continued
Minor Changes
I. Determination of delegated authority
2. Request to delegated authority via letter, site-specific
test plan, or verbally (during a test)
3. Consideration of request
4. Change approved via official letter or approval of test
report in^ which change is documented
Alternative Test Method/
Monitoring Approval Process,
continued
'Major and Intermediate Changes, continued
4. Review of request
5. EMC request for additional supporting
information (optional)
6. Official letter of approval/disapproval with
applicability constraints
Publication of Alternatives'
Test method alternatives with wide applicability are currently
published w/ methods on EMC home page at
http://www.epa.gov/ttn/emc/tmethods.html
OAQPS may also promulgate alternatives with wide applicability in
FR
Monitoring alternatives are published in the Applicability
Determination Index (ADI) maintained by OECA at
http://l 34.67.104.12/cfdocs/adiwww/adiwww.html-ssi
If resources allow, EMC plans to compile database of intermediate
alternatives to test methods and monitoring
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Criteria for Approval
' Change in test method or monitoring must
provide a determination of compliance at same
or higher stringency as the method or
monitoring specified in the applicable regulation
(2/26/93 Memo from Gil Wood)
"Section 63.7(f) requires that major and
intermediate alternatives to test methods be
validated according to Method 301
Alternatives to SIP Methods and
Monitoring
"Appears that the authority to approve
alternatives to SIP test methods and monitoring
requirements has been delegated to the
Regional Administrators along with the
authority to approve/disapprove SIP (Delegation
7-10)
'Process and approval criteria should be similar
to that for Parts 60, 61, and 63
Criteria for Approval, continued
'Examples of approvable alternative monitoring
are included in Sections 60.13(1), 6l.l4(g), and
63.8(f)
New approvals should be consistent with prior
approvals (ADI, EMC home page)
Interface with Related Processes
PBMS - Where PBMS applies, approval of
alternatives will be unnecessary
'Part 63, Subpart E - State test methods are
approved as part of the substitute rules with
which they are associated, not typically as an
alternative method
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Interface with Related Processes,
continued
Title V Permitting - Part 60, 61, 63, and 51
approval processes will still apply; the upcoming
Part 70 rulemaking will address type of permit
revision triggered by an alternative method or
monitoring approval
ETV - Is not an "approval" mechanism, but will
generate information that will be invaluable to
the approval process
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-ป\iปป "ซV
y '*_
~: UNITED STATES ENVIRON .tENTAL PROTECTION AGENCY
5 RESEARCH TRIANGLE PARK. NC 27711
AID QUALITY PLANNING
. _ AND STANDARDS
10 1998
frTEMORANDUM
SUBJECT: Delegation of 40 CFR Part 63 General Provisions Authorities to State and Local
Air Pollution Control AjenciซORICJNj4L SJCNED
BY
FROM: John S. Seitz, Director JOHN S. SEITZ
Office of Air Quality Planning and Standards (MD-10)
TO: See Addressees
This memorandum is to provide guidance to the EPA Region"! Offices on delegation of
discretionary authorities relating to air toxics in 40 CFR part 63, subpart A (the General
Provisions) to State and Local Air Pollution Control (S/L) agencies through 40 CFR pan 63,
subpart E (Approval of State Programs). Under the General Provisions, the EPA Administrator
has the authority to approve certain changes to, or make decisions under, specific General
Provisions requirements. Questions have been raised by the Regions about whether S/L agencies
may nake the same discretionary decisions when they are delegated the General Provisions.
In explaining the straight delegation process for delegating air toxics provisions to S/L
agencies under 40 CFR part 63, subpart E, we did not clarify what discretionary authorities are
delegated to S/L agencies when they seek straight delegation of the General Provisions.
Although this is briefly discussed in the proposed General Provisions' preamble (Federal
Register. August 11,1993, page 42775-42777), the forthcoming proposed subpart E revisions
will fill that gap by clarifying which discretionary authorities may bซi delegated to S/L agencies
through straight delegation of the General Provisions. At your discretion, the Regional Offices
must then specify in delegation agreements or documents which of the subpart A authorities are
being delegated to each State. We recommend that you begin implementing these changes as
soon as possible. Therefore, this memorandum is intended to explain the changes and provide
guidance for you to begin implementing the changes now. Neither this memorandum nor the
subpart E rulemaking changes any source-specific decisions that have already bften made under
the General Provisions, but the guidance in this memorandum should be used as guidance for ill
future decisions regarding the General Provisions* authorities.
To implement these changes, you will need to clarify vith your S/I. *,-*encies which
General Provisions' authorities have and have not been delegated. In cases when*, you may have
delegcted authorities in the past that should no longer be delegated, yoj will neeti to inform your
S/L -^encies that delegation of th;*e authorities Trill be revoked.
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At this time, we are also providing clarification of section 63.60X1), "Extension of
Compliance with Emission Standards," General Provisions authority. This section states "(u)ntil
an extension of compliance has been granted py the Administrator (or t State with an approved
permit program) under this paragraph, the'owner or operator of an affected source subject to the
requirements of this section shall comply with all applicable requirements of this part" It is our
interpretation that this authority does not require delegation through subpart E and, instead, is
automatically granted to States as part of their part 70 operating permits program approval
regardless of whether the operating permits program approval is interim or final. Additionally, it
is our interpretation that the State would not need to have been delegated a particular source
category or have issued a part 70 operating permit for a particular source to grant that source a
compliance extension.
We are also providing clarification of section 63.5(e) and (f), "Approval and Disapproval
of Construction and Reconstruction,** General Provisions authority. The Clean Air Act as
amended (1990 Amendments), sections 112(iKl) and (3) state that the "Administrator (or a State
with a permit program approved under title V)n can determine whether a source will comply with
the standard if constructed properly. It is our interpretation that this authority does not require
delegation through subpart E and, instead, is automatically granted to States as part of their
part 70 operating permits program approval
Link to section 1120): This guidance only addresses the case where the General
Provisions are delegated to an S/L agency through straight delegation under section 112(1)
provisions which were promulgated in 40 CFR part 63, subpart E. Therefore, the guidance
addresses S/L agencies* authority to make source-specific decisions only, not source-category
wide decisions. Any S/L agency wishing to make discretionary decisions on a source-category
wide basis under the General Provisions or any other part 63 requirement would need to use the
section 112(1) delegation process under 40 CFR pan 63, subsections 63.92,63.93, or 63.94 to
substitute its own rule or program. When subpart E revisions are promulgated, section 63.97 will
be added to the above list as a delegation option.
*
Consistency with Previous Policies: This guidance is intended to be consistent with
previous policies developed for new source performance standards (NSPS) under 40 CFR
part 60,' national emission standards for hazardous air pollutants (NESHAP) under 40 CFR
'See, for example, February 24,1983 Memorandum on Delegation of New Source
Performance Standards Authority to States, from Jack Farmer, Acting Director, Emission
Standards and Engineering Division, OAQPS, to Allyn Davis, Director, Air and Waste
Management Division, Region VI; and March 24,1982 Memorandum on Delegation of
Authority to States: NESHAPS, from Kathleen M. Bennett, Assistant Administrator for Air,
Noise and Radiation to Regional Administrators, Regions I-X.
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part 61, and for changes to State implementation plans (SIP's).2 Past guidance issued for NSPS
changes has permitted delegation to S/L agencies of all the Administrator's authorities except
those that require Federal rulemaking, or those for which Federal oversight is critical to ensuring
national consistency in the application of standards. Additionally, such delegations were not
intended to give S/L agencies the authority to issue interpretations of Federal law that are
subsequently binding on the Federal Government. Current SIP policy, as reflected in White
Paper Number 2 for Improved Implementation of the Part 70 Operating Permits Program?
permits S/L agencies to alter SIP requirements so long as the alternative requirements are shown
to be equally stringent and are within a pre-approved protocol (and so long as public review is
provided and ETA approval is obtained). The S/L agencies can show equivalent stringency by
providing substantive criteria in SIPs governing the implementation of alternative requirements.
We recognize that Regions have the prerogative to approve delegation of specific
authorities to some S/L agencies and not to others. Therefore, we encourage Regions to provide
as clearly as possible an explanation of the criteria they have used to approve or disapprove
delegation of a specific authority, and to apply those criteria consistently across their S/L
agencies. Such criteria could include a determination of whether the ?/L agency has sufficient
expertise to make such decisions, or a determination that the working relationship between the
Region and the S/L agencies is such that individual decisions could or could not be deteimined
through consultation on an "as needed" basis. For example, you may want to work more closely
with your S/L agencies on their first decision-making for some authorities, thus gaining
assurance that the S/L agencies can and will make appropriate decisions. We also recommend
that Regions obtain copies of all S/L agencies' alternative determinations for their records;
especially where new issues are addressed.
Delegation of Specific Authorities
The part 63 General Provisions lists 15 specific types of authorities for which the
Administrator may make discretionary decisions on a source-specific basis. When the General
Provisions are delegated to an S/L agency, such discretion maybe appropriately delegated,
provided the stringency of the underlying standard would not be compromised.
We recognize that, in order for Regional Offices to have the authority to delegate some of
the authorities outlined in this memorandum (such as intermediate changes to test methods),
delegation 7-121 must first be revised to delegate these authorities to the Regions. We intend to
make this revision, i.e., to delegation 7-121, as soon as possible. Additionally, the Emission
2However, we are expanding our interpretation of previous policy for the applicability
determinations' discretionary authority.
3 Memorandum from Lydia Wegman, Deputy Director, OAQPS, to Regional Air Division
Directors, March 5,1996.
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Measurement Center of the Emissions Monitoring and Analysis Division must receive copies of
any approved intermediate changes to test methods or monitoring. Please note that intermediate
changes to test methods must be demonstrated as equivalent through the procedures set out in
EPA method 301 (see Attachment 1). This information will be used to compile a database of
decisions that will be accessible to the S/L agencies and Regions for reference in making future
decisions. Regions are asked to ensure that initial intermediate changes to testing and monitoring
made in each Region are evaluated. All intermediate test changes and State-issued intermediate
changes to monitoring should be provided via mail or facsimile to:
Chief^ Source Characterization Group A
U.S.EPA(MD-19)
Research Triangle Park, NC 27711
Facsimile Telephone Number (919) 541-1039
Changes in monitoring issued by Regional Offices should continue to be posted on the
Applicability Determination Index (ADI). For electronic file transfer procedures for ADI
updates, please contact Belinda Breidenbach in the Office of Compliance at 202-564-7022.
We have divided the General Provisions discretionary authorities into two categories,
based upon the relative significance of each discretionary type of decision: they are those
authorities which can be delegated and those authorities which cannot be delegated. These
categories are delineated below:
Category I. General Provisions That May Be Delegated
In general, we believe that, where possible, authority to make decisions which are not
likely to be nationally significant or to alter the stringency of the underlying standard should be
delegated to S/L agencies. While we understand the need for Federal oversight of S/L agency
decision-making which will ensure that the delegated authorities are being adequately
implemented and enforced, we do not want to impede S/L agencies in running the part 70
operating permit and Federal air toxics programs with oversight that is cumbersome. We
recommend that Regions rely on their existing mechanisms and resources for oversight. During
oversight, if the Region determines that the S/L agency had made decisions that decreased the
stringency of the standard, then corrective actions should be taken and the source(s) should be
notified. Withdrawal of the program should be initiated if the corrective actions taken are
insufficient.
The authorities listed in Table 1 may be delegated to S/L agencies, so long as the S/L
agencies have the capability to carry out the Administrator's responsibilities and any decisions
made do not decrease the stringency of the standards. Since you are ultimately responsible for all
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Genera] Provisions authorities' decision-making made in your Region, I am comfortable with
trusting your judgement about which of the Administrator's discretionary authorities listed here
should be delegated to the S/L agencies in your Region. When the Region delegates any category
I authority to the S/L agency, it could be accomplished either when the General Provisions are
delegated or at the time that each relevant maximum achievable control technology (MACT)
standard is delegated, with the exception of approval of construction and reconstruction (40 CFR
part 63, section 63.5), which should be delegated when the General Provisions are delegated.
There are some category I authorities, such as approval of intermediate alternatives to test
methods, for which you should be notified when decisions are made by your S/L agencies. Also,
you may want to monitor the progress of S/L agencies' decision-making, in addition to updating
your files for compliance and enforcement matters. We have indicated these authorities in
Table 1 with an asterisk. We encourage you to document, in delegation agreements or delegation
rulemaking, the request for notification when decisions are made regarding the indicated
category I authorities.
Category II. General Provisions That May Not Be Delegated
Authorities listed in this section are those decisions which could result in a change to the
stringency of the underlying standard, which are likely to be nationally significant, or which may
require a rulemaking and subsequent Federal Register notice. Therefore, these authorities must
-be-retained4>y4he EPA Regional Office or EPA Headquarters. As a result, the following
authorities in Table 2 may not be delegated to S/L agencies (all reffej-ences are to sections of 40
CFR part 63, subpart A):
If you have any questions, or would like to discuss this matter further, please contact me
at (919) 541-5608, or Tom Driscoll of my staff at (919) 541-5135.
