i 

PUBLIC 

PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

RULE / STAFF 

COMMENT BY SECTION RESPONSE ACTION / JUSTIFICATION 

........................ ................................................................ 

I The proposal requires Existing CEMS to 

meet new standards in 3 years (or 5 years 

from certification date) regardless of the 

CEMS current performance in generating 

good quality data. 

2 The requirement to modify or change an 

existing CEMS to meet new standards 

is a cost without any air quality benefit. 

Staff should consider to adopt the 

performance standards in 40CFR60 App. B 

and just default QA requirements to 40 

CFR60 App. F. The proposal duplicates 

the performance standards for CEMS. 

The District should be able to arrange for 

certification test with no more than 14-day 

notice in contrast to the 45-day notice. 

LACSD PAR2 1 8 

WSPA (d)( 1 ) (2) 

LACSD PAR2 18 

WSPA (d)(l) & (2) 

LACSD PAR2 18 

SCAQA (dl( 1 )(C) 

(Dl 

CSDLA PAR2 18 

(c)( 1 )(A) 

Agree - Staff modified language to provide added time 

Revised language (7 years) and included a waiver provision every 3 

years thereafter which allows existing CEMS to 

operate provided that data quality meet good 

quality standards. 

Agree - Language revision is the same as #1 above. 

Revised language This allows facilities to continue operating 

CEMS that generates acceptable quality until 

increased in maintenance cost or unavailable 

vendor support of the equipment mandates a 

new CEMS. 

Agree - PAR218 now provides an option to the facility 

Revised language to comply with either PR2 18.1 or 40CFR60 App 

B & F. There are advantages and disadvantages 

to each choice and mostly related to 

concentration levels. 

Agree - The 45-day notification has been revised to 

Revised language 14-day notification before a scheduled 

certification test. 

I Staff Report - Attachment A 

Page 1 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

1 I PUBLlC RULE / STAFF 

I 

. 

I 

6 Facilities should have the ability to expand 

existing RECLAIM QNQC to include 

R2 18 requirements. 

# COMMENT BY SECTION RESPONSE ACTION / JUSTIFICATION 

-----------------__-------------------------------------- _----__-___________------------------- ............................................................. ---- 

I 

I 

7 CEMS , specifically time-shared CEMS 

should not automatically be subjected to 

the new standards if a modification is 

performed following R-002 Technical 

Guidance Document 

5 Subparagraph (f)(3)(R) should include CSDLA PAR2 18 Agree - Added language to the rule allowing qualified 

Rule 5 18.2, by reference, to assure that (f)(3)(B) Revised language operators to obtain Hearing Board approval of 

Reg. XXX facilities are protected in the an alternative operating condition in 

event of CEMS failures in excess of 96 accordance with the established procedure in 

hours. District Rule 51 8.2. 

Chevron PAR2 18 

(c)(4) 

CSDLA PAR2 1 8 

Chevron (d)(2)(D) 

(a>( 1 1 ) 

Agree - This is acceptable as long as all aspects of 

Clarify in PR2 18.1 QNQC requirements are met. 

staff report 

Agree - Any CEMS modified following the R-002 

Clarify in Technical Guidance Document will not be 

Modified CEMS 

8 The CEMS definition includes a total 

combination of equipment and systems 

required to determine emissions of air 

contaminants- i~lcluding analyzers, 

sampling interface and data recorder. 

CSDLA PAR218 Agree - It is not the intent of the proposal to include 

WSPA (a)(6) Clarify in non-Rule 21 8 CEMS or those systems that are 

Chevron . staff report not covered by the current Rule 2 18. The 

Tosco proposal does not expand the applicability of 

the current Rule 21 8. Staff has provided clarifying 

Staff Report - Attachment A 

Page 2 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I PUBLIC RULE I STAFF 

COMMENT BY SECTION RESPONSE ACTION 1 JUSTIFICATION 

Many situations where only a flowmeter or 

a continuous oxygen analyzer is required 

by a permit. This will bring non-Rule 2 18 

CEMS or monitoring equipment under 

Rule 2 18, requiring wholesale changes to 

existing CEMS to meet new standards. 

language in the staff report. 

