Comment submitted by Kevin Moses, LDARtools, Inc.

Document ID: EPA-HQ-OAR-2010-0869-0038
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: July 12 2012, at 12:00 AM Eastern Daylight Time
Date Posted: July 16 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: March 26 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: September 24 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8109c5bd
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This is comment on Proposed Rule

National Emission Standards for Storage Vessels, Equipment Leaks, and Closed Vent Systems and Control Devices; and Revisions to the National Uniform Emission Standards General Provisions

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At some facilities it is standard for probe filters to be changed right before drift assessments. Studies have shown that a decreased flow rate due to a dirty filter can cut ppm readings by up to 90%. Is it acceptable to change filters when out in the field if you are not using some kind of filter (vacuum, flow, pressure) monitoring system? Is it acceptable to change filters before or during a drift assessment?