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Table 1. General Provisions' Authorities that may be Delegated
Section
Section 63. 1*
Section 63.6(e)
Section 63.6(f)
Section 63.6(h)
Sections 63.7(cK2)(i) and (d)
Section 63.7(e)(2)(i)'
Sections 63.7(e)(2)(ii) and (f)'
Section 63.7(e)(2)(iii)
Sections 63.7(e)(2)(iv) and (h)(2), (3)
Sections 63.8(c)(l) and (e)(l)
Section 63.8(f)"
Section 63.8(f)"
Sections 63.9 and 63.10
Authorities
Applicability Determinations
Operation and Maintenance Requirements -
Responsibility for Determining Compliance
Compliance with Non-Opacity Standards -
Responsibility for Determining Compliance
Compliance with Opacity and Visible
Emissions Standards - Responsibility for
Determining Compliance
Approval of Site-Specific Test Plans
Approval of Minor Alternatives to Test
Methods (see Attachment 1)
Approval of Intermediate Alternatives to Test
Methods (see Attachment 1)
Approval of Shorter Sampling Times and
Volumes When Necessitated by Process
Variables or Other Factors
Waiver of Performance Testing
Approval of Site-Specific Performance
Evaluation (monitoring) Test Plans
Approval of Minor Alternatives to
Monitoring (see Attachment 1)
Approval of Intermediate Alternatives to
Monitoring (see Attachment 1)
Approval of Adjustments to Time Periods for
Submitting Reports4
"Regions should be notified when these decisions are made by S/L agencies who have
been delegated authority to make these kinds of decisions.
'Adjustments to the timing that reports are due can be delegated, as mentioned in sections
63.9(i) and 63.10(d) and (e), but not the contents of the reports. For title V sources, semiannual
and annual reports are required by part 70 and nothing herein changes that requirement.
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Table 2. Authorities That May Not Be Delegated
Section
Section 63.6(g)
Section 63.6(h)(9)
Sections 63.7(e)(2)(ii) and (f)
Section 63.8(f)
Section 63. 10(f)
Authority
Approval of Alternative Non-Opacity
Emission Standards
Approval of Alternative Opacity Standard
Approval of Major Alternatives to Test
Methods (see Attachment 1)
Approval of Major Alternatives to Monitoring
(see Attachment 1)
Waiver of Recordkeeping all
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Addressees:
Director, Office of Ecosystem Protection, Region I
Director, Division of Environmental Planning and Protection, Region n
Director, Air Protection Division, Region HI
Director, Air, Pesticides and Toxics Management Division, Region IV
Director, Air and Radiation Division, Region V
Director, Multimedia Planning and Permitting Division, Region VI
Director, Air, RCRA and Toxics Division, Region Vn
Assistant Regional Administrator, Office of Pollution Prevention,
State and Tribal Programs, Region Vffl
Director, Air and Toxics Division, Region DC
Director, Office of Air Quality, Region X
Attachments
cc: B. Buckheit,2242A
C. Garlow,2111A
B. Hunt,MD-14B
B. Jordan, MD-13
S. Mitoff, 2223A
J. Seitz,MD-10
L. Wegman,MD-10
bcc: K. Blanchard, MD-12
F. Dimmick, MD-12
K. Kaufrnan, MD-12
J. Szykman, MD-13
Regional Air Toxics Coordinators
This letter has been concurred with William Lamason, SCGA, Emission Measurement Center,
Charles Garlow, OECA, and verbally from Patrick Chang, OGC.
OAQPS:ITPE>.-nG:TDriscoll:cjbaines:xl-5319:MD-12:June 17,1998:
File: Driscoll/delauth9.mem
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ATTACHMENT 1
Intermediate change to monitoring is a modification to federally required monitoring
involving "proven technology" (generally accepted by the scientific community as equivalent or
better) that is applied on a site-specific basis and that may have the potential to decrease the
stringency of the compliance and enforcement measures for the relevant standard. Though site-
specific, an intermediate decrease may set a national precedent for a source category and may
ultimately result in a revision to the federally required monitoring. Examples of intermediate
changes to monitoring include, but are not limited to: (1) use of a continuous emission
monitoring system (CEMS) in lieu of a parameter monitoring approach; (2) changes to quality
control requirements for parameter monitoring; and (3) use of an electronic data reduction system
in lieu of manual data reduction.
Intermediate change to a test method is a within-method modification to a federally
enforceable test method involving 'proven technology" (generally accepted by the scientific
community as equivalent or better) that is applied on a site-specific basis and that may have the
potential to decrease the stringency of the associated emission limitation or standard.
Intermediate changes are not approvable if they decrease the stringency of the standard. Though
site-specific, an intermediate change may set a national precedent for a source category and may
ultimately result in a revision to the federally enforceable test method In order to be approved,
an intermediate change must be validated according to EPA method 301 (part 63, appendix A) to
demonstrate that it provides equal or improved accuracy and precision. Examples of
intermediate changes to a test method include, but are not limited to: (1) modifications to a test
method's sampling procedure including substitution of sampling equipment that has been
demonstrated for a particular sample matrix and the use of a different impinger absorbing
solution; (2) changes in sample recovery procedures and analytical techniques, such as changes
to sample holding times and use of a different analytical finish with proven capability for the
analyte of interest; and (3) "combining*1 a federally-required method with another proven method
for application to processes emitting multiple pollutants. As an example, Region DC and the
CARB have developed a testing protocol to determine whether California chromium
electroplaters needed to "retest" for the Chromium Electroplating NESHAP. This testing
protocol has been attached (Attachment 2) for your information should you choose to use it
Again, these examples should only be approved if they do not decrease the stringency of the
monitoring requirement.
Major change to monitoring is a modification to federally required monitoring that uses
unproven technology or procedures or is an entirely new method (sometimes necessary when the
required monitoring is unsuitable). A major change to a test method may be site-specific or may
apply to one or more source categories and will usually set a national precedent. Examples of
major changes to a test method include, but are not limited to: (1) use of a new monitoring
approach developed to apply to a control technology not contemplated in the applicable
regulation; (2) use of a predictive emission monitoring system (PEMS) in place of a required
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Attachment 1 Continued
continuous emission monitoring system (CEMS); (3) use of alternative calibration procedures
that do not involve calibration gases or test cells; (4) use of an analytical technology that differs
from that specified by a performance specification; and (5) use of alternative averaging times for
reporting purposes.
Major change to a test method is a modification to a federally enforceable test method
that uses unproven technology or procedures or is an entirely new method (sometimes necessary
when the required test method is unsuitable). A major change to a test method may be site-
specific or may apply to one or more source categories and will usually set a national precedent
In order to be approved, a major change must be validated according to EPA method 301
(part 63, appendix A). Examples of major changes to a test method include, but are not limited
to: (1) use of an improves analytical finish; (2) use of a method developed to fill a test method
gap; (3) use of a new test method developed to apply to a control technology not contemplated in
the applicable regulation; and (4) "combining" two or more sampling/analytical methods (at least
one unproven) into one for application to processes
Minor change to monitoring is a modification to federally required monitoring that
(a) does not decrease the stringency of the compliance and enforcement measures for the relevant
standard; (b) has no national significance (e.g., does not affect implementation of the applicable
regulation for other affected sources, does not set a national precedent, and individually does not
result in a revision to the monitoring requirements); and (c) is site-specific, made to reflect or
accommodate the operational characteristics, physical constraints, or safety concerns of an
affected source. Examples of minor changes to monitoring include, but are not limited to:
(1) modifications to a sampling procedure, such as use of an improved sample conditioning
system to reduce maintenance requirements; (2) increased monitoring frequency, and
(3) modification of the environmental shelter to moderate temperature fluctuation and thus
protect the analytical instrumentation.
Minor change to a test method is a modification to a federally enforceable test method
that (a) does not decrease the stringency of the emission limitation or standard; (b) has no
national significance (e.g., does not affect implementation of the applicable regulation for other
affected sources, does not set a national precedent, and individually does not result in a revision
to the test method); and (c) is site-specific, made to reflect or accommodate the operational
characteristics, physical constraints, or safety concerns of an affected source. Examples of minor
changes to a test procedure, such as a modified sampling traverse or location to avoid
interference from an obstruction in the stack, increasing the sampling time or volume, use of
additional impingers for a high moisture situation, accepting paniculate emission results for a
test run that was conducted with a lower than specified temperature, substitution of a material in
the sampling train that has been demonstrated to be more inert for the sample matrix, and
changes in recovery and analytical techniques such as a change in quality control/quality
assurance requirements needed to adjust for analysis of a certain sample matrix.
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NOTE: The authority to approve decreases in sampling times and volumes when
necessitated by process variables has typically been delegated in conjunction with the
minor changes to test methods, bnt these types of changes are not included within the scope
of minor changes.
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- Examples of Recent Alternative Approvals
Terry Harrison
Source Testing in the New
Regulatory World Workshop
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ABSTRACT
Examples of Recent Alternative Method Approvals
Terry Harrison
What I am going to describe is the way we have recently promoted new measurement technology
by working up front with people outside EPA to voluntarily define, conduct, and submit
development programs that will result in sufficient supporting information on alternative
instrumental test methods for EPA to take action.. These are considered major changes since the
goal is an new alternative test method. What I want to give you is a flavor for how we assure that
we are reasonably certain that (if properly used in the future) these methods are capable of
providing a determination of compliance at the same or higher stringency as required by our
guidelines.
I'm going to do that by walking you through the administrative steps we followed in four
examples. I am not going to provide the technical details of the methods or the approvals. If you
want that information you can download that from our Website or see me later. You will see that
this outreach program has not always been smooth but we believe it is the right thing to do.
-------
Examples of Recent
Alternative Method
Approvals
How did it happen?
Example I: Direct interface GC/MS
Initial proposal presented by a GC/MS
manufacturer via an 'independent' consultant - May
95
i Proposed a 5 step iterative general approval
process - Aug 95
- initial disclosure and method proposal
ป basic lab evaluation
- extended lab evaluation
field evaluation
interpretation of results and applicability
What alternative methods are you
going to hear about ?
Direct interface GC/MS
iNOx - Ultraviolet detector
i Roof monitor flow - scintillation anemometer
i Proposed Method 322- HCI
Example I: Direct interface GC/MS
(continued)
lAgreed to try 5 step procedure for direct interface
GC/MS - Dec 95
9 Notified that initial disclosure & method proposal
(I) and basic lab evaluation (2) done - Nov 96
i Field evaluation (4) following Method 301 - Nov 96
s Partial field evaluation data submitted (5) and
alternative requests made - Mar 97
i Partial approval for use at the two sites field - May
97
-------
Example I: Direct interface GC/MS
(continued)
i Method posted as conditional method CTM-28 -
Apr 98
i Requests for alternative to method 18, 25, 25a
-series of subparts -Mar 98
Interpretation of results and applicability (step 5)
submitted -July 97
i Method posted as alternative method ALT-017
with letter - Aug 98
- Method 18 at specific subparts
Overview of the review process
sthis
significant
improvemen
and is the
project likely
to succeed?
Comments
provided
Review for
conformance to
action plan and
validity of
conclusions /
rationale
Approval
of plan
Direct interface GC/MS (epilogue)
5 step process not always needed for a good
method
H Internal guidance developed to identify win-win
opportunities
a Guidance developed to clarify expectations &
responsibilities in voluntary method development
What should be in the initial proposal?
a Minimum category of method that's acceptable
i An explanation of the measurement principals
i Unbiased presentation of the cost benefits
B Unbiased presentation of applicability limits
- acquiring a representative sample
detecting positive and negative interferrents
-------
What should be in the initial proposal?
(continued)
iA draft test method with QA/QC not specific to
one instrument vendor
Technical "action plan"
What will be done?
How will data be interpreted to define successful
proof?
Example 2 - NOx Ultraviolet detector
Initial proposal presented by a manufacturer via an
'independent' consultant - June 96
i Win-win ? - July 96
Revised proposal - Nov 96
Non proprietary Package - April 97
Independent Peer Review Comments - Oct 97
Manufacturer's response to peer review - April 98
Is this a significant improvement and is
the project likely to succeed?
i 2 independent in-house reviews
Optional Peer review- to augment technical
expertise and provide support for EPA comments
i Initial review of method to assure that it is
applicable to more than one vendor
Additional or different QC identified
Additional or different QA identified
Confirmation that proposal fairly presents pros and
cons
Example 2 - NOx Ultraviolet detector
(epilogue)
Awaiting electronic version- preliminary method
Spin-off project- QA/QC for all NOx methods
Start a low NOx issue lab study
-------
Example 3 - Roof monitor flow -
scintillation anemometer
(Initial proposal presented by a potential user
company -June 97
i Independent Peer Review Comments - Oct 97
i Key QA/QC questions provided to user - Jan 98
i User, with manufacturer support, provided
answers -June 98
Yet another early example,
HCI by GFCIR @ Portland Cement
i Initial proposal presented by industry association
Negotiation over QA requirements in the method
to make it self validating
> Does it get to the detector?
i How much proof is enough?
ป At least 12 successful runs @ a range of kiln types
i Industry submitted final method and support data
i EPA modified slightly and proposed Method 322
Example 3 - Roof monitor flow -
scintillation anemometer (epilogue)
i Letter posted as alternative method (ALT-016)
with conditions - Aug 98
i Hurdles overcome
-Method 14 measures velocity @ discrete points
- Alternative measures path averaged velocity but not
equally over path length
Complicated technology
Empirical correction to calibration data needed -
good only for specific instrument design
Summary
i No single cookie cutter that automatically makes
good test methods
i Procedure to promote new methods
decide to actively pursue only the good methods
different levels of approval helps
different hurdles for different levels
-------
- Method 301 Revisions, Guidance
Gary McAlister
pt Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
METHOD 301 REVISIONS
Gary McAlister
Method 301 became a final rule in December of 1992. As its use has become more common,
some problems with the method have been uncovered. This session discusses some of the more
important problems and explains their significance. It suggests possible solutions for some of
the problems and presents a brief plan for resolving the problems.
