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8887137709

,JIIIIIIII1IUIIII11111
I1III1III
United States
Environmental Protection

Office of Air Quality


Planning and Standards

Agency

Research triangle

EPA-450/3-86-008
July 1986

Park NC 27711

Air

\~f

Summary

r;C;i~

Comments

and

Responses

for

R(lethods
55 and

liM

'I

of

5F

'

~ma

REPRODUCED BY
U.S. DEPARTMENT

OF COMMERCE

NATIONAL
TECHNICAL
INFORMATION
SERVICE

fECHNICAL

REPORT

DATA

(Pleoserc~dlnrnucrionson the reversebclorecompleringl


REPORT

NO.

~E~t~iP5"''~~~9
~6c i~

12.

EPA-450/3-86-008
TITLE

AND

REPORT

SVBTITLE

DATE

Sunrmary
of Comments
ant 9esponsesfor MPthods
SRan~SF JUlv1986
.AUTHOR(S)

PERFORMING

ORG~NIZATION

CODE

PERFORMING

ORGANIZATION

REPOR'

Oary McAlister
PERFORMING
ORGANIZATION
NAMEANDADDRESS

U.S. Environmental

Protection

Office of Air Quality

Jlo. PROGRAMELEMENT
NO.

Agency

Planning. and Standards

~~.CONtRACTICRINT
NO.

Research Tri-angle Park, North Carolina 27711


12.SPONSORING
AGENCYNAMEANDADDRESS

12. TYPEOF REPORT*ND PERIODCOVE

OAA
for A~r~ual~tyPlanningand Standards
Office

of

Air

U.S. Environmental
Research Triangle
15. SUPPLEMENTARY

Final

IO~SPONSORING

and Radiation

AGENCY

CODE

Protection
Agency
Park, North Carolina

NOTES

1B_\~BETRL~ET

cC

S$a~yoftonentsandResDonPer
forIlethods
55and5F

Twonewmethods for measuring particulate matter from stationary sources withol


measuring condensed sulfuric acid have been developed. The public connmentson the

?roposed methods have been suirsnarired along with the Agency's responses to the comnl

7.

I<EY WORDS AND DOCUMENT ANALYSIS

DESCRIPTORS

Electric
Petroleum

Particulate

Utility

Ib.lDENTIFIERS/OPEN
ENDEDTERMS Ic cqs~rl~icldlc~

Steam Generators

Refineries

Matter

Emissions

2. D1STRIBUTlONSTATEMENT

119. SECURITY CLASS IThir Rrpor~l


22. SECURITY

EP* C,m 112011(R~. I-n,

PL1~VIOUI
tD(tlOW I oReoLeTe ~1:9~

CLASS (~hiSollcJ

)1~ NO. OF PAGES


(22. PRICE

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
I~a

r"

I This report has been reviewed by theEmission Standards and Engineering Divisionof the Office of Air Quality Planning

j ;nd Standards,EPA,andapproved
forpublication.
Mentionoftradenamesorcommercial
product$is notintendedto
constituteendorsement
or recommendation
foruse.Copiesofthisreportare availablethroughthe LibraryServices
Office(MD-35),U.S.EnvironmentalProtectionAgency,ResearchTrianglePark,N.C.27711, or fromthe National
TechnicalInformationServices,5285 PortRoyalRoad,Springfield,Virginia22151.

TABLE OF CONTENTS

Page

Chapter i.

Introduction ........

Chapter 2. Summaryof ChangesSince Proposal. ..........


Chapter 3. Summaryof Commentsand Responses. ..
List of Commenters ; .~. .....

.';

2
..._-

~~ 3

~ 18

LIST

OF ACRONYMS USED

EPA - Environmental Protection Agency.


FCCU- Fluid catalytic

cracking

unit.

~S

FGD - Flue gas desulfurization.

~PA-Isopropyl

alcohol.

NSPS- New source performance standards

SIP.- State Implementation Plan.

Chapter

INTRODUCTION

On May29, 1985, the U.S. Environmental Protection Agency(EPA)

published in the Federal R_egister(50 FR21863)Method58, "Determination


of Nonsulfuric

Acid Particulate

Matter from Stationary

Method 5F, "DeterminBtidn of Nonsulfate Particulate


Sources."

Sources,"

and

Matter from Stationary

These methods were proposed under the authority

of Sections

111~,

114, and 301(a) of the Clean Air Act, as amended.