9 Rule 2 18 should specify what information Chevron PAR2 1 8 Agree - The District has an application form for both 

should be contained in the CEMS (c)( 1 )(A) No change to ' RECLAIM and non-RECLAIM CEMS. This 

application or a similar Draft application language application form details all information needed 

for Approval for RECLAIM CEMS. to evaluate CEMS applications. 

10 In previous meetings, it was considered that CSDOC PAR2 1 8 Agree - The earlier proposal was for existing CEMS to 

existing CEMS are required to comply with (d)(4) Revised language comply with the new standards no later than 

the new specifications within five years. It two-years from adoption date, or five years 

changed to two years. from the most recent certification date, 

whichever is later. Staff has revised the 

compliance date to seven years from adoption 

date with a waiver provision. 

I I The requirement to perform certification PES PAR2 18 Agree - Staff has revised proposal to perform 

test within 60 days from start-up and (c)(l) & Revised language certification within 90 days from equipment 

Staff Report - Attachment A 

Page 3 
PUBLIC 

COMMENT 

PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

RULE I STAFF 

BY SECTION RESPONSE ACTION I JUSTIFICATION 

submission of a QAIQC plan in 30 days 

from CEMS installation may not be 

technically feasible. 

The "Significant Modification" definition CSDLA PAR2 18 Agree - 

could have profound impacts on Reg.XXX (a)(ll) Revised language 

facilities wherein the significant permit 

revision procedural requirements may 

apply. 

In siluations where CEMS are off-line CSDLA PAR2 18 ~~ree in part - 

while repair parts take 30 to 60 days to (f3)(3)(B) No change to 

arrive, the availability percentage will not language 

meet the 95% requirement and may trigger 

a CEMS re-certification unnecessarily. 

The "Continuous Monitoring" requirement could CSDLA PAR2 1 8 Agree in part 

eliminate future-time sharing. Gas Chevron (a)( l6), Revised language 

chron~atograph- type CEMS will also be Mobil (c)(2), (3) and clarified in 

excluded. If this requirement reduces averaging & (4) staff report 

time,'the stringency of the permit condition 

or rule requirement is effectively 

increased 

start-up and submit QAIQC within 45 days from 

CEMS installation. 

Staff has revised the term "Significant ' 

modification" to "Modification Requiring 

Recertification" of CEMS. 

Rule 21 8, in its current for& provides that if a 

CEMS is shutdown for repair exceeding 96 

hours, a variance must be filed with the Hearing 

Board. These situations are better handled by 

the Hearing Board, on a case-by-case basis. 

Staff revised language that provides for semicontinuous operation (minimum of one data point 

every 15 minutes). CEMS owners will need to define 

how the SCEMS will operate, sample, calculate 

averages, recover valid data, etc., to meet a 

representative sample data. 

Staff Report - Attachment A 

Page 4 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I PUBLIC RULE I STAFF 

COMMENT BY SECTION RESPONSE ACTION I JUSTIFICATION 

5 Title V requires five year records retention in Chevron PAR2 1 8 Agree - To be consistent with recent federal rulemaking 

contrast to two years in the proposal Mobil (el( 1 activities on 40CFR59,60 & 61 recordkeeping and 

reporting, the two-year record retention period is still 

required unless otherwise a much longer retention 

period is required by another rule or regulation, such 

as Title V. 

16 The requirement that all CEMS CSDLA PAR218 Disagree - This is a requirement of the current Rule 21 8. 

concentration data be reported for Rule (f)(2) No change to The form and content of the reports are 

21 8 CEMS is unwarranted, time language discussed and developed with permitting 

consuming with little benefit. and/or enforcement staff. 