-------
\
Method 301 Revisions
And Guidance :/
Future Developments
Background:
Experimental Design Is Divided Into Two
Cases
There is an existing method.
There is no existing method.
Background:
What Is Method 301?
A Procedure For Evaluating Data And
Test Methods
It Describes
> Experimental Design
> Data Analysis
+ Acceptance Limits For
Bias
Precision
Background:
Requirements For The Existing Method Case
Paired Sampling Betweeen the Existing
Method and the Candidate Method
Candidate Method's Precision Must Be
Equal or Better Than Existing Method's
Bias Must be 10% or Less
-------
Background:
Requirements For The Case Without An
Existing Method
Quadruplicate Sampling With Analyte
Spiking
Precision Must Be Less Than 50%
Bias Must Be Less Than 30%
Important Issues:
Similar Sources
Validation Testing May Be Waived For
Methods Validated at a "Similar Source"
. How Do We Define A "Similar Source"?
One Solution - Well Defined
Ruggedness Testing
Important Issues:
Instrumental Methods
Experimental Design Works Best With
Manual Sampling Methods
Need To Revise Experimental Design
To Accomodate Instrumental Methods
Important Issues:
Correction Factors
Should Correction Factors Developed at
a Single Site Be Applied Universally?
Possible Solution: Revise Method 301
To Reduce the Cases Where Correction
Factors Are Required.
-------
Important Issues:
Alternatives To Existing Methods
Method 301 Only Allows Direct
Comparison Testing Where There Is an
Existing Method
Posible Solution: Allow the Option of
Analyte Spiking Where There Are
Existing Methods
Next Steps
Evaluate Possible Solutions
Seek Peer Review of the Proposed
Solutions
Propose Acceptable Solutions for Public
Comment
Important Issues:
Precision Limits
Method 301 Accepts New Methods With
Precision As Low As 50%
> Affects Our Ability To Detect Bias
> Lowers Confidence in Test Results
Possible Solution: Tighten the Precision
Limits
-------
- Method Precision Evaluation (PQL)
Gary McAlister
of Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
METHOD PRECISION EVALUATION
Gary McAlister
When test results are used for determining compliance with an emission limit, the precision of
the data can become a very important issue. This session discusses precision and testing issues.
It describes some of the ways that precision is measured and why it is important. It also discusses
detection and quantitation limits and how they are related to precision.
-------
Test Method Precision
A Chemist's View of Statistics
Measures of Precision
= Sample standard deviation - a measure of
the dispersion of a frequency distribution.
CV = Coefficient of variation - the sample
standard deviation divided by the average
value measured.
RSD = Relative standard deviation - the CV
expressed as a percentage.
Cl = Confidence interval - the range of values
within which some parameter may b\expec
to lie with a stated confidence.
What Is Precision?
BAD PRECISION
GOOD PRECISION
How Is The Precision Related To The
Practical Quantitation Limit (PQL)?
PQL is a number that is reasonably far
away from the minimum detection so that you
have sufficient confidence to report it.
The minimum detection limit can be defined
as the lowest concentration of a pollutant that
you can distinguish from zero with a single
measurement at a stated level of probability.
-------
How Is The Precision Related To The
Practical Quantitation Limit (PQL)?
The MDL can be defined as follows:
MDL = tx(s)
Where
tx = The Student's t value for the x
confidence level and n-1
degrees of freedom.
s = The sample standard deviation.
Is The PQL A Useful Concept?
has a concrete meaning
PQL is subjective
How far is "reasonably far from the minimum
detection limit..."?
What is the significance of limiting the Cl about a
single measurement to ฑ 30%.
How Is The Precision Related To The
Practical Quantitation Limit (PQL)?
Similarly, the PQL can be defined as follows:
PQL = 10a
Where
a =The standard deviation.
10= Simply a constant, or
10 = Factor that insures that the 99% CI of
a single result will be no greater than
+ 30%.
How Can Precision Vary With
Measurement Level?
standard deviation (sigma) can be
constant.
*-The standard deviation can vary with the
concentration, but the CV can be constant.
>.The standard deviation can vary with the
concentration, and the CV can also vary.
-------
What Does All Of This Mean?
>. Precision is important because as precision
increases so does our confidence in our
results.
^Determining the Mimimum Detection Limit is
important because it helps define the
limitations of our test methods.
> Practical Quantitation Limits are not so
important because they are not real limits on
the application of test methods.
-------
Why Is Precision Important?
Measured Concentration
180
160
140
120
100
80
60
40
Emission
Limit
Upper
Limit
Lower
Limit
0 0.05 0.1 0.15 0.2 0.25 0.3 0.3&
Coefficient of Variation
90% Confidence Level With 3 Runs ^f ^
Minimum Detection Limit
Response
2
1.8
1.6
1.4
1.2
1
0.8
0.2
0.4 0.6
Concentration
0.8
What Is The Effect Of More
Samples?
Measured Concentration
180
160
140
120
100
80
60
40
0.05
90% Confidence Level
0.1 0.15 0.2 0.25
Coefficient of Variation
Limit
UCL 3 Runs
LCL 3 Runs
......
UCL 6 Runs
- -C- -
Variation of Precision With
Measurement Level
Sigma
2.5
2
1.5
1
0.5
X
X
xx
; S/
X
X
X
! 1 . I . 1 . ._! ,
Constant
sigma
Constant
CV
Decreasing
CV
10 15 20
Measurement
25
30
-------
Effect of Variation In Precision
On Confidence Interval
Confidence Interval
0 5 10 15 20
Measurement
Assuming 95% Confidence Level
Effect of Variation In Precision
On Confidence Interval
Confidence Interval
35
30
25
20
15
10
5
Decreasing
CV
True
Value
0 5 10 15 20
Measurement
Assuming 95% confidence interval.
25
30
Effect of Variation In Precision
On Confidence Interval
Confidence Interval
10 15 20 25 30
Measurement
Assuming 95% confidence interval
Effect of Variation In Precision
On Confidence Interval
Cl / Average Measurement
2
1.5
1
0.5
n
"\
\
\
\
\
'"ซ
f..^
, . , " r t
Constant
Sigma
Constant
CV
Decreasing
CV ^
' 'W
10 15 20
Measurement
25
-------
- Environmental Technology Verification
Robert Fuerst
of Air
"*/;
vsrsfc*'
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
ETV's Advanced Monitoring System Pilot
Robert G. Fuerst
Throughout its history, the U.S. Environmental Protection Agency (EPA) has evaluated
technologies to determine their effectiveness in monitoring, preventing, controlling, and cleaning
up pollution. Since the early 1990's, numerous government and private groups have identified the
lack of an organized and ongoing program to produce independent, credible performance data as
a major impediment to the development and use of innovative environmental technology. Such
data are needed by technology buyers and permitters both at home and abroad to make informed
technology decisions. Because of this broad input, the President's environmental technology
strategy, Bridge to a Sustainable Future and the Vice President's National Performance
Review proposed initiatives for an EPA program to accelerate the development of environmental
technology through objective verification and reporting of technology performance. In 1994,
EPA's Office of Research and Development (ORD) formed a workgroup to plan the
implementation of the Environmental Technology Verification (ETV) Program. ETV is not an
approval or certification process, but rather provides a quantitative assessment of technology
performance. A third party provides the objective verification of the technology's performance
data. At present ETV consists of 12 pilot verification programs addressing a wide range of
technology areas. The pilot programs are operated by diverse "verification organizations" who
serve as EPA's partners in the program. Descriptions of these pilot ETV programs can be
obtained at the ETV website: http://www.epa.gov/etv/ . In addition to EPA and the verification
partner, most ETV programs include active involvement of appropriate stakeholder groups, such
as technology manufacturers/vendors, consulting engineers, scientific service organizations,
federal and state regulatory agencies, and potential monitoring technology buyers. EPA and the
stakeholders provide overall guidance to the verification partner and assist in the design of the
verification protocols and the establishment of verification priorities. EPA also provides review of
all documents. After about 5 years of operation these verification programs will evolve into
privatized programs and will be sustained through program generated income and leveraged
resources with minimal or no funding from EPA.
The ETV pilot program for Advanced Monitoring Systems is managed by ORD's National
Exposure Research Laboratory and partnered with Battelle-Columbus. The major program goal
is to collect and report performance data from monitoring systems that are routinely used to
characterize and/or model environmental emissions influencing the quality of air, water, and soil.
At present only monitoring technologies for verification of air and water quality are being
proposed. Soil technologies verification will begin at a later date.
-------
Twenty-seven air technology stakeholders participate in the air advisory committee while twenty-
six stakeholders participate in the water advisory committee. The air technology needs suggested
by the stakeholders include: real-time field instruments that can measure fine paniculate matter
in ambient air; automated monitors with sample inlets specially designed for speciation of volatile
organic compounds in ambient air; portable field NO/N02 analyzers for small sources (internal
combustion units and small boilers); and real-time field monitors for measurement of speciated
organics and/or inorganics from point sources. The water technology needs suggested include:
home test kits for measuring pathogens (fecal coliform) or metals (lead, copper) in drinking water;
chemical-specific field probes for monitoring volatile organic compounds or synthetic organic
compounds in groundwater; real-time field instrumentation for monitoring pathogens or synthetic
organic compounds in surface water; and rapid field measurement technology to determine the
"wholesomeness" of seafood (e.g., finfish and shellfish) by measuring the presence of polycyclic
aromatic hydrocarbons and other contaminants.
NO/N02 analyzers were chosen as the first AMS verification technology. Vendors submitting
instruments for verification include Testo, Inc., TSI, Inc., Energy Efficient Systems, COSA
Instruments Corp., ECO Physics Inc., ECOM American Ltd., and Horiba Instruments. All of
these monitors are continuous, portable instruments for small sources.
The next air technologies to be considered for verification testing will be: fine paniculate
monitors, both mass and speciation (10 interested vendors); long path FTIR (4 interested
vendors); and, possibly, specialized sampling inlets used to speciate Volatile Organic Compounds.
The proposed first water technology to be considered for verification testing will be test kits for
domestic drinking water for lead, copper and nitrates and fiber optic sensors for monitoring
organics in groundwater and surface water.
-------
Environmental
Technology
Verification
Advanced Monitoring Systems Pilot
http ://www. epa. gov/etv
%J^r
ETV Goals
Draw out promising innovative technologies from the
private sector through EPA supported performance
verification
Provide objective performance data to purchasers and
permitters of environmental technologies
Work with permitters at the state and local level
Reduce risk for financial investors
Create a level playing field among competitors
Facilitate export of American products
Program Background
i Numerous reports/committes identify need for
environmental technology verification
slow rate of innovation; poor U.S. markets
lack of credibility of new technologies
inertia of system, risk aversion of purchasers and permitters
burgeoning international market
i 1995 - President's environmental technology strategy,
"Bridge to a Sustainable Future", adopts EPA lead
verification program as an initiative
i 1995 - Vice-President's "National Performance
Review" - improvements in government service to
the American public
ETV Strategy Operating
Principles
"ivfak'e objective p'erformance information available to
environmental marketplace
voluntary program
all vendors welcome
do not "approve" or "disapprove" technologies
Focus solely on commerical-ready technologies
Leverage capacity, expertise, and facilities of others
through third party partnership
Utilize expertise of stakeholders
technology area priorities
protocol development review
verification report review
-------
ETV Strategy Operating
Principles (cont)
i Program begins with 5 year pilot phase 12
technology areas
i Nine pilots focus all, most, or some resources on P2
technologies
i Data collection on pilot operations and outcomes;
program decisions in the year 2000
Developing comprehensive outreach strategy to state
and federal permitters, consulting community, and
international markets
Will move from primarily government funded
program to primarily private sector program
ETV Program Pilots (continued)
P2 Air Pollution Control Technologies - Research
Triangle Institute
Advanced Monitoring Systems - Battelle, Columbus
OH
P2 Metal Finishing - Concurrent Technologies Corp.
~ (technologies for reduction of chromium, cyanide,
and chlorinated solvents)
Wet Weather Flow Technologies - NSF International
~ (uncontrolled storm water discharges, sewer
overflows, and treatment)
ETV Program Pilots
Drinking Water Systems - NSF International
P2 WasteTreatment - California EPA
i Site Characterization and Monitoring Technologies -
Sandia National Lab & Oak Ridge National Lab
Unspecified "EvTEC" - Civil Engineering Research
Foundation
Indoor Air Products - Research Triangle Institute
P2 Innovative Coatings and Coating Equipment -
Concurrent Technologies Corp., Johnstown, PA
(powder and liquid)
ETV Program Pilots (continued)
Source Water Protection - NSF International ~
(innovative septic tanks, pipeline and tank design,
other groundwater impact technologies)
Greenhouse Gas Technology - Southern Research
Institute (fuel cells, natural gas, cookstoves,
methane recovery technologies)
-------
ETV Pilot Process
Organization Phase Operations Phase
Verification Partner (VP)
Selected (EPA)
Stakeholder Groups
Formed (EPA/VP)
Technologies Prioritized
and Generic Protocols
Developed
(EPA/VP/Stakeholders)
Open Solicitation (VP)
Generic/Tailored Test
Plans (Developer/VP)
Testing by VP or Testing
by Developer with VP
Oversight
QA Evaluation (EPA/VP)
Verification
Report/Statement
(EPA/VP)
Information Diffusion
(EPA/VP/Stakeholders)
Outreach Activities
i Website operational
Program/pilot descriptions
EPA Verification Statements
Pilot protocols
Technology test plans
Upcoming events/meetings
Stakeholder lists
i www.epa.gov/etv
Stakeholder Functions
i Stakeholders unique to each technology area
i Role of Stakeholders
Set verification priorities
Review protocols and operating procedures
Review other important documents
Assist in designing and conducting outreach activities
Serve as information conduits to their constituencies
Advanced Monitoring
Systems (AMS) Pilot
The major program goal will be to plan for, collect,
and report performance data from advanced
monitoring technologies that are commercially
available to characterize and/or model environmental
emissions influencing the quality of air, water, and
soil.
