of Air



The Emission Measurement Center
                     Presents

     Source  Testing
           in  the New
  Regulatory  World
  Sheraton Imperial Conference Center
         Research Triangle Park, INC

            November 2 - 4, 1998
  $EPA
      Emission Measurement Center
Emissions, Monitoring, and Analysis Division
 Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711

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                     WORKSHOP  EVALUATION
            Please return Workshop Evaluation to the registration desk by noon
            on Wednesday, November 4th.
1.   Length of Workshop:     	Adequate  	Too Long  	Too Short

2.   Workshop Facilities:      	Adequate  	Needs Improvement (in what areas);
3.  Selection of Topics:	Adequate      	Inadequate
                                                                 Other Topics of Interest;
4.  What did you like about the workshop?
5.  What did you dislike about the workshop?
6.  Which topics would you have liked covered in more depth;
7.  Should the presentation level be more technical or less technical?
8.  Was the workshop format useful for you? If not, what do you recommend?
9.  What were your goals for attending?  Were they met?
10. With what frequency would you like the workshop to be repeated?

11. On a scale of one to fivซ wher* '"?" v "—>t    "   %      T ^  f

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                                                                        Comments
VOC Methods Application, Guidance
    - Method 25 versus 25A/25B versus 18
    - Capture Efficiency Guidance
    - Reporting VOCs
Open Discussion of Technical Presentations
     2345
     2345
     2345
     2345
DAY 2

MACT Rule Development
    - Role of EMC in MACT Development               12345
    - MACT And Other Air Toxic Emission Standards    12345
    - MACT Test Methods Rule Format                12345
    - MACT Monitoring  For Compliance                12345

MACT Test Methods Review
    - Methods 306, 306A & 306B for Chrome Plating   12345
    - FTIR Methods                                  12345

Approval of Alternative Test Methods and Monitoring
    - Alternative fvi-.ihods Policy & Approval Process    12345
    - Examples of Recent Alternative Approvals         12345
    - Method  301  Revisions, Guidance                 12345
    - Method  Precision Evaluation (POU                12345
    - Environment! ';,ohnology Verification            12345
Continuing the Infoim-stlon Exchange Workshop
    - EPA, EMC Perspc-Uv;                           1
    - EPA, OAQPS Perspective                        1
    - EPA, OECA Perspe:,Hy-                         1
    - State Agency Perspfetr- ;•                       1
      2345
      2345
      2345
      2345
The information Exchange Opsfs Discussion             12345
DAY 3
MACT implementation Issues
    -  iViACT/Titie V interface Issues
    -  Flexible Permits
    -  MACT and Enforcement issues
    -  MACT and SIP interface
   CT implementation Open Discussion
      2345
      2345
      2345
      2345
      2345
   12345
Name
Tills
Telephone number_
Agency 	

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Source Testing in the New Regulatory World
                 Workshop
         EPA Contract No. 68-D-98-046
                 Prepared for:

            Clyde E. Riley (MD-19)
        Source Characterization Group B
  Emissions, Monitoring, and Analysis Division
  Office of Air Quality Planning and Standards
      U.S. Environmental Protection Agency
  Research Triangle Park, North Carolina 27711
                 Prepared by:

        TRC Environmental Corporation
        6340 Quadrangle Drive, Suite 200
        Chapel Hill, North Carolina 27514

             Under subcontract to:

              EC/R Incorporated
          2327 Englert Drive,  Suite 100
              Durham,  NC 27713
                November 1998

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         Welcome
         Preamble
 Table of Contents
  List of Acronyms
Workshop Agenda
       Source Testing in the New
      Regulatory World Workshop

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                                  us  EPA Workshop

               SOURCE TESTING IN THE NEW REGULATORY WORLD

   	GENERAL WORKSHOP INFORMATION	


Welcome to the Source Testing in the New Regulatory World Workshop!

The  workshop  registration desk  will  be open  during  conference  hours for
registration and information.  A message board with a lost and found area is also
located in the registration area.  If you have any  questions or need assistance,
please check with the workshop staff.

Refreshments will be available in the  Empire D and E Prefunction Area during the
morning and afternoon breaks (see agenda for scheduled break times).

For incoming calls, the Sheraton's main telephone number is (919) 941-5050; for
telefax transmissions, use (919) 941-5156.

A list of local restaurants is at the registration  desk.  In  addition, the Sheraton
shuttle will provide transportation for  hotel guests to the Triangle Morrisville Mall
(shopping  and fast food restaurants)  and the Angus Barn Steak House.  Please
check with the hotel's front desk for departure times.

We hope you have a productive and enjoyable stay  in the Triangle area!

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     Preamble to the Emissions Measurement Center Information Exchange Workshop
                        Source Testing in a New Regulatory World
The 1990 Clean Air Act Amendments (CAAA) have changed much about the business of regulating air
pollution control. Among the changes is an increased emphasis on the frequent and accurate measurement
of toxic air pollutants from a wide variety of source types and operations. This emphasis has led to the
relatively rapid development of new test methods and application of existing methods to new situations.
Other regulatory approach changes have led to new development and broader application of continuous
emission monitoring systems. Some of the changes brought about by the CAAA were unanticipated and
have led to significant questions from  both the regulator and the regulated communities about how
emission testing and  monitoring methods are applied and how such data are used in compliance and
enforcement decisions.

We in the Emission Measurement Center (EMC) of the Office of Air Quality Planning and Standards
(OAQPS) provide an important focal  point for responding to these questions. In our continuing effort to
advance the field of emission measurements and communicate those advancements to the user-community,
we have organized this workshop. Our purpose for the workshop is to provide a forum for relaying
technical information on new and developing emission testing and monitoring procedures, and for
discussing additional needs in the emission measurement area.

The intended audience for the workshop is you, our partners in this effort, the EPA and state and local
agency professionals  who conduct, observe, prescribe, and rely on emission testing and monitoring in
implementing air pollution control programs.

