United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-86-008
July 1286
Air
Summary of
Comments and
Responses for
Methods
5B and 5F
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EPA-450/3-86-008
Summary of Comments
and Responses
for Methods 5B and 5F
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
July 1986
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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from the National
Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
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TABLE OF CONTENTS
Page
Chapter 1. Introduction 1
Chapter 2. Summary of Changes Since Proposal 2
Chapter 3. Summary of Comments and Responses. . . 3
List of Commenters . .- 18- -
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LIST OF ACRONYMS USED
EPA - Environmental Protection Agency.
FCCU- Fluid catalytic cracking unit.
FGD - Flue gas desulfurization.
IPA - Isoprop.yl alcohol..
NSPS- New source performance standards
SIP - State Implementation Plan.
iv
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Chapter 1
INTRODUCTION
On May 29, 1985, the U.S. Environmental Protection Agency (EPA)
published in the Federal Register (50 FR 21863) Method 5B, "Determination
of Nonsulfuric Acid Particulate Matter from Stationary Sources," and
Method 5F, "Determination of Nonsulfate Particulate Matter from Stationary
Sources." These methods were proposed under the authority of Sections 111,
114, and 301(a) of the Clean Air Act, as amended.
Public comments were solicited at the time of proposal. To provide
interested persons the opportunity of oral presentation of data, views,
or arguments concerning the proposed revisions and test methods, a public
hearing was scheduled for July 16, 1985, at the Research Triangle Park,
North Carolina, but no person desired to make an oral presentation. The
public comment period was from May 19, 1985, to July 31, 1985.
Nine comment letters were received concerning issues relative to the
proposed test methods. A detailed discussion of these comments and
responses is summarized in this document. The comments have been carefully
considered, and necessary changes have been made in the proposed methods.
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Chapter 2
SUMMARY OF CHANGES SINCE PROPOSAL
The following changes have been made in the rule since proposal.
1. Section 4.3, Method 5F. Section 4.3.3 has been revised to change
the beaker size from 600 ml to 250 ml.
2. Section 4.4, Method 5F. Section 4.4.1 has been added" to include -
a filter blank in the analysis procedure.
3. Section 4.4, Method 5F. Section 4.4.2 has been added to describe
the treatment of the water blank.
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Chapter 3
SUMMARY OF PUBLIC COMMENTS AND RESPONSES
Commenter IV-D-1, IV-D-3
1.1 Comment: Inasmuch as the Environmental Protection Agency's
(EPA's) intention was not to include sulfuric acid (^504) whe_n the
emission standards for particulate matter were established for facilities
subject to Subparts D, Da, Db, and J, these amendments will provide more
meaningful measurements of particulate emissions.
Response: No response is necessary.
Commenter IV-D-2
2.1 Comment: In the "Supplementary Information" section of the
proposal, the recognition that the proposed methods "may not-be
appropriate" for emission limits that are based on achieving a particular
impact on ambient air quality should be changed to "are not appropriate."
Otherwise, considerable pressure will be placed on control agencies to
allow these methods on existing sources.
Response: The phrase "are not appropriate," was not used because it
would prevent State governments from choosing Methods 5B and 5F, when they
are deemed appropriate to their programs. However, we believe that
Methods 58 and 5F would not be appropriate in the majority of these cases.
The paragraph cited in the comment has 'been revised to clarify its meaning.
2.2 Comment: The report, "Impact of Temperature and Filter
Material on Combustion Source Particulate Results," did not_ conclusively
prove that particulate weight reductions achieved by sampling at elevated
probe/filter temperatures and subsequent drying of samples at elevated
temperatures were due to avoiding H2S04 collection and vaporizing
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after collection. The fact that extraction of samples with isopropyl
alcohol (IPA) did not yield weights equivalent to weight reductions on
heating of the samples may mean that particulate matter other than H2S04
is being lost through these processes.