-------
Question 1
i Does the environmental marketplace need/value an
ETV AMS pilot?
The ETV AMS pilot will help develop protocols that provide
information about technology performance across a wide range of
operating conditions to supply the user community with a measure of
technology predictability
The ETV AMS pilot with stakeholder assistance will increase the
speed at which new technologies reach full-scale commercialization
and acceptance
The ETV AMS pilot will provide the infrastructure for systematically
testing and verifying the performance of new innovative technologies
Question 3
i Where is value added from the ETV AMS pilot?
By promoting, through encouragement and rapid acceptance,
commercially-ready new advanced monitoring technologies
By attempting to reduce the overall cost of regulatory
compliance
By providing EPA participation in protocol development
By supplying independent EPA QA oversight of the
verification process
By preparing a Verification Statement that can be trusted
Question 2
i Can we design a credible ETV AMS pilot program
that the regulated community can afford?
This will be a challenge
The verification partner must be perceived as an industry-
leading institution or consortium displaying strong
performance in testing technologies
The SAB concluded that privatization of the ETV pilots may
not be achievable in a short time-frame, but may require 5-8
years with some level (10 to 20%) of government support
What is the ETV AMS
Verifying?
i What do I want to know about this technology?
Performance of the technology
Accuracy
Precision
Sample throughput
Operator requirements
Error rate
Detection limit
-------
Who is the Audience for the
Verification Report?
EPA/ NERL reviews/approves report
Venders - need it now; quick turnaround
Buyers-Users - want a quick payback
Enablers - concern for regulations; does it work?
Stakeholders must represent a large sector of expertise
Proposed Technologies For
Verification in the AMS Pilot
_ Air Technologies:
,. NO/NO2 Analyzers (Small Sources)
>. Monitors for Fine Paniculate - Mass & Speciation
Long-Path FTIR
> Specialized Sampling Inlets Used to Speciate VOC's
_ Water Technologies:
.. Home Test Kits for Measuring Metals (Pb, Cu, nitrates) in
Drinking Water
.. Fiber Optic Sensors for Monitoring Organics in Groundwater
and Surface Water
Finish One, Do One, Plan One
i Proposed Schedule
Award of Co-op Agreement Sept. 1997
-Nominate Stakeholders Nov. 1997
_ Stakeholder Kickoff Meeting Feb. 1998
-Initial Technology Solicitation March 1998
Select Technologies for Verification May-June 1998
Second Stakeholders Meeting Sept. 1998
Technology Verification Begins Oct. 1998
-------
Presentation 9
-------
9
-------
Continuing the Information
Exchange Workshop
- EPA, EMC Perspective
- EPA, OAQPS Perspective
- EPA, OECA Perspective
- State Agency Perspective
Conniesue Oldham
Henry Thomas
Charles Garlow
Mike Fogle
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
CONTINUING THE INFORMATION EXCHANGE WORKSHOP
(Federal and State Perspective)
Conniesue Oldham
This panel discussion will address the need for an on-going information exchange in emission
measurement. The change in the way EPA conducts business, including more reliance on outside
sources for new methods, means that the entire testing community will need frequent and clear
communications. Federal and state representatives will discuss their ideas for continuing this forum
to facilitate smooth transitions from rule development to rule implementation and to continue to build
partnerships to advance air pollution control.
-------
ABSTRACT
CONTINUING THE INFORMATION EXCHANGE WORKSHOP
(EPA, OAQPS Perspective)
Henry Thomas
-------
ABSTRACT
CONTINUING THE INFORMATION EXCHANGE WORKSHOP
(EPA, OECA Perspective)
Charles Garlow
-------
ABSTRACT
CONTINUING THE INFORMATION EXCHANGE WORKSHOP
(State Perspective)
Mike Pjetraj
-------
Presentation 10
-------
-------
MACT Implementation Issues
- MACT/Title V Interface Issues
- Flexible Permits
- MACT and Enforcement Issues
- MACT and SIP Interface
Barrett Parker
Mike Trutna
Charles Garlow
Mike Fogle
Source Testing in the New
Regulatory World Workshop
-------
- MACT/Title V Interface Issues
Barrett Parker
of Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT IMPLEMENTATION ISSUES
(MACT/Title V Interface Issues)
Barrett Parker
-------
- Flexible Permits
Mike Trutna
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT IMPLEMENTATION ISSUES
(Flexible Permits)
Mike Trutna
-------
- MACT and Enforcement Issues
Charles Garlow
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT IMPLEMENTATION ISSUES
(MACT and Enforcement Issues)
Charles Garlow
-------
- MACT and SIP Interface
Mike Fogle
of Air
Source Testing in the New
Regulatory World Workshop
-------
ABSTRACT
MACT IMPLEMENTATION ISSUES
(MACT and SIP Interface)
Mike Fogle
-------
Appendix A
-------
Appendix A
-------
List of Participants
(Alphabetical by Last Name)
of Air
Source Testing in the New
Regulatory World Workshop
-------
Source Testing in the New Regulatory World
EPA Workshop
Participant List
Alphabetical by Last Name
David Ajayl
FL DEP
2600 Blairstone Road
Tallahassee, FL 32399-5505
(850)921-6675
(850)922-6979 fax
ajayl_d@dep.state.fl.us e-mail
Mike Aldridge
NC DENR
2728 Capital Blvd
Raleigh, NC 27626-0580
(919)733-1727
(919)733-1812/0*
Ashby Armistead
NC DENR
943 Washington Sq Mall
Washington, NC 27889
(252)946-6481
(252)975-3716 fax
Lara Autry
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5544
(919)541-1039 fax
autry.lara@epamail.epa.gov e-mail
David Baker
PA DEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
baker.david@al .dep.state.pa.us e-mail
Christopher Bednar
VADEQ
4949-A Cox Road
Glen Allen, VA 23060
(804)527-5046
(804)527-5106 fax
cabednar@deq.state.va.us e-mail
Ramelito Biscocho
Hammond DEM
5925 Calumet Ave, Rm 304
Hammond, IN 46320
(219)853-6306
(219)853-6343 fax
Dan Bivins
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-5244
(919)541-1039 fax
bivins.dan@epamail.epa.gov e-mail
Stephen Boone
NC DENR
127 Cardinal Dr Ext
Wilmington, NC 28405
(910)395-3900
(910)350-2004 fax
niea504@wiro.enr.state.nc.us e-mail
John Bosch
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5583
(919)541-1039 fax
Paul Boys
U.S. EPA - Region 10
1200 6th Avenue
Seattle, WA 98101
(206)553-1567
(206)553-0119 fax
boys.paul@epa.gov e-mail
Matthew Boze
FLDEP
2600 Blairstone Rd MS-5510
Tallahassee, FL 32399-2400
(850)921-9577
(850)922-6979 fax
boze_m@dep.state.fl.us e-mail
-------
Michael Branton
SC DHEC
2600 Bull Street
Columbia, SC 29201
(803)734-9933
(803)734-4556 fax
brantonm@columb31 .dhec.state.se.us e-mail
Timothy Brooks
PADEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
brooks.timothy@al.dep.state.pa.us e-mail
Joelle Burleson
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Howard Caine
U.S. EPA - Region 5
77 West Jackson Blvd (AE-17J)
Chicago, IL 60604
(312)353-9685
(312)353-8289/ox
caine.howard@epamail.epa.gov e-mail
Robert Cannone
AKDEC
610 University Ave
Fairbanks, AK 99709-3643
(907)451-2133
(907)451-2187/0*
bcannone@envircon.state.ak.us e-mail
Albion Carlson
U.S. EPA - Region 8
999 18th St. Suite 500
Denver, CO 80202-2466
(303)312-6207
(303)312-6409/0*
Yvonne Chandler
U.S. EPA - OAQPS
MD-13
RTP, NC27711
(919)541-5627
(919)541-0942/0*
Yongcheng Chen
NC DENR
225 Green St. Ste 714
Fayetteville, NC 28301
(910)486-1541
(910)486-0707/0*
Michael Ciolek
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-4921
(919)541-1039/0*
ciolek.michael@epamail.epa.gov e-mail
Wayne Coe
ADEM
PO Box 301463
Montgomery, AL 36130-1463
(334)271-7861
(334)279-3044/0*
wec@adem.state.al.us e-mail
Christopher Corley
SC DHEC
2600 Bull Street
Columbia, SC 29201
(803)734-4903
(803)734-4556/0*
corleycl@columb31 .dhec.state.us.se e-mail
Misti Cormier
Knox Co. APC
400 Main St, Ste 339
Knoxville, TN 37902
(423)215-2488
(423)215-4242/0*
Stephen Crane
ORDEQ
750 Front Street NE
Salem, OR 97310
(503)378-8240
(503)378-4196/0*
crane.steve@deq.state.or.us e-mail
-------
Foston Curtis
U.S. EPA - OAQPS
MD-19
RTF, NC 27711
(919)541-1063
(919)541-1039 fax
curtis.foston@epamil.epa.gov e-mail
Brendon Davey
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Charles Davis
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/ox
Kimberly Davis
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
John DeGirolamo
CTDEP
79 Elm Street 6th Floor
Hartford, CT 06106
(860)424-3957
(860)424-4064 fax
Curt Demuth
VADEQ
4949A Cox Road
Glen Allen, VA 23060
(804)527-5147
(804)527-5106 fax
cldemuth@deq. state.va.us e-mail
Rima Dishakjian
U.S. EPA - Region 9
75 Hawthorne St AIR-4
San Francisco, CA 94105-3901
(415)744-2336
(415)744-1076 fax
dishakjian.rima@epamail.epa.gov e-mail
Yogesh Doshi
VADEQ
P.O. Box 10009
Richmond, VA 23240-0009
(804)698-4017
(804)698-4510/0*
yndoshi@deq.state.va.us e-mail
Richard DuBose
U.S. EPA - Region 4
Sam Nunn Fed Ctr, 61 Forsyth
Atlanta, GA 30303-3104
(404)562-9168
(404)562-9163 fax
David Edgington
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Lisa Ehrhart
VADEQ
4949A Cox Road
Glen Allen, VA 23060
(804)527-5091
(804)527-5106 fax
lkehrhart@deq.state.va.us e-mail
Doug Elley
MODNR
P.O. Box 176
Jefferson City, MO 65102-0176
(573)751-4817
(573)751-2706 fax
Jay Evans
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/ojc
Michael Fogle
GADNR
4244 International Pkwy Ste 120
Atlanta, GA 30354
(404)363-7128
(404)363-7100 fax
-------
Kirk Foster
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Stephen Friend
IDEM
100 North Senate Avenue
Indianapolis, IN 46204
(317)233-3438
(317)233-6865 fax
Robert Fuerst
U.S. EPA - NERL
MD-46
RTF, NC27711
(919)541-2270
(919)541-3527 fax
fuerst.robert@epamail.epa.gov e-mail
Tony Gallagher
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Charles Garlow
U.S. EPA
401 M Street SW (2242A)
Washington, DC 20460
(202)564-1088
(202)564-0068 fax
garlow.charlie@epa.gov e-mail
Bill Grimley
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-1065
(919)541-1039 fax
grimley.william@epamail.epa.gov e-mail
Donald Gunter
ADEM
PO Box 301463
Montgomery, AL 36130-1463
(334)271-7902
(334)279-3044/0*
dhg@adem.state.al.us e-mail
Patrick Haines
Ohio EPA
1600 Watermark
Columbus, OH 43215
(614)644-4838
(614)644-3681/0*
patrick.haines@epa.state.oh.us e-mail
Kristina Hansen
Hammond DEM
5925 Calumet Ave, Rm 304
Hammond, IN 46320
(219)853-6306
(219)853-6343/0*
Michael Harley
FLDEP
2600 Blairstone Rd MS-5510
Tallahassee, FL 32399-2400
(850)921-9509
(850)922-6979/0*
harley_m@dep.state.fl.us e-mail
Terry Harrison
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-5233
(919)541-1039/0*
harrison.terry@epamail.epa.gov e-mail
Mark Hedrick
NCDAQ
127 Cardinal Dr Ext
Wilmington,NC 28405
(910)395-3900
(910)350-2004/0*
mark_hedrick@wiro.enr.state.nc.us e-mail
Ronald Holder
Hammond DEM
5925 Calumet Ave, Rm 304
Hammond, IN 46320
(219)853-6306
(219)853-6343/0*
Betsy Huddleston
NC DENR
943 Washington Sq Mall
Washington, NC 27889
(252)946-6481
(252)975-3716/0*
-------
David Hughes
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Wayne Hunt
AZDEQ
3033 N Central Avenue
Phoenix, AZ 85012
(602)207-2327
(602)207-2366 fax
hunt.wayne@ev.state.az.us e-mail
William Hunt
U.S. EPA - OAQPS
MD-14
RTF, NC27711
(919)541-5536
Roy Huntley
U.S. EPA - OAQPS
MD-14
RTP, NC27711
(919)541-1060
(919)541-0684 fax
huntley.roy@epa.gov e-mail
Dennis Igboko
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
John Jenks
NJDEP-BTS
PO Box 437
Trenton, NJ 08625-0437
(609)530-3897
(609)530-4504 fax
jjenks@dep.state.nj.us e-mail
David Johnson
ADEM
PO Box 301463
Montgomery, AL 36130-1463
(334)271-7861
(334)279-3044/0*
daj@adem.state.al.us e-mail
Emmett Keegan
U.S. EPA - Region 5
77 West Jackson Blvd (AE-17J)
Chicago, IL 60604