17 Deviation notification and reporting under CSDLA PAR2 1 8 Disagree - Title V cannot define a specific form of reporting 

Rule 2 18 is unnecessary and redundant (f)(2)(A) No change to that would apply to all equipment or rules, as it 

for Title V facilities. Rule 2 1 8 should & (B) language will refer to the requirements of specific rules or 

default to Reg. XXX in the form of an permit condition. 

exemption. 

8 The language in Subparagraph (c)(l)(A) and CSDLA PAR218 Disagree - Where an application has been determined not 

Rule 2 10 where re-submittals are (c)( 1 )(A) No change to to be complete, Government Code 65943(a) 

concerned are illconsistent with State law, language requires the agency to specify "those parts of 

Section 65943, which states that, "Upon the application which are incomplete and 

receipt of any resubmittal of the application, .... { to) indicate the manner in which they can be 

Staff Report - Attachment A 

Page 5 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I PUBLIC RULE / STAFF 

COMMENT BY SECTION RESPONSE ACTION / JUSTIFICATION 

a new 30-day period shall begin." A new 

30-day period does not begin, however, with the 

submittal of "...additional information". 

made complete. The submittal of information 

in support of a determination that an 

application is complete has the same effect as 

the re-submittal of an application itself: the 

30-day clock begins when the new information 

is received by the agency. Thus, staff 

interprets Rule 210 as consistent with the 

provisions of G.C., 65943 

9 Reports of CEMS failure or shutdown Chevron PAR2 18 Disagree The District has revised the requirement to 

provision should be consistent with CsDoc (f)(3)(B) No change to report within 24 hours, or the next working day, 

RECLAIM and retail1 the 96-hour language any failure or shutdown that exceeds 24 hours in 

reporting period. duration (from 60 consecutive minutes). for 

R2 18 CEMS. RECLAIM requires RTU to report 

mass emissions and valid data flags on a daily 

basis. 

20 The "CEMS" definition implies that CSDLA PR218.1 Agree - Staff revised language as "....required to 

concentration and mass emission rate is Chevron (a)( 10) Revised language continuously determine gas concentration 

required. Revise and clarify rule language. EERC PAW 18 and/or mass emission rate.. . ." 

(a)(6) 

I I Subparagraph (b)(l)(B) requires that the ' CSDLA PR218.1 Agree - Deleted the language and replaced with a 

Staff Report - Attachment A 

Page 6 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I PUBLIC RULE / STAFF 

COMMENT BY SECTION RESPONSE ACTION / JUSTIFICATION 

"probe tip shall be located at a 45' angle WSPA @I( 1 ) Revised language requirement that the owner or operator must 

and half stack diameter downstream.. ." locate the probe so as to obtain a 

becomes an enforceable requirement representative sample of the source emission 

without exception and potentially costly. and the sampling and the reference method 

probe must not interfere with the other. ' 

22 Cylconic flow should only be required Gas Co. PR2 18.1 Agree - Staff revised/clarified the language that 

when measuring mass emission rates. (b)(3)(D) Revised language cyclonic flow is required only for emission rate 

measurements. 

23 The 0- 17% oxygen analyzer range is in CSDLA PR218.1 Agree - Staff revised requirement to a maximum span 

error and should be 0-25% range. (b)(l)(C)(iv) Revised language setting of 25.0% oxygen. 

24 The calibration error requirement requires 

24-hour tests which are normally 

associated with drift. The 24-hr CE check is 

required at low, middle and high ranges The 

purpose is drift assessment which can be 

acconlplished without mid-range injections, 

while linearity can be determined with a 

single injection of a mid-range gas on one 

CSDLA PR218.1 Agree - The calibration error (CE) test requirement has 

EERC (a)(15) & Revised language been revised to be performed at the low 

(b)(2)(a)0) (0-20%) and high range(80- 100%) of span. 