The topic areas in the workshop include recent method development activities for measuring hazardous
or toxic air pollutants.  We in EMC and other EPA offices will describe developments and application of
methods for organic  and inorganic toxic air pollutants including the use of FTIR instrumentation. In
addition, we intend to address developments for fine particulate emissions measurements, for organic vapor
capture efficiency testing, and on the use of instrumental test methods. Also on the agenda will be
discussions of how alternatives to existing methods are proven and approved.

We have also included  on the agenda presentations by staff from other EPA offices and from state and local
agencies to address topic areas related to emission measurement. These include the status of regulatory
development in OAQPS and the evolving standardized format for monitoring in new MACT regulations.
There will also be discussions of how the requirements of new rules are incorporated and implemented
through the operating permits program (i.e., Title V) and how compliance and enforcement decisions are
affected by measurement results. The auditing of the accuracy and reliability of measured data will also be
discussed.

The format for the workshop is intended to encourage the interchange of ideas. We have included time for
you to engage the presenters and  other participants on each  presentation topic. In addition, we have
designated moderated discussion periods to promote open and free exchange of ideas on testing problems,
needs, and suggestions for improvements. We have arranged this workbook to include copies of the
presentations and, where available, additional technical support material for your use during and following
the workshop.

We look forward to a fruitful two and a half days devoted to an exchange of ideas and information that will
help us all improve and advance the emission measurement field.

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     . ol Air
                                    U.S. EPA Workshop

               SOURCE TESTING IN THE NEW REGULATORY WORLD

                               Table of Contents

Title                                                               Presentation

Welcome
Preamble
Table of Contents
List of Acronyms
Workshop Agenda

Opening Remarks
       - Welcome
       - Introduction

Keynote Address

EMC Test Method Development Activities	   1
Stationary Source Compliance Audit Program (SSCAP)

Fine Particulate Measurements	  2
       - Filterable and Condensible Particulate

Performance-Based Measurement System	'.	  3

Instrumental Methods: Review of Current Projects and Guidance  	  4
       - Reference Test Methods
       - Portable Emission Analyzers

VOC Methods Application & Guidance  	  5
       - Method 25  versus 25A/25B versus 18
       - Capture Efficiency Guidance
       - Reporting VOCs

MACT Rule Development  	  6
       - Role of EMC in MACT Development
       - MACT And Other Air Toxic Emission Standards
       - MACT Test Methods Rule Format
       - MACT Monitoring For Compliance

MACT Test Methods Review	  7
      - Methods 306, 306A, & 306B for Chrome Plating
      - FTIR Methods
                                                                         Page 1

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                             U.S. EPA Workshop

        SOURCE TESTING IN THE NEW REGULATORY WORLD

                          Table of Contents (Continued)


Title                                                                Presentation

Approval of Alternative Methods and Monitoring  	  8
       - Alternative Methods Policy and Approval Process
       - Examples of Recent Alternative Approaches
       - Method 301 Revisions, Guidance
       - Method Precision Evaluation (PQL)
       - Environmental Technology Verification (ETV)

Continuing the Information Exchange Panel  	  9
       - EPA, EMC Perspective
       - EPA, OAQPS Perspective
       - EPA, OECA Perspective
       - State Agency Perspective

MACT Implementation Issues	  10
       - MACT/Title V Interface Issues
       - Flexible Permits
       - MACT and Enforcement Issues
       - MACT and SIP Interface

                               List of Appendices

Appendix A  List of Participants

Appendix B  List of Presenters

Appendix C  Mission Statement
            Organization
            -OECA
            Mission Statements
            Organizational Charts
            - OAQPS
              -EMAD
              -EMC

Appendix D  Technology Transfer Network (TTN) Web

Appendix E  RTF Map
            Sheraton Imperial Map
            List of Restaurants with Map
                                                                          Page 2

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                                                  U.S. EPA Workshop
                             SOURCE TESTING IN THE NEW REGULATORY WORLD
                               ACRONYMS USED IN EMISSION MEASUREMENT
                                        DISCUSSIONS AND REGULATIONS
AA(S)          Atomic absorption (spectroscopy) - analytical technique for metal ions.

ACME         Accreditation  and Certification  for the Measurement  of Emissions - EPA  developed program for
               accreditation of emission testing companies and certification of source testing personnel on a national
               basis.

ACS           American Chemical Society.

AISI           American Iron and Steel Institute.

AIRS          Aerometric Information Retrieval System - database for air pollution measurement data.

ANPR          Advanced  notice  of proposed rulemaking - an announcement vehicle for regulation appearing in the
               Federal Register.

ANSI          American National Standards Institute.

APTI          Air Pollution  Training  Institute -  organization in  OAQPS responsible for providing training for
               implementing air  pollution regulations.

AP-42          The  document codifying the emission  factors  for stationary sources,  available from  the  Emission
               Inventory Branch in OAQPS.

AQMD         Air Quality Management Division -  organization in OAQPS responsible for requirements and guidance
               for developing SIPs.

ARD          Acid Rain Division - organization in  EPA responsible for implementing the acid rain regulations (40 CFR
               Part 75).

AREAL        Atmospheric Research and Exposure Assessment Laboratory - the part of the EPA's Office for Research
               and Development responsible for research on air pollution test methods.

ASME          American  Society of Mechanical Engineers - a professional organization that publishes guidance and
               protocols  for evaluating  process operation, efficiencies, and emission  measurements  among other
               industrial support activities.

ASTM          American Society for Testing and Materials - a professional organization that publishes standard methods
               and performance  criteria often incorporated by reference in EPA regulations and methods.

AWMA        Air and Waste  Management Association  -  a  professional organization that  coordinates  technical
               information dissemination on environmental issues through workshops, conferences,  publications, and
               other outreach activities.
                                                                                                   Page 1

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                               (continued)
BACT          Best available control technology - the basis for establishing emission limits for major existing sources
               of hazardous compounds.

BBS            Bulletin Board System - functional unit of the OAQPS Technology Transfer Network (TTN).

