Public comments for: DEP Proposed Rule Concerning Emission Control Devices on Certain Commercial Char broilers

Comments

Comment:
Please include the SCAQMD method 5.1 attached as an approved method under 37-06 b) (ii). It is a well-established, simpler and just as accurate method for determining filterable and condensible particulate matter from cooking emissions as EPA method 5 ( front and back halves) and has been the analytical method for char broiler air quality regulation development in California, with the BAQD looking at a direct side by side comparison of the two methods. The analytical testing required to meet this rule is very expensive and by having a method that satisfies both jurisdictions, manufacturers are more likely to participate in product development and testing to meet the regulations in both locales. I have participated in both testing methodologies and have first hand experieince that the SCAQMD 5.1 is more facile and less likely to have sampling errors. The method has been forwarded to DEP previously for consideration. Attached is an email from my colleague Bill Welch, senior air quality engineer at SCAQMD, commenting on the issue. Thank you.
Supporting Document:
Agency: DEP