Linearity error (LE) definition, calculation and 

requirements were added to the rule. 

Staff Report - Attachment A 

Page 7 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I PUBLIC RULE / STAFF 

COMMENT BY SECTION RESPONSE ACTION / JUSTIFICATION 

Allowances should be provided for an CSDLA 

environmental enclosure for those 

locations where the diurnal temperature. 

variation is small. 

26 The determination of CEMS availability 

should also include preventive 

maintenance measures recommended by 

the manufacturer. The blanket requirement 

for an analyzer enclosure is unsupported 

unless required by the manufacturer. 

-7 The CEMS operational period should only 

be required during initial certification tests, 

and not during any relative accuracy test. 

PR218.1 Agree - Staff added language to exempt CEMS from 

Revised language the environmental enclosure requirement if the 

owner is able to demonstrate that the CEMS is 

located in a geographic area where the 

seasonal high and low temperatures do not' 

exceed the operational temperature 

specifications of the analyzer, and where the 

diurnal temperature variation is less than 30 

degrees F throughout the year. 

I CiSDLA PR218.1 Agree - 

EERC (b)(2)(B) Revised language 

PR218.I Agree - 

(b)(l)(F) Revised language 

Staff Report - Attachment A 

Page 8 

Staff received CEMS calibration, audits and 

preventive (routine) maintenance downtime -- which concurred with staffs proposal of 

excluding no more than 40 hours in CEMS 

availability computation. Staff also revised 

language to exclude preventive maintenance 

and repair in the availability calculations. 

The operational period requirement for 

relative accuracy tests has been deleted. It should 

apply only during initial certification tests. 
PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I# COMMENT 

28 Stratification testing is very costly and 

should not be required annually. One 

demonstration should be sufficient. 

29 Sample system bias can be a cause of many 

possibilities including drift. Operators should be 

allowed to choose diagnostic techniques to 

resolve problems. 

30 A separate relative accuracy for moisture 

is both costly and unnecessary without a 

commensurate air quality benefit. 

31 All referenced technical guidance 

documents should be provided so that 

sources could determine the impacts 

I RULE / STAFF 

I BY 

SECTION RESPONSE ACTION / JUSTIFICATION 

C PR218.1 Agree - Staff clarified language in the rule that if a 

* 

C 

(b)(4)(C) Clarified language source has previously demonstrated the 

absence of stratification, annual check may not 

be required as long as the operating conditions 

during the previous stratification test are ' 

basically the same. 

levron 

as co. PR218.1 Agree - Staff revised sample bias test requirement to be 

(b)(4)(B) Revised Language performed in conjunction with annual RATA or when 

a CEMS specific part is replaced following the 

technical guidance document. In addition, the criteria 

for excessive drift and diagnostic techniques are 

required to be included in QAIQC Plan. 

PR218.1 Agree - Moisture relative accuracy requirement has 

(b)(Z)(C) Deleted language been deleted. 

PR218.1 Agree - Staff provided in the staff report (App, A) 

No change Technical Guidance Documents that are 

to language referenced in the proposed rule. 

PR218:l Agree - Staff will clarified in the staff report that Fd 

Staff Report - Attachment A 

Page 9 
PUBLIC 

# COMMENT 

calculations should also be deemed 

appropriate for use for Rule 2 18.1 

PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

33 District has guidance documents which 

reference tests for rejecting statistical 

outliers (e.g., Dixon Ratio, Grubbs) and are 

valid tests for determining rejection. 

I RULE / STAFF 

l By 

SECTION RESPONSE ACTION / JUSTIFICATION 

34 Dual-span range should not be required 

for sources where the contaminant 

concentration is significantly less than the 

limit. This would incur additional cost 

without benefit. 

Clarified in factors that are approved for RECLAIM may be 

staff report used for Rule R2 18.1 calculations. 