BOAT          Best demonstrated available technology.

BIF            Boilers and industrial furnaces - source category burning hazardous waste materials covered  by OSW
               regulations.

BUS           BACT/LAER Information System (one BBS of TTN).

BTEX          Benzene,  toluene, ethyl benzene,  and  xylene.

Btu            British thermal unit - measurement unit of heat often used in emission standards, e.g., Ib/MMBtu or
               pounds of emission per million Btu.

BTX           Benzene,  toluene, and xylene.

CAAA         Clean Air Act Amendments of 1990.

CAM           Compliance Assurance Monitoring -  rule identifying monitoring requirements for Title V,  Part 70,
               permits.

CEMS          Continuous emission monitoring system - the equipment for the sampling, analysis, and data reduction
               of gaseous emissions measurements on a continuous basis.

CERMS        Continuous emission  rate monitoring system - the  equipment for the sampling,  analysis,  and  data
               reduction of stack emission rate (e.g., Ib/hr) on a continuous basis.

CFC           Chlorofluorocarbon.

CFR           Code of Federal Regulations - codification of all Federal regulations divided by titles and parts.  Title
               40 contains essentially all of the environmental regulations.

CNAEL        Committee on National Accreditation of Environmental Laboratories - organized by EPA to address a
               national accreditation  of laboratories doing environmental analyses.

COMS         Continuous opacity monitoring system - the equipment for the sampling, analysis, and data reduction of
               stack opacity measurements on a continuous basis.

CMA           Chemical Manufacturers Association.

CPB           Chemicals and Petroleum Branch - operations and emissions data collection branch in ESD.

CPMS          Continuous parameter monitoring system - the equipment for measurement of a control device or process
               operating parameter or other conditions to correlate with source emissions.

CPM           Condensible paniculate matter as measured with Method 202 involving analysis of back half of Method
               5 or 17 sampling train.
                                                                                                    Page 2

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                                (continued)
CRADA        Cooperative Research  and Development Agreement  - vehicle used by EPA and industry to combine
               resources for environmental studies.

CRM          Certified reference material - an audit material, usually calibration gas certified by the National Institute
               for Standards and Technology to be of known quantity or value.

CTC           Control Technology Center - EPA organization providing technical assistance on the selection, operation,
               and design of air pollution control equipment (one BBS of TIN).

CTG           Control technology guideline -  document produced by EPA to assist regulatory agencies and private
               industry select  and operate affective pollution control equipment.

CVAAS        Cold vapor atomic absorption spectroscopy - analytical technique for mercury and other metal ions.

DAR          Data assessment  report - report for the responsible enforcement agency prepared by regulated sources
               that quantifies  emission status, usually quarterly.

DQO          Data quality objectives.

ECD           Electron capture  detector - analytical technique used in gas chromatography.

EIB            Emission Inventory Branch - TSD organization responsible for publishing AP-42.

EGR           Exhaust gas recycle - used in extractive PM-10 sampling train to maintain constant sample flow through
               separator.

ELCD          Electroconductivity detector (Hall detector) - analytical technique used in gas chromatography.

EMB          Emission Measurement Branch - About 30 people in OAQPS responsible for developing and publishing
               emission test methods,  collecting and evaluating emission data in support of regulatory development, and
               providing technical guidance on the application of test methods.

EML          Emission Measurement Laboratory - location in RTP for the EMB.

EMMC        Environmental Monitoring Management Council -an EPA workgroup involving all of the program offices
               in evaluating the  Agency's measurement procedures and research programs.

EMM!          Environmental Monitoring and Measurements Index - a personal computer based information file of all
               the EPA methods used for environmental measurements.

EMRD         Enhanced Monitoring  Reference Document - background guidance document  providing support for
               implementing the enhanced monitoring and compliance certification regulations.

EMTIC        Emission Measurement Technical Information Center - the information center in EPA responsible for
               providing guidance and technical assistance for stationary source emission test methods.

EPA           Environmental  Protection Agency, U. S. Government and some states.

EPRI          Electric Power Research Institute - research organization representing the utility industry interests.
                                                                                                    Page 3

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                                (continued)
ESD           Emission Standards Division - organization in OAQPS responsible for publishing the stationary source
               emission regulations.

ETO           Ethylene oxide.

FCCU          Fluid catalytic cracking unit - device used in SOCMI and' petroleum refining.

FGD           Flue gas desulfurization - SOX emission control device often used at fossil fuel fired utilities.

FIA or FID     Flame  ionization analyzer or detector - analytical technique for organic compounds for total organic
               compounds or as the analytical technique with gas chromatographic separation.

FLAA          Flame  atomic absorption.

FPD           Flame  photometric detector -  analytical detector for organic compounds.

FR            Federal Register - publication vehicle for Federal regulations printed daily.

FTIR          Fourier transform infrared.

GC            Gas chromatography.

GC/MS        Gas  chromatography/mass spectrometry  - Highly  specific  analytical technique used for organic
               compounds.

GFAA(S)       Graphite furnace atomic absorption (spectroscopy) - analytical method for metal  ions.

GFC           Gas filter correlation - analytical technique usually applied  in the IR for TRS.

HAPs          Hazardous  air pollutants - compounds listed in Title III of the  1990 CAAA as the major air toxic
               pollutants.

HAZMAT      Hazardous  materials - used in conjunction with hazardous waste incinerator testing.

HPLC          High performance liquid chromatography.

HRGC/HRMS  High resolution gas chromatography/high resolution mass spectrometry - highly sensitive analytical
               technique for dioxin and furans.

HON          Hazardous  Organic National Emission Standard for Hazardous Air Pollutants - a regulation in Title 40,
               Part 63, of the CFR addressing the control of hazardous organic emission from some 40 processes in the
               synthetic organic chemical manufacturing  industry.

HWI           Hazardous  waste incinerator.

1C             Ion chromatography - analytical technique for anions and cations.

ICE            Internal combustion engine.

