Update on Environmental Protection Agency (EPA)

Update on Environmental Protection Agency (EPA)

Regulatory Program Planned 2014 - 2015 Activities Related to Environmental Methods and Monitoring

by

David Friedman

ACIL Annual Meeting

Chicago, IL

October 5, 2014

Office of Resource Conservation and Recovery

SW-846 Program

Current emphasis by Office is on finishing up and publishing Update V to SW-846.

-The update was proposed on October 23, 2013 (78 FR No. 205).

-At the time, EPA announced the availability of 23 new and revised methods, 5 revised chapters, and the SW-846 Policy Statement that ACIL and ELAB had been asking for.

-The comment period closed on January 23, 2014 and 111 comments were received.

-After reviewing the comments, ORCR revised several methods.

-Current plans are to formally incorporate the final methods into SW-846 in late 2014.

-The update should contain the following update or new methods:

1030 / Ignitability of Solids
3200* / Mercury Species Fractionation and Quantification by Microwave-assisted Extraction,
Selective Solvent Extraction and/or Solid Phase Extraction
3511* / Organic Compounds in Water by Microextraction
3572* / Extraction of Wipe Samples for Chemical Agents
3620C / Florisil Cleanup
4025* / Screening for Polychlorinated Dibenzodioxins and Polychlorinated Dibenzofurans (PCDD/Fs) by
Immunoassay
4430* / Screening For Polychlorinated Dibenzo-p-Dioxins And Furans (PCDD/Fs) By Aryl
Hydrocarbon-Receptor PCR Assay
4435* / Method For Toxic Equivalents (TEQS) Determinations For Dioxin-Like Chemical Activity with the
CALUX® Bioassay
5021A / Volatile Organic Compounds in Various Sample Matrices Using Equilibrium Headspace Analysis
6010D / Inductively Coupled Plasma-Atomic Emission Spectrometry
6020B / Inductively Coupled Plasma-Mass Spectrometry
6800 / Elemental and Speciated Isotope Dilution Mass Spectrometry
8000D / Determinative Chromatographic Separations
8021 / Aromatic and Halogenated Volatiles by Gas Chromatography Using
Photoionization and/or Electrolytic Conductivity Detectors
8111 / Haloethers by Gas Chromatography
8270D / Semivolatile Organic Compounds by Gas Chromatography/Mass Spectrometry
8276* / Toxaphene and Toxaphene Congeners by Gas Chromatography/Negative Ion Chemical
Ionization Mass Spectrometry (GC-NICI/MS)
8410 / Gas Chromatography/Fourier Transform Infrared Spectrometry for Semivolatile Organics:
Capillary Column
8430 / Analysis of Bis(2-Chloroethyl) Ester and Hydrolysis Products by Direct Aqueous Injection
9013A / Cyanide Extraction Procedure for Solids and Oils
9014 / Titrimetric and Manual Spectrophotometer Determinative Methods for Cyanide
9015* / Metal Cyanide Complexes by Anion Exchange Chromatography and UV Detection
9320 / Radium 228
Chapters / Revised Chapters 1 -5
Policy Statement / SW-846 Policy Statement, definitions and terms

Once Update V is finalized, the push will be on preparing and proposing an Update VI. Currently the office anticipates including in the Update VI package the following methodology:

Leaching Environmental Assessment Framework (LEAF) and its new leaching methods. This includes:

-Method 1313 - Liquid-Solid Partitioning as a Function of Extract pH using a Parallel Batch Extraction Procedure

-Method1316 - Liquid-Solid Partitioning as a Function of Liquid-Solid Ratio using a Parallel Batch Extraction Procedure

-Method 1314 – Liquid-Solid Partitioning as a Function of Liquid-Solid Ratio for Constituents in Solid Materials using an Up-flow Percolation Column Procedure

-Method 1315 – Mass Transfer Rates of Constituents in Monolithic of Compacted Granular Materials using a Semi-dynamic Tank Leaching Procedure

The LEAF test methods have already been published and are available for use to characterize the leaching potential over a range of conditions (i.e., pH, liquid-to-solid ratio, and waste form). LEAF characterization tests can be used to evaluate range of materials to identify leaching behavior for range of field conditions for disposal and beneficial use Supporting software is available for implementation including (1) LEAF method templates and (2) LeachXS-Lite for data entry, analysis, visualization, and reporting. To obtain the software, contact Greg Helms (EPA/ORCR) at 703-308-8845 ().