Public

interested

comments were solicited

at the time

of proposal.

persons the opportunity of oral presentation

To provide

of data, views,

or arguments concerning the proposed revisions and test methods, a public


a

hearing was scheduled for July 16, 1985, at the Research iriangle Park,
North Carolina, but no person desired to make an oral presentation.

The

public commentperiod was from May 1'9, 1985, to July 31, 1985.
Nine comment letters

were received

proposed test methods. A detailed

concerning

issues

relative

to the

discussion of these comments and

responses is summarited in this document. The commentshave been carefully


considered,

and necessary

changes have been made in the proposed methods.

Chapter 2
SUMMARY OF CHANGES SINCE

PROPOSAL

The following changes have been madein the rule since proposal.
i.
the

beaker

2.

a filter
3.

Section
size

4.3,
from

Section

4.4,

Method 5F.
600

mlto

Method

250

5F.

Section

4.3.3

has been revised

4.4.1

has

to change

mi.

Section

been

added

to

rnclude-

blank in the analysis procedure.


Section

the treatment

4.4,

Method 5F.

I,

Section

of the water blank.

-7
4.4,2

has been added to describe

"3

Chapter

SUMMARYOF PUBLIC COMMENTSAND RESPONSES

Commenter IV-D-1,

1.1

IV-D-3

Comment: Inasmuch as the Environmental

(EPA's) inte;ltion was not to include su!fijric


emission standards for particulate

Protection

Agency's

acid (HZOOq)whennhhe

matter were established

fo~r-facilities

subject to Subparts D, Da, Db, and J, these amendments wil'l providemore


meaningful measurements of particulate
Response:
Commenter

No response

emissions.

is necessary.

IV-D-2

2.1

Comme
nt :

In the "Supplementary

proposal, the recognition


appropriate"

Information"

section

of the

that the proposed methods nmay not be

for emission limits that are based on achievinga

particular

impacton ambientair quality s.ho;ld be changedto "are not appropridte."


Otherwise,
allow

considerable

these

methods

Response:

pressure

on existing

will

be placed on control

agencies

to

sources.

The phrase "are not appropriate,"

was not used because it

would prevent State gqvernments from choosing Methods 58 and 5F, whenthey
are deemed appropriate to their
Methods

programs. However, we believe that

5B and 5F would not be appropriate

in the

majority

of these

The paragraph cited in the commenthas ~been revised to clarify


2.2
Material

Comment: The report,


on Combustion

prove that particulate


probe/filter

Source

"Impact of Temperature
Particulate

Results,"

cases.

its meaning.

and Filter

did nQt~conclusively

weight reductions achieved by sampling at elevated

temperatures and subsequent drying of samples at elevated

temperatures were due to avoiding H2SO4co~lection and vaporizing H2S04

after

collection.

The fact

that

extraction

alcohol

(IPA) did not yield

heating

of the samples may mean that

is being

lost

Response:

through

of samples

weights equivalent

these

with

to weight reductions

particulate

:~

isopropyl

matter other

on

than'H2S0q

processes.

We agree that

this

report

does not present

conclusive

proof

that samplingand subsequentdrying at elevated temperatures eliminate `

only
H2504
from
particulate
matter
I~mpier.
However,
twoother
reports
in
the docket present

more convincing

"Evaluation of the Particulate


Unit (FCCU) Regenerator

Coal -fi red Boiler."

evidence,

These two reports

Test Method for Fluid Catalyti~e Cracking

Emissions" and "Evaluation

of Method 58 at a

As discussed in these reports,

both FCCU's and fossil-fuel

are

paired samples from

fired ~oilers showed good agree?n~i~twhen one

sample was measured by the water ex~raction procedure (Method 5F) and the
other

sample was heated.to

1600C before being extracted.

than H2S04 was lost during the heating


concentrations

from the latter

step,

analysis

than those from the former analysis.

If material

then the particulate

matter

would have been significantly


Because this

other

lower

was not the case,

we

concluded that the heating step removed only H2S04.


2.3

Comment: The primary intent

of these amendments is to minimire

the measurement of H2S04 mist on particulate


proposal

has not succeeded in accurately

of the sample.

as dictated

As indicated

samples.

eliminating

We believe
that

in Comment Number 2.2, heating

by Method 5B may eliminate particulate

Method 5F, on the other hand, permits

the exclusion

sulfater.

specific

the

portion

of the sample

Mtterother
of all

that

than H2S04.

water soluble

;1

Response: As discussed in the response to Comment2.2, we believe


that Method 58 does not eliminate particulate
Method 5F does exclude water soluble

matter other than H2S04.

sulfates.

