                      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.
      
