Kris:

My responses to your questions follow your questions below. I'll put them is italic so you can tell when the questio n ends and the response begins.

First, your questions from 6/18 (which I apologize for not responding sooner).

1. In Section 1.7 of OTM-27 there is a statement re garding the mass of PM that should be

collected: “... you must extend the sampling time so that you collect the minimum mass necessary for weighing on each portion of this sampling train .” This statement is referring to the use of OTM-27 as a replacement for M5 or M17, however it seems to impl y that there is a requirement for a

minimum mass to be collected for OTM-27. I don’t see an y place where the minimum mass is specified. Are there any guidelines for what the minim um mass should be? In the ERT report that we will need to fill out after testing there is a request to report in parentheses the detection limit if the result is under the DL. This is something that is normally associated with methods such as M29 or M23, but what about OTM-27? For example , in Oregon the DEQ requires the test company report the emissions based on a default of 20 mg if less than 20 mg of sample was collected for the entire train, front half plus back half. For OTM -27 we will be using a 5 place balance and weighing to a constant weight of 0.05 mg. In the case of sources that have

control devices the mass of PM 2.5 collected may be very low, even in a 2-4 hour test. If a

specified mass isn’t required then I would expect that the re will be many PM 2.5 results that will

be very low, and potentially meaningless. Another conside ration is that the since there is normally a bidding process, if Test Company A bids for 2 h our runs and Test Company B bids for 8 hour runs, Company A will get the project, but C ompany B would have provided much more representative results. In the absence of a mass requ irement, I would be concerned that a lot of the data reported may not be representative.

For the purposes of the ICR, you are only required to p erform the testing for the indicated time period. If you obtain less than detection limit results with these times, it will become our issue to resolve. While Oregon DEQ wold like to have 20 mg of P M collected, this may not be feasible in all situations and with good sampling and analytical procedures may not be needed to get reliable data. Laboratory data EPA developed many year s ago indicates that with good techniques, the standard deviation of blank Method 5/17 samples is on the order of 0.4 mg. The precision and accuracy of the balance is probably not t he limiting factor in this variation of measurements. If one were to assume that this level of p recision is achieved with non blank samples, the detection limit for PM on filters (say with 201A) is about 1.5 mg and that one could be within 10% of actual mass when you collect 4 to 5 mg o f sample.

2. In Section 1.6 of OTM-27 there is a statement re garding the maximum stack temperature:

“ This method may not be suitable for sources with stack gas temperatur es exceeding 260°C (500°F).” For very clean sources that have good control devices it doesn’ t seem that there would be any problem just using M5/OTM-28 and assuming that all part iculate matter collected is less than

PM 2.5 . However, for sources such as small refuse burning incinera tors with only secondary

combustion as a control device, using M5/OTM-28 would bias the PM 2.5 results high. This

might be fine for a “worse-case” compliance determinatio n, but would not be ideal for establishing an emission standard. The outlet temperatu res may be in the range of 1000-1800

oF. Page 1 of 5

8/25/2010 file://C:\Documents and Settings\KFaught\Local Settings\Temp\XPgrpw ise\4C7526DBDo

...The issues of wet stack conditions and hot stack conditions are issues that we now address

with the statement to use EPA Method 5 and consider all the material as PM10 or PM2.5. For the purpose of the ICR, if you encounter either of the se conditions follow the directions and guidance in Guideline Documents 51, 51A, 51B and 51C ( and any subsequent GD51 documents). These are located at http://www.epa.gov/ttn/emc/guidlnd.html

.

_________________________________ Ron Myers U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policy and Programs Division Monitoring Policy Group, D243-05

RTP NC 27711

Tel. 919.541.5407

Fax 919.541.1039
E-mail myers.ron@epa.gov

Ron – I have some additional questions regarding the te st methods associated with the Section 114 letters. I still would appreciate answers to the qu estions that were in the email below (6/18).

1. If only the PM 2.5 head is used (without the PM 10 head), does this affect the equations

shown in the method? OTM 27 states that sampling can be performed using only the PM 2.5 head, but I don’t see where it mentions if the equati ons need to be modified. I am talking
specifically about equations that directly affect the sampli ng rate and PM 2.5 cut diameter. I am

assuming that the equations don’t need modification, bu t want to verify that this is correct. We

are starting our 1 st test program on Monday and the test port will not accom modate a

PM 10 /PM 2.5 head configuration.

