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Instrumental Test Methods Updated (6/9/06)

On May 15, 2006, EPA published “Updates of Continuous Instrumental Test Methods” in the Federal Register as a final rule.  The final rule revises Reference Methods 3A, 6C, 7E, 10 and 20.  Highlights of the changes are listed below.  These new methods must be used on any RATA or compliance test after August 14, 2006.  RMB suggests that you contact your testing company immediately to make sure that it has a plan for implementing these Reference Methods.

  • Method 7E now serves as the foundation of the instrumental methods as opposed to Method 6C.

  • Method 7E introduces more stringent QA test requirements (e.g., a Manufacturer’s StabilityTest for “low concentration analyzers”) and associated recordkeeping requirements for the tester.

  • Method 7E requires that the reference method analyzer span be equal to the high-level gas concentration.  This will likely prove to be problematic for sources that require the test contractor to use in-house calibrations gases during RATAs since setting the span value to the high-level gas may render the low- or mid-level concentrations as unsuitable for use.

  • Although Method 20 has not been removed as a reference method, effectively there is no difference between Methods 7E and 20.  For example, the Method 20 preliminary O2 traverse and four-level calibration gas requirements have been removed.

A copy of the final instrumental test method rule is available in our FTP Library.

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RMB Consulting & Research, Inc.
Last Revised: January 31, 2007