However, its

use is limited

to FCCU'.sthat are not equipped with wet flue gas desulfurization


units.

We believe that any water soluble sulfates

(FGD)

at these facilities

wouldbe limitedto condensed


H2S04
or metalsulfates formedfromcondensed~~_~
H2S04in the samplingtrain.

Thusboth methodsminimizethe measurementof

H2S04 only.
Commenter

IV-D-4

4.1

fossil

Comment:

fuel-fired

The same rationale

which EPA has applied

generators and petroleum refineries

to

should also be

applied to other sources which emit sulfur oxides and pa-rticulate matter.
We have shown that gaseous compounds in the off gases of copper smel~ters
can combineto form particulate

matter wl:thinand after the control

equipment. Thus primary copper smelters are sub~ect to the same conditions
which prompted EPAto propose a method to accommodatethe utility

petroleum refinery industries.


amendments to test

and

In conclusion, EPAshould adopt similar

methods for primary copper smelters

and other similar

sources.

Response:

Our action in proposing Methods 5B and 5F to measure

particulate matter without measuring condensed H2S04was a specific response


to a specific
established

problem.

for the industries

in use were relatively


sulfur

Whenthe particulate
affected

by this

low in sulfur content.

oxides were relatively

matter emission standards were


proposali

the feed stocks

Consequently, emiss i ons~of

low, and the potential

for collecting

condensed H2S04along with the particulate matter sample was also low.

Because the -data base to support

industries

the emission.limit

for both of these

were collected using Method 5, any potential

for measuring

condensedH2S04
wasconsideredin establishing the emissionlimit.
After

the particulate

established,

matter

standard

for these

industries

had been

new control techniques for sulfur dioxide (502) emissions

allowedthe use-of higher sulfur content feed stocks. AlthoughSOp


controls

reduce S02 emissions,

they have little

effect

on sulfur

trioxide

(S03) emissions. Conventionalparticulate matter control devices are also


unable to reduce S03 emission.

Thus, the net effect of using higher sulfur

feed stocks is an increase in the level of 503 in the gas stream.

Under

certainconditions,
this S03condenses
to formHZSOq
andis collectedin a
Method 5 sampling train

Because little

as particutate

matter.

or no condensed H2S04was measured with the particulate

matter when the emission limit was being established,


be measured with the particulate
this

emission limit.

matter when determining compliance with

This is the specific

were designed to address.

problem that

Methods 58 and 5F

The issue is not simply that Method 5 may

measure condensed H2S04 as particulate

the potential

then H2S04 should not

matter.

Rather,

the issue

is that

for condensed H2S04 has increased greatly because the sulfur

content
ofthefeed
rtochr
nau
being
ured
ir much
higher.
There
ir no
evidence that

4.2

a similar

exists

for copper smelters.

Comment: Weapplaud the realitation

indeed difficult
equipment.

situation

by EPAthat H2S04mist is

to control, especially when it is generated by the control

it is also laudable that EPAhas decided to propose changes to

Method 5 to accommodate this

problem.

However, we believe

that

EPA must

-I

investigate methodsother than the simple increase in filter temperature to


minimize H2S04collection

on the filter.

Specifically, we believe that the following factors affect the


adequacy of the proposed test methods.

i. TheH2S04
normallyexists with eight water moleculesof hydration
instead

of two as stated

in the EPA proposal.

2. Whenglass fiber filters are used to collect particulate matter

samples,the amountof condensedH2SOq


collected varies directly with the
size

of

the

filter.

3. Whilemaintaininga samplingtemperaturegreater than 1~00C(320"F)


can be difficult,

it is not an insurmountable problem. Wehave shownin

these preceding comments


that merely increasing the filtratwn temperature

is inadequateand continuesto penalize sourceswith high acid dewpoints.


Response: Webelieve that we have demonstratedfor sources covered

by this proposalthat increasing filtration temperatureaccompanied


either
by additional heating after collection (Method58) or by water extraction
with subsequentanalysis for sulfate (Method5F) will eliminate the
condensedH2S04contribution to particulate matter measurements. Thus,

questionsaboutthe numberof water moleculesassociated with H2SOq


at
equilibriumis not an issue with either of these methods. In.Method58,
any H2S04
collected in samplingis driven off by heating in the laboratory
while in Method5F any collected H2SOqis converted to the nonhygroscopic
ammonium sulfate

before

weighing.