I as Co. PR218.1 Agree - Staff clarified in the staff report that 

(a)(23) Clarified in guidance documents that are approved by the 

staff report District for rejecting statistical outliers may be 

used for this purpose. 

evron PR218.1 Agree in part - Staff clarified in the staff report that the 

@)(I )(C)(iii) Clarified in low-concentration span range are required for 

staff report sources that may need to quantify their 

emissions for Emission Fee Billing and 

Reporting. 

35 The requirement for a 10-inch strip chart CSDLA PR218.1 Agree in part - Staff revisedladded language in the rule to 

recorder in addition to DAS is (b)(l)(D)(I) Revised language clarify that this requirement applies to CEMS 

unwarranted and incurs additional cost. & (ii) and clarified n where the strip chart is the primary means to 

staff report recordlstore data. When used for back-up, 

and for CEMS with only one parameter to be 

charted, a lesser size strip chart may be 

allowed. 

Staff Report - Attachment A 

Page 10 
I# COMMENT 

36 The inclusion of data point requirements 

falling below 10% is not necessary unlike 

RECLAIM. The source must merely show 

compliance with an e~nission limit. And 

readings below 10% be reported as-is. 

37 Allow the use of ambient air for calibration 

and zero gas. 

38 Data demonstrated that RM 307.91 

precision can be as high as 15 ppmv; 

often in the 5 to 7 ppmv range. Therefore, 

the de-minimus concentration for TRS be 

set at 7 ppm, instead of 4 ppm. 

39 The confidence coefficient (CC) should 

be eliminated from relative accuracy (RA) 

calculation and the number of runs be 

PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

I RULE I STAFF 

I BY 

SECTION RESPONSE ACTION I JUSTIFICATION 

DLA PR218.1 - Agree in part - The proposal allows the operators to report 

s Co. (b)( 1 )(C)(v) Clarified in readings below lo%, as-is, or at 10% of the span 

staff report range. Reporting concentration/emission 

below the 10% range may only be required for 

operators who are quantifying emissions to 

report actual data for fee billing purposes. 

levron PR2 1 8.1 Agree in part - Ambient air may not be dry air. Staff 

(dm Revised language considered that instrument air or plant 

and clarified in process air may be used as long as QAIQC 

staff report addresses the production and control 

process of the said air, demonstrating 

equivalent quality with certified zero gas. 

1"" PR218.1 Disagree - Method 307-91 laboratory data indicated that at 

clarified in low concentration (20 ppm or less), the 

staff report uncertainty is better than +/- 4.0 ppmv. 

C levron PR218.1 Disagree - The statistical calculations provided for 

No change to relative accuracy is the standard calculation 

language as provided by EPA as well as RECLAIM. 
PUBLIC 

COMMENT 

reduced from 9 to 4. With CC, the RA is 

biased high. 

10 Existing requirement for certified ( 

calibration gases should remain 

unchanged since EPA-600/R93/224 

omments were submitted by the following companies, 

-ganizations, and agencies: 

hevron Products Company (Chevron) 

MA Southern California Air Quality Alliance 

;CAQA) 

ounty Sanitations District of Orange County 

:SDOC) 

ounty Sanitations District of Los Angeles 

ounty (CSDLA) 

nergy and Environmental Research 

orporation (EERC) 

lobil Oil Corporation (Mobil) 

xific Environmental Services (PES) 

wthern California Gas Company (Gas Co.) 

tammen & Associates (Stammen) 

osco Refining Corp. (Toscol 

rester11 States Petroleum Association (WSPA) 

PAR218 & PR218.1 

SUMMARY OF PUBLIC COMMENTS 

RULE / STAFF 

BY SECTION RESPONSE ACTION / JUSTIFICATION 

evron PR218.1 Disagree - The existing requirement is now obsolete. 

(dl( 1) & (2) No change to Alternatives were also provided in the proposal 

language if protocol gases are not available. 

Staff Report - Attachment A 

Page 12