ICAP          Inductively-coupled argon plasmography - analytical technique for metal ions.
                                                                                                    Page 4

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                               (continued)
ICPCR         Ion chromatography with a post  column reactor - analytical technique  specifically for hexavalent
               chromium.

IP A            Isopropyl alcohol.

IR             Infrared radiation range.

ISB            Industrial Studies Branch  - operations and emissions data collection branch  in ESD.

ISO            International Standards Organization - Multinational organization that develops and publishes measurement
               criteria and performance standards.

LAER          Lowest achievable emission rate - basis for HAP emission limits for existing sources under CAAA.

LFG           Landfill gas.

LOD           Limit of detection.

LOQ           Limit of quantitation.

LRMS          Low-resolution mass spectrometry.

LUST          Leaking underground storage tanks.

MACT         Maximum achievable control technology - the basis for establishing emission  limits for major new sources
               of hazardous compounds subject to rules under CFR Title 40,  Part 63.

MM5          Modified Method 5 - extractive adsorbing emission sampling train for the measurement of volatile organic
               compounds, usually toxic or hazardous compounds, with boiling points over about 130ฐC.  Analysis is
               by GC/MS.  Called Method 0010 in SW-846; also labeled semi-VOST method.

MS            Mass spectrometry - highly specific analytical method for organic and inorganic compounds.

MWC          Municipal waste combustor.

MWI           Medical waste incinerator.

NAAQS        National Ambient Air  Quality Standard.

NAPAP        National Acid Precipitation Assessment Program.

NCASI         National Council for Air and Stream Improvement - research organization supporting environmental
               efforts for the pulp and paper industry.

NDIR          Nondispersive infrared spectroscopy - narrow band infrared absorption.

NESCAUM     Northeast States for Coordinated Air Use Management - organization representing state environmental
               agencies from the Northeast U.S.
                                                                                                   PageS

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                               (continued)
NESHAP       National Emission Standard for Hazardous Air Pollutants - regulations found in Part 61 and 63 of Title
               40 of the CFR.

NIOSH         National Institute for Occupational Safety and Health.

NIST          National Institute for Standards and Technology - Federal organization responsible for evaluating and
               setting performance and design standards for measurements (formerly NBS).

NMOC         Nonmethane organic compounds - volatile organic compounds other than methane.

NO,           Oxides of nitrogen.

NPD           Nitrogen-phosphorous detector.

NRDC         Natural Resources Defense Council.

NSPS          New Source Performance Standards - regulations found in Part 60, Title 40 of the CFR.

NTIS          National Technical Information Service - publication center for EPA  research documents in Cincinnati.

NTRM         NIST traceable reference material.

OAQPS        Office of Air Quality  Planning and Standards - about  700  EPA people  responsible for developing,
               publishing,  and  providing guidance for implementation  of air pollution regulations, both ambient air
               quality standards and stationary source  emission standards.

OMB          Office of Management  and Budget, U.  S. Government.

QMS          Office of Mobile Sources.

OPM          Open path monitoring system (long path monitoring).

ORD          Office of Research  and Development - program office  of EPA responsible for research on pollution
               control,  abatement,  and measurement issues.

OSHA         Occupational Safety and Health Administration.

OSW          Office of Solid  Waste - the EPA organization responsible  for publishing regulations addressing the
               handling and destruction of solid hazardous materials.

OSWER        Office of Solid Waste and Emergency Response.

PAH           Polyaromatic  hydrocarbons  - long chain organic compounds often in  particulate form at ambient
               conditions.

PCB           Polychlorinated  biphenyl compounds -  includes dioxins and furans.

PCDD         Pentachlorodibenzodioxin.

PCDF         Pentachlorodibenzofuran.
                                                                                                   Page 6

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                                (continued)
PIC -          Product of incomplete combustion.

PID            Photoionization detector - Analytical technique used in conjunction with gas chromatography.

PM            Particulate matter - defined by the test method used to collect and analyze the sample (e.g., Method 5
               defines PM as material collected in the sample probe and on the filter at 250ฐF).

PM10          Particulate matter less than 10 microns in aerodynamic diameter.

POHC         Principal organic hazardous constituents.

POM          Polycyclic organic matter - includes benzene and related compounds often in particulate form at ambient
               conditions.

PPB            Parts per billion (volume).

PPM           Parts per million (volume).

PPFF          Positive pressure fabric filter.

PPT            Parts per trillion (volume).

PQL           Practical quantitation limit.

PS             Performance  Specification  - performance criteria and procedures for evaluating a CEMS in the field
               installation, found in Federal  regulations including Appendix B, Part 60,  Title 40 of the CFR.

QAMS         Quality Assurance Management staff (EPA).

QAPP         Quality assurance project plan.

QA/QC        Quality assurance and quality control - procedures and acceptance criteria established for the measurement
               data quality.

RACT         Reasonably available control  technology.

RCRA         Resource Conservation and Recovery Act - the regulatory act addressing  hazardous waste handling and
               destruction.

RECLAIM     Regional Clean Air Incentives Market - the emission control regulation involving the accumulation and
               potential trading of emission credits for SOX, NOX, and ROG sources in the SCAQMD of California.

ROG          Reactive organic gases.

RSD           Relative standard deviation.

RTF           Research Triangle Park, NC  - location for several EPA Program offices.

SCAQMD      South Coast Air Quality Management District.
                                                                                                     Page?

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 ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                                (continued)
 SCR           Selective catalytic reduction - NO, control technique.

 Semi-VOST     Semivolatile organic compounds sampling train - see MM5.

 SIP            State Implementation Plan - compilation of regulations developed by each State agency to implement air
                pollution control requirements.

 SMRB          Source Methods Research  Branch  -  group  in  AREAL responsible  for stationary source  emission
                measurement methods research.

 SOCMI         Synthetic organic chemical manufacturing industry.

 SOTDAT       Source test data.

 SO,            Oxides of sulfur.

 SRM           Standard reference material (see CRM).