In OTM 27 (and the proposed Method 201A), the equati ons are the same for all the configurations of the particle sizing cyclones. Of course if you do not use the PM10 cyclones Equation 32 (Actual Particle Cut Diameter for Cyclone I ) is a moot point since you should not care whether you would have achieved the correct PM10 cut d iameter if you would have used that cyclone.

2. For OTM 28: Is there any reason that ice water ca n’t be used in the 1 st section of the sample box where the knockout impinger needs to be kept at less than 85oF? Section 8.4.2 has the <85oF requirement, but I don’t see why it woul d hurt to use ice water to cool the From: "Kris Hansen" <khansen@hoeflernet.com>

To: Ron Myers/RTP/USEPA/US@EPA, Peter Westlin/RTP/USEPA /US@EPA

Cc: "Angela Hansen" <ahansen@hoeflernet.com>, "Steve Fr yberger" <sfryberger@hoeflernet.com>, "Steve Mackey "

<smackey@hoeflernet.com>

Date: 07/09/2009 04:51 PM

Subject: Section 114 Electronic Reporting Page 2 of 5

8/25/2010 file://C:\Documents and Settings\KFaught\Local Settings\Temp\XPgrpw ise\4C7526DBDo

...impinger.

The purpose of the divided box with somewhat different temperature requirements is to minimize the potential to form sulfate artifact in the first two impingers and to maximize the collecteion of water vapor for calculating the moisture co ntent of the sampled gas.

If you do not mind the increased potential to form sulf ate artifact in the first two impingers, you can put the first two impingers in the same box or part of the box for the impingers that are intended to collect water vapor passing through the first two impingers and the back up filter. The temperature at the exit of the back up filter wil l be much lower than 85F and satisfy the requirements of the method. For the purposes of the I CR we would encourage stack testers to maintain the exit temperatures as near 85F as they can wi thout exceeding that temperature and consistent with minimizing sulfate bias.

In the stakeholder process to develop the method, there w ere two considerations for selecting the temperature level. The first consideration was the desire to minimize sulfate artifact formation. Environment Canada provided information t hat the solubility of SO2 in water was greater at lower temperatures. Decreasing the solubili ty of SO2 reduces the quantity of SO2

that can oxidize to SO3 where it can not be removed with the nitrogen purge. The second consideration was the desire to establish a collection temp erature that is consistent and is representative of ambient temperature. In the use of another sampling method that is based upon the dilution of the sampled gas with filtered an d conditioned ambient air during a hot humid day, we were only able to reduce the filtration temperature to 85F. This is a temperature that is reasonable as an ambient temperature level and is near the standard temperature and within the normal 25F range for maintaining tempera ture for stack sampling. Also, this somewhat elevated temperature addresses concerns that the p romulgated Method 202 condenses organic and inorganic vapors greater than would be consistent with ambient temperatures of about 35 to 40F. The dilution in am bient air would further reduce the solid concentrations of these compounds. The combination of the lower temperature and the lack of dilution would tend to provide a high bias to the par ticulate matter collected. This information is documented in the running commentary on the method deve lopment that is in the docket and on the FAQ page for Method 202 ( http://www.epa.gov/ttn/emc/methods/method202.html#af ).

3. For ASTM D6784-02 (OHM): Do you have a protocol to handle averaging runs where one or two of the runs are under the DL, but at least one run is above the DL? Without guidelines I

would assume that those runs under the DL would be avera ged as zero. Or should we use 1⁄2 DL or the DL in the average of the runs?

When you encounter situations where one or more results a re below the detection level of the analytical (or instrument) you should report the fact th at that (those) run(s) were below the

detection limit and what was that detection limit. I would also be helpful (since some laboratories differ widely on their method to determi ne their limit of detection) to have a brief

indication on the criteria used to determine the detect ion limit.

4. The electronic Emission Test Template states: “Facil ities on the Boilers and Process Heaters test plan that were selected to test for HCl tha t do not use Method 26A to test for HCl

or HF ”. This is a little confusing, because what if you are usi ng M26A – wouldn’t you want to

use the same form?

