EPA/OAQPS Pollutant Emissions Measurement Update 2019

1. EPA/OAQPS Pollutant Emissions Measurement Update 2019 Robin Segall EPA Office of Air Quality Planning & Standards ACIL Environmental Sciences Section Meeting March 27, 2019

2. Stationary Source Measurement Program • Sources of emissions (industrial plants) are required to conduct measurements to demonstrate compliance with emission standards • Short-term methods • Continuous monitoring

3. Test Method Update Rulemakings • Latest Test Method Update • Finalized November 14, 2018 (83 FR 56713) • Revisions to over 25 Test Methods & Performance Specifications for continuous emissions monitoring systems • Numerous corrections/clarifications • Added detailed reporting requirements for CEMS performance evaluations and QA tests • Revised Methods 325A & B for fence-line monitoring of benzene from refineries • Based on broadly applicable alternative method approval • Next Test Method Update to be proposed later in 2019

4. Test Method Validation • Revisions to Method 301 – Field Validation of Pollutant Measurement Data and Methods • Finalized March 20, 2018 (83 FR 12118) • Distinguish between validation requirements for single- and multiple-source application of candidate method • Clarified validation approaches and associated statistical calculations • Reference 40 CFR Part 136, Appendix B approach for limit of detection • Developed web tool for Method 301 calculations • On EMC website with Method 301 at: www.epa.gov/emc/method-301-field-validation-pollutant-measurement-methods-various-waste-media

5. Revisions to Method 23 for Dioxins & Furans • Method 23 collects stack gas sample on filter/probe/XAD sorbent with analysis by isotope dilution HRGC/HRMS • Revisions to analytical procedures are performance-based to allow for flexibility in using method and technology advances without need to revise the method • Will now accommodate PCB and PAH compounds • Proposal package including method are nearly complete • Expect proposal in summer of 2019

6. Revisions to Method 202 for Condensable Particulate Matter (CPM) • Method 202 is a “dry-impinger” based method for the measurement of CPM • Current version published December 21, 2010 (75 FR 80118) • Eliminated SO2 “artifact” bias in the previous version of the method which utilized “water-impingers” • Many testers could not meet the Blank Sample criteria • EPA published interim guidance allowing an increased blank criterion for PSD/NSR testing • Published Best Practice Document in 2016 aid testers in meet the blank sample criteria of the Method • Proposed revisions to incorporate Best Practices into the method on September 08, 2017 (82 FR 42508) • Response to Comments is complete and regulatory package is being prepared • Expect to finalize in late Summer or early Fall 2019

7. New Method 326 for Isocyanates • Published March 4, 2019 (84 FR 7707) • Included in Residual Risk and Technology Review rule for Surface Coating of Wood Building Products • Based on the previous proposed Method 207 (62 FR 64532) which was never finalized • No significant changes to the sampling and analytical techniques of the previously proposed method • Uses SW-846 Method 0010 sampling train • Derivatizing reagent [1-(2-pyridyl) piperazine in toluene] in the impingers to immediately stabilize the isocyanate compounds upon collection • Collected samples are analyzed using high performance liquid chromatography (HPLC)

8. Planned Revisions to Other Test Methods • Method 18 – Gaseous Organic Compounds by GC • Method 25A - Total Gaseous Organics by FID • Method 320 - Vapor Phase Organics and Inorganics by FTIR • Stakeholder Groups formed and input received; beginning to pull together draft rulemakings

9. Approved Alternative Methods • Nimble alternative test method approval process • Typically act on approximately 50 alternative method requests per year, most facility-specific and several broadly applicable • Announce broadly applicable approvals on our website at: www.epa.gov/emc and on yearly basis in Federal Register • In 2018, sorbent trap-based method for HCl emissions approved for use at electric utility boilers

10. PFAS (Per- and Polyfluoroalkyl Substances) • EPA Action Plan issued on February 14, 2019 • Initial focus has been on drinking water Method 537.1 • Working with EPA ORD to evaluate methods for stack emissions, ambient air, and deposition • Will support states, tribes, federal partners, and other stakeholders in site assessment, remediation, potential for exposure, etc.

11. Ethylene Oxide (EtO) • Latest National Air Toxics Assessment identified EtO as a potential concern in several areas across US • Measurement in ambient air is challenging since levels of concern are in ppt range • Direct measurement of emissions from facilities using FID or GC/FID will be used with modeling to provide more information on ambient levels; challenge is representative measurement of fugitive emissions • MTG is working on improved measurement techniques which are more sensitive and faster to respond than previous methods for both source and near-source measurement

12. Questions?