 SSCD          Stationary Source Compliance Division - organization in EPA responsible for providing guidance on the
                compliance issues for implementing  stationary source air pollution regulations.

 SSEIS          Stationary Source Emissions and Inventory System.

 STAPPA       State and Territorial Air Pollution Program Administrators.

 SW-846        The designation for the OSW codification of sampling and analytical methods related to solid waste
                regulations and referenced in 40 CFR  Part 266.

 TCDD          Tetrachlorodibenzodioxin.

 TCDF          Tetrachlorodibenzofuran.

 THC           Total hydrocarbons (see VOC).

 TRJ            Toxics Release Inventory.

 TRS           Total reduced sulfur compounds.

 TSAR          Test methods storage and retrieval  system - library file system  for the EMTIC technical document
                depository.

' TTE           Temporary total enclosure - a ventilated enclosure surrounding a line printing or coating operation and
                used in the evaluation of VOC emissions capture efficiency.

 TTN           Technology Transfer Network  - computer network for electronic bulletin boards addressing OAQPS
                activities (telephone number 919/541-5247).

 TRIS           Toxic chemical release inventory system.

 TSD           Technical Support  Division of OAQPS - organizational location for EMB and EIB.


                                                                                                    Page 8

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ACRONYMS USED IN EMISSION MEASUREMENT DISCUSSIONS AND REGULATIONS
                                             (continued)
TSDF         Treatment, storage, and disposal facilities - hazardous waste handling and disposal operations regulated
              by RCRA regulations.

TSP           Total suspended particulate matter.

UARG        Utility Air Regulatory Group - utility industry policy support organization.
                                                                   •
UV           Ultraviolet radiation range.

UV-DOAS     Ultraviolet dual optical absorption spectrometry.

VEO          Visible emission observation or observer -  opacity measurement according  to Method 9, 40 CFR Part
              60, Appendix A.

VOC          Volatile organic compounds.

VOST        Volatile organic sampling train -  extractive adsorbing emission sampling train for the measurement of
              volatile  organic compounds, usually toxic  or hazardous  compounds, with boiling points up to about
              130ฐC.  Analysis of sample is by  GC/MS.   Entitled Method 0030 in SW-846.

XRF          X-ray fluorescence (spectrometry).
                                                                                               Page 9

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            SOURCE TESTING IN THE NEW REGULATORY WORLD
                                      WORKSHOP

                                CONFERENCE AGENDA
Day 1 - November 2, 1998 (Monday)

08:30am   Opening Remarks
            - Welcome
            - Introduction

08:45am   Keynote Address
            - OAQPS Activities

09:00am   EMC Test Method Development Activities
          Stationary Source Compliance Audit Program (SSCAP)

10:00am   Break

10:30am   Fine Paniculate Measurements
            - Filterable and Condensible Particulate

ll:00am   Performance-Based Measurement System

12:00pm   Lunch

01:00pm   Instrumental Methods:
          Review of Current Projects and Guidance
            - Reference Test Methods
            - Portable Emission Analyzers

01:30pm   VOC Methods  Application, Guidance
            - Method 25 versus 25A/25B versus 18
            - Capture Efficiency Guidance
            - Reporting VOCs

02:30pm   Break

03:00pm   Methods Application, Guidance
          Open Discussion

04:30pm   Adjourn
William F. Hunt
John Seitz
Peter Westlin
Lara Autry
Tom Logan


Lara Autry



Bill Grimley
Gary McAlister
Candace Sorrell
Mike Pjetraj
Autry/McAlister/Logan
Sorrell/Pjetraj/Grimley
Moderator - Westlin
Day 2 - November 3, 1998 (Tuesday)

08:30am   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
Bill Lamason
Susan Wyatt
Jim Szykman
Sally Mitoff
10:15am   Break

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      SOURCE TESTING IN THE NEW REGULATORY WORLD
                                WORKSHOP

                    CONFERENCE AGENDA (Continued)
10:45am   MACT Test Methods Review
            - Methods 306, 306A, & 306B for Chrome Plating
            - FTIR Methods

12:00pm   Lunch

01:00pm   Approval of Alternative Methods And Monitoring
            - Alternative Methods Policy and Approval Process
            - Examples of Recent Alternative Approvals

02:30pm   Break

03:00pm   Alternative Methods And Monitoring Approval (cont'd)
            - Method 301 Revisions, Guidance
            - Method Precision Evaluation (PQL)
            - Environmental Technology Verification

04:00pm   Continuing The Information Exchange Workshop
            - EPA, EMC Perspective
            - EPA, OAQPS Perspective
            - EPA, OECA Perspective
            - State Agency Perspective

04:30pm   The Information Exchange; Open Discussion

05:00pm   Adjourn

Day 3 - November 4, 1998  (Wednesday)

08:30am   MACT Implementation Issues
            - MACT/Title V Interface Issues
            - Flexible Permits
            - MACT and Enforcement Issues
            - MACT and SIP Interface

10:00am   Break

10:30am   MACT Implementation Open Discussion
Gene Riley
Rima Dishakjian
Robin Segall
Terry Harrison
Gary McAlister
Gary McAlister
Robert Fuerst
Conniesue Oldham
Henry Thomas
Charles Garlow
Mike Pjetraj

Moderator - Oldham
Peter Westlin
Barrett Parker
Mike Trutna
Charles Garlow
Mike Fogle
Moderator - Westlin
12:00pm  Adjourn

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Opening Remarks
          - Welcome
       - Introduction

            Bill Hunt
 Keynote Address
          John Seitz
       Source Testing in the New
      Regulatory World Workshop

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Presentation  1

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November 2 - 4,1998


                                 Get Tagged

                                       at the

                          Emission Measurement Center
                 Emission Measurement Information Exchange

      Below is a table of workshop participants organized (sort of alphabetically) by agency
affiliation.  Also on the table for each participant is the name of one of the Emission Measurement
Center (EMC) contacts who is your Tag Person. During the course of the 2Vi - day workshop,
we want to you to meet your EMC contact and help us to get to know you better. When you
meet your EMC contact, he or she will give you a sticky tag for you to put on your name badge
to show that you have been tagged by EMC. Receiving this lofty recognition requires you to do a
few things:

1)    The EMC contact will be looking for you too, so you must wear your name badge at all
      times during the workshop (and at any impromptu social events that might take place in
      the hotel lounge, etc.), and

2)    Share with your EMC contact your thoughts and ideas for future emission measurement
      developments or improvements, especially on cooperative projects.