Response: We agree that this report does not present conclusive proof
that sampling and subsequent drying at elevated temperatures eliminate
only H2S04 from particulate matter samples. However, two other reports in
the docket present more convincing evidence. These two reports are
"Evaluation of the Particulate Test Method for Fluid Catalytic Cracking
Unit (FCCU) Regenerator Emissions" and "Evaluation of Method 5B at a
Coal-fired Boiler." As discussed in these reports, paired samples from
both FCCU's and fossil-fuel fired boilers showed good agreement when one
sample was measured by the water extraction procedure (Method 5F) and the
other sample was heated to 160°C before being extracted. If material other
than H2S04 was lost during the heating step, then the particulate matter
concentrations from the latter analysis would have been significantly lower
than those from the former analysis. Because this was not the case, we
concluded that the heating step removed only ^$04.
2.3 Comment: The primary intent of these amendments is to minimize
the measurement of ^804 mist on particulate samples. We believe that the
proposal has not succeeded in accurately eliminating that specific portion
of the sample. As indicated in Comment Number 2.2, heating of the sample
as dictated by Method 5B may eliminate particulate matter other than
Method 5F, on the other hand, permits the exclusion of all~water soluble
sulfates.
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Response: As discussed in the response to Comment 2.2, we believe
that Method 5B does not eliminate particulate matter other than ^804.
Method 5F does exclude water soluble sulfates. However, its use is limited
to FCCU's that are not equipped with wet flue gas desulfurization (FGD)
units. We believe that any water soluble sulfates at these facilities
would be limited to condensed f^SCty or metal sulfates formed from condensed^
H2S04 in the sampling train. Thus both methods minimize the measurement of
H2S04 only.
Commenter IV-D-4
4.1 Comment: The same rationale which EPA has applied to
fossil fuel-fired generators and petroleum refineries should also be
applied to other sources which emit sulfur oxides and partfctflate matter.
We have shown that gaseous compounds in the offgases of copper smelters
can combine to form particulate matter within and after the control
equipment. Thus primary copper smelters are subject to the same conditions
which prompted EPA to propose a method to accommodate the utility and
petroleum refinery industries. In conclusion, EPA should adopt similar
amendments to test methods for primary copper smelters and other similar
sources.
Response: Our action in proposing Methods 58 and 5F to measure
particulate matter without measuring condensed H2S04 was a specific response
to a specific problem. When the particulate matter emission standards were
established for the industries affected by this proposal, the feed stocks
in use were relatively low in sulfur content. Consequently, emissions of
sulfur oxides were relatively low, and the potential for collecting
condensed H2S04 along with the particulate matter sample was also low.
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Because the data base to support the emission limit for both of these
industries were collected using Method 5, any potential for measuring
condensed ^804 was considered in establishing the emission limit.
After the particulate matter standard for these industries had been
established, new control techniques for sulfur dioxide (S02) emissions
allowed the use of higher sulfur content feed stocks. Although S02
controls reduce S02 emissions, they have little effect on sulfur trioxide
($03) emissions. Conventional particulate matter control devices are also
unable to reduce $03 emission. Thus, the net effect of using higher sulfur
feed stocks is an increase in the level of $03 in the gas stream. Under
certain conditions, this 863 condenses to form HgSt^ and is collected in a
Method 5 sampling train as particulate matter. "
Because little or no condensed H2S04 was measured with the particulate
matter when the emission limit was being established, then H2S04 should not
be measured with the particulate matter when determining compliance with
this emission limit. This is the specific problem that Methods 5B and 5F
were designed to address. The issue is not simply that Method 5 may
measure condensed H2S04 as particulate matter. Rather, the issue is that
the potential for condensed H2$04 has increased greatly because the sulfur
content of the feed stocks now being used is much higher. There is no
evidence that a similar situation exists for copper smelters.
4.2 Comment: We applaud the realization by EPA that H2S04 mist is
indeed difficult to control, especially when it is generated by the control
equipment. It is also laudable that EPA has decided to propose changes to
Method 5 to accommodate this problem. However, we believe that EPA must
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investigate methods other than the simple increase in filter temperature to
minimize H2S04 collection on the filter.
Specifically, we believe that the following factors affect the
adequacy of the proposed test methods.
1. The H2$04 normally exists with eight water molecules of hydration
instead of two as stated in the EPA proposal.