Weagree that, althoughit is difficult, it is possibleto maint~din


samplingtemperatures above 1609C(3200F). However,for the sources

covered

under this

proposal

we do not believe

maintain

sampling

temperatures

above this

that

there

is a need to

level.

The data submitted by this commenterdo show a relationship between


filter

size and H2S04collection.

reaction

This is most probably related to a

between the H2S04 and the filter

specify that glass fiber filters


must be of a type.that
selection

media.

Methods 5, 58, and 5F

used at sources containin

are unreactive to these gases.

of such filter

materials

502 and SD3

Guidance on the

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 CFRPart 51, Appendix8, EPApromuT4ateda

particulate standard basedon the State of Coloradoprocessweightcurve


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.

would measure particulate

Obviously, the method

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 EPAon

September 25, 1979, by the Phelps DodgeCorporation. Thus, the standard


for primary copper smelters is based on a test method which did not include

condensible material.

In the May29, 1985, Federal Register, EPAstates

that it "undertooka study to developa methodconsistent with the original

standards"promulgated
for fossil fuel fired powerplants andFCCUls.With
regard to primarycoppersmelters, EPAadopteda standardwhichwas
inconsistent with the test methodmandatedfor their use. Phelps Dodgenow
seeks to be treated in a mannersimilar to that afforded the aforemen4ioned

sourcesto have,a test method


compatible
withcontrolequipment
in;talled
in compliance
with State and Federalregulations. We,therefore, believe
that EPAshould, either changethe particulate standard for copper smelters
based on a study using Method5 or apply Method5Bto coppet smelters as
well as to the industries cited in the May29, 1985, Federal Register.

Response: This comment


is not applicableto this proposedaction.

Theregulationreferencedwasadoptedunderthe State Impl~m~ntation


Plan
(SIP) program. Methods5B and 5F are proposedfor use only at sources

regulated underthe newsource pe~formance


standards (NSPS)
program.
Actions taken under this programhave no direct effect on the SIP program.

Anycomment
on regulations adoptedunderthe SIP programshouldbe made
directly to the State in which the regulation was adopted.
Commenter

5.1

IV-D-5

Comment: The present particulate standard for Subpart D and

De units with wet scrubbers was based upon test data obtained before wet

scrubbers. Therefore, to changethe testing location to after the wet FGD


scrubber.withoutpositive data to showno increase in particulates due to
the scrubber

is in fact

changing the standard.

Response: -Theoriginal intent of this regulation wasto require


testing downstream
of anyfGDunit. Becauseof concernthat condensed
sulfuric acid following the FGDwouldbe counted as particulate matter~by

Method5, sources were temporarily given the option of testing upstream


of the FGD, Method58 will not measure the condensed sulfuric acid and,
therefore, may be used downstreamof the FGDunit 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 bedeveloped
particulate

that would not countcondensed

sulfuric

acid as-

matter.

In addition, during its developmentMethod58 was shownto yield


particulate

,~

matter measurements that were always equal to or less than

those measured:byMethod5 at the samelocation. Since the promulgation

of SubpartDa, at least three sources equippedwith FGD


units have
conducted compliance tests

unit and the particulate

where the test

point was downstrPam of the FGD

matter was measured using Method 5,

sources wer~ found to be in compliance with the ~articulate

standard.

All of these
matter

Because the particulate matter measured by Method 58 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 58 had been used to
measure the particulate

matter,

Therefore,

we believe

it

is reasonable

I~

to require that sources equipped with'FGDunits must conduct particulate


matter

tests

downst.ream

of the

FGD unit.

Commenter ~V-D-6

6.1
Commenter

7.~

Comment: See Commenter IV-D-1, Comment1.1,


IV-D-7

Comment: Fiethod 58 is designed to minimite themeasurement of

H2S04mist as particulate matter from boilers employing a wet FGDsystem.

The rationale for doing so is that under conditions afhigh moisture


content and with S03 present in the flue gas, the acid dew point occurs at
10

:_9

temperaturesabovethe allowedMethod5 collection temperature. This

allows503to condense
on the filter therebyincreasingthe measured
particulate

mass.