(312)353-0678
(312)353-8289/0*
keegan.emmett@epamail.epa.gov e-mail
Michael Klein
NJDEP-BTS
PO Box 437
Trenton, NJ 08625-0437
(609)530-3897
(609)530-4504/0*
mklein@dep.state.nj.us e-mail
Garry Kuberski
FLDEP
3319MaguireBlvd
Orlando, FL 32803
(407)893-3333
(407)897-5963/0*
kuberski_g@orli. dep. state.fl.us e-mail
Bill Kuykendal
U.S. EPA - OAQPS
MD-14
RTP, NC 27711
(919)541-5372
(919)541-0684/0*
kuykendal.bill@epa.gov e-mail
William Lamason
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-5374
(919)541-1039/0*
lamason.bill@epamail.epa.gov e-mail
AnnMary Lanagan
PA DEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303/0*
lanagan.annmary@al.dep.state.pa.us e-mail
-------
Thomas Lancaster
SCDHEC
2600 Bull Street
Columbia, SC 29201
(803)784-8733
(803)784-3581 fax
Iancasti@columb31.state.sc.us e-mail
Johnnie Little
OKDEQ
707 N Robinson Ste 4100
Oklahoma City, OK 73101-1677
(405)702-4106
(405)702-4101 fax
johnnie.little@deqmail.state.ok.us e-mail
Thomas Logan
U.S. EPA - OAQPS
MD-19
RTF, NC 27711
(919)541-2580
(919)541-1039 fax
logan.thomas@epamail.epa.gov e-mail
Thomas Lovell
CO APCD
4300 Cherry Creek Drive South
Denver, CO 80246-1530
(303)692-3204
(303)782-0278 fax
David Manning
VTAPC
103 South Main St. Bldg 3 S
Waterbury, VT 05671-0402
(802)241-3855
(802)241-2590 fax
davem@qtm.anr.state.vt.us e-mail
Kevin Mattison
ILEPA
1701 S. First Ave, Ste 500
Maywood, IL 60153
(708)338-7872
(708)338-7930 fax
epa2325@epa.state.il.us e-mail
Doris Maxwell
U.S. EPA - OAQPS
MD- 13
RTF, NC 27711
(919)541-5312
Gary McAlister
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-1063
(919)541-1039 fax
Ron McCulloch
NCDENR
PO Box 29580
Raleigh, NC 27626-0580
(919)715-2968
(919)733-1812/0*
ron.mcculloch@aq.enr.state.nc.us e-mail
Ann Mclver
IDEM
100 North Senate Avenue
Indianapolis, IN 46204
(317)232-8411
(317)233-6957 fax
amciver@dem.state.in.us e-mail
Bernard McKee
NC DENR
943 Washington Sq Mall
Washington, NC 27889
(252)946-6481
(252)975-3716/0*
David McNeal
U.S. EPA - Region 4
Sam Nunn Fed Ctr, 61 Forsyth
Atlanta, GA 30303-3104
(404)562-9102
(404)562-9095/0*
mcneal-dave@epamail.epa.gov e-mail
Marjorie Meares
NCDENR
59 Woodfm Place
Asheville, NC 28801
(828)251-6208
(828)251-6452/0*
Greg Meeker
WY DEQ
250 Lincoln Street
Lander, WY 82520
(307)332-6755
(307)332-7726/0*
gmeeke@missc.state.wy.us e-mail
-------
Kevin Miller
NC DENR
943 Washington Sq Mall
Washington, NC 27889
(252)946-6481
(252)975-3716 fax
Sally Mitoff
U.S. EPA
401 M Street SW (2223A)
Washington, DC 20460
(202)564-7012
(202)564-0050 fax
Benjamin Morton
FLDEP
7825 Baymeadows Way Ste 200B
Jacksonville, FL 32256-7590
(904)448-4310
(904)448-4363 fax
benj amin_m@j ax 1. dep. state. fl. us e-mail
Ronald Myers
U.S. EPA - OAQPS
MD-14
RTP, NC27711
(919)541-5407
(919)541-0684 fax
myers.ron@epa.gov e-mail
Craig Nicol
VADEQ
7705 Timberlake Rd
Lynchburg, VA 24502
(804)582-5120
(804)582-5125 fax
crnicol@deq.state.va.us e-mail
Thomas Nyhan
Hammond DEM
5925 Calumet Ave, Rm 304
Hammond, IN 46320
(219)853-6306
(219)853-6343 fax
Gregg O'Neal
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Conniesue Oldham
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-7774
(919)541-1039 fax
oldham.conniesue@epamail.epa.gov e-mail
Philip Orr
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Tom Pace
U.S. EPA - OAQPS
MD-14
RTP, NC 27711
(919)541-5634
Jaime Pagan
U.S. EPA - OAQPS
MD-13
RTP, NC 27711
(919)541-5340
(919)541-0942 fax
pagan.jaime@epa.gov e-mail
Jaydeb Pai
PA DEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
pai.jaydeb@al .dep.state.pa.us e-mail
Samir Parekh
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/ojc
Barrett Parker
U.S. EPA - OAQPS
MD-12
RTP, NC 27711
(919)541-5635
(919)541-5509 fax
parker.barrett@epamail.epa.gov e-mail
-------
Guatam Patnaik
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Romona Pedersen
VADEQ
7705 Timberlake Rd
Lynchburg, VA 24502
(804)582-5120
(804)582-5125 fax
ronpedersen@deq.state.va.us e-mail
Roscoe Peele
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-4945
Tony Pendola
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Bernie Pittman
NC DENR
943 Washington Sq Mall
Washington, NC 27889
(252)946-6481
(252)975-3716/0*
Michael Pjetraj
NC-DENR
2728 Capital Blvd
Raleigh, NC 27604
(919)733-1469
(919)733-1812/0*
michael_pjetraj@ncair.net e-mail
Scott Postma
U.S. EPA - Region 7
25 Funston Road
Kansas City, KS 66115
(913)551-5063
(913)551-5218/0*
postma.scott@epamail.epa.gov e-mail
Bryon Richwine
PADEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
richwine.bryon@al.dep.state.pa.us e-mail
Solomon Ricks
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-5242
(919)541-1039/0*
Gene Riley
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5239
(919)541-1039/0*
riley.gene@epamail.epa.gov e-mail
Ana Rivera
PREQB
POBox 11488
Santurce, PR 00910
(787)767-8025
(787)756-5906/0*
jcaaire@prtc.net e-mail
Robert Russ
Forsyth Co Env Affairs Dept
537 N. Spruce Street
Winston-Salem, NC 27101
(336)727-8060
(336)727-2777/0*
russro@co.forsyth.nc.us e-mail
Dallas Safriet
U.S. EPA - OAQPS
MD-14
RTP, NC 27711
(919)541-5371
(919)541-0684/0*
safriet.dallas@epa.gov e-mail
-------
Robert Samaniego
NM Env. Dept
2048 Galisteo
Santa Fe, NM 87505
(505)827-1494
(505)827-1523 fax
robert_samaniego@nmenv.state.nm.us e-mail
Gary Saunders
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Robin Segall
U.S. EPA - OAQPS
MD-19
RTF, NC27711
(919)541-0893
(919)541-1039 fax
segall.robin@epamail.epa.gov e-mail
John Seitz
U.S. EPA - OAQPS
MD-10
RTP, NC27711
(919)541-5618
Richard Simpson
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Candace Sorrell
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-1064
(919)541-1039 fax
sorrell.candace@epamail.epa.gov e-mail
Mark Sport
ADEM
PO Box 301463
Montgomery, AL 36130-1463
(334)271-7772
(334)279-3044 fax
vms@adem.state.al.us e-mail
Todd Starner
PA DEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
starner.todd@al.dep.state.pa.us e-mail
Daniel Strochak
NJDEP-BTS
PO Box 437
Trenton, NJ 08625-0437
(609)530-3897
(609)530-4504/
-------
Richard Tayler
GADNR
4244 International Pkwy Ste 120
Atlanta, GA 30354
(404)363-7128
(404)363-7100 fax
Henry Thomas
U.S. EPA - OAQPS
MD-14
RTP, NC27711
(919)541-5273
Fredrick Thompson
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5474
(919)541-2357 fax
Michael Toney
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5247
(919)541-1039 fax
miketoney@epa.gov e-mail
Mike Trutna
U.S. EPA - OAQPS
MD-12
RTP, NC 27711
(919)541-5345
(919)541-4028 fax
Michael Verzwyvelt
SC DHEC
2600 Bull Street
Columbia, SC 29201
(803)734-3552
(803)734-4556 fax
Migvia del Vidal
PREQB
POBox 11488
Santurce, PR 00910
(787)767-8025
(787)756-5906 fax
jcaaire@prtc.net e-mail
Shannon Vogel
NC DENR
2728 Capital Blvd
Raleigh, NC 29580
(919)733-1727
(919)733-1812/0*
Margaret Wagner
VADEQ
7705 Timberlake Rd
Lynchburg, VA 24502
(804)582-5120
(804)582-5125 fax
Peter Westlin
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-1058
(919)541-1039 fax
westlin.peter@epamail.epa.gov e-mail
Christopher Whitcash
PADEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303 fax
whitcash.christopher@al.dep.state.pa.us e-
mail
Mark Winter
U.S. EPA - Region 2
2890 Woodbridge Avenue
Edison, NJ 08833-3679
(732)321-4360
(732)321-6616/0*
winter.mark@epamail.epa.gov e-mail
Susan Wyatt
U.S. EPA - OAQPS
MD-13
RTP, NC27711
(919)541-5674
(919)541-0942 fax
10
-------
George Yarbrough
ADEM
PO Box 301463
Montgomery, AL 36130-1463
(334)270-5625
(334)279-3044 fax
gay@adem.state.al.us e-mail
Mohammad Yassin
MSDEQ
PO Box 10385
Jackson, MS 39289-0385
(601)961-5171
(601)961-5674/0*
mohammed_yassin@dep.state.ms.us e-mail
Peter Yronwode
MODNR
P.O. Box 176
Jefferson City, MO 65102-0176
(573)751-4817
(573)751-2706 fax
Andrew Zemba
PADEP
400 Market Street
Harrisburg, PA 17105-8648
(717)787-6547
(717)772-2303/oc
zemba.andrew@al.dep.state.pa.us e-mail
11
-------
Appendix B
-------
Appendix B
-------
List of Presenters
(Alphabetical by Last Name)
of Air
Source Testing in the New
Regulatory World Workshop
-------
Source Testing in the new Regulatory World
EPA Workshop
Presenter List
Alphabetical by Last Name
Lara Autry
U.S. EPA - OAQPS
MD-19
RTF, NC 27711
(919)541-5544
(919)541-1039 fax
autry.lara@epamail.epa.gov e-mail
Rima Dishakjian
U.S. EPA - Region 9
75 Hawthorne St AIR-4
San Francisco, CA 94105-3901
(415)744-2336
(415)744-1076 fax
dishakjian.rima@epamail.epa.gov e-mail
Michael Fogle
GA DNR
4244 International Pkwy Ste 120
Atlanta, GA 30354
(404)363-7128
(404)363-7100 fax
Robert Fuerst
U.S. EPA - NERL
MD-46
RTP, NC27711
(919)541-2270
(919)541-3527/0*
fuerst.robert@epamail.epa.gov e-mail
Charles Garlow
U.S. EPA
401 M Street SW (2242A)
Washington, DC 20460
(202)564-1088
(202)564-0068 fax
garlow.charlie@epa.gov e-mail
Bill Grimley
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-1065
(919)541-1039 fax
grimley.william@epamail.epa.gov e-mail
Terry Harrison
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5233
(919)541-1039 fax
harrison.terry@epamail.epa.gov e-mail
William Hunt
U.S. EPA - OAQPS
MD-14
RTP, NC 27711
(919)541-5536
William Lamason
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-5374
(919)541-1039 fax
lamason.bill@epamail.epa.gov e-mail
Thomas Logan
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-2580
(919)541-1039 fax
logan.thomas@epamail.epa.gov e-mail
Gary McAlister
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-1063
(919)541-1039 fax
-------
Sally Mitoff
U.S. EPA
401 M Street SW (2223A)
Washington, DC 20460
(202)564-7012
(202)564-0050 fax
Conniesue Oldham
U.S. EPA - OAQPS
MD-19
RTF, NC27711
(919)541-7774
(919)541-1039/0*
oldham.conniesue@epamail.epa.gov e-mail
Barrett Parker
U.S. EPA - OAQPS
MD-12
RTF, NC 27711
(919)541-5635
(919)541-5509 fax
parker.barrett@epamail.epa.gov e-mail
Michael Pjetraj
NC-DENR
2728 Capital Blvd
Raleigh, NC 27604
(919)733-1469
(919)733-1812 fax
michael_pjetraj@ncair.net e-mail
Gene Riley
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-5239
(919)541-1039/0*
riley.gene@epamail.epa.gov e-mail
Robin Segall
U.S. EPA - OAQPS
MD-19
RTP, NC27711
(919)541-0893
(919)541-1039 fax
segall.robin@epamail.epa.gov e-mail
John Seitz
U.S. EPA - OAQPS
MD-10
RTP, NC 27711
(919)541-5618
Candace Sorrell
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-1064
(919)541-1039/0*
sorrell.candace@epamail.epa.gov e-mail
Jim Szykman
U.S. EPA - OAQPS
MD-13
RTP, NC27711
(919)541-2452
(919)541-0942/0*
szykman.jim@epamail.epa.gov e-mail
Henry Thomas
U.S. EPA - OAQPS
MD-14
RTP, NC27711
(919)541-5273
Mike Trutna
U.S. EPA - OAQPS
MD-12
RTP, NC 27711
(919)541-5345
(919)541-4028/0*
Peter Westlin
U.S. EPA - OAQPS
MD-19
RTP, NC 27711
(919)541-1058
(919)541-1039/0*
westlin.peter@epamail.epa.gov e-mail
Susan Wyatt
U.S. EPA - OAQPS
MD-13
RTP, NC27711
(919)541-5674
(919)541-0942/0*
-------
Appendix C
-------
Appendix C
-------
Mission Statements
Organizational Charts
OAQPS
- EMAD
-EMC
Source Testing in the New
Regulatory World Workshop
-------
Organization
Office of Ail Quality Planning and Standards
US Environmental Protection Agency
Organization Chart (Image)
Mission
The Office of Air Quality Planning and Standards is part of EPA's Office of Air and Radiation. Its
primary mission is to preserve and improve air quality in the United States. To accomplish this, OAQPS
compiles and reviews air pollution data
develops regulations to limit and reduce air pollution
assists states and local agencies with monitoring and controlling air pollution
makes information about air pollution available to the public
reports to Congress the status of air pollution and the progress made in reducing it
See the history of the Office of Air Quality Planning and Standards for some insight into our past.
