Letters from Oldham, C. B., EPA to Burgher, E. C., Rupprecht & Patashnick Co, Inc., TEOM 

letters of conditional approval for filterable PM testing, March 4, 2005.
OFFICE OF

AIR QUALITY PLANNING

AND STANDARDS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RESEARCH TRIANGLE PARK, NC 27711

Mr. Edward C. Burgher

Rupprecht & Patashnick Co., Inc.

25 Corporate Circle

Albany, NY 12203

Dear Mr. Burgher:

This is in response to your October 1, 2001 letter transmitting an EPA Method 301 (40

CFR 63, Appendix A) analysis comparing the performance of your Series 7000 Source

Particulate Monitor (an In-situ, Tapered Element Oscillating Microbalance (TEOM)) to EPA

Methods 5 and 17 (40 CFR 60, Appendix A). This letter also transmitted three sets of source

emission test data supporting this comparison. On March 4, 2002 you transmitted a February 27,

2002 analysis that revised the original analysis and also included an additional four sets of

supporting test data. Lastly, on June 14, 2002, you transmitted a study evaluating the sampling

head inlet effects of the Series 7000 TEOM.

In your October 1, 2001 letter you made two requests to the Environmental Protection

Agency (EPA). They were:

1. EPA acceptance of your Series 7000 Source Particulate Monitor as an alternative to

EPA Method 17 for use in measuring particulate matter emissions produced by coalfired utility boilers regulated under 40 CFR Part 60 or other applicable parts.

2. EPA acceptance of your Series 7000 Source Particulate Monitor as an alternative to 

EPA Method 5 for use in measuring particulate matter emissions produced by coalfired utility boilers regulated under 40 CFR Part 60 or other applicable parts.

We have reviewed your report entitled, “Application for Alternative Method Approval

for the Determination of Particulate Matter in Coal Fired Utility Boiler Emission Sources Using

an In-Situ Inertial Microbalance” dated February 27, 2002 which revised and supplemented the

data supporting the October 1, 2001 request. We agree with your conclusion that the Series 7000

TEOM method incorporating the 20.5 percent volume correction factor met the Method 301 bias

and precision criteria for measuring particulate matter from coal fired utility boilers when

compared with EPA Method 17 and Method 5. I have summarized in the enclosed Tables 1

through 9 the revised supporting data and Method 301 calculations contained in Tables 8-1

through 8-9 of the above report. Additional discussion of our review is presented below.

As we have discussed, we do not have the authority to grant approval of an alternative

test method on a source category-wide basis. Rather, each owner/operator that wants to use the

Series 7000 TEOM method as an alternative to EPA Method 5 or 17 for measuring particulate
matter must submit his own facility-specific request. We can and will consider the validation

data that you submitted in evaluating an alternative method request from any source similar to

the ones at which you collected your validation data. In addition to coal-fired utility boilers, this

would include other coal fired combustion sources that are controlled with electrostatic

precipitators or fabric filters.

Further Discussion of Method 301 Review

As presented in the attached Tables 1 through 4 and in Tables 6 through 8, the Series

7000 TEOM provides concentration measurements that are unbiased statistically from EPA

Method 17 and EPA Method 5. When compared to EPA Method 17, the bias of the Series 7000

TEOM ranges from -0.336 to 0.728. When compared to EPA Method 5, the bias of the Series

7000 TEOM ranges from 0.275 to 0.578. However, since the t-statistic is less than the critical

t-value for the 80 percent confidence level, these biases are not statistically significant by EPA

Method 301 criteria. As a result, no correction factor is required for the Series 7000 TEOM to

provide concentrations equivalent to EPA Methods 5 and 17. 

EPA Method 301 also requires that the alternative test method be as precise as the

validated test method. For five of the seven test series, the variance of the Series 7000 TEOM

test method was less than the variance of the validated test method. For two of the test series,

the variance of the Series 7000 TEOM test method was more than the variance of the validated

test method. However, since the experimental F-values for these two test series was less than the

95 percent confidence level F-value, these differences in precision are not statistically significant

by EPA Method 301 criteria.

