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Proposed Revisions to Reference Method 2H (9/23/09)

EPA published proposed revisions to Reference Method 2H in the August 25, 2009 Federal Register.  The Agency is revising Method 2H in order to harmonize the method with Conditional Test Method 41 (CTM-041).  The proposed revisions address wall effects for both circular stack and rectangular duct measurement locations and extend the improvements that were included in CTM-041 to all units.

The revisions to Method 2H will increase the accuracy of the method and simplify its application:

  • Increased accuracy while eliminating unnecessary tests.  The revisions would significantly reduce the uncertainty of wall effect adjustment factors (WAFs) by requiring that at least three wall effect runs be conducted rather than a single run as is currently allowed.  However, consistent with EPRI and EPA field test results  showing wall effects are independent of load and do not change over time, the revisions allows the WAF to used for any subsequent RATAs, provided that the same number of traverse points are use or changes are made to the duct or stack.  Thus, while the initial effort would be increased, the overall testing requirements would be reduced.  Do it once but do it right.

  • Decoupled from RATA.  The revised method does not need to be coupled with a RATA, allowing sources to avoid the potential difficulties and problems associated with trying to measure wall effects using Methods 2F or 2G.

  • Consistent Application.  By harmonizing Method 2H and CTM-041 into one revised method covering both circular stack and rectangular duct sources, the reporting should be streamlined.  CAMD would no longer have to address petitions for the use of CTM-041 and consistent reporting could be used for both groups of sources. 

  • Unit-specific defaults.  The arbitrary default WAFs and cap have been removed under from the revised method.  Instead, the revisions include options to determine conservative default WAF values that are based on viscous shear theory and take into account stack/duct geometry into consideration.

A copy of the proposed revisions to Method 2H is available in our FTP library.  Comments on the proposed rule are due by October 26, 2009.  Given the improvements to the method, RMB encourages positive comments in support of the proposed revisions.  If you have any questions regarding the proposed Method 2H revisions, please contact Steve Norfleet at (919) 791-3123 or norfleet@rmb-consulting.com.

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Last Revised: February 05, 2012