EPA HCl Performance Specification 

Draft Conference Call Summary

Thursday August 4, 2011 from 1:30-2:00 EDT.

Call in Conference Number 1-866-299-3188, code is 9195415511. 

Stakeholder Discussion Topic:

RATA – Requirements?

1) Welcome – Introduction

a) EPA plans to have stakeholder calls on various topics at a frequency of once every two weeks

b) We will work from the list of issues previously sent to the stakeholder. We will try to limit 

discussion to the announce topic so stakeholders can choose which conference calls to attend. 

Our timing remains to start the first draft by the middle of August and have the first full draft for 

Stakeholder review by the end of the calendar year (2011).

c) Today’s agenda includes: 

i) Should a RATA be required? 

ii) What is the reference method? (Method 26A or Method 320) 

iii) Should RATA be done at the level of the standard?

d) For the performance specification EPA will follow the existing template that includes the initial instrument 

qualification. Ongoing QC will be promulgated separately. General provision in 60.13 and 63.8 will be 

reviewed and may apply. 

2) Is a RATA necessary for some or all of the HCl technologies?

a) Is a RATA required that includes traversing the stack with the reference method

b) How should stack gas stratification be addressed

c) What RATA methodology can be applied to the new low standards for Cement MACT (~3 ppm) 

and Utility Industry MACT (proposed ~1.2 ppm). 

Ralph Roberson, RMB Consulting: How can you do a relative accuracy test using a conventional 

reference method with a CEM and expect there to be a 10% agreement at these low emission 

limits? The alternative example is the option in for mercury analysis including allowable mean 

differences to be on the order of the standard limit. Conventional RATAs don’t seem to provide 

useful comparison information at these low concentration levels. 

Jim Peeler, Emission Monitoring Inc.: Most cement plants running with inline raw mills will have 

fractional ppm of HCl emissions when the mill is operating and much higher HCl emissions when 

the mill is off line. Neither the CEMs nor Method 321 (FTIR) have the ability to provide 

meaningful RATA comparison at the fractional ppm concentrations expected during “mill off” 

operation. Since cement kiln operators don’t have a way to set their HCl emissions at a particular 

level, it is not possible to specify performing a RATA during process operation that generates 

HCl at the standard limit. 

Ray Merrill, EPA: Under consideration is self validating performance based measurements in 

sufficient replicates with one instrument to generate statistically valid precision and bias results 

that qualify the initial setup of an HCl CEM. Examples of method evaluation/validation include 

Method 320 and Method 301. Each of these methods requires spiked and unspiked 

measurements to generate statistically valid precision and bias method performance measures. 
The object for the performance evaluation is to ensure data of known and useful quality are 

generated during the initial setup and use of the HCl CEM.

Jim Peeler: I’m assuming RATA is used in the conventional sense of using a reference method 

for comparison to the CEMs. Analyte spiking with an appropriate number of replicates would be 

a substitute for a RATA.

Pete Zemek, MKS Instruments: Moving away from a RATA toward a self validating technique 

raises concerns:

(a) Do you assume the tag value of the spike gas is correct or is a secondary source required 

for the spiking gas. His experience is that measured values of two tanks at the same nominal 

concentration vary by 20%. When he gets different values from two cylinders that are 

nominally the same concentration the standard procedure is taking the vendor for 

recertification.

(b) Do you analyze the spike gas directly at the analyzer dry to determine the spike 

concentration and then measure through the probe to determine bias and precision against 

the analyzer spike values

(i) RATAs include much more stringent agreement than the method validation 

techniques. (e.g.,  30 % is a much looser requirement than  10 % to a reference 

method.

Jim Peeler: His test team always analyzes the cylinder gas directly from the tank. When the tank 

concentration fails to agree with his IR reference spectra, his team send the cylinders back to the 

vendor. He bases this procedure on the fact that his reference spectra are as good as the spectra 

being used by gas vendors.

3) NIST Certified HCl Gas Standards

a) Bob Davis, AirGas: Adopting the self validating procedure using certified calibration gas 

underscores the need for a NIST certified HCl standard gas to ensure Vendor supplied gases are 

certified and recertified correctly.

b) Ray Merrill: As an update, EPA has spoken with NIST and there is a plan in place to have a 

reference gas material (RGM) standard HCl certification available to gas vendors. NIST will start 

their HCl RGM process in June of 2012. During the call, Frank Gunther at NIST asked about 

instrumental technologies that are available to measure low level HCl gas. Bob Wright in EPA’s 

Office of Research and Development will include the HCl RGM in his Green Book descriptions 

of protocol gases. VSL in the Netherlands has a memo of understanding and will be working 

with NIST on the HCl RGM standard.

4) Stack Stratification Measurement related to HCl Performance Specification 24:32/34:14

a) Pete Zemek: We’ve assumed HCl was a homogeneous well-mixed gas and that stratification 

added no bias to the measurement of HCl. Well mixed gases can be sampled proportionately. 