In the Discussion and Conclusions section of your February 27, 2002 analysis, you

suggested that a bias correction factor be included for the Series 7000 TEOM when used as an

alternative for EPA Method 5. You indicated that the increased statistical power created by

combining the three data sets reveals a small negative bias. Although you proposed a bias

correction factor, the correction factor is not supported statistically when the number of

quadruplicate samples specified by Method 301 are used to estimate the relative bias. 

Individually, all three sets of field data submitted on March 4, 2002 support the capability of

using the Series 7000 Source Particulate Monitor as an alternative to Method 5 for coal fired

utility boilers. Therefore, EPA believes that the use of a bias correction factor is not warranted. 

The submitted field data was reviewed and revised by EPA and is shown in Tables 6 through 8

along with the bias and precision information determined by the procedures specified in EPA

Method 301.

In the cover letter for your March 4, 2002 submission, you indicated that in addition to

correcting the filter blank calculations for the reference methods, a correction was made in the

computation of the sample volume for the Series 7000 TEOM. You stated that the information

generated by a computational fluid dynamic (CFD) model analysis indicates that an error of up

to 22 percent in the volume of the undisturbed gas stream collected could be caused by the “bow

wake” created ahead of the mass transducer inlet nozzle. You further stated that an average 20.5

percent correction is included in the computation of the sample volume collected by the Series

7000 TEOM. We have reviewed your report entitled “Series 7000 Source Particulate Monitor -

Inlet Effects and Volume Measurement Study Report” dated June 14, 2002. This report
documents the computational fluid dynamics flow modeling, wind tunnel research and empirical

data analysis performed to characterize the deformation of air flows near the Series 7000 TEOM

sample inlet caused by the sample head. This report concludes that the flow disturbance induced

by the geometric configuration of the Series 7000 TEOM sample head is consistent throughout

the design stack gas flow range of 600 to 5400 ft/min (3 to 28 m/sec). Lastly, the report

indicates that the deformation of the specific volume was determined to be 20.5 percent and is

based upon the best fit from the CFD model simulation. As you stated in your September 23,

2002 e-mail to Ron Myers, this volume correction factor is automatically included in the

software/firmware of the Series 7000 TEOM whenever the “Traverse” and “EPA” radio buttons

are selected as the test mode from the RP7000 software and transferred to the control unit

computer. Also in this e-mail, you state that the volume adjustment value stored in the control

unit during an emission test is transferred to the Series 7000 TEOM control unit Results data file. 

The Series 7000 TEOM software which generates the MS-Excel formatted test report reads the

volume adjustment factor data stored in the Results file and displays that value in the “QA and

Calibration Data Sheet” of the test report. We believe that the procedures described in your

e-mail (enclosed) are sufficient to allow adequate field auditing and review of the final emission

test report to insure that the operation of Series 7000 TEOM is the same as was used to generate

the data you supplied with this application. 

If you have any questions about this determination, please call Ronald Myers at

(919) 541-5407 or Tom Logan at (919) 541-2580.

Sincerely,

Conniesue B. Oldham, Ph.D., Group Leader

Source Measurement Technology Group

Enclosures

cc: Deputy Director, Office of Ecosystem Protection, Region I

Director, Division of Environmental Planning and Protection, Region II

Director, Air Protection Division, Region III

Director, Air, Pesticides, and Toxics Management Division, Region IV

Acting Director, Air and Radiation Division, Region V

Director, Multimedia Planning and Permitting Division, Region VI

Director, Air, RCRA, and Toxics Division, Region VII

Director, Air & Radiation Program, Region VIII

Director, Air Division, Region IX

Director, Office of Air, Region X

Michael S. Alushin, Compliance Assessment & Media Programs Division, OECA

Rich Biondi, OECA/ORE

Bruce Buckheit, OECA/ORE

Tom Curran, OAQPS

Sally Shaver, ESD 
1

Enclosure 1 (Revised Tables 8-1 through 8-9 in submitted report)

Table 1: Site 1 - Set 1: Series 7000 TEOM vs. Method 17 - Probe Configuration A

Test No.

