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EPA Proposes QA/QC Procedures for Opacity Analyzers (2/24/12)

On February 14, 2012, EPA published Procedure 3 in the Federal Register both as a direct final rule and parallel proposed rule. Procedure 3 is intended to define ongoing QA/QC for continuous opacity monitoring systems (COMS) that are used for compliance. Comments on the proposed procedure are due by March 15, 2012. This rulemaking effort has caught many off guard. Even though the Agency first proposed QA/QC for COMS twenty years ago in 1992, the revised proposal that it subsequently published in 2003 languished. EPA never finalized that proposal after receiving comments. Now nine years later, EPA is suggesting the potential of a direct final rule that would become would effective on April 16, 2012 if no adverse comments are received.

In addition to the daily calibration requirements, the Procedure 3 proposal includes quarterly optical alignment checks, filter audit checks and zero compensation assessments as well as annual zero alignment checks. These proposed core QA/QC specifications may, in general, be reasonable but there are a number of details the proposal, such as the 95% data capture requirement that that pose problems and are inappropriate for such a procedure. There are still references to Performance Specification 1 that could be problematic for COMS installed prior to 2001 as well concerns that the applicability language may not be specific enough keep sources with blanket references to Appendix F in their permits or state regulations from being required to comply with Procedure 3.

A copy of the Procedure 3 proposal can be found in our FTP library

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Last Revised: February 16, 2016