### i

PUBLIC PAR218 & PR218.1 SUMMARY OFPUBLIC 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 andjust 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 contrastto 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 

## - Staffmodified 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 dataquality meet good quality standards. Agree 

## - Languagerevision is the same as#1 above. Revised language This allows facilities to continueoperating CEMSthat generates acceptable quality until increased in maintenance cost orunavailable vendor support of the equipmentmandates a new CEMS. Agree 

## - PAR218 now provides an option to the facility Revised language to complywith either PR2 18.1 or40CFR60 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

### notificationbefore ascheduled certification test. 

## I StaffReport

## - Attachment A Page 1PAR218 & PR218.1 SUMMARY OF PUBLIC COMMENTS 

# 1 I PUBLlC RULE/ STAFF
I

. I

6 Facilities should have the abilityto expand existing RECLAIM QNQCto 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 facilitiesare protected in the an alternative operating condition in event of CEMS failures in excessof 96 accordance with the established procedure in hours. District Rule 51 8.2.
Chevron PAR2 18 (c)(4)

CSDLA PAR2 18 Chevron (d)(2)(D) (a>( 11

) Agree 

## - This is acceptable as long as all aspects of Clarify in PR2 18.1 QNQCrequirements aremet. staffreport

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 todetermine emissionsof air contaminants- i~lcluding analyzers, sampling interface and data recorder. CSDLA PAR218 Agree 

## - It is not the intent ofthe proposal to include WSPA (a)(6) Clarify in non-Rule 218 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 218. Staff has provided clarifying

StaffReport

## - Attachment A Page 2PAR218 & PR218.1 SUMMARY OF PUBLIC COMMENTS 

# I PUBLIC RULE I STAFF COMMENT BY SECTION RESPONSE ACTION 1JUSTIFICATION
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 staffreport.

9 Rule 

### 2 18 should specify what information Chevron PAR2 1 8 Agree 

## - TheDistrict 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 informationneeded for Approval for RECLAIM CEMS. to evaluate CEMS applications.

10 In previous meetings, it was considered that CSDOC PAR2 1 8 Agree 

## - The earlierproposal was for existing CEMS to existing CEMS arerequired to complywith (d)(4) Revised language comply with the new standards no later than the new specifications within five years. It two-years from adoption date, orfive years changed to two years. from the most recent certification date, whichever is later. Staffhas revised the compliance dateto seven years from adoption date with a waiver provision.

I I The requirement to perform certification PES PAR2 

### 18 Agree 

### - Staffhasrevised proposal to perform test within 60 days from start-up and (c)(l) & Revised language certification within 90 days from equipment

StaffReport

## - Attachment A Page 3PUBLIC COMMENT PAR218 & PR218.1 SUMMARY OF PUBLIC COMMENTS RULE I STAFF BY SECTION RESPONSE ACTION IJUSTIFICATION

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 impactson 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 daysto (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 eliminatefuture-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) staffreport 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 theterm "Significant ' modification" to "Modification Requiring Recertification" of CEMS.

Rule 218, 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.
Staffrevised language that provides for semicontinuous operation (minimumof one data point every 15minutes). CEMS ownerswill need to define how the SCEMS will operate, sample, calculate averages, recover valid data, etc., to meet a 

### representativesampledata.

StaffReport

## - Attachment A Page 4PAR218 & PR218.1 SUMMARYOFPUBLIC COMMENTS 

# I PUBLIC RULE I STAFF COMMENT BY SECTION RESPONSE ACTION IJUSTIFICATION

5 Title 

### V requires five year records retention in Chevron PAR2 1 8 Agree 

### - Tobe 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 isrequired 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 218. concentration data be reported for Rule (f)(2) No change to The form and content of thereports are 218 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 218 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 210where 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 "thoseparts of Section 65943, which states that, "Upon the application which areincomplete and receipt of any resubmittal of the application,


## .... {to) indicate the manner in which they can be

StaffReport

## -Attachment A Page 5PAR218 & PR218.1 SUMMARYOFPUBLIC 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 ofG.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, orthe next working day, RECLAIM and retail1the 96-hour language any failure or shutdown that exceeds 24 hours in reporting period. duration (from 60consecutive 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 

## - Staffrevised 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 PAW18 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

StaffReport

## - Attachment A Page 6PAR218 & PR218.1 SUMMARYOF 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 requirementthat the owner or operator must and half stack diameter downstream.. 