Future efforts will focus on:

-developing guidance to implement LEAF;

-Method 1340- In-Vitro Bioaccessibility Assay For Lead in Soil;

-Method 3050 - Acid Digestion of Sediments, Sludges, and Soils;

-Method 6200 – Field Portable X-Ray Fluorescence Spectrometry For the Determination of Elemental Concentrations in Soils and Sediment;

-Method 8260 - Volatile Organic Compounds by Gas Chromatography/ Mass Spectrometry; and

-Method 8270 - Semivolatile Organic Compounds by Gas Chromatography/ Mass Spectrometry

(Progress on Methods 8260 and 8270 is currently running behind schedule and this might result in a delay in the issuance of Update VI which is planned for 2015.)

Office of Air Quality Planning and Standards

Clean Air Act Program

Below is a status report of projects and other current activities involving air emissions methods and monitoring and other emissions quantification tools, databases, and protocols obtained from EPA Clean Air Act methods program.

New and Revised 40 CFR Part 60, Appendix A, Test Methods

-Test Methods Update Rulemaking – Over the last 10 years, EMC has been cataloging errors and other needed revisions to test methods, performance specifications, and associated regulations in 40 CFR parts 60, 61, and 63. Many of these needed revisions have been brought to our attention by affected parties and end-users. The corrections and revisions consist primarily of technical errors in equations and diagrams, the addition of alternative equipment or methods the Agency has found acceptable to use, removal of requirements to use mercury-in-glass thermometers, and typographical errors. Updates have been made to Methods 1, 2, 2A, 2B, 2D, 3A, 3C, 4, 5, 5A, 5E, 5H, 6, 6C, 7, 7A, 7E, 8, 10, 10A, 11, 12, 14A, 16A, 16C, 18, 23, 24, 25, 25C, 25D, 26, 26A, 29, 30B, 101, 101A, 102, 104, 108, 108A, 306, 306A, 308, 315, 316, and 321; Performance Specifications 3, 4, 4B, 7, 11, 12B, 15, and 16: and Procedures 1, 2, and 5 of Appendix F. The final rule was signed by the Administrator on January 28, 2014 and published on February 27, 2014. The rule is posted at Contact: Lula Melton, MTG,

-Method 2H Revisions – Method 2H describes the procedures to determine the decay of stack gas velocity near the wall of circular stacks. On August 25, 2009 (74 FR 42819), we proposed revisions to Method 2H to incorporate the improvements from Conditional Test Method (CTM)-041 for assessment of wall effects for rectangular stacks which have been frequently requested for use through the petition process of the Acid Rain Program. These revisions would allow Method 2H to address wall effects in rectangular stacks, allow multiple runs at a single load, decouple the wall effects testing from the Relative Accuracy Test Audit (RATA), and provide a mathematical formula for determination of a stack specific default wall effect adjustment factor. Comments were received on the proposal and promulgation has been rescheduled for late 2014. Contact: Jason DeWees, MTG, .

New and Revised 40 CFR Part 60, Appendix B, Performance Specifications for Continuous Monitoring Systems

-Performance Specification 11 Revisions and Guidance –Corrections and clarifications to the equations and confidence and tolerance interval calculations in the Specifications and Test Procedures for Particulate Matter Continuous Emission Monitoring Systems at Stationary Sources (PS-11) were finalized on March 25, 2009 (74 FR 12575). The preamble to the 2009 revisions signaled forthcoming guidance on precision and bias, handling of paired train data, example calculations, spreadsheets, stratification, and auditing. As part of this commitment, we posted a set of files on the EMC FAQ web page associated with PS-11( that includes (1) a spreadsheet and instructions for evaluating correlation test data to demonstrate compliance with PS-11, (2) information on evaluation of response correlation audit (RCA) data and evaluation of particulate matter stratification in ducts and stacks, (3) summary sheets on audit and routine system checks required by Procedure 2 for PM CEMS, and (4) question and answer documents. We are curently in the process of evaluating a number of potential changes to be made to PS-11. In addition, the recently signed Test Methods Update Rulemaking included corrections to the correlation equations in PS-11. Contact: Kim Garnett, and Jason DeWees, MTG, .