Perhaps that statement is a little confusing in that it does not address the use of Method 26. Both method 26 and 26A are supported in the ERT. T hat statement is in the ICR because we Page 3 of 5

8/25/2010 file://C:\Documents and Settings\KFaught\Local Settings\Temp\XPgrpw ise\4C7526DBDo

...had already received a comment/request to use EPA Method 320 or the ASTM method for HCl.

Since Method 320 is not supported, HCl and HF would n ot have to be reported with the ERT.

I have cc’d Peter Westlin on this email. Is there anyone else that might be able to help me with these questions? We are starting the Section 114 testing this Monday (7/13) and will be performing this test program for a variety of clients alm ost weekly for the balance of the summer. I really appreciate your assistance.

Thanks,



### Kris

Kris Hansen, QEP

Sr. Consultant AmTest Air Quality,
a Division of Hoefler Consulting Group

PO Box 525

Preston, WA 98050

425-222-7746
425-222-7849 (fax)

khansen@hoeflernet.com

www.amtestairquality.com

From: Kris Hansen

Sent: Thursday, June 18, 2009 3:14 PM

To: 'Myers.Ron@epamail.epa.gov'

Cc: 'Steve Fryberger'; Steve Mackey; Angela Hansen
Subject: Section 114 Electronic Reporting & OTM 27

Ron – I have a couple of questions regarding OTM-27 and the Section 114 letters:

1. In Section 1.7 of OTM-27 there is a statement re garding the mass of PM that should be

collected: “... you must extend the sampling time so that you colle ct the minimum mass necessary for

weighing on each portion of this sampling train .” This statement is referring to the use of OTM-27 as a replacement for M5 or M17, however it seems to impl y that there is a requirement for a

minimum mass to be collected for OTM-27. I don’t see an y place where the minimum mass is specified. Are there any guidelines for what the minim um mass should be? In the ERT report that we will need to fill out after testing there is a request to report in parentheses the detection limit if the result is under the DL. This is something that is normally associated with methods such as M29 or M23, but what about OTM-27? For example , in Oregon the DEQ requires the test company report the emissions based on a default of 20 mg if less than 20 mg of sample was collected for the entire train, front half plus back half. For OTM -27 we will be using a 5 place balance and weighing to a constant weight of 0.05 mg. In the case of sources that have

control devices the mass of PM 2.5 collected may be very low, even in a 2-4 hour test. If a

specified mass isn’t required then I would expect that the re will be many PM 2.5 results that will

be very low, and potentially meaningless. Another conside ration is that the since there is normally a bidding process, if Test Company A bids for 2 h our runs and Test Company B bids for 8 hour runs, Company A will get the project, but C ompany B would have provided much more representative results. In the absence of a mass requ irement, I would be concerned that a lot of the data reported may not be representative.

2. In Section 1.6 of OTM

- 27 there is a statement regarding the maximum stack tempe rature: Page 4 of 5

8/25/2010 file://C:\Documents and Settings\KFaught\Local Settings\Temp\XPgrpw ise\4C7526DBDo

...“ This method may not be suitable for sources with st ack gas temperatures exceeding 260°C (500°F).”

For very clean sources that have good control devices it doesn’ t seem that there would be any problem just using M5/OTM-28 and assuming that all part iculate matter collected is less than

PM 2.5 . However, for sources such as small refuse burning incinera tors with only secondary

combustion as a control device, using M5/OTM-28 would bias the PM 2.5 results high. This

might be fine for a “worse-case” compliance determinatio n, but would not be ideal for establishing an emission standard. The outlet temperatu res may be in the range of 1000-1800

oF.

Sorry to keep bothering you, but we want to make sure th at we do the best job as possible for

our clients.

Thanks,



### Kris

Kris Hansen, QEP

Sr. Consultant AmTest Air Quality,
a Division of Hoefler Consulting Group

PO Box 525

Preston, WA 98050

425-222-7746
425-222-7849 (fax)

khansen@hoeflernet.com

www.amtestairquality.com Page 5 of 5

8/25/2010 file://C:\Documents and Settings\KFaught\Local Settings\Temp\XPgrpw ise\4C7526DBDo

...