3)    Wear your sticky tag on your badge to show you have been tagged. Conniesue Oldham
      and Bill Lamason will seek out the tagless few before the end of the workshop.

Note - If your name is not on the list but you are substituting for someone else whose name is on
this list, your EMC contact person is the one designated for the original person (got that?).

Second note - If your name is not on the list and you are not substituting for someone else, your
EMC contact person is Gene Riley or Peter Westlin.

      The EMC will  prepare a summary of all the comments and suggestions gathered during
the tagging and distribute to the attendees along with the workshop summary. We hope that this
exercise helps us to get to know each other better and to learn more about what our respective
programs can do to help further emission measurement and monitoring technology.

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Alabama Delegates
Department of Environmental Management (ADEM)
           Name
      Wayne Coe
      Donald Gunter
      David Johnson
      Mark Sport
      George Yarbrough
Primary Work Area
Technical
Technical
Technical
Technical
Technical
EMC Contact
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister
Arkansas Delegates
Department Pollution Control & Ecology (ARDPC&E)
           Name
      Mitchel Stroh
      William Swafford
Primary Work Area
Inspections
Enforcement
EMC Contact
Tom Logan
Terry Harrison
Alaska Delegate
Department of Environmental Conservation (AKDEC)
           Name
      Robert Cannone
Primary Work Area
Inspections
EMC Contact
Bill Grimley
Arizona Delegates
Department of Environmental Quality (AZDEQ)
           Name
      Wayne Hunt
Primary Work Area
Inspections
     Contact
Foston Curtis
Colorado Delegates
Air Pollution Control Department (APCD)

           Name
      Thomas Lowell
Primary Work Area
Inspections
EMC Contact
John Bosch

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Connecticut Delegates
Department Environmental Protection (DEP)

           Name
      John DeGirolamo
Primary Work Area
Inspections
EMC Contact
Dan Bivins
District of Columbia Delegate
Department of Health (DOH)

           Name
      William Gillespie
Primary Work Area
Permits
EMC Contact
Lara Autry
Florida Delegates
Department of Environmental Protection (DEP)
           Name
      David Ajayl
      Matthew Boze
      Michael Harley
      Garry Kuberski
      Benjamin Morton
Primary Work Area
Regulatory
Inspections
Inspections
Inspections
Inspections
EMC Contact
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister
Georgia Delegates
Department Natural Resources (DNR)

           Name
      Michael Fogle
      Richard Tayler
Primary Work Area
Inspections
Inspections
     Contact
Tom Logan
Terry Harrison
Indiana Delegates
Department Environmental Monitoring (IDEM)
           Name
       Stephen Friend
       Ann Mclver
Primary Work Area
Compliance Testing
Compliance Testing
EMC Contact
Bill Grimley
Foston Curtis

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Indiana (Hammond) Delegates
Department Environmental Monitoring (IDEM)
           Name
      Ramelito Biscocho
      Kristina Hansen
      Ronald Holder
      Thomas Nyhan
Primary Work Area
Permits
Permits
Permits
Permits
EMC Contact
John Bosch
Dan Bivins
Lara Autry
Candace Sorrell
Illinois Delegates
Environmental Protection Agency (EPA)

           Name
      Kevin Mattison
Primary Work Area
Testing
EMC Contact
Mike Toney
Tennessee (Knox County) Local Delegate
Air Pollution Control (APC)

           Name
      Misti Cormier
Primary Work Area
Regulatory
EMC Contact
Robin Segall
Missouri Delegates
Department Natural Resources (DNR)

           Name
      Doug Elley
      Peter Yronwode
Primary Work Area
Regulatory
Regulatory
     Contact
Solomon Ricks
Gary McAlister
Mississippi Delegate
Department Environmental Quality

           Name
      Mohammad Yassin
Primary Work Area
Inspections
EMC Contact
Tom Logan

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North Carolina Delegates
Dept. Environment, Health & Natural Resources
           Name
      Mike Aldridge
      Ashby Armi stead
      Stephen Boone
      Joelle Burleson
      Yongcheng Chen
      Brendon Davey
      Charles Davis
      Kimberly Davis
      David Edgington
      Jay Evans
      Kirk Foster
      Tony Gallagher
      Betsy Huddleston
      David Hughes
      Dennis Igboko
      Steve Maynard
      Ron McCulloch
      Bernard McKee
      Marjorie Meares
      Kevin Miller
      Gregg O'Neal
      Philip Orr
      Samir Parekh
      Guatam Patnaik
      Tony Pendola
      Bernie Pittman
      Michael Pjetraj
      Gary Saunders
      Richard Simpson
      Shannon Vogel
Primary Work Area
Regulatory
Permits
Inspections
Planning
Permits
Regulatory
Ambient Monitoring
Regulatory
Regulatory
Regulatory
Regulatory
Mobil Sources
Permits
Regulatory
Regulatory
Regulatory
Monitoring
Regulatory
Regulatory
Permits
Regulatory
Regulatory
Regulatory
Permits
Permits
Permits
Regulatory
Regulatory
Regulatory
Regulatory
EMC Contact
Terry Harrison
Bill Grimley
Foston Curtis
John Bosch
Dan Bivins
Lara Autry
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister
Tom Logan
Terry Harrison
Bill Grimley
Foston Curtis
John Bosch
Dan Bivins
Lara Autry
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister
Tom Logan
Terry Harrison
Bill Grimley
Foston Curtis
John Bosch
Dan Bivins
Lara Autry
North Carolina (Local) Delegate
Department Air Quality