Webelieve it would be appropriate for EPAalso to allow the use of

Method5Bon combinationwood/oil and wood/coalboilers subject to NSPS,

whether
equipped
withscrubbersor not,.andevenif the scrub_bers
are not :_:_
used for FGD. Similar flue gas conditions, including high moisture content,

can occur with these boilers whichleads to the condensationof H2SO4


mist
and collection

as particulate

matter by Method 5.

Wehave 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

Response:
Commenter

8.1

SIP compliance.

See response to Comment4.1.

IV-D-8

Comment: The approach and terminology used for Method5F are

confusingsince it appearsthat all water soluble material.(including

H2S04)
is beingremoved
fromthe particulatematterdetermination.If the
intent was only to removeH2S04,then whywas a water extraction procedure

used?Water
will remove
anyHatersolublematerialwhereas
anIPA
extraction wouldonly removeH2SO4.Whyshould water soluble material
(other than H2S04mist) be removedfromthe particulate matter
determination?

Response: ThoughMethod5Fdoes include a water extraction as ~part


of its analysis procedure,an aliquot of this extract is subsequentTy
analyzedfor sulfate content while the remai~nder
of the sampleis dried and

weighed.Onlythe measured
sulfate contentis subtractedfromthe final
particulate matterweight. Thus, not all water soluble material is

eliminated
fromtheparticulate
matterdetermination;
onlythewater
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 samp~leeliminates only H2S04.

Weagree that an IPAextraction wouldremoveonly H2S04and not other


sulfate

compounds. However, our experimental results

was not always 100%effective

in extracting

indicated that IPA

H2S04. For these reasons, we

believe that the water extraction procedure proposed in Method 5F is

appropriatefor eliminatingHpSOq
fromparticulate matter samples.
8.2

Comment:

It seems to me that

EPA needs to revieo~he

data of

other researchers in more detail before eliminating the use of higher


temperatures for the sample probe and 100 percent IPA extraction
H2SOqfrom particulate

matter.

to remove

The EPAEnvironmental Sciences Research

Laboratory researchers (EPA600/3-84-056) have developed a miniature acid


condensation system and stated in their report that "a procedure can be

followed to separate absorbed H2S04frommetallic sulfates.


involves washing the filter,
SOq-free filter

alone.

the filter

holder, and the probe through an

media using 100 percent IPA. This recovers

Following this, the particulates

The procedure

[-j
:7

the H2S04

can be washedwith 80 percent

IPA/20 percent H202to recover the remaining water soluble sulfates


separately."

Note that their probe and filter

temperature is 2710C (5200F).

The EPAIndustrial EnvironmentalResearchLaboratory (EPA6~b/7-79-1~56,159)


recommended3160C(6000F) for the probe and 2810C(5500F) for the filter.

Other researchers outside EPAhave cometo similar conclusions. Broakhaven


National Labalso recommends
100 percent IPAwashto separate the H2S04
'12

:I

fromother sulfates. If, however,the intent is to removeH2S04


and other
water soluble material, then Method5Fas proposedwill accomplishthis
separation.

Response: Uedo not believethat there is anyneedto operatethe

sampleprobeat a temperatur~
higherthanthat specifiedin Methods
55and
5F. Ourowntests did Showthat a higher probetemperatureof 2050C

(4000F)
resultedin the collectionof smalleramounts
of condensed
H2S04
in
the probewash,but it did not completely
eliminateit Themostprobable
explanationfor this is that the probeandconnectingsiasswarewerenot
heateduniformlyfromnozrleto filter, andcold spots in the probecaused

H2S04
condensation
to occur. Higher
temperatures
mayhelpreducethe cold
,

spots throughconduction,but wehaveno conclusivedata to showthat any


temperature
wouldguaranteeeliminationof cold spots andinsurethat no

H2S04
condensed
in the sampling
system.Therefore,subsequent
laboratory
treatmentto removeany residual H2S04
wouldbe required even if higher

probetemperatures
wereused. Asa result, there is no advantageto
operatingthe sampleprobeat highertemperatures
andthere maybe

significantdisadvantages
becauseoperatingat highertemperatures
is a
much more difficult

task,

Weagreethat 100percentIPAwill dissolveH2S04


withoutdissolving
other sulfates. However,
the moreimportantquestionis whether100percent
IPAis capableof quantitativelyextractingH2S04
fromparticulate matter

samples.Ourownresults indicatethat it is not alwayseffective,andthe


water extraction is morereliable.. Althoughthe water extraction will
removeall water soluble sulfates, webelieve that H2S04is the only source
of water soluble sulfates at those facilities for whichwehaveproposed
its

use.

