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 toEPA 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 toEPA 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 particulatematter 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 revi sed 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 reportdocuments the computational fluid dynamics flowmodeling, 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 Environmenta l Planning and Protection, Region II Director, Air Protection Division, Region III Director, Air, Pesticides, and Toxics Management Division, Region IV Acting Director, Air and Ra diation Division, Region V Director, Multimedia Planning and Permitting Division, Region VI Director, Air, RCRA, and T oxics 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, ESD1 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 your2 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 Environmenta l 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 T oxics 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, ESD1 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%