2. When glass fiber filters are used to collect particulate matter
samples, the amount of condensed ^864 collected varies directly with the
size of the fiIter.
3. While maintaining a sampling temperature greater than 160°C (320°F)
can be difficult, it is not an insurmountable problem. We have shown in
these preceding comments that merely increasing the filtrat4en temperature
is inadequate and continues to penalize sources with high acid dew points.
Response: We believe that we have demonstrated for sources covered
by this proposal that increasing filtration temperature accompanied either
by additional heating after collection (Method 5B) or by water extraction
with subsequent analysis for sulfate (Method 5F) will eliminate the
condensed H2S04 contribution to particulate matter measurements. Thus,
questions about the number of water molecules associated with ^04 at
equilibrium is not an issue with either of these methods. In Method 5B,
any ^$04 collected in sampling is driven off by heating in the laboratory
while in Method 5F any collected 83804 is converted to the nonhygroscopic
ammonium sulfate before weighing.
We agree that, although it is difficult, it is possible~to maintain
sampling temperatures above 160°C (320°F). However, for the sources
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covered under this proposal we do not believe that there is a need to
maintain sampling temperatures above this level.
The data submitted by this commenter do show a relationship between
filter size and H2S04 collection. This is most probably related to a
reaction between the HgSCty and the filter media. Methods 5, 5B, and 5F
specify that glass fiber filters used at sources containing S02 and SQ% ~
must be of a type that are unreactive to these gases. Guidance on the
selection of such filter materials can be found in the report "Inertial
Cascade Impactor Substrate Media for Flue Gas Sampling." Copies of this
report are available for a fee from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
4.3 Comment: In 40 CFR Part 51, Appendix B, EPA promulgated a
particulate standard based on the State of Colorado process weight curve
for sources with reasonably available control technology. This curve was
formulated in the same manner as the Bay Area Air Pollution Control
District process weight regulation developed in 1959. The curve
was determined by testing the best controlled sources in the Bay Area and
fitting the results under a curve. The test method used was similar to the
American Society of Mechanical Engineers Power Test Code method which uses
an in-stack filter for determination of particulate. Obviously, the method
would measure particulate at control device temperatures and "condensible
material present at the gas phase" would not be measured. A complete
discussion of this matter was formally submitted to the EPA on
September 25, 1979, by the Phelps Dodge Corporation. Thus, the standard
for primary copper smelters is based on a test method which did not include
condensible material. In the May 29, 1985, Federal Register, EPA states
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that it "undertook a study to develop a method consistent with the original
standards" promulgated for fossil fuel fired power plants and FCCU's. With
regard to primary copper smelters, EPA adopted a standard which was
inconsistent with the test method mandated for their use. Phelps Dodge now
seeks to be treated in a manner similar to that afforded the aforementioned
sources to have a test method compatible with control equipment installed .
in compliance with State and Federal regulations. We, therefore, believe
that EPA should, either Change the particulate standard for copper smelters
based on a study using Method 5 or apply Method 5B to copper smelters as
well as to the industries cited in the May 29, 1985, Federal Register.
Response:. This comment is not applicable to this proposed action.
The regulation referenced was adopted under the State Implementation Plan
(SIP) program. Methods 5B and 5F are proposed for use only at sources
regulated under the new source performance standards (NSPS) program.
Actions taken under this program have no direct effect on the SIP program.
Any comment on regulations adopted under the SIP program should be made
directly to the State in which the regulation was adopted.
Commenter IV-D-5
5.1 Comment: The present particulate standard for Subpart D and
Da units with wet scrubbers was based upon test data obtained before wet
scrubbers. Therefore, to change the testing location to after the wet FGD
scrubber without positive data to show no increase in particulates due to
the scrubber is in fact changing the standard.
Response: The original intent of this regulation was to require
testing downstream of any FGD unit. Because of concern that condensed
sulfuric acid following the FGD would be counted as particulate matter by
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Method 5, sources were temporarily given the option of testing upstream
of the FGD. Method 5B will not measure the condensed sulfuric acid and,
therefore, may be used downstream of the FGD unit as originally intended
by the regulation. The change in test location does not represent a change
in the standard, but merely eliminates a temporary option granted until a
method could be developed that would not count condensed sulfuric acid as ~
particulate matter.
