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Annual Span Evaluation Due 12/31/99 (10/18/99)

As previously noted (see Time Table for Implementation of Part 75 Rule Revisions), EPA has issued a guidelines for implementing the May 26, 1999 revisions to Part 75. A copy of EPA’s Implementation Guidelines can be found in RMB’s FTP Library. EPA identified six categories of rule revisions with associated time lines for implementation. In an effort to keep affected sources abreast on these phased-in Part 75 requirements, RMB will periodically post notices similar to the span evaluation discussion below to our website.

The span/range evaluation required in Appendix A, Sections,, and for SO2, NOx, CO2 and flow monitors, respectively, must be completed by December 31, 1999. The completion of the span evaluation was identified as a Category 3 provision in EPA’s Implementation Guidelines. Consistent with Appendix A to Part 75, the owner or operator must conduct a periodic evaluation of the maximum potential concentration, maximum expected concentration, span and range for each pollutant and volumetric flow monitor. Future periodic evaluations must be performed annually-at minimum. The span setting should ensure that the readings during normal operation are between 20% and 80% of full-scale range, to the extent practical. Adjustments may be required when changes are made to the fuel supply, unit operation, or installation for air pollution control equipment.

The owner or operator is required to maintain a copy of the most recent span evaluation on-site in a form suitable for inspection. Each span change must be made within 45 days after the end of the quarter in which the evaluation was conducted. However, up to 90 days after the end of the quarter may be taken to implement the span change if the calibration gases currently used for the calibration error tests and linearity checks are unsuitable for the new span. Moreover, whenever a span change is sufficient to render the calibration gases unsuitable for use, a linearity check must be passed as a diagnostic test. Data is considered invalid from the hour of adjusting the span until the successful completion of a linearity check.

Both the hardcopy and the electronic EDR version of the Monitoring Plan must be updated whenever changes are made to an analyzer’s span. The changes to the Monitoring Plan must be made in the quarter for which the span adjustment was made. For the hardcopy Monitoring Plan, the designated representative is required to submit only those portions of the document that have changed.

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RMB Consulting & Research, Inc.
Last Revised: October 21, 1999