Strategic Vision
The strategic vision of OAQPS is to provide leadership in achieving the greatest overall health and
environmental benefits through the successful implementation and integration of air programs. Strategic
goals in support of this vision include:
Develop a well rounded and self-assured staff
Effectively communicate the purpose, benefit, and success of our program
Establish and maintain cooperative working relationships with partners and
stakeholders to build consensus
. Use common sense approaches in all things
Director: John beitz
Secretary: Sandy Cahill
OAQPS Organization
Office of the Director
o Office of the Deputy Director
o Policy Analysis and Communications Staff
o Washington Operations Staff
o Planning Resources and Regional Management Staff
Air Quality Strategies and Standards Division
Emission. Monitoring, and Analysis Division
Emission Standards Division
Information Transfer and Program Integration Division
Office of Air Quality Planning and Standards
Mail Drop 10
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
-------
OAQPS Senior Management
Director: John S. Seitz
Secretary: Sandy Trippe
Phone: (919) 541-5616 Fax: 919-541-2464
Deputy Director: Lydia N. Wegman
Secretary: Sherry Russell
Assistant to the Deputy Director: Debbie Stackhouse
Phone: 919-541-5504 Fax: 919-541-2464
Acting Assistant Director for Program Operations: Henry Thomas
Secretary: Sherry Russell
Phone: 919-541-5642 Fax: 919-541-2464
Associate Director, Science/Policy and New Programs: John D. Bachmann
Secretary: Marion Casey
Phone:919-541-5359 Fax:919-541-2464
Director, Policy Analysis and Communications Staff: Jeffrey S. Clark
Secretary: Jan Touma
Assistant to the Director, Policy Analysis and Communications Staff: Polly Hunter
Phone: 919-541-5557 Fax: 919-541-2464
Director, Washington Operations Staff: Anna Duncan
Secretary: Denise Johnson
Program Analysts: Alan Rush. Mary Henegin
Phone: 202-260-5575 Fax: 202-260-0451
Director, Planning Resources and Regional Management Staff: leva G. Spons
Secretary: Rita Vestal
Phone: 919-541-0882 Fax: 919-541-7925
-------
OAQPS Organizational Chart
Officeofthe^ii '$,ป
Deputy Director "
I
Emissions. Monitoring.^*
and Analysis Division" - '
Office;of the Director '
Air Quality Trends
Analysis Group
'Monitoringtetjuality 'J ^
Assurance Group :~r
Air Quality Modeling ''.
Group '
Emission Factor tc j
Inventory Group , v, -
-
^ ^ St. "
Source Characterization *<
' "* , Group A "^< "' "v
w" ' ~
SourcerCharacterization"
GroupB'- < -
I
'v^^&WMBsGroupilll^
Office of the Director
11 Integrated Policy tt ,
- ; Strategies Group >
"
ff-~j-" <(," -.j"" ซ. / VF > *j
7' ^Health Effects ซc^C^
r*^ ^Standards Group -'ซ
ป<^-ป\K^ .*></ซ:<;'-
!> vA'^W^S?'ซ*"* r/.
<.^a-fmซ'Exposure,.^,
V Assessment Group .
-^-.^^ic^r ^jiyv-
'-.-r.
ซ
^^Sft^SWkaStfi:,
V. 'o-ft^,^yt. S*A . ,
^'Innovative Strategies &
-r*> Economics Group - ,
-^"<'* V * '
. .
V"Regional Management S&
tvV/" Staff^Biฎ^!
1
a^Bformatipn'Jrahsfer&'jjJ:?
t'^'X'i DBMMVVcii^ l^k'^i..*^!^^"';' ***
^ * t ป- (
, \ "
x Office of the Director
* * V _l * -
/'Operating Permits Group
,
f .Implementation Group '
" :
v'
.Information Management
^ i< ,^ Group
A^*-yV* ^v "-*t ^^\
^ t^ *t ^ ^ ^ K
.'^Information Transfer *
i&JiOutiMoJ]i Group .
yVA >V ' ^g^i. #** s -TUj
jf Program Review Group
'/'<ซ t ซ.
-------
^^^, f Office of Air Quality Planning and Standards
i***r US Environmental Protection Agency
Emissions, Monitoring,
and Analysis Division
The Emissions, Monitoring, and Analysis Division (EMAD) is responsible for directing a national
program of scientific and technical policy and guidance for EPA Headquarters, Regional Offices, and
State and local agencies, in air quality monitoring and modeling, control strategy demonstrations, and
emissions measurement.
In particular, the Division: develops and distributes guidelines for air quality models and provides
technical assistance in applying the models; develops and distributes guidance on air quality and source
monitoring; establishes air quality indicators of progress, analyzes air pollution trends, and distributes
information on progress in reaching air quality goals; conducts control strategy demonstrations, source
monitoring, and ambient monitoring for OAQPS; develops new methods for ambient monitoring and
modeling and develops and issues guidance and training materials to apply them; develops emission
factors and provides technical guidance on emission inventories; and, conducts source testing and
develops new source test methods for use by Regional, State, and local clients.
The Division analyzes air quality data for use in program evaluation and coordinates development and
use of emission inventories in program evaluation. It promotes the integration and simplification of
information and data management systems. It also serves as a source of technical expertise for OAQPS
and provides technical support to Regional, State, and local clients on source testing and methods.
Two major publications of the Division, released annually, describe the current status and multi-year
trends in emissions and ambient levels of air pollutants. Summaries of the National Air Pollutant
Emission Trends report and the Air Quality Trends report are available on this Web site.
EMAD Organization
Director: Bill Hunt
Secretary: Vacant
Office of the Director
Air Quality Modeling Group
Air Quality Trends Analysis Group
Emission Factor and Inventory Group
Monitoring and Quality Assurance Group
Source Characterization Group A
Source Characterization Group B
-------
EMISSIONS, MONITORING, AND ANALYSIS DIVISION
OFFICE OF THE DIRECTOR
William F. Hunt, Jr., Director
Denise Warren, Secretary
Barbara B. Parzygnat, Program Analyst
Kathy Weant, Contract Liaison Specialist
Vickie Presnell, Contract Liaison Specialist
Fred Thompson (covering for Barbara starting August)
FAX: 1-2357
David Mobley, Associate Director
Cathie Collins, Secretary
Susan Curtis, Management Analyst
Kathy Scon, Administravive Officer
Marion Casey, Clerk Typist*
EMISSION FACTOR &
INVENTORY GROUP
Misenheimer, David
Group Leader
Cleland, Mary
Secretary
Beauregard, Dennis G.
Bromberg, Steven M. + +
Dombrowski, Sally
Driver, Laurel (Detail)
Huntley, Roy
Kuykendal, William B. + +
McMullen, Tom*
Myers, Ronald
Nizich, Sharon V.
Pace, Thompson G..III
Pope, Anne A.
Ryan, Ronald B.
Safriet, Dallas W.
Stella.Greg
Taborn, Mary*
Tooly, Rebecca L. + +
^^^^^^^^^^^SS
Fax: 1-0684
AIR QUALITY
MODELING GROUP
Tikvart, Joseph A.
Group Leader
Winstead, Edna
Secretary
Atkinson, Dennis +
Bailey, Desmond +
Baldridge, (Catherine W.
Black, Annette*
Braverman, Thomas N.
Coulter, Tom
Cox, William M.
Doll, Dennis
Eckhoff, Peter A.
Evangelism, Mark L. +
Highsmith, Bonnie*
Irwin, John+
Jang, Carey
Mersch, Jerry *
Meyer, Edwin L. (Ned)
Orndorff, Brian +
Peters, Warren
Possiel, Norman+
Schultz, Laurel
Touma, Jawad S. (Joe)+
MBMB^^^MM^^MBHBM>^MMHBi^H^^^^H^^MI
Fax: 1-0044
AIR QUALITY TRENDS
ANALYSIS GROUP
Guinnup, David E.
Group Leader
Effle, Deborah
Acting Secretary
Fitz-Simons, Terence R.
Freas, Warren P.
Kilaru.Vasu
Mintz. L. David III
Scarborough, Pearline*
Schmidt, Stephen M.
Thompson, Rhonda L.
Wayland, Michelle
Frechtel, PetenW
Gillespie, LisajW
Detailed:
Sansevero, Christine, OROS
Hemby, James B. Ill, OD
^^^^^^^^^^^^^MHM^^H
Fax: 1-1903
MONITORING AND
QUALITY ASSURANCE
GROUP
Scheffe.Rich
Group Leader
Ferrell, Linda
Acting Secretary
Berg, Neil J.. Jr. + +
Byrd, Lee Ann
Eberly.Shelly
Elkins, Joseph B., Jr.
Frank, Neil H. + +
Gerald, Nash O.
Hanks, Edward J.
Hanley.Timothy
Hinton, Helen*
Homolya, James B.
Jones, Mike (Detail)
Lutz, David
Manire, George L.***
Millar, Brenda
Mustek, David R.
Papp, Michael L.
Peele, Janie*
Rice, Joann
Shanis, Mark
Williams, Jesse*
Watkins, W. Nealson#
**Pitchford, Marc (NV)+
^^^^^^^^VM^BM^^^BM^^^H^M^M
Fax: 1-1903
SOURCE
CHARACTERIZATION
GROUP A
Lamason, William H.,11
Group Leader
McCormick.Corlis
Secretary
Bivins, Daniel G.
Curtis, Foston Jr.
Harrison, Robert T.
Logan, Thomas J.
Peele, Wade*
Ricks, Solomon O.
Segall. Robin R.
Sorrell, Candace B.
Toney, Michael L.
Roeder, Mindy##
Romeas, Virginie*
Detailed;
Dishakjian, Rima N., Region IX
Fax: 1-1039
SOURCE
CHARACTERIZATION
GROUP B
Oldham, Conniesue
Group Leader
Cheek, Lala
Secretary
Autry, Lara P.
Bosch, John C.
Ciolek, Michael K.
Detter, Becky*
Grimley, Kenneth W.
McAlister, Gary D.
Riley, Clyde
Westlin, Peter R.
Detailed:
Lori Tussey, ITPID
Thompson, Fredrick J., OD
^^-^^^^>^
Fax: 1-1039
+ NOAA
+ + Public Health Service
SEE Employee
8SCEP
"Nevada "'Jenkins Road Site ##ECO
^Guest Worker
Revised 10/9/98 (114 Employees)
-------
Emission Measurement Center (EMC)
The Emission Measurement Center, made up of two groups, is responsible for:
Development and advancement of effective and reliable emission measurement
technology; and
Advocating effective use and analysis of emission measurement information and
monitoring technology.
Specifically, the EMC staff:
/ Evaluates and prepares new methods and technology for possible applications as EPA
methods and works with outside groups (including industry, State and local agencies,
equipment vendors, ASTM and ASME) on method development activities.
/ Provides expert technical assistance, including reviewing proposed technical
modifications and alternatives to EPA source test techniques.