Method 17 

Results Train 1

Method 17 

Results Train 2

Series 7000 

Results

System 1

Series 7000 

Results

System 2

1 38.46 36.21 37.23 33.30

2 1.74 1.61 2.25 2.20

3 2.64 3.77 4.18 3.92

4 12.45 14.45 15.14 15.79

Reference Method Average 13.92 Inertial Microbalance Method

Average

14.25

Bias -0.336 Correction Factor 1.00

t-statistic 0.389 Critical t value 1.638

Reference Method Variance (S 2

v) 1.292 Inertial Microbalance Method

Variance (S 2

p)

1.992

Critical F Value 3.787 Experimental F Value 1.542

RSD v (%) 9.29% RSD p (%) 13.98%

Table 2: Site 1 - Set 2: Series 7000 TEOM vs. Method 17 - Probe Configuration B

Test No.

Method 17

Results Train 1

Method 17 

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 2.98 4.03 3.63 3.61

2 3.93 1.71 2.94 3.24

3 8.76 5.93 6.21 6.20

4 4.95 5.26 6.06 5.90

Reference Method Average 4.7 Inertial Microbalance Method

Average

4.72

Bias -0.029 Correction Factor 1.00

t-statistic 0.068 Critical t value 1.638

Reference Method Variance (S 2

v) 1.763 Inertial Microbalance Method

Variance (S 2

p)

0.015

Critical F Value 3.787 Experimental F Value 0.008

RSD v (%) 37.54% RSD p (%) 0.31%
2

Table 3: Site 2 - Set 5: Series 7000 TEOM (w/ Auto Mol. Wt. On) vs. Method 17 - 

Probe Configuration A

Test No.

Method 17

Results Train

1

Method 17

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 10.56 8.66 8.27 8.26

2 6.73 8.31 8.29 7.93

3 9.36 8.67 7.22 7.08

4 6.98 7.31 6.75 6.95

Reference Method Average 8.32 Inertial Microbalance Method

Average

7.59

Bias 0.728 Correction Factor 1.00

t-statistic 1.331 Critical t value 1.638

Reference Method Variance (S 2

v) 0.835 Inertial Microbalance Method

Variance (S 2

p)

0.024

Critical F Value 3.787 Experimental F Value 0.028

RSD v (%) 10.03% RSD p (%) 0.31%

Table 4: Site 4 - Set 1: Series 7000 TEOM (w/ Auto Mol. Wt. On) vs. Method 17

Test No.

Method 17

Results Train

1

Method 17

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 9.12 7.52 8.89 8.31

2 8.20 8.87 8.40 8.41

3 7.55 8.36 8.34 8.04

4 8.62 7.60 9.22 8.31

Reference Method Average 8.23 Inertial Microbalance Method

Average

8.49

Bias -0.26 Correction Factor 1.00

t-statistic 1.611 Critical t value 1.638

Reference Method Variance (S 2

v) 0.587 Inertial Microbalance Method

Variance (S 2

p)

0.157

Critical F Value 3.787 Experimental F Value 0.267

RSD v (%) 7.13% RSD p (%) 1.85%
3

Table 5: Series 7000 TEOM vs. Method 17 Statistical Analysis Combining All Test Runs

Test No.