In addition, during its development Method 5B was shown to yield
particulate matter measurements that were always equal to or less than
those measured by Method 5 at the same location. Since the promulgation
of Subpart Da, at least three sources equipped with FGD units have
conducted compliance tests where the test point was downstream of the FGD
unit and the particulate matter was measured using Method 5. All of these
sources were found to be in compliance with the particulate matter
standard. Because the particulate matter measured by Method 5B is always
equal to or less than that measured by Method 5, these sources would
also have been shown to be in compliance if Method 5B had been used to
measure the particulate matter. Therefore, we believe it is reasonable
to require that sources equipped with FGD units must conduct particulate
matter tests downstream of the FGD unit.
Commenter IV-D-6
6.1 Comment: See Commenter IV-D-1, Comment 1.1.
Commenter IV-D-7
7.1 Comment: Method 5B is designed to minimize the measurement of
H2S04 mist as particulate matter from boilers employing a wet FGD system.
The rationale for doing so is that under conditions of high moisture
content and with $63 present in the flue gas, the acid dew point occurs at
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temperatures above the allowed Method 5 collection temperature. This
allows $03 to condense on the filter thereby increasing the measured
particulate mass.
We believe it would be appropriate for EPA also to allow the use of
Method 5B on combination wood/oil and wood/coal boilers subject to NSPS,
whether equipped with scrubbers or not, and even if the scrubbers are not .
used for FGD. Similar flue gas conditions, including high moisture content
can occur with these boilers which leads to the condensation of H2S04 mist
and collection as particulate matter by Method 5.
We have substantial data which indicate particulate catches from such
combination boilers can contain 10 to 40 percent soluble sulfates when
Method 5 is used to determine SIP compliance. '"
Response: See response to Comment 4.1.
Commenter IV-D-8
8.1 Comment: The approach and terminology used for Method 5F are
confusing since it appears that all water soluble material (including
^2^04) is being removed from the particulate matter determination. If the
intent was only to remove H2S04, then why was a water extraction procedure
used? Water will remove any water soluble material whereas an IPA
extraction would only remove ^$04. Why should water soluble material
(other than H2S04 mist) be removed from the particulate matter
determination?
Response: Though Method 5F does include a water extraction as part
of its analysis procedure, an aliquot of this extract is subsequently
analyzed for sulfate content while the remainder of the sample is dried and
weighed. Only the measured sulfate content is subtracted from the final
particulate matter weight. Thus, not all water soluble material is
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eliminated from the participate matter determination; only the water
soluble sulfates are eliminated. Though there are water soluble sulfates
other than H2S04, we believe that the only source of water soluble
sulfates at the facilities for which we propose the use of Method 5F is
H2S04. Thus, eliminating water soluble sulfates from the sample eliminates
only H2S04. '''""_,:.
We agree that an IPA extraction would remove only H2S04 and not other
sulfate compounds. However, our experimental results indicated that IPA
was not always 100% effective in extracting H2S04. _For these reasons, we
believe that the water extraction procedure proposed in Method 5F is
appropriate for eliminating 1^804 from particulate matter samples.
8.2 Comment: It seems to me that EPA needs to review^the data of
other researchers in more detail before eliminating the use of higher
temperatures for the sample probe and 100 percent IPA extraction to remove
H2S04 from particulate matter. The EPA Environmental Sciences Research
Laboratory researchers (EPA 600/3-84-056) have developed a miniature acid
condensation system and stated in their report that "a procedure can be
followed to separate absorbed ^$04 from metallic sulfates. The procedure
involves washing the filter, the filter holder, and the probe through an
S04-free filter media using 100 percent IPA. This recovers the ^04
alone. Following this, the particulates can be washed with 80 percent
IPA/20 percent H202 to recover the remaining water soluble sulfates
separately." Note that their probe and filter temperature is 271°C (520°F).
The EPA Industrial Environmental Research Laboratory (EPA 600/7-79-156,159)
recommended 316°C (600°F) for the probe and 281°C (550°F) for the filter.