## ." locate the probe so as to obtain a becomes an enforceable requirement representative sampleofthe 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 

## - Staffrevised/clarifiedthe 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 

## - Staffrevised requirementto 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 assessmentwhich 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.

StaffReport

## - Attachment A Page 7PAR218 & 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 operationalperiod should only be required during initial certification tests, and not during any relative accuracytest. PR218.1 Agree 

### - Staffadded languageto exempt CEMS from Revised language the environmental enclosure requirement if the owner is ableto demonstratethat the CEMS is located in a geographic area where the seasonal high and low temperatures do not' exceed the operational temperature specificationsof 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

StaffReport

# - Attachment A Page 8 

### Staff received CEMS calibration, audits and preventive (routine) maintenance downtime -- 

### which concurred with staffsproposal of excluding no more than 

### 40 hours in CEMS availability computation. Staff also revised languageto 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 certificationtests.PAR218 & PR218.1 SUMMARYOF 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 qualitybenefit.

31 All referenced technical guidance documents should be provided sothat sourcescould determine the impacts 

# I RULE/ STAFF 

# I BY SECTION RESPONSE ACTION/ JUSTIFICATION

PR218.1 Agree 

## - Staff clarified language in therule that if a C

* C (b)(4)(C) Clarified language sourcehaspreviously demonstratedthe 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 

## - Staffrevised 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 staffreport (App, A) No change Technical Guidance Documents that are to language referenced in the proposed rule.
PR218:l Agree 

## - Staffwill clarified in the staffreport that Fd

StaffReport

## - Attachment A Page 9PUBLIC 

### # COMMENT

calculationsshould 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 determiningrejection. 

# I RULE/ STAFF 

# l By SECTION RESPONSE ACTION / JUSTIFICATION

34 Dual-span range should not be required for sources where the contaminant concentration is significantlyless than the limit. This would incur additional cost without benefit. Clarified in factorsthat 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 staffreport that (a)(23) Clarified in guidance documents that are approved by the staffreport District for rejecting statistical outliers may be used for this purpose.

evron PR218.1 Agree in part 

### - Staffclarified in the staffreport that the @)(I)(C)(iii) Clarified in low-concentration span range are required for staffreport sources that may need to quantify their emissions forEmission Fee Billing and Reporting.

35 The requirement for a 10-inch strip chart CSDLA PR218.1 Agree in part 

## - Staffrevisedladded 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 stripchart may be allowed.

StaffReport

## - 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 ofruns be PAR218 & PR218.1 SUMMARYOF PUBLIC COMMENTS 

# I RULE I STAFF 

# IBY SECTION RESPONSE ACTION IJUSTIFICATION

DLA PR218.1 - Agree in part 

### - The proposal allows the operatorsto report s Co. (b)(1 )(C)(v) Clarified in readings below lo%, as-is, or at 10% of the span staffreport range. Reporting concentration/emission below the 10%range may only be required for operators who arequantifying emissionsto 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

staffreport addresses the production and control process ofthe said air, demonstrating equivalent qualitywith certified zero gas. 

# 1"" PR218.1 Disagree

## - Method 307-91 laboratory data indicated that at clarified in low concentration (20 ppm or less), the staffreport 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 asRECLAIM.PUBLIC COMMENT



### reduced from 

### 9 to 4. With CC, the 

### RA is biased high.

10 

### Existing requirement for certified ( 

### calibration gases should remain unchanged sinceEPA-600/R93/224

omments were submitted by the following companies, -ganizations,and agencies: hevron Products Company (Chevron) MA Southern CaliforniaAir 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) xificEnvironmental Services (PES) wthern California Gas Company (Gas Co.) tammen & 

### Associates (Stammen) osco Refining Corp. (Toscol rester11States Petroleum Association (WSPA) PAR218 & PR218.1 SUMMARY OF PUBLIC COMMENTS RULE/ STAFF BY SECTION RESPONSE ACTION / JUSTIFICATION



### evron PR218.1 Disagree 

## - The existingrequirement is now obsolete. (dl(1) & (2) 

### No change to Alternatives were alsoprovided in the proposal language if protocol gases arenot available.

StaffReport

## - Attachment A Page 12