Method 17

Results Train

1

Method 17

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

Site 1, Set 1, Run 1 38.46 36.21 37.23 33.30

Site 1, Set 1, Run 2 1.74 1.61 2.25 2.20

Site 1, Set 1, Run 3 2.64 3.77 4.18 3.92

Site 1, Set 1, Run 4 12.45 14.45 15.14 15.79

Site 1, Set 2, Run 1 2.98 4.03 3.63 3.61

Site 1, Set 2, Run 2 3.93 1.71 2.94 3.24

Site 1, Set 2, Run 3 8.76 5.93 6.21 6.20

Site 1, Set 2, Run 4 4.95 5.26 6.06 5.90

Site 2, Set 5, Run 1 10.56 8.66 8.27 8.26

Site 2, Set 5, Run 2 6.73 8.31 8.29 7.93

Site 2, Set 5, Run 3 9.36 8.67 7.22 7.08

Site 2, Set 5, Run 4 6.98 7.31 6.75 6.95

Site 4, Set 1, Run 1 9.12 7.52 8.89 8.31

Site 4, Set 1, Run 2 8.20 8.87 8.40 8.41

Site 4, Set 1, Run 3 7.55 8.36 8.34 8.04

Site 4, Set 1, Run 4 8.62 7.60 9.22 8.31

Reference Method Average 8.79 Inertial Microbalance Method

Average

8.76

Bias 0.026 Correction Factor 1.00

t-statistic 0.094 Critical t value 1.341

Reference Method Variance (S 2

v) 1.121 Inertial Microbalance Method

Variance (S 2

p)

0.547

Experimental F Value 0.488 Critical F Value 1.822

RSD v (%) 15.44% RSD p (%) 6.24%
4

Table 6: Site 1 - Set 3: Series 7000 TEOM vs. Method 5 - Probe Configuration A

Test No.

Method 5

Results Train 1

Method 5

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 5.11 5.78 4.40 4.19

2 1.57 1.43 2.12 1.59

3 1.93 2.12 1.44 1.65

4 1.64 1.34 1.09 1.28

Reference Method Average 2.62 Inertial Microbalance Method

Average

2.22

Bias 0.396 Correction Factor 1.00

t-statistic 1.28 Critical t value 1.638

Reference Method Variance (S 2

v) 0.074 Inertial Microbalance Method

Variance (S 2

p)

0.051

Experimental F Value 0.682 Critical F Value 3.787

RSD v (%) 2.84% RSD p (%) 2.28%

Table 7: Site 2 - Set 4: Series 7000 TEOM (w/ Auto Mol. Wt. On) vs. Method 5 - 

Probe Configuration A

Test No.

Method 5

Results Train 1

Method 5

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 7.97 6.83 6.04 6.12

2 3.51 4.10 3.45 3.34

3 7.23 6.59 5.79 6.14

4 6.42 5.81 6.00 6.96

Reference Method Average 6.06 Inertial Microbalance Method

Average

5.48

Bias 0.578 Correction Factor 1.00

t-statistic 1.578 Critical t value 1.638

Reference Method Variance (S 2

v) 0.304 Inertial Microbalance Method

Variance (S 2

p)

0.133

Critical F Value 3.787 Experimental F Value 0.438

RSD v (%) 5.01% RSD p (%) 2.42%
5

Table 8: Site 4 - Set 2: Series 7000 TEOM (w/ Auto Mol. Wt. On) vs. Method 5 -

Probe Configuration A

Test No.

Method 5

Results Train

1

Method 5

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

1 7.82 9.98 9.57 9.20

2 10.47 9.94 9.56 9.41

3 8.91 8.84 8.05 7.10

4 10.21 9.67 11.66 9.09

Reference Method Average 9.48 Inertial Microbalance Method

Average

9.21

Bias 0.275 Correction Factor 1.00

Reference Method Variance (S 2

v) 0.658 Inertial Microbalance Method

Variance (S 2

p)

0.958

t-statistic 0.623 Critical t value 1.638

Experimental F Value 1.457 Critical F Value 3.787

RSD v (%) 7.04% RSD p (%) 10.41%
6

Table 9: Series 7000 TEOM vs. Method 5 Statistical Analysis Combining All Test Runs

Test No.