Other researchers outside EPA have come to similar conclusions. Brookhaven
National Lab also recommends 100 percent IPA wash to separate the H2S04
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from other sulfates. If, however, the intent is to remove ^$04 and other
water soluble material, then Method 5F as proposed will accomplish this
separation.
Response: We do not believe that there is any need to operate the
sample probe at a temperature higher than that specified in Methods 5B and
5F. Our own tests did show that a higher probe temperature of 205°C ,.
(400°F) resulted in the collection of smaller amounts of condensed H2S04 in
the probe wash, but it did not completely eliminate it. The most probable
explanation for this is that the probe and connecting glassware were not
heated uniformly from nozzle to filter, and cold spots in the probe caused
^504 condensation to occur. Higher temperatures may help reduce the cold
spots through conduction, but we have no conclusive data to^show that any
temperature would guarantee elimination of cold spots and insure that no
H2S04 condensed in the sampling system. Therefore, subsequent laboratory
treatment to remove any residual H2S04 would be required even if higher
probe temperatures were used. As a result, there is no advantage to
operating the sample probe at higher temperatures and there may be
significant disadvantages because operating at higher temperatures is a
much more difficult task.
We agree that 100 percent IPA will dissolve H2S04 without dissolving
other sulfates. However, the more important question is whether 100 percent
IPA is capable of quantitatively extracting H2S04 from particulate matter
samples. Our own results indicate that it is not always effective, and the
water extraction is more reliable. Although the water extraction will
remove all water soluble sulfates, we believe that H2S04 is the only source
of water soluble sulfates at those facilities for which we have proposed
its use.
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8.3 Comment: It is clear from this proposal that EPA wants to
use an ion chromatograph to analyze the sulfate portion of the particulate
matter extract. I do not object to the use of the ion chromatograph as
the analytical method of choice, but I do object to the exclusion of the
barium-thorin titration method as an equally acceptable analytical method.
Response: At the time of the proposal, we did not have data to show
that the barium-thorin titration procedure was an acceptable alternative
method of measuring sulfate in the water extract. We recently completed
the necessary development work and will propose this as an alternative
method. This proposal will have to be published as a separate document to
allow public comment. The current schedule calls for its publication in
1986. —
8.4 Comment: I question the need to extract water soluble sulfate
from a soiled filter for 6 to 8 hours using a reflux apparatus (at an
unspecified temperature) in order to insure complete extraction. We
normally extract water soluble sulfates from a soiled filter using
distilled water at room temperature with repeated stirring over a 30-minute
period and found this procedure to be acceptable. Does EPA have data to
support the need for such a lengthy extraction using the more sophisticated
reflux apparatus to achieve complete sulfate extraction? If not, this
requirement should be eased.
Response: We do have data to show that the reflux step will
quantitatively recover water soluble sulfates from glass fiber filters, but
we do not have any comparable information to show that otfier, less -
rigorous, extraction procedures will also quantitatively recover the water
soluble sulfates. In the absence of such information it would be premature
to revise the extraction procedure.
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8.5 Comment: It would also appear that only a distilled water
blank is being used to correct the particulate matter weight. A distilled
water blank and a mass filter blank treated in the same manner as the
sample is necessary if EPA decides to use Section 4.3.3 as written. The
same is true for the sulfate analysis in 4.3.2.
Response: We agree that insufficient sample blanks are included in
Method 5F and have revised the method to require the extraction of a filter
blank with subsequent analysis of the extract for sulfate content.
8.6 Comment: Because the weight of a 600-ml beaker is typically
about 200 g, the combined weight of the beaker and sample residue will
exceed the capacity of most balances that can weigh to 0.1 mg. The EPA
needs to choose a beaker whose weight is more in line with tlie amount of
residue left after the evaporation of the water and whose weight will not
exceed the capacity of the balance.
Response: We agree that the tare weight of a 600-ml beaker is too
high and have amended Method 5F to require a 250-ml beaker instead.
Commenter IV-D-9
9.1 Comment: We agree with EPA that condensed $03 should not be
included as part of particulate emission measurements, given that use of
the best demonstrated technology does not effectively reduce condensed $03.