Method 321 does not require traversing the CEM probe. That leaves isokinetic sampling only a 

requirement if a reference method (such as Method 26A) is selected for the RATA.

b) Jim Peeler: We think that Method 26A is entirely inappropriate for measuring HCl at any source 

category where there is reactive particulate that can remove HCl from the gas stream. Both 

Method 26A and Method 26 are not allowed by EPA for use in the cement and lime 
manufacturing industry for over 10 years because of the known low biases with these method at 

those sources. The initial flow traverse to determine stratification should be used to select the 

point of average velocity and that representative sampling point should cover 98% of the cases 

encountered in the field. 

c) Ray Merrill: A key to the issue of representative HCl measurement, whether it be determining 

stratification or overall performance of a CEM during installation and setup is the need for a 

comparison method that is as sensitive and precise as the CEM technology, or for that matter 

sensitive enough to measure at the lower limits being set in new regulations. If the CEM does not 

agree with an inferior manual method due to sensitivity, precision, or known bias of the 

comparison method then the comparison is not reasonable.

d) Jim Peeler: Speaking of bias, the results from Method 26A are total chloride values with no 

distinction between HCl and ammonium chloride. The method measures chloride ion in the 

impingers. The method cannot distinguish between ammonium chloride, hydrogen chloride, 

sodium chloride, etc. Assuming everything is HCl is OK for an area source test, (if a source 

operator wants to do so) but completely inappropriate for a compliance demonstration. Cement 

plants can have high levels of ammonia in the effluent.

5) Other Discussion

a) Jim Peeler: There are CEM requirements that do not have RATAs. For example, measurements of 

total hydrocarbons at hazardous waste combustors do not require RATAs per PS-8a.

b) Topic for next time: Calibration – zero and span. We may also discuss the quality of the HCl 

standards for this purpose. 
Table 1: Conference Call Attendees and Contact Information

Stakeholder Name Affiliation Interest Email Present

Rachael Agnew EPA/OAQPS/SPPD/MPG EPA agnew.rachael@epa.gov

Joe Aldina Covanta Energy Facility jaldina@covantaenergy.com

Collin Boswell EPA/OAQPS/SPPD/MPG EPA boswell.collin @epa.gov

Rich Brown Altech Equip Vendor rbrown@altechusa.com

Gary Catchatory Tyco Environmental Systems

Goyen Valve Corporation

Equip Vendor gcacciat@aol.com or 

gcacciatore@goyen.com

Kieth Crab Cemtech Environmental Equip Vendor keith@cemtecks.com Y

Edul Chikhliwala EcoChem Analytics Equip Vendor chikli@ecochem.biz

Michael Corvese Thermofisher Equip Vendor michael.corvese@thermofisher.com

Bob Davis AirGas Gas Vendor bob.davis@airgas.com Y

Jason Dewees EPA/OAQPS/AQAD/MTG EPA dewees.jason@ epa.gov

Frank Duckett Thermofisher Equip Vendor frank.duckett@thermofisher.com

Andy Edwards Ash Grove Cement Facility andy.edwards@ashgrove.com Y

Gerri Garwood EPA/OAQPS/SPPD/MPG EPA garwood.gerri@epa.gov

Fred Grunewald MKS Instruments Inc. Equip Vendor fred.grunewald@mksinst.com

Desirea Haggard Cal Portland Facility dhaggard@calportland.com Y

Jeff Harrington Tyco Environmental Systems Equip Vendor jsharrington@goyen.com

Malik Hatar Altech Equip Vendor

Mike Hayes Linde Gas Gas Vendor mike.hayes@linde.com

Andre Hegre Gas Technologies, Finland Equip Vendor

Stephen Johnson Thermofishter Inc. Equip Vendor Stephen.Johnson@thermosisher.com

Dan Kietzer Sick-Maihak Equip Vendor dan.kietzer@sickmaihak.com Y

Laura Kenner Emission Monitoring Inc. Tester lkinner@mindspring.com Y

Dieter Kita Thermofisher Equip Vendor dieter.kita@thermofisher.com

Phil McMaster PermaPure Equip Add-on pmcmaster@permapure.com Y

Barbara Marshick MKS Instruments Equip Vendor Barbara_Marshik@mksinst.com

Ray Merrill EPA/OAQPS/AQAD/MTG EPA merrill.raymond@epa.gov Y

Barrett Parker EPA/OAQPS/SPPD/MPG EPA parker.barrett@epa.gov

Ashmud Patel Ethyl Smith Automation

Jim Peeler Emission Monitoring Inc. Tester jimpeeler@mindspring.com Y

Allan Rilling ABB Equip Vendor allan.j.rilling@ca.abb.com Y

Ralph Roberson RMB Consulting EGU Consultant Roberson@mb-consulting.com Y

Matthew Rutledge Lafarge Facility

Robin Segall EPA/OAQPS/AQAD/MTG EPA segall.robin@@epa.gov

Luc Sevrette Gasmet Equip Vendor luc.sevrette@gasmet.com

Ty Smith Cemtech Environmental Equip Vendor ty@cemteks.com

Candace Sorrell EPA/OAQPS/AQAD/MTG EPA sorrell.candace@epa.gov Y

Martin Spartz Prism Analytical technology Tester m.spartz@pati-air.com

Bob Vantuyl Ash Grove Cement Facility bob.vantuyl@ashgrove

Henry Vergeer CEM Specialties Equip Vendor vergeer@cemsi.on.ca Y

Dave Vigowax Marantee Tile Facility

Bethany White RMB Consulting EGU Consultant white@rmb-consulting.com Y

James Willis Titan America Facility jwillis@titanamerica.com

Hector Ybanez, Holcim Inc. Facility hybanez@gmail.com

Musa Zada Altech Equip Vendor

Peter Zemek MKS Instruments Equip vendor Peter_Zemek@mksinst.com Y

Y= Higlighted attendance indicates first time participants.