/ Develops and implements good field and laboratory practices through new quality
assurance technologies and national standards programs such as the National
Environmental Laboratory Accreditation Committee and EPA's Environmental
Monitoring Management Council.
/ Plans and conducts field test programs to provide quality data in support of regulatory
development consistent with data quality objectives.
/ Evaluates and reviews test programs and results developed by other groups (both EPA,
State/local agencies as well as the private sector) and works with outside groups on test
program development.
/ Provides expert review and evaluation of source characterization data and related
documentation in support of regulatory development programs.
/ Plans and conducts quality assurance programs to provide quality data in support of
regulatory development and compliance programs consistent with data quality objectives
and quality management plans.
/ Issues national rulemakings and guidance on source measurement and monitoring issues,
including new and revised EPA source methods and performance specifications and
broadly applicable source measurement and monitoring requirements.
/ Implements and maintains the compliance monitoring regulations and policies, including
tracking rule effectiveness.
-------
/ Promotes consistency in the application and use of all source measurement and
monitoring technology by providing expert technical assistance on the development of
monitoring policies in areas such as periodic monitoring and continuous emission
monitoring, including guidance on monitoring requirements for permits.
/ Evaluates, reviews and issues appropriate memorandum and policy guidance on
alternative methods. Manages alternative methods decisions information systems and
issues decisions on major alternatives to EPA methods developed by other groups (both
EPA, State/local agencies as well as the private sector), including the review of methods
submitted under Method 301.
/ Provides expert evaluation of data and related documentation in support of regulatory
development programs through statistical analyses of standards and data, including data
submitted from outside EPA.
/ Prepares and disseminates technical guidance and other informational documents, test
methods and procedures, and test report and emission data summaries through the EMC
Internet home page, training workshops, and other media.
-------
Mission Statement
Organization
OECA
Source Testing in the New
Regulatory World Workshop
-------
xvEPA
Audit Policy
Update.
March 1998
Multimedia
Enforcement
Division
(202) 564-6003
Aji
Enforcement
Division
(202) 564-2417
RCRA
Enforcement
Division
(202) 564-4067
Toxics &
Pesticides
Enforcement
Division
(202) 564-4071
Water
Enforcement
Division
(202) 564-2240
Financial
Analysis
Computer
Models
OECA's Office of Regulatory
Enforcement
Eric Schaeffer, Director
Connie Musgrove, Deputy Director
(202) 564-3807
The Office of Regulatory Enforcement enforces our environmental
laws to protect human health and the environment. We also provide
National environmental leadership to deter and correct
noncompliance. We accomplish our mission through the expertise
and commitment of the people in our organization.
In pursuing this mission we will:
Ensure enforcement consistency by developing National
policies, providing legal and technical support and overseeing
Regional enforcement programs.
Manage and develop National enforcement cases and
enforcement initiatives.
Ensure that regulations contain clear and enforceable
provisions.
Develop strong enforcement provisions in the nation's
environmental laws.
Promote multimedia enforcement, pollution prevention, and
environmental justice.
Support and develop our diverse work force and foster job
satisfaction.
Strengthen our enforcement partnerships with the EPA
Regional offices, other EPA offices, States, Territories, Tribes,
the Department of Justice, and other Federal agencies.
With our partners, develop timely, effective and, when
appropriate, risk-based enforcement programs.
Enhance relationships with the public, including citizen groups,
international organizations, and foreign governments to use our
collective expertise in addressing mutual environmental
concerns.
-------
Enviri>$en$e
Air Enforcement Division
ORE's Air Enforcement Division
Mission Statement
Bruce C. Buckheit, Director
(202) 564-2260
The Air Enforcement Division (AED). Office of Regulatory Enforcement, is responsible for judicial and
administrative enforcement activities under the Clean Air Act (CAA) and the Noise Control Act (NCA).
AED ensures the enforceability of rules promulgated under the Clean Air Act, including the 1990
Amendments. The Division provides national direction, leadership, and consistency in case selection.
case development, and resolution and appeal of civil judicial and administrative enforcement actions
pursuant to its statutory authorities.
AED's Mobile Source Program enforces motor vehicle fuels and emissions rules nation-wide. The
Stationary Source Program serves as lead EPA counsel for cases developed by headquarters-managed
programs, including woodstoves, acid rain, and stratospheric ozone protection. AED provides:
Technical, scientific and engineering support, through experts or contracts, to the development
and pursuit of enforcement actions.
Participation in and management of case negotiations, preparation of litigation and settlement
documents, and development and presentation of the Government's cases in administrative and
court proceedings and on administrative or judicial appeal.
A focal point for the coordination of air enforcement issues with the Department of Justice, the
Office of General Counsel and other offices.
The Division is the centerpiece of EPA expertise on all enforcement aspects of the programs related to
the Clean Air Act. AED has the lead responsibility of enforcement related rulemakings and participates
in rulemaking and regulatory interpretation workgroups. AED develops national enforcement policies,
penalty policies, guidance, and outreach, focusing on high-profile enforcement initiatives and innovative
programs. AED develops settlement policies, other policies and activities encouraging pollution
prevention, technology innovation, environmental auditing and environmental justice. AED is
responsible for reviewing Citizen Suits and Amicus Briefs under the Clean Air Act.
AED serves as the legal enforcement counsel on Clean Air Act issues across the Office of Enforcement
and Compliance Assurance sector and other Headquarters programs, and for EPA Regions and the
States. The Division works closely with the other Divisions in the Office of Regulatory Affairs in the
areas of multi-media case management. AED develops and coordinates enforcement initiatives with the
other Offices and Divisions in the Office of Enforcement and Compliance Assurance in the areas of
strategic planning, regulatory applicability determinations, prioritization, and development of
enforcement initiatives.
AED reviews and recommends actions on proposed regulations, programs and policies affecting the
Division's programs to the Director of the Office of Regulatory Enforcement. AED represents its
concerns and interests to other EPA Offices, States, Regions, the regulated community, and public
interest and environmental groups.
-------
&EPA
UniMd SUM
Envlmmtnul Pri.wctlon
Office of Compliance
Elaine Stanley, Director
Bruce Weddle, Deputy Director
(202) 564-2280
COMPLIANCE ANALYSIS, COMPLIANCE
MONITORING, AND
COMPLIANCE ASSISTANCE
Welcome to the Office of
Compliance Home Page!
Office of Compliance Mission: The overriding
mission of the Office of Compliance is to improve
compliance with environmental laws. The Office
of Compliance achieves this by:
Setting national compliance assurance and
enforcement priorities through strategic
planning and targeting;
Collecting and integrating compliance data;
Developing effective compliance monitoring
programs to support inspections and
self-reporting;
Building the capacity for more effective
compliance assistance to the regulated
community;
Improving the quality of regulations;
Working with Regions, States,
municipalities, citizen groups and industry;
and
Supporting enforcement activities.
-------
The Office of Compliance is comprised of four
divisions. The Enforcement, Planning , Targeting
, and Data Division is responsible for strategic
and annual planning to set compliance
assurance and enforcement priorities; State/tribal
grant guidance; targeting for
inspection/enforcement activity; data
management; and integration of compliance and
enforcement data from EPA program offices. The
remaining Divisions are organized by economic
sector. Their mission is to develop strategies to
identify patterns of noncompliance within the
regulated community; support Federal
enforcement actions through inspection guidance
and better compliance monitoring techniques;
and help the regulated community understand
and comply with complex federal requirements.
Enforcement Planning. Targeting & Data
Division- (202)564-2290
Manufacturing. Energy & Transportation
Division-(202)564-7079
Chemical. Commercial Services &
Municipal Division-(202)564-7031
Agriculture & Ecosystem
Division-(202)564-4198
-------
&EPA
United SUtut
Environmental Protection
Agency
Office of Compliance
Manufacturing, Energy And Transportation Division
John B. Rasnic, Director
Richard Biondi, Associate Director
COMPLIANCE MONITORING & COMPLIANCE ASSISTANCE
Welcome to the METD Home Page!
The Manufacturing, Energy And Transportation Division (METD) is charged with developing strategies and
programs that help organize and better explain, through inspection guidance and compliance monitoring
techniques, environmental requirements that affect the regulated community.
METD is organized by economic sectors:
Energy And Transportation Branch
Manufacturing Branch
-
iBlSECTOR FACILITY INDEXING
EPA Aoolicabilitv Determinations Index
Energy and Transportation Sector ;
Petroleum Refining
Power Generation
Transportation
Auto Services & Repair ;
Inspections and Inspector Training i
Radio nuclides
EPA Sector Notebooks !
,._ !
Search ErarLw&Scnse i
Manufacturing Sector
Mining and Aggregates
Apparel
Forest Products
Rubber and Plastics
Primary and Secondary Metals
Metal Products and Machinery
Wood Stoves Program
Initiatives
Common Sense Initiative
Environmental Leadership Program
_ ._ ,
Announcements, News Flashes, and other
_ ._ _ ....... ,
Pilot Project
Information
Energy And Transportation Branch
-------
David Lyons, P.E., Chief
The Energy and Transportation regulates the following sectors: Coal mining, oil/gas extraction,
petroleum refining, transit, transportation (airt land, rail, water), pipelines, electric and gas utilities,
steam production, petroleum bulk storage and terminals, and auto repair/dcalcrs/serviccs.
Industry Sectors
Petroleum Refinine
Transportation
Ifower Generation
aฃL] Auto Services & Repair
Inspections and Inspector Training
Manufacturing Branch
Mamie Miller, Chief
The Manufacturing Branch develops compliance strategies for several industrial sectors including
mining, wood products, metal products, and vehicle assembly. The branch has lead responsibility for
compliance issues under the Clean Air Act (CAA) and the Emergency Planning and Community
Right-to-Know Act (EPCRA). The following information will provide information about the branch's
activities as well provide federal compliance requirements information regarding the aforementioned
industry sectors.
Industry Sector Activities
Clean Air Act Activities
EPCRA Activities
-------
Appendix D
-------
Appendix
-------
Technology Transfer Network (TTN) Web
of Air
Source Testing in the New
Regulatory World Workshop
-------
What File Types Are Available on
TTNWeb?
TTNWeb contains many documents. You will
be able to download or display to your screen
many of these documents. The list below
shows some, but not all, of the file types that
are available on TTNWeb.
A metadata record lor a particular file. These files
display background information for the docu-
ments, including title, subject, related documents,
contacts, regulatory authority, etc.
A PC executable module that can be executed after
downloading by typing the exe name. This may
also be a self-extracting archived file. File exten-
sion name: .exe
An I rfML file that may be viewed within a Web
browser such as Netscape. File extension name:
.html
An Adobe Acrobat file that requires the use of an
Acrobat reader available from Adobe, free of
charge. Readers are available for UNIX, Win-
dows, Macintosh and DOS. TfN currently uses
Acrobat Reader version 3.0. File extension name:
.pdf
ASCII text files that can be read on the screen or
downloaded and processed with a word processor
or text editor. File extension name: .txt
WordPerfect files. File extension name: .wpd
Dbase File. File extension name: .dbf
Zipped (Compressed) Files. Windows programs
are available to decompress these files. File
extension name: .zip
Technology Transfer Network
Sponsored by
Office of Air Quality Planning and Standards
U.S. EPA(MD-12)
Research Triangle Park, NC 27711
EPA's Premier Technical Web site
for Information Transfer
TTN Access Information
INTERNET/ World Wide Web
Home Page:
http://www.epa.gov/ttn
Can I Get Assistance with Using TTN?
Each Web site within the TTNWeb has its own
webmaster. If you have questions or comments about the
site, you can click on the "contact webmaster" or
"comments" link at the bottom of one of that site's web
pages.
If you have questions or problems using TTNWeb, please
feel free to call the TTN Help Desk at 919-541-5384.
(Please note that this is a toll call.) This desk is manned
during the hours of Sam to 5pm EST, Monday through
Friday. There is a voice mail system for times when the
help desk personnel are unavailable, and all calls will be
returned providing you leave accurate contact informa-
tion. We will be happy to answer your questions or direct
you to an appropriate EPA information source or service.
This project has been funded wholly by the United Stales Environmental Protection
Agency The contents of this document do not necessarily reflect the views and
policies of the Environmental Protection Agency, nor does any mention of trade
names or commercial products constitute endorsement or recommendation of use.
vvEPA
^Mf>f^:"^^Y^
Office o^PKr Quality
Planning & Standards
nology
rahsfer
etwork
Printed on Recycled Paper
U.S. Environmental Protection Agency EPA-456/F-98-003
Research Triangle Park, NC 7/98
-------
What is OAQPS and TTN?
The Office of Air Quality Planning and Standards is a
vital pail of EPA's Ollicc of Air and Radiation. Its primary
mission is to preserve and improve air quality in the
United States. To accomplish this, OAQPS compiles and
reviews air pollution data, develops regulations to limit
and reduce air pollution, assists states and local agencies
with monitoring and controlling air pollution, makes
information about air pollution available to the public, and
reports to Congress the status of air pollution and the
progress made in reducing it.
'llic Technology Transfer Network is a section of the
EPA Web site system developed and operated by OAQPS.
The primary mission of the TTN is to promote access to
OAQPS leclinical data in a one-stop shopping center. The
1TN has evolved from an electronic bulletin board system
to the more professional and reliable World Wide Web
electronic data deliver)' system. The TTN is dedicated to
provide public access to OAQPS data/products via the
Internet. The Internet provides the most up-to-date, user
friendly access method available to encourage pro-active
outreach for OAQPS data products. The Internet version
of the TTN is known as the TTN Web.