-HCl CEMS Performance Specification 18 and Procedure 6 – We are preparing a flexible measurement based Performance Specification (PS 18) for HCl CEMs to support standards for the Mercury and Air Toxics rule, and the Portland Cement MACT Standard. The PS 18 is a result of work with stakeholder(s) and vendors who provided information on current HCl CEMS availability and performance. We held a series of conference calls with the stakeholders to discuss technology, the current status of field measurement implementation, and the availability of certified calibration and reference gas standards. Like PS 15 for FTIR continuous emissions monitoring, the draft HCl CEMS Performance Specification is appropriate for measuring HCl emissions in the range of 0 to 5 ppm, but unlike PS 15 it is designed to be technology neutral. We distributed three draft versions of PS18 and one draft version of Procedure 6 to the stackholders for review. Currently the PS 18/ Procedure 6 Proposal package has been submitted for review, approval and EPA Administrator signature. We are hoping the package will be signed in March 2014 with promulgation in late 2014 or early 2015. Proposal was May 14, 2014 Contacts: Candace Sorrell, MTG, , and Ray Merrill, MTG, ,

New and Revised 40 CFR Part 60, Appendix F, Quality Assurance Procedures for Continuous Monitoring Systems

-Procedure #3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources - EPA published a direct final and a parallel proposed rule to establish quality assurance and quality control (QA/QC) procedures for continuous opacity monitoring systems (COMS) on February 14, 2012 (77 FR 8160). The proposed QA/QC requirements (referred to as Appendix F, Procedure 3) were revised to address public comments received and a final rulemaking package has now been submitted to EPA’s Office of General Counsel (OGC) for review. We will publish the final Procedure 3 as soon as possible after receiving comments from OGC. Promulgation was May 16, 2014 Contact: Lula Melton, MTG, , 919-541-2910 and Solomon Ricks, AAMG, , 919-541-5242.

New and Revised 40 CFR Part 63, Appendix A, Test Methods

-Draft Methods 325Aand 325B for Passive Fenceline Monitoring for Fugitive and Area Sources - We have drafted a method to assess fugitive/area source emissions that uses sorbent tubes coupled with thermal desorption and gas chromatographic (GC)-based analysis. The methods address field placement (M-325A) of sorbent tubes that passively accumulate volatile organic compound (VOC) from air at or near area or fugitive emission sources (M-325A) and gas chromatographic analysis of the tubes (M-325B). Method 325A allows sampling site placement using equal linear distance between samplers or equal degrees of separation around the geometric center of a facility. We have evaluated the performance of the methods in laboratory and field comparisons using duplicate samples and passivated steel canisters for comparison. Evaluation tests include the effects of temperature, humidity, variable concentration and storage time. The portability and small size of typical sampling packages for passive sorbent-based sampling and the wide range of sorbent choices make this monitoring approach appealing for special monitoring studies of human exposure to toxic gases and the measurement of volatile organic compounds (VOC) from area or fugitive emission sources. We anticipate the passive monitoring procedures will be used as one of a combination of tools to identify and quantify emissions from fugitive and area sources. In the future, the passive sorbent tube measurement approach may be combined with active sorbent tubes, canister-based monitoring methods, on-site auto GC systems, open path instrumentation, and other specialized point monitoring instruments to address measurement needs for VOCs around fugitive and area emission sources. We’re targeting proposal of these methods as part of the Refinery MACT revisions due for release in 2014. Proposal was published on June 30, 2014 Contacts: Ray Merrill, MTG, and Jason DeWees, .

New and Revised 40 CFR Part 51, Appendix M, Test Methods

-Methods 201A and 202 Revisions - Revisions to Methods 201A and 202 for fine PM emissions were promulgated on December 21, 2010 (74 FR 12970). Clarifications to the methods for the two methods are now posted as part of the Final Rule: Revisions to Test Methods and Testing Regulations and can be found at We have completed the first phase of a new project to evaluate and propose minor changes to Methods 201A and 202. We plan to post best practices for Method 201A including how to individually measure filterable PM10, PM2.5 and/or total particulate later this calendar year. We also plan to post a document addressing best practices for measuring low concentration condensable particulate using Method 202 on the EMC website. Contacts: Ray Merrill, MTG, or Jason DeWees, MTG, .

Source Category Approved Alternative Test Methods

These methods, published on the EPA/EMC website at are broadly approved alternatives to the methods required by 40 CFR Parts 59, 60, 61, 63 and 65 as described by the General Provisions and/or subparts of the corresponding Parts. As such, they may be used by sources for determining compliance with the requirements of these Parts per their specified applicability provisions without further EPA approval. The Administrator’s delegated authority (the Leader of the Measurement Technology Group), has approved these methods for the specified applications; this approval has been documented through an official EPA letter. These methods include quality control and quality assurance procedures that must be met. Note that EPA staff may not necessarily be the technical experts on these method alternatives.