8. 3

Comment: It is clear from this proposal that EPAwants to

use an ion chromatographto analyze the sulfate portion of the particulate


matter extract.

I do not object to the use of the Son chromatographas

the analytical methodof choice, but I do object to the exclusion of the

barium-thorintitration methodas an equally acceptableanalytical method.


Response: At thetime of the proposal, we did not have data t.o show_

that the barium-thorintitration procedurewas an acceptable alternative

method
ofmeasuring
sulfateint~ewater
extract.We recently

completed

the necessary developmentworkand will propose this as an alternative


method. This proposal will have to be published as a separate documentto

allow public comment.Thecurrent schedulecalls for its publi;ation in


1986.

8.4

Comment: I question the need to extract water solub~esulfate

froma soiled filter for 6 to 8 hours using a reflux apparatus (at an


unspecified temperature) in order to insure complete extraction.

We

normallyextract water soluble sulfates froma soiled filter using


distilled water at roomtemperature with repeated stirring over a 30-minute
period and found this procedure to be acceptable. DoesEPAhave data to

supportthe needfor sucha lengthyextractionusingthe moresophisticated


reflux apparatusto achievecompletesulfate extraction? If not, this
requirement

should

be eased.

Response: Wedo havedata to showthat the reflux step will


quantitatively recoverwater soluble sulfates fromglass fiber filters, but
we do not have any comparableinformation to showthat other, less

rigorous, extraction procedureswill also quantltatively recoverthe water

solublesulfates. In the absenceof suchinformationIt wouldbe premature


to revise

the extraction

procedure.

8.5

Comment: It would also appear that only a distilled

water

blank is being used tocorrect the particulate mattei weight. A distilled


water blank and a~mass filter

blank treated

ii the same manner as the

sampleis necessaryif EPAdecidesto useSection 4.3.3 as written. The


same is true for the sulfate

analysis

in 4.3.2.

Response: Weagree that insufficient sampleBlanks are included in


Method5F and have revised the methodto require theextraction

of a filter

blank with subsequent analysis of the extract for sulfate content.


8.6

Comment: Because the weight of a 600-mi beaker is typically

about 200 g, the combinedweight of the beaker and sampleresidue will


exceedthe capacity of most balances that can weighto 0.1 mg. TheEPA

needsto choosea beakerwhoseweightis morein line with't7~eamountof


residueleft
exceed the

after th.e evaporation of the water and whose weight will not
capacity

of the

balance.

Response: Weagree thatthe tare weight'of a 600-mibeaker is too


high and have amendedMethod5F to require a 250-m1
beaker instead.
Commenter

IV-D-9

9.1 Comment: Weagree with EPAthat condensed S03 shduld not be

included as part of particulate emission measurements,given that use of


the best demonstrated technology does not effectively reduce condensed SOg.
Our review of the information in the docket indicates that Method58 can
reduce the measurementof condensed S03 at FGDand non-FGDsources.

It is

puzzlingthat the agencyhas limited the application of Method53 to only


those NSPSfacilities

that are equipped with wet FGDsystems. Werecommend

that the use of Method 58 be permitted for particulate

emission testing

all fossil fuel-fired combustion sources, not just those equipped with a
wet

FGD system.

at

:li

Response: Method
5Bwasproposedas a specific solutionto a
specific problem. The problemis the increased Rotential for H2S04

emissionsas a direct result of the use of higher sulfur content fuels


which was madepossible by the advent of FGDunits.
appropriate
potential

for use only at those sources which have this

increased

for H2S04 emi.ssions.

9.2
required,

Thus, Method5B is

Comment: The Agency has acknowledged, and the courts have


that the techniques used by EPAto collect

data to establish

standard, andthe requirementsprescribedfor determiningcompliancewith


the standard have a knownand consistent relationship.

Webelieve that EPA

has not demonstratedthat Method58 used after wet FGDsystems produces


data that are consistent with Method5 measurementsupstrea~~of wet FGD
systems.

In the absence of such comparative data, we recommendthat

Subpart Daoperators should retain the option of conductingparticulate


emission tests with Method5 or 5B, upstream of wet FGDsystems.
Response:

See Response to Comment 5,1.