Method 5

Results Train

1

Method 5

Results Train 2

Series 7000

Results

System 1

Series 7000

Results

System 2

Site 1, Set 3, Run 1 5.11 5.78 4.40 4.19

Site 1, Set 3, Run 2 1.57 1.43 2.12 1.59

Site1, Set 3, Run 3 1.93 2.12 1.44 1.65

Site 1, Set 3, Run 4 1.64 1.34 1.09 1.28

Site 2, Set 4, Run 1 7.97 6.83 6.04 6.12

Site 2, Set 4, Run 2 3.51 4.10 3.45 3.34

Site 2, Set 4, Run 3 7.23 6.59 5.79 6.14

Site 2, Set 4, Run 4 6.42 5.81 6.00 6.96

Site 4, Set 2, Run 1 7.82 9.98 9.57 9.20

Site 4, Set 2, Run 2 10.47 9.94 9.56 9.41

Site 4, Set 2, Run 3 8.91 8.84 8.05 7.10

Site 4, Set 2, Run 4 10.21 9.67 11.66 9.09

Reference Method Average 6.05 Inertial Microbalance Method

Average

5.64

Bias 0.416 Correction Factor 1.074

t-statistic 2.083 Critical t value 1.363

Reference Method Variance (S 2

v) 0.344 Inertial Microbalance Method

Variance (S 2

p)

0.381

Experimental F Value 1.105 Critical F Value 2.014

RSD v (%) 5.69% RSD p (%) 6.75%
OFFICE OF

AIR QUALITY PLANNING

AND STANDARDS

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RESEARCH TRIANGLE PARK, NC 27711

Mr. Edward C. Burgher

Rupprecht & Patashnick Co., Inc.

25 Corporate Circle

Albany, NY 12203

Dear Mr. Burgher:

This is in response to your March 26, 2003 letter transmitting an EPA Method 301 (40

CFR 63, Appendix A) analysis comparing the performance of your Series 7000 Source

Particulate Monitor (an In-situ, Tapered Element Oscillating Microbalance (TEOM)) to EPA

Method 5 (40 CFR 60, Appendix A). Your letter also transmitted source emission test data

supporting this comparison. These test data were collected at an undisclosed 500 megawatt

utility boiler controlled with an electrostatic precipitator (ESP) and wet flue gas desulfurization

system.

In your letter you requested that the Environmental Protection Agency (EPA) accept your

Series 7000 Source Particulate Monitor as an alternative to Method 5 for use in measuring

particulate matter emissions produced by coal-fired utility boilers controlled by wet scrubbing

systems regulated under 40 CFR Part 60 or other applicable parts.

We have reviewed your report entitled, “Application for Alternative Method Approval

for the Determination of Particulate Matter in Coal Fired Utility Boiler Emission Sources

Controlled by Wet Scrubbing Systems Using an In-Situ Inertial Microbalance” dated March 5,

2003. We agree with your conclusion that the Series 7000 TEOM method incorporating the 20.5

percent volume correction factor met the Method 301 bias and precision criteria for measuring

particulate matter from coal-fired utility boilers when compared with EPA 5. I have summarized

in the enclosed Table the supporting data and Method 301 calculations contained in Tables 8-1

and 8-2 of the above report. Additional discussion of our review is presented below.

As we have discussed, we do not have the authority to grant approval of an alternative

test method on a source category-wide basis. Rather, each owner/operator that wants to use the

Series 7000 TEOM method as an alternative to EPA Method 5 or 17 for measuring particulate

matter must submit his own facility-specific request. We can and will consider validation data

that you submitted with both your request of October 1, 2001 and March 26, 2003 in evaluating

an alternative method request from any source similar to the ones at which you collected your 
2

validation data. In addition to coal-fired utility boilers, this would include other coal-fired

combustion sources that are controlled with ESP’s, fabric filters and wet scrubbing systems.

Further Discussion of Method 301 Review

As presented in the attached Table, the Series 7000 TEOM provides concentration

measurements that are unbiased statistically compared to those of Method 5. When compared to

Method 5, the bias of the Series 7000 TEOM is -0.259. However, since the t-statistic is less than

the critical t-value for the 80 percent confidence level, this bias is not statistically significant by

Method 301 criteria. As a result, no correction factor would be required for the Series 7000

TEOM where used as an alternative for Methods 5. 

Method 301 also requires that the alternative test method be as precise as the validated

test method. For the test series, the variance of the Series 7000 TEOM test method was more

than the variance of the validated test method. However, since the experimental F-values for

these two test series was less than the 95 percent confidence level F-value, these differences in

precision are not statistically significant by Method 301 criteria.