           Name
      Mark Hedrick
Primary Work Area
Permits
EMC Contact
Candace Sorrell

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New Jersey Delegates
Department Environmental Protection (DEP)

           Name
      John Jenks
      Michael Klein
      Daniel Strochak
Primary Work Area
Regulatory
Regulatory
Regulatory
EMC Contact
Mike Toney
Robin Segall
Solomon Ricks
New Mexico Delegate
Environmental Department

           Name
      Robert Samaniego
Primary Work Area
Inspections
EMC Contact
Gary McAlister
Ohio Delegates
Environmental Protection Agency (EPA)

           Name
      Patrick Haines
Primary Work Area
Permits
EMC Contact
Tom Logan
Oklahoma Delegates
Department Environmental Quality (DEQ)

      	Name	
      Johnnie Little
Primary Work Area
Enforcement
EMC Contact
Terry Harrison
Oregon Delegate
Department Environmental Quality (DEQ)

           Name
      Stephen Crane
Primary Work Area
Permits
EMC Contact
Bill Grimley

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Pennsylvania Delegates
Department of Environmental Protection (DEP)
           Name
      David Baker
      Timothy Brooks
      AnnMary Lanagan
      Jaydeb Pai
      Bryon Richwine
      Todd Starner
      Richard Szekeres
      Christopher Whitcash
      Andrew Zemba
Primary Work Area
Testing
Testing
Testing
Testing
Testing
Testing
Testing
Testing
Testing
EMC Contact
Foston Curtis
John Bosch
Dan Bivins
Lara Autry
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister
Puerto Rico Delegates
EQB

           Name
      Migvia del Vidal
      Ana Rivera
Primary Work Area
Permits
Air Toxics
EMC Contact
Tom Logan
Terry Harrison
South Carolina Delegates
Dept. Health & Environmental Control

           Name
      Michael Branton
      Christopher Corley
      Thomas Lancaster
      Michael Verzwyvelt
Primary Work Area
Compliance Testing
Inspections
Source Evaluation
Compliance
EMC Contact
Bill Grimley
Foston Curtis
John Bosch
Dan Bivins
Virginia Delegates
Department Environmental Quality (DEQ)

           Name
      Christopher Bednar
      Curt Demuth
      Yogesh Doshi
      Craig Nicol
      Romona Pedersen
      Margaret Wagner
Primary Work Area
Inspections
Inspections
Permits
Inspections
Inspections
Inspections
EMC Contact
Lara Autry
Candace Sorrell
Mike Toney
Robin Segall
Solomon Ricks
Gary McAlister

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Vermont Delegate
Air Pollution Control (APC)

           Name
      David Manning
Primary Work Area
Inspections
EMC Contact
Tom Logan
Wyoming Delegate
Department Environmental Quality (DEQ)

           Name
      Greg Meeker

EPA Region 2
           Name
      Mark Winter

EPA Region 4
           Name
      Richard DuBose
      David McNeal

EPA Region 5
           Name
      Howard Caine
      Emmett Keegan

EPA Region 7
           Name
      Scott Postma

EPA Region 8
      	Name
      Albion Carlson

EPA Region 9
      	Name
      Rima Dishakjian

EPA Region 10
           Name
      Paul Boys
Primary Work Area  EMC Contact
Permits                   Terry Harrison
Primary Work Area
Quality Assurance
Primary Work Area
Inspections
Regulatory
Primary Work Area
Enforcement
Enforcement
Primary Work Area
Inspections
Primary Work Area
Inspections
Primary Work Area
Regulatory
Primary Work Area
Permits
EMC Contact
Bill Grimley
EMC Contact
Foston Curtis
John Bosch
EMC Contact
Dan Bivins
Lara Autry
EMC Contact
Candace Sorrell
EMC Contact
Mike Toney
EMC Contact
Robin Segall
EMC Contact
Solomon Ricks

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                                      Tag questions
Name	
Organization	
Telephone/e-mail_
1.     Do EMC products and technical assistance efforts add value to your work?  If so, in what
       ways?  If not, what improvements would you like to see?
2.     What specific pollutant measurement or source category testing issues cause you the most
       problems?
3.     Are there problem solving activities in your shop for which EMC technical assistance would
       be of value?  Are there  resources available for emission measurement development or
       technology evaluation projects which, if combined with EMC technical assistance or other
       resources, could pay off with enhanced dividends?

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EMC Test Method Development
                        Activities

                      Peter Westlin

                     Source Testing in the New
                     Regulatory World Workshop

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                                     ABSTRACT

    HIGHLIGHTS OF EMISSION TEST METHODS DEVELOPMENT ACTIVITIES
                                      FOR 1998

                             Peter Westlin and Gene Riley
The Emission Measurement Center has published several new test methods in the past year including
proposed methods for measuring isocyanates and formaldehyde, final capture efficiency determination
methods, final methods for styrene in rubber, and proposed performance specifications for FTIR
CEMS.  The Agency has also proposed reformatting and revisions to almost all the existing test
methods to correspond to the Environmental Monitoring and Management Council requirements and
to correct minor issues with the methods.  The proposal has elicited a number of comments from the
source testing community and the Agency is preparing responses to these. The EMC is also involved
in several regulatory development activities under the MACT program.

Included in the presentation, is a review of the different guidance categories used for EMC emission
test methods and monitoring procedures. The categories are based on a combination of (a) the legal
status of the methods with regard to their application under federally enforceable regulations and (b)
the validation information available on the method and the Agency's corresponding  confidence in
application of the method for its intended use.  Each  category is explained and defined with
stipulations for guidance therein. Also included will be a review of "Frequently Asked Questions For
EPA Test Methods."

The purpose of the presentation  is to provide an update  on recent method development activities
sponsored by EPA, to summarize the methods revisions package and issues associated with it, and
to highlight several of the regulatory development activities.