Federal Register Notice on Broadly Applicable Alternative Test Method Approvals -The first of these notices, published January 30, 2007 (72 FR 4257), announced broadly applicable alternative test method approval decisions that EPA had made prior to 2007 under and in support of the New Source Performance Standards and the National Emission Standards for Hazardous Air Pollutants. This notice announced our plans to issue broadly applicable alternative test method approvals in the future and to post these broadly applicable approvals on the EMC website as well as announce them in the Federal Register. The publication of these broadly applicable alternative test method approvals on our website provides information about options and flexibility for the regulated community that may reduce the burden on source owners and operators in making site-specific alternative test method requests and the permitting authorities and the EPA Administrator in processing those requests. Updated announcements of the broadly applicable approval decisions for 2007, 2008, 2009, 2010, 2011, and 2012 were published in the Federal Register on April 7, 2008 (73 FR 18794), February 26, 2009 (74 FR 8791), February 22, 2010 (75 FR 7593), February 22, 2011 (76 FR 9777), February 15, 2012 (77 FR 8865), and February 15, 2013 (78 FR 11174). We are in the process of developing the Federal Resister notice for broadly applicable approval decisions made in 2013. Contact: Lula Melton, MTG, , Jason DeWees, MTG, , and Robin Segall, MTG,

Other Test Methods

These methods, published on the EPA/EMC website at are test methods which have not yet been subject to the Federal rulemaking process. Each of these methods, as well as the available technical documentation supporting them, have been reviewed by the EMC staff and have been found to be potentially useful to the emission measurement community. The types of technical information reviewed include field and laboratory validation studies; results of collaborative testing; articles from peer-reviewed journals; peer-review comments; and quality assurance (QA) and quality control (QC) procedures in the method itself. These methods may be considered for use in federally enforceable State and local programs (e.g., Title V permits, State Implementation Plans (SIP)) provided they are subject to an EPA Regional SIP approval process or permit veto opportunity and public notice with the opportunity for comment. The methods may also be considered as candidates to be alternative methods to meet Federal requirements in 40 CFR Parts 60, 61, and 63; however, they must be approved as alternatives under 40 CFR 60.8, 61.13, or 63.7(f) before a source may use them for this purpose. The methods are available for application without EPA oversight for other non-EPA program uses including state permitting programs and scientific and engineering applications. The EPA strongly encourages the submission of additional supporting field and laboratory data as well as comments in regard to these methods.

-OTM for Wind Blown Dust - The Measurement Technology Group (MTG) was contacted by the Center for Study of Open Source Emissions (CSOSE), which is a research center for measurement method development for open source dust and particle pollution. CSOSE submitted to MTG for consideration a method which describes how to measure PM emissions near roadways. This method, designated OTM 32, is designed to quantify from open, roadside sources. This method utilizes plume profiling, which is an open source emission test method based on the exposure profiling concept, with exposure defined as the time-integrated mass flux of pollutant at a sampling point. The mass flux is the product of pollutant concentration and wind speed, which gives the pollutant mass passing the sampling point per unit cross-section of the plume per unit time. The total emissions from the source during the sampling period is found by spatial integration of the exposure over the cross-section of the plume, in the same manner as performed in standard emission testing of ducted sources based on the principle of conservation of mass. Contact: Dennis Mikel, . This method is currently available at Emission Monitoring Center (EMC) website at:

-OTM Using a Mobile Platform - This method was submitted by the CSOSE and Desert Research Institute (DRI). This test method is designed to quantify road dust PM emissions from vehicles traveling on paved and unpaved roads. The method, designated OTM 34, relies on the measurement of the increase in PM concentrations over ambient background levels at one or more locations that are directly influenced by road dust that is emitted from the interaction of vehicle tires with the road surface. This method can be applied to any paved road or unpaved (dirt or gravel) road that is 100 meters or greater in length. The total emissions from the source during the sampling period is found by spatial integration of the exposure over the cross-section of the plume, in the same manner as performed in standard emission testing of ducted sources based on the principle of conservation of mass. Contact: Dennis Mikel, .

Tools for Improved Monitoring and Testing

-Technical Foundation for Potential Future Optical Gas Imaging (OGI) Protocol– MTG is conducting studies to assess the technical underpinnings necessary to support a possible future rulemaking to govern the use of OGI for leak detection and repair or other work practice standards. EPA is trying to quantitatively determine the detection capabilities for these instruments and parameter envelopes for their use. Some of the parameters of interest include background versus gas temperatures, homogeneity of the thermal background, effects wind speed, relative humidity, and gas composition, and concentration-depth of the gas versus the performance of OGI instruments. Contacts: Jason DeWees, , Robin Segall, , Gerri Garwood, .