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
                                     10

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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
                                     11

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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
                                     12

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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.
                                     14

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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.
                                      15

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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.
                                    16

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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
                                   17

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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
                                18

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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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