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Substantial Part 60 Reference Method Changes Proposed (10/25/97)

Early last week RMB began to receive messages from utility associations, individual utilities and EPA regional personnel that the proposed revisions (08/27/97) to 40 CFR Part 60 were substantive and not reformatting as suggested in the Federal Register Notice. These revisions affect any industry that uses continuous emissions monitors or has a requirement to use any of the EPA Reference Methods or Performance Specifications. This Federal Register Notice had slipped by most industry personal (including RMB) because it implied that the changes to Part 60 and the EPA Reference Test Methods were only to reformat the methods to a consistent Agency format. The revised reference methods were not included in the notice; only information on where to obtain the revisions. The Utility Air Regulatory Group (UARG) asked RMB to review pertinent sections of the proposed revisions and provide technical comments (This was done and the UARG comments will be filed before the comment deadline). Upon review it was discovered that there were a number of substantive changes, many of which are unworkable. Comments on the proposed rule are due on Monday, 10/27/97; however, we have been assured that late comments of a technical nature will be considered by EPA. We have bundled several pertinent files into a fairly large zip file and put it on our FTP Library. The file name is prorul60.zip and it includes the Federal Register Notice, revised EPA Reference Methods 3A, 6C, 7E and revised Performance Specification 2 in Adobe PDF format.

Now for the fun (We can't be serious all the time) - RMB is offering a $100 reward for the first person that that can tell us the emission standard for O2 and CO2 for an electric utility steam generator. Hint - read revised Method 6C first and then read revised Method 3A. The first person to E-mail the correct answer, per the revised methods, to webmaster@rmb-consulting.com wins a brand new Ben Franklin!! We will even award the Franklin for the best or most humorous answer (since we do not believe there is a correct answer).

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RMB Consulting & Research, Inc.
Last Revised: May 22, 1998