Instrumental Test Methods Updated
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
A copy of the final
instrumental test method rule is available in our
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January 31, 2007