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   EMISSION MEASUREMENT
       METHODS UPDATE
                          Peter Westlin
              Emission Measurement Center
    Ofiice of Air Quality Planning and Standards
I  OAQPS  Methods Numbering
?             System
Title 40 of the Code of Federal Regulations
V Part 60 Appendix A
  *• NSPS Methods 1 to 99 - Criteria
   pollutants
•/ Part 60 Appendix B
  *• CEMS Performance Specifications 1 to 1
•S Part 61 Appendix A
  + NESHAP Methods 101 to 199 - Toxic air
   pollutants (pre-1991)
                                                            Workbook Entries
  Method Activities & Status
  / From TIN/EMC website
  EMC Method Guidance Categories
  / Part 51 Appendix M
  *> Methods 201 to 299 - Example
       methods for SIPs
 ^ Part 63 Appendix A
  + Methods 301 to 399 - Hazardous
       air pollutants for MACT
       standards (post-1990)

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  ;        Method Si
<*••  Low PM Concentrations
  Validated for HWI
  Application - calibrating PM CEMS
  Description
  v' Isokinetic sampling
  •s Lightweight out-of-stack filter assembly
  •s Entire assembly weighing
  FR notice - December 30,1997
  FY 99 promulgation
  Contact: Dan Bivins (919) 541-5244
\
/
    Method 23
Dioxins and Furans
   Revisions to Current Method
   Corrections, Clarifications, Delete MeCl
   Rinse
   Proposed: May 31, 1995
   Review of Comments Indicate MeCl
   Rinse Should be Optional
   FY 99 Promulgation
   Contact:  Gary McAlister (919) 541-1062
                                                       I
                                                           Method 14A
                                                         Total Fluorides
                                               Source Specific - Primary Aluminum
                                               Plants
                                               Alcan Cassette Collection, Colorimetric
                                               or SIE Analysis
                                               Promulgation:  October 7, 1997
                                               Contact:  Terry Harrison (919) 541-5233
                                                                 PS-1 Revisions
                                                          Opacity Monitoring Systems
8
%
*?
                                             ' EPA/ASTM Cooperative Effort
                                             1 Proposed PS-1 Revisions - September 23,
                                              1998
                                             V Supplemental proposal incorporating
                                               by reference ASTM D6216
                                             " FY 99 Promulgation
                                             'Contact: Solomon Ricks (919)541-5242

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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
             .  t     •         t
             '            /
     -  . ;  ,  Lara"P:Autry  , - '. •
          •November 2, t998  *      •
      BACKGROUND/HISTORY
                    y
 . ^ ORD Divestment/in Quality Assurance
    Progra'msr *  .'*,*.'   , •'  . '
  p Transition .Of;Audit Program:'-.  '    /  -.  *
    • .Effective "January 1,1998' -  "
 ;   • Coordination between NERU arid EMC ;
-  p 'Problems Igentified:''.  -:'   ' ,' t' : •' /  ,
   ' * Lapse irtSample Availability,: ;  - ^ :-'" '
 _.  • Time Frame for Turnaround.    *.  -
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  "    * _ ~>   i J! S *• '   ^
        .  .OVERVIEW
        '_   '.""V- 7.;:<;'^
 - Background/History- "'"' -'^  .
  Acquiring Audit SamplfesV
            ' ฃ  •** **•  *
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? Audit Sample Request'Fqrm: ,  '.-.•,'•'-'.
  • The Source" (Autqmatetl Telephone IJne), ป, *•
-. '• (919)ฃ41-0200 -/'*'    *  ;  ~ "  \ V
 -• EMC Website:-':  ~  .. :  • ~  ''. < ฐ  ' *  ..
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? Time Frame for Response:7 T'' -:- '  '
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 .• Cylinders:' Varies  V* •' -- .*.  /-/'( ;-  ';>' '.'
                                                                   xnsE


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   .   SAMPLE AVAILABILITY
p Method 6/8:-' Available-, -  .  •  '-  -  .
p Method 7:  Available  *•  •  '   • "•  :  '
p MethodI13A: Fall 1998  "•.''•'
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^ Method 23:-Available   .'"   .  ซ  "  "
p Method 24 (solvent based paints): Fall
  1998. ;  -   ;  : - '   ;  \  -    -'  :  •
p Method 24 (Inks): Under Development

           : DATABASE
  Objective of'the Database:.       -  ,
  • Run the SSCAp'in a.rrfore: efficient and'
   'effective way.*- f  /"'ซ''.   > /   v
         , • f  *   ,- •   /     , •
  Advantages:,- ; •     ..   • • ;
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      SAMPLE AVAILABILITY
         *•'' '(continued)  "<:''-['•
  Method 25: Available-„.--.  .    '•.  -,
  Method 26: 'Available V'. / ,:  \ .
  Method 29:' Fall 199#  :   /'   '/
  Method 101: F;alLi998  ;  ''"'   7 ; ;
  Method 101 A:  Fajl 1998V- •"    ; '"
  Method 101B:' .Fait. 19^8 "   .   . *-'.
  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

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* .
>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

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- Capture Efficiency Guidance
               Candace Sorrell
                 Source Testing in the New
                Regulatory World Workshop

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                                     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.

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           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.

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     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)

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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.

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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.

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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)

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              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

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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

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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

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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

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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..

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       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.

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       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)

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     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

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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)

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 - FTIR Methods

Rima Dishakjian
        of Air
       • and
  Source Testing in the New
  Regulatory World Workshop

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                                     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.

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   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

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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

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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

-------
                                    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.

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        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

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   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/
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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

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Appendix B

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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

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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.

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      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
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      charge. Readers are available for UNIX, Win-
      dows, Macintosh and DOS. TfN currently uses
      Acrobat Reader version 3.0. File extension name:
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      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
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              U.S. EPA(MD-12)
      Research Triangle Park, NC 27711

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(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

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 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.

CHIEF—The 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.
 GEI—The 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.

 NELAC—The 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&G—The 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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                           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
                       Icj
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                                             w/ md^ ofCftirrjl Businett District
\.   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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