Who Should Use TTNWeb?
Anyone in the world who has a need to obtain tccluiical
information about air pollution, including personnel in
stale and local agencies, the private sector, HPA, and
foreign countries will find the TI'NWeb to be an invalu-
able resource.
How Do I Access TTNWeb?
Accessing TI'NWeb is as simple as accessing any site on
the World Wide Web. All you have to do is establish your
Internet connection, start your browser, and enter the
'ITNWeb address into your browser. The web address for
TTNWeb is www.epa.gov/ttn.
Once your connection is established, you have access to all
the tools, technology, and information in any of the
technical areas available at your fingertips. You can find
tools to estimate pollutant emissions, download computer
code for regulatory air models, or download the latest
regulations atul^^^iscd rules from the Policy and
Guidance site.
What Sites Arc on TTNWeb?
The following technical sites are all available on Ti'Ntl'eb.
You can reach the page with the most current listing by
selecting Technical Sites from the JTNH'eli main page.
AIRS AIRS is the repository of air quality related
information submitted by Stale and local agencies. The
AIRS 'ITN contains important teclinical information that
State and local agencies need to utilize AIRS in an effective
manner. Information includes key guidance meinos on data
reporting requirements, procedures to implement new
system features, AIRS newsletter, list of contacts, user
manuals and the like
AMTIC The Ambient Monitoring Technology Informa-
tion Center contains information and files on ambient air
quality monitoring programs, details on monitoring
methods, relevant documents and articles, information on
air quality trends and nonattainment areas, and federal
regulations related to ambient air quality monitoring.
CHIEFThe ClearingFIouse for Inventories and Emission
factors contains the latest information on emission
inventories and emission factors. It provides access to the
latest information and tools for estimating emissions of air
pollutants and developing air emission inventories.
CATC The Clean Air Technology Center serves as a
resource for all areas of emerging and existing air pollution
prevention and control technologies, and provides public
access to data and information on their use, effectiveness,
and cost. CATC includes RACT/I3ACT/LAER Clearing-
house (RI3I.C).
CICA The U.S. - Mexico Information Center on Air
Pollution (Ccntro de Informacion sobre Conlaminacion de
Aire-CICA) provides technical support and assistance in
evaluating air pollution problems along the U.S.-Mexico
border. CICA is sponsored by the EPA's Clean Air Tcclinol-
ogy Center (CATC).
EMC The Emission Measurement Center provides
access to emission test methods and testing information for
the development and enforcement of national, state, and
local emission prevention and control programs.
GEIThe Geographic/Ecosystems Initiatives are
geographically focused environmental activities which
leverage the resources of stales, local governments,
regulated communities, environmental groups, and
citizens.
ICCR 'Hie Industrial Combustion Coordinated
Rulemaking Web site serves as the primary mode of
communication among the various workgroups and the
Coordinating Committee involved with the development
of this regulation.
NELACThe National Environmental Laboratory
Accreditation Conference promotes acceptable perfor-
mance standards for the operation of environmental
laboratories.
NSR The New Source Review (NSR) Web site is
designed to provide material and information pertaining
to NSR permitting.
OAR P>he OAR Policy and Guidance Web site is
designed to provide access to rules, policy, and guidance
documents produced by the US EPA Office of Air and
Radiation (OAR).
OTAG The Ozone Transport Assessment Group is a
national workgroup that addresses the problem of
ground-level ozone (smog) and the long-range transport
of air pollution across the I-astern United Stales.
SBAP 'Hie Small Business Assistance Program has
been developed to help slate and EPA small business
assistance programs share information about their
materials and activities.
SCRAM The Support Center for Regulator)' Air
Models is a source of information on atmospheric
dispersion (air quality) models that support regulatory
programs required by the Clean Air Act.
UATW The Unified Air Toxics Web site is a coopera-
tive Web site for Federal/Stale and local air toxics
programs and central repository lor air toxics intomia-
lion.
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Appendix E
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Appendix E
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RTPMap
Sheraton Imperial Map
Imperial Athletic Club
List of Restaurants with Map
_ of Air
-
Source Testing in the New
Regulatory World Workshop
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?5as
The Sheraton Imperial Hotel and Convention Center is centrally
located in Research Triangle Park, 15 minutes from Raleigh,
s)urham and Chapel Hill off Interstate 40. The hotel is live minutes
from Raleigh-Durham International Airport. The Sheraton provides
complimentary 24 hour transportation to and from the airport. We
have over 1,000 parking spaces available at no charge.
The Sheraton Imperial is a full service hotel featuring 331
newly renovated guest rooms, new 25" color
TY's with remote control, AAI/FM clock \miuborough
radios with alarms, coffee makers, hair dryers,
full-size ironing boards and irons, voice mail in
evenr room, ESPN/complimentary Showtime and
"On-demand" movies.
The Concierge Level offers continental breakfast. IBM
compatible computer and express check-out. In the
evening, we offer complimentary drink coupons &
hors d'oeuvres, turn-down service and upgraded
amenities in room.
Cascades Restaurant offers casual dining with a wide
variety of menu selections. Seating capacity 163 (Daily
Breakfast Buffet). Cocktails are served in the Lobby Bar
where you can relax and enjoy live piano music.
A 34,000 square foot Athletic Club includes:
Racquetball courts, gym for basketball/volleyball, lap
Other Points of Interest:
Prestigious Universities close by-10 - 20 minutes
Various Professional Golf Clubs -10 - 20 minutes
Arts Center. Museums and convenient Shopping
Centers, all within 10-20 minutes
Triangle Area
Map
pool. Jacuzzi, nautilus & life circuit equipment, 2 aerobic studios,
^treadmills, stair climbers, rowing machines, life cycles. There is a fee to
iise if you are a guest in the hotel.
We offer lighted tennis courts and lighted 2-1/2 mile jogging trail,
outdoor pool and Jacuzzi. Gift Shop open 7:00 a.m. to 10:00 p.m.
For your convenience a USAToday newspaper is delivered to your
room Monday through Friday.
HOTEL & CONVENTION CENTER
RESEARCH TRIANGLE PARK. NC
1-40, EXIT 282-PAGE ROAD
Knlghtdalt
Fuquay-Varina
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Convention Center
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Gift Shop
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Imperial Convennon Center
Pre-Function Lobby
Phone*
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ial AfHetic Club
Open 7 Days A Week Monday-Friday:6am-1 Opm Saturday/Sunday: 8am-7pm 941-9010 833-4036
AEROBIC STUDIO FITNESS CENTER
The Triangle's Largest
3800 Square Feet
Over 45 Exercise Classes Weekly
including:
- STEP - Toning
- Hi/Low Impact - Yoga
- AB Workout - Karate
CARDIOVASCULAR EQUIPMENT
Lifecycles
Monarch Bikes
Lifesteps/Stairmasters
Liferowers
Precor Treadmills
Trackmaster Treadmills
BASKETBALL/VOLLEYBALL GYM
Regulation Courts
Basketball Challenge Courts
Coed Volleyball
Tournaments/Leagues
RACQUETBALL
Challenge Court
Racquetball Lessons/Clinics
Tournaments/Leagues
Walleyball Programs
LifeCircuit
Chrome Nautilus Circuit
2000 Square Feet - Free Weights
Universal Multi-Gym
Personalized Exercise Program
INDOOR SWIMMING POOL
25 Yards
Lap Swimming
Water Exercise Classes
Swimming Lessons For Adults & Children
Outdoor Sundeck
Coed Jacuzzi
FITNESS CONSULTATION AND TESTING
Cardiovascular Condition
Muscular Strength
Muscular Endurance
Body Fat Percentage
Flexibility
Blood Pressure
Heart Rate
Exercise Prescription
NURSERY
Trained Staff
Children's Aerobics Classes
Children's Programs
LOCKER ROOMS
Locker & Towel Service
Steam Room & Sauna
TV Lounge
TURN PAGE FOR
SPECIAL OFFER
FOR WORKSHOP
PARTICIPANTS!
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The Imperial Athletic Club is
offering Source Testing
Workshop participants a
special rate of $9 per day for
unlimited use of their facilities.
This is a $6 discount from
their usual rate of $15 per day!
To take advantage of this
discount, buy your Athletic
Club pass from the Sheraton
Imperial front desk. A current
pass must be shown when
checking in at the Athletic
Club.
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RESTAURANTS LOCATED AT HIGHWAY 54/55
The following restaurants are located near exit 278 off of 1-40:
Triangle Village (TV)
Research Triangle Park
Shor Szechuan
544-3629 Chinese
U.S. Market Rotisserie
484-8040 American
Arby's
Pizza Hut
Jersey Mike's Subs
Taco Bell
Triangle Square (TS)
Fazoli's
Italian
Jamaica Jamaica
544-1532
Ginger Inn
544-7660 Chinese
North on H\vy 55
China One
361-3388 Chinese
Waffle House
544-4204 Breakfast Only
Park West Crossing (PWC)
Brigs at the Park Restaurant
544.7473 Homestyle
El Dorado
361-0302 Mexican
Java Republic Coffeehouse
361-0055
Greenwood Commons (GC)
Fortune Garden Restaurant
544-6009 Chinese/Thai
Country Junction
Southern/barbecue
O'Briens
3484-1742 SoutheiWbarbecue
Jacarandas Restaurant
544-2713 Mexican
Bojangle's
Miami Subs Grill
Burger King
It's A Wiener
McDonald's
Wendy's
Miami Grill
Philly Steak Factory
Papa John's Pizza
Highway 54
Sal's Restaurant
544-1104 Italian
Bombay Grille Restaurant
544-6967 Indian
Scholtzsky's
544-4927 Deli
Kentucky Fried Chicken
Food Court:
Hunam Express 544-3532
Philly Subs
South of Park West Crossing
on Hwy 55
Golden Corral Steak House
544-2275
Hong Kong Express
LeCoco Restaurant
544-5330 Homestyle
Lucia Ristorante
544-9196 Italian
Sara's Empanadas
544-2441 Mexican
Park Diner
405-2270 Lunch Deli
The Sheraton shuttle will take guests to the Angus Barn Steakhouse and to the Triangle Mall Food Court. Make
arrangements with hotel front desk.
Delivery:
China Express (Call Guest Services for menu) 544-7013 or 544-6702
Pizza Hut 361-2728
Domino's Pizza 544-1751
Papa John's Pizza 484-7766
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Downtown Durham Restaurants
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\. Anotherthyme
109 NGregson St. 682-5225
Multicultural seasonal cuisine
2. Aramark at North Carolina Mutual
411 W Chapel Hill St. 682-9201
Cafeteria (Lunch)
3. The Jerk Pit Cafe
317 W. Main St 680-4336
Caribbean food
4. Bull City Cafe
104 W.Parrish St. 682-9129
Lunch only
5. Bull City Subs
914 W. Main St. 688-2297
Subs, sandwiches
6. Brightleaf905
905 W. Main St. 680-8848
Old & new world cuisine
7. Caflfe del Popolo
300 W. Morgan St. 680-0276
Breakfast & lunch only
8. Durham Cafe
200 E Main St. 682-8731
Breakfast & lunch only
9. Dawson's
105 W. Main St. 688-7971
Lunch only
10. Devine's Restaurant & Sports Bar
904 W. Main St. 682-0228
Sandwiches
11. The Dog House
501 Foster St. 688-9400
Breakfast & lunch only
12. Down Under Pub
802 W. Main St. 682-0039
Deli/pub fare
13. El Rodeo Mexican Restaurant
905 W. Main St. 683-2417
Mexican
14. Fishmonger's
806 W. Main St. 683-0128
Seafood/oyster bar
15. FJ's Emporium
106 Morris St. 682-6455
Breakfast & lunch
16. Fowlers Gourmet Grocery
112 S. Duke St. 683-2555
Gourmet
17. Hunam Chinese Restaurant
910W. Main St. 688-2120
Chinese
18. J's Snack Shop at CCB
335 W. Main St. 956-8438
Breakfast & lunch
19. James Joyce Irish Pub
912 W. Main St. 688-6189
Irish Pub
20. Jimmy's Bagel Bakery
335 W. Main St. 682-8826
Breakfast & lunch
21. King's Sandwich Shop
701 Foster St. 682-0071
Breakfast & lunch
22. McDonald's
102 Morgan St. 688-3070
Fast food
23. Ninth Street Bakery Downtown
136-G E. Chapel Hill St. 688-5606
Pastries
24. Cafe 201
201 Foster St. 683-6664
American cuisine
25. Papa John's Pizza
1018 W. Main St. 682-7272
Pizza
26. Pizza Hut
100W. Main St. 683-3223
Pizza (take-out & delivery)
27. Plaza Restaurant
101 E. Chapel Hill St. 682-8991
Sandwiches
'28. Pop's
810 W. Peabody St. 956-7677
Italian
29. Ron's Food
110 E.Parrish St. 683-2057
Breakfast & lunch
30. Satisfaction Restaurant & Bar
905 W. Main St. 682-7397
Lunch & dinner
31. Tobacco Roadhouse Restaurant
115 N. Duke St. 688-4505
Lunch & dinner
32. Talk of the Town
108 E. Main St. 682-7747
American cuisine
33. TavemaNikos
905 W. Main St. 682-0043
Greek cuisine
34. The Thyme Table
427 W. Main St. 683-1414
Lunch
35. Torero's
800 W. Main St. 682-4197
Mexican
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