As the seasons change, so will your Performance Test Methods (Potentially)!

As the season changes from summer to fall, so will most of your performance test methods and performance specifications.  U.S. EPA issued a final rule on August 30, 2016 to make technical and editorial corrections and updates to testing provisions.  The revisions are intended to improve the quality of data and provide flexibility in the use of approved alternative procedures.  The rule is effective as of October 31, 2016, which is can be viewed here.

Noteworthy changes include, but are not limited to:

• Method 202: Among other corrections, U.S. EPA added a section to require calibration of the field balance used to weigh impingers and to require a multipoint calibration of the analytical balance.
• 40 CFR Part 60, Subpart A (General Provisions): §60.8(f) will be revised to require reporting of specific emissions test data in test reports.
  • Current language:

Unless otherwise specified in the applicable subpart, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic means of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator’s control, compliance may, upon the Administrator’s approval, be determined using the arithmetic mean of the results of the two other runs.

• • Language as proposed:

Unless otherwise specified in the applicable subpart, each performance test shall consist of three separate runs using the applicable test method.

(1)….

(2) Contents of report (electronic or paper submitted copy). Unless otherwise specified in a relevant standard or test method, or as otherwise approved by the Administrator in writing, results of a performance test shall include general identification information for the facility including a mailing address, the actual address, the owner or operator or responsible official (where they are applicable) or an appropriate representative and an email address for this person, and the appropriate Federal Registry System (FRS) number for the facility; the purpose of the test including the regulation requiring the test, the pollutant being measured, the units of the standard or the pollutant emissions units, and any process parameter component; a brief process description; a complete unit description, including a description of feed streams and control devices, the appropriate source classification code (SCC), and the latitude and longitude of the emission point being tested, and the permitted maximum process rate (where applicable); sampling site description; description of sampling and analysis procedures and any modifications to standard procedures; quality assurance procedures; record of operating conditions, including operating parameters for which limits are being set, during the test; record of preparation of standards; record of calibrations; raw data sheets for field sampling; raw data sheets for field and laboratory analyses; chain-of-custody documentation; explanation of laboratory data qualifiers; example calculations of all applicable stack gas parameters, emission rates, percent reduction rates, and analytical results, as applicable; identification information for the company conducting the performance test including a contact person and his/her email address; and any other information required by the test method, a relevant standard, or the Administrator.

• • U.S. EPA has proposed to add specific test report requirements in lieu of the generalized approach in the current language.  It should be noted that most of the information that will now be required in the proposed §60.8(f) revision is already included in most test reports.  However, now with “Next Gen” compliance and increased transparency, the information will be available to a much wider audience and will possibly include the contact information for the environmental manager.
• Performance Specification (PS) 1 of Appendix B of Part 60:  PS1 will be revised to not limit the location of a continuous opacity monitoring system (COMS) to a point at least four duct diameters downstream and two duct diameters upstream from a control device or flow disturbance.
• PS2 of Appendix B of Part 60: The definition of span will be revised to include the sentence, “For spans less than 500 ppm, the span value may either be rounded upward to the next highest multiple of 10 ppm, or to the next highest multiple of 100 ppm such that the equivalent emissions concentration is not less than 30 percent of the selected span value.”
• PS3 of Appendix B of Part 60: PS3 will be revised to clarify how to calculate relative accuracy.
• Procedure 2 of Appendix F of Part 60: Equations 2-2 and 2-3 in Section 12.0 will be revised to correctly define the denominator when calculating calibration drift.  Equation 2-4 will be revised to correctly define the denominator when calculating accuracy.

The above mentioned corrections and/or revisions are definitely not all inclusive.  U.S. EPA plans to make several revisions in addition to the ones listed above.  As the fall season begins, grab a piece of pumpkin pie and review what revisions may affect your facility’s test program.  If you would prefer to just enjoy your pumpkin pie, give us a call and let us review the changes specific to your test program for you. At a minimum, you will want to share these revisions with your stack test company to make sure they are aware for any testing performed after the October 31^st effective date.  If you have any questions, feel free to contact me at (334) 855-3382 or sbowden@all4inc.com.