16

LIST OF COMMENTERS
'

Docket Number A-81-05


~"

Do~ket~tem

Commenter/Af

Number

IV-D-1

V.W. Redin,

fi 1 iat i on

Vice~President

Plant Operations ~anPEngineering.._._~~


~~~~
New York State
Corporation
4500 Vestal

Electric

Gas

Parkway East

Binghamton, NewYork 13903

IV-D-P

James K. Hambright, Director


Bureau of Air Quality

Control

Department of Environmental
Resources

Commonwealth of Pennsylvania
Post Office Box 2063

Harrisburg,
IV-D-3

Penns~i~Vania17120

U.V. Henderson, Associate


Director
Environmental
Affa.irs Research
Environment.and
Safety Department
Texaco,
Inc.
Post Office
Box 509

Beacon,

IV-D-4

New York 12508

Richard W. Rice, Manager


Engineering Sciences
Phelps Dodge Corporation
2600

North

Central

Avenue

Phoenix, Arizona 85004

IV-D-5

Peter C. Cunningham
Hoppin9, Boyd Green and Sams
for Florida
Electric
Coordinating
Group
Post Office Box 6526

Tallahassee,
IV-D-6

Phillip

Florida

Power

32314

L. Youngblood, Director

Air and Toxic


Conoco,
Inc.

Post Office

Programs

Box 2197

Houston, Texas 77252

LIST OF COMMENTEHS
(Continued~

Docket

Number

A-81-05

Docket Item Number

Coffrmenter/Affiliation

Iv-D-!

David R. Pathe, Senior Analyst,'Ail


In.ternational

Paper

Cbmpany

77 West 45th Street


New York,
IV-D-8

New York

Jim Steiner
Pape and Steiner
5801

Environmental

Services

Norris-Road

Bakersfield,

lv-o-9 '

10036

California

93308

Charles
Knaur
Hunton
and
Past
Office

Williams
for
Box 19236

Washington,

D.C. 20036

3
UARG

_3

18

TECHNICAL REPORT DATA

IPle~se
~e~d
Insnc~cnb2s~2
thereverse
beforecompleringl
RECIPIENT'S
1 REPORT NO.

ACCESSION

NO

2.

EPA-450/3-86-008

FIEPORT

TITLEANDSUBTlTLE

~Julv

Suimnary of Corr~nentsand Responses for Methods 55 and 55

DATE

1986

.PERFORMINt

ORGANIZATION CODE

PERFORMING ORGANIZATION REPORT NO.

.AUTnOA(~bur~o~W1
ister
10. PROGRAM

PERFORMING
ORGANIZATION
NAMEANDADDRESS

U.S. Environmental

Protection

Agency

Office of.Air Quality Planning and

Standarcis

ELEMENT

NO.

~i;a'c~FR';a';N~-N~j:

Research Triangle Park, North Carolina 27711

17. TYPE O F REPORT AND PE RIC D COVE RED

12.SPONSORING
AGENCY
NAME
AND
ADDRESS
DAAfor Air Quality Planning and Standards
Office

Pi nal

14. SPONSORING

AGENCY

CODE

of Air and Radiation

U.S. Environmental

Protection

Agency

Research Triangle Park, North Carolina


ls. S~CPLEMENTARY NOTES

iB. ABSTRACT

Swmnarv
of Coranents
and9esDonses
for Iiethods
SEan~5F
matter

Two newmethods for measuring barticulate

from stationary

sources

without

acid have been developed; The publi.e conrmentson the


proposed methods have been sumarized along with the Agency's resrJonses to the conlPnent!

measuring condensed sulfurfe

I<EY WORDS AND DOCUMENT ANALYSIS

7.

Electric
Petroleum

DESCRIPTORS

Utility

b.IDENTIFIERS/OPEN
ENDED
TERMS

cosn.rl Field/Crouy!

Steam Generators

Refineries

Particulate

Matter

g. DISTRIBUTION

STATEMENT

EPA Fo~mtZZO-l (Rar. 1-77)

Emissions

19.SECURITYCLASS(ThiSRcporrl~

(2~ NO. OF PACES

20. SECURITY CLASS /Thir pogcl

)22. PRICE

PaEviOua EO(~IONIS OBSOLETE 19

-`7

*P887137769~

*BAX

_;I
BIN:

M23

61-69-63

INVOICE:

1225468

SH I PT`O:

1*883443

PAYMENT:

CSH*V

-il~'

"
_1