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EPA Releases Revisions to Stack Flow Reference Method (05/10/99)

The EPA Acid Rain Division has released long awaited new 3-D, yaw corrected and wall effects flow measurement test methods. The methods are designated 2F, 2G and 2H respectively and are very helpful in reducing the positive bias in the standard Method 2 measurement of stack flowrate. This positive bias results in reporting excessive SO2 and NOX mass emissions. All utilities and other affected sources should say "Thank You" to the Electric Power Research Institute for funding the initial studies that demonstrated the positive bias in Method 2 and the precision of the 3-D methods. We have put Methods 2F, 2G and 2H on our FTP library for your download. The file is titled "3dflow.zip" and the zip file contains seven files - a HTML fact sheet, the rule preamble in both pdf and WP6 format and the three methods in WP6 format (Method 2F is in 2 files, Part 1 and Part 2).

It is important to recognize that these test methods will be published in the Federal Register as a "Direct Final" rule which means that they will become final 60 days following promulgation UNLESS NEGATIVE COMMENTS ARE RECEIVED. We recommend that negative comments NOT BE SENT for the reasons discussed below. If negative comments are submitted, it is probable that the direct final rulemaking will be canceled and promulgation of the methods will be delayed for 6-9 months.

RMB personnel have been involved in the review of drafts of these methods and recognize that all of the methods are excruciatingly detailed and extrodinarily difficult to conduct under actual field conditions. Even though the methods are less than optimum, we recommend that they be supported because of the obvious benefit of reducing the positive bias in Method 2. We are assuming that, as the methods are used under actual field conditions, users can provide feedback to EPA and the methods will be modified to conform to reality.

EPA also published another clarification to the EDR 2.1 format and a revision to the EDR instructions. We have also put that group of files on our FTP Library as "EDR 2_1 99 05 04 version.zip" This zip file contains 3 files - the EDR version 2.1 and instructions in pdf format and the instructions in WP6 format.

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Last Revised: May 28, 1999