In the cover letter for your previous submission of March 4, 2002, you indicated that a

correction was made in the computation of the sample volume for the Series 7000 TEOM. You

stated that the information generated by a computational fluid dynamic (CFD) model analysis

indicates that an error of up to 22 percent in the volume of the undisturbed gas stream collected

could be caused by the “bow wake” created ahead of the mass transducer inlet nozzle. You

further stated that an average 20.5 percent correction is included in the computation of the

sample volume collected by the Series 7000 TEOM. In response to your previous submission,

we reviewed your report entitled “Series 7000 Source Particulate Monitor - Inlet Effects and

Volume Measurement Study Report” dated June 14, 2002. This report documents the

computational fluid dynamics flow modeling, wind tunnel research and empirical data analysis

performed to characterize the deformation of air flows near the Series 7000 TEOM sample inlet

caused by the sample head. This report concludes that the flow disturbance induced by the

geometric configuration of the Series 7000 TEOM sample head is consistent throughout the

design stack gas flow range of 600 to 5400 ft/min (3 to 28 m/sec). Lastly, the report indicates

that the deformation of the specific volume was determined to be 20.5 percent and is based upon

the best fit from the CFD model simulation. As you stated in your September 23, 2002 e-mail to

Ron Myers, this volume correction factor is automatically included in the software/firmware of

the Series 7000 TEOM whenever the “Traverse” and “EPA” radio buttons are selected as the test

mode from the RP7000 software and transferred to the control unit computer. Also in this

e-mail, you state that the volume adjustment value stored in the control unit during an emission

test is transferred to the Series 7000 TEOM control unit Results data file. The Series 7000

TEOM software which generates the MS-Excel formatted test report reads the volume

adjustment factor data stored in the Results file and displays that value in the “QA and

Calibration Data Sheet” of the test report. We believe that the procedures described in your

e-mail (enclosed in our previous response) are sufficient to allow adequate field auditing and

review of the final emission test report to insure that the operation of Series 7000 TEOM is the

same as was used to generate the data you supplied with this application. 
3

If you have any questions about this determination, please call Ronald Myers at

(919) 541-5407 or Tom Logan at (919) 541-2580.

Sincerely,

Conniesue B. Oldham, Ph.D., Group Leader

Source Measurement Technology Group

Enclosure

cc: Deputy Director, Office of Ecosystem Protection, Region I

Director, Division of Environmental Planning and Protection, Region II

Director, Air Protection Division, Region III

Director, Air, Pesticides, and Toxics Management Division, Region IV

Director, Air and Radiation Division, Region V

Director, Multimedia Planning and Permitting Division, Region VI

Director, Air, RCRA, and Toxics Division, Region VII

Director, Air & Radiation Program, Region VIII

Director, Air Division, Region IX

Director, Office of Air, Region X

Michael S. Alushin, Compliance Assessment & Media Programs Division, OECA

Carol Holmes, OECA/ORE

Adam Kushner, OECA/ORE

Greg Green, OAQPS

Sally Shaver, ESD 
1

Enclosure 1 (Application for Alternative Method Approval)

Table 1: Site 7 - Set 1: Series 7000 TEOM vs. Method 5 - Probe Configuration C

Test No.

Method 5 

Results Train 1

Method 5 

Results Train 2

Series 7000 

Results

System 1

Series 7000 

Results

System 2

1 3.86 5.06 2.95 4.10

2 5.43 5.47 5.09 5.04

3 3.07 2.92 4.32 2.41

4 4.82 4.56 5.14 4.08

Reference Method Average 4.40 Inertial Microbalance Method

Average

4.14

Bias -0.259 Correction Factor 1.00

t-statistic 0.946 Critical t value 1.638

Reference Method Variance (S 2

v) 0.191 Inertial Microbalance Method

Variance (S 2

p)

0.762

Critical F Value 3.438 Experimental F Value 4.568

RSD v (%) 4.34% RSD p (%) 21.08%