Our review of the information in the docket indicates that Method 5B can
reduce the measurement of condensed $03 at FGD and non-FGD sources. It is
puzzling that the agency has limited the application of Method 5B to only
those NSPS facilities that are equipped with wet FGD systems. We recommend
that the use of Method 58 be permitted for particulate emission testing at
all fossil fuel-fired combustion sources, not just those equipped with a
wet FGD system.
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Response: Method 58 was proposed as a specific solution to a
specific problem. The problem is the increased potential for ^804
emissions as a direct result of the use of higher sulfur content fuels
which was made possible by the advent of FGD units. Thus, Method 5B is
appropriate for use only at those sources which have this increased
potential for HgSC^ emissions.
9.2 Comment: The Agency has acknowledged, and the courts have
required, that the techniques used by EPA to collect data to establish a
standard, and the requirements prescribed for determining compliance with
the standard have a known and consistent relationship. We believe that EPA
has not demonstrated that Method 5B used after wet FGD systems produces
data that are consistent with Method 5 measurements upstream"of wet FGD
systems. In the absence of such comparative data, we recommend that
Subpart Da operators should retain the option of conducting particulate
emission tests with Method 5 or 5B, upstream of wet FGD systems.
Response: See Response to Comment 5.1.
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LIST OF COMMENTERS
Docket Number A-81-05
Docket Item Number Commenter/Affi 1 iat Ion
IV-D-1 V.W. Redin, Vice President
Plant Operations and Engineering
New York State Electric Gas
Corporation
4500 Vestal Parkway East
Binghamton, New York 13903
IV-D-2 James K. Hambright, Director
Bureau of Air Quality Control
Department of Environmental
Resources
Commonwealth of Pennsylvania
Post Office Box 2063
Harrisburg, Pennsylvania 17120
IV-D-3 U.V. Henderson, Associate Director
Environmental Affairs Research
Environment and Safety Department
Texaco, Inc.
Post Office Box 509
Beacon, New York 12508
IV-D-4 Richard W. Rice, Manager
Engineering Sciences
Phelps Dodge Corporation
2600 North Central Avenue
Phoenix, Arizona 85004
IV-D-5 Peter C. Cunningham
Hopping, Boyd, Green and Sams
for Florida Electric Power
Coordinating Group
Post Office Box 6526
Tallahassee, Florida 32314
IV-D-6 Phillip L. Youngblood, Director
Air and Toxic Programs
Conoco, Inc.
Post Office Box 2197
Houston, Texas 77252
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LIST OF COMMENTERS
(Continued)
Docket Number A-81-05
Docket Item Number Cemmenter/Aff11 iation
IV-D-7 David R. Pathe, Senior Analyst, Ai.r:;i
International Paper Company
77 West 45th Street
New York, New York 10036
IV-D-8 Jim Steiner
Pape and Steiner Environmental Services
5801 Norn's'Road
Bakersfield, California 93308
IV-D-9 Charles Knaus
Hunton and Williams for UARG
Post Office Box 19230"
Washington, D.C. 20036
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-450/3-86-008
4. TITLE AND SUBTITLE
Summary of Comments and Responses for Methods 5B an
7. AUTHOR(S)
Gary McAlister
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of. Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina
15. SUPPLEMENTARY NOTES
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
H SF July 1986
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO. . ;..".'—-• - ...
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
16. ABSTRACT ^^~
Summary of Comments and Responses for Methods 5B and 5F
Two new methods for measuring particulate matter from stationary sources without
measuring condensed sulfuric acid have been developed. The public comments on the
proposed methods have been summarized along with the Agency's responses to the comments
17. KEY WORDS AND DOCUMENT ANALYSIS ~~
3. DESCRIPTORS b.lDENTIFI
Electric Utility Steam Generators
Petroleum Refineries
Particulate Matter Emissions
18. DISTRIBUTION STATEMENT 19. SECURI
20. SECURI
ERS/OPEN ENDED TERMS C. COSATI Field/Group
TY CLASS (This Report) 21. NO. OF PAGES
TY CLASS (Thispage) 22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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