United States       Stationary Source         EPA-340/1-84-016
Environmental Protection  Compliance Division        September 1984
Agency         Washington DC 20460
Air
Summary of
Opacity and Gas
CEMS Audit
Programs

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                                   EPA 340/1-84-016
Summary  of Opacity and Gas
      CEMS Audit Programs
                   Submitted by

                 Engineering-Science
                10521 Rosehaven Street
                Fairfax, Virginia 22030
                 Contract 68-01-6312
                Work Assignment 130
                   Submitted to

          EPA Contract Project Officer: John Busik
         EPA Work Assignment Manager: Louis Paley
         U.S. ENVIRONMENTAL PROTECTION AGENCY
           Stationary Source Compliance Division
         Office of Air Quality Planning and Standards
                Washington, D.C. 20460

                  September 1984
                                          or,
                                             ,
                                Chicago, -IL  606G4

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                                DISCLAIMER
     This report was prepared by Engineering-Science under Contract No.
68-01-6312, Work Assignment No. 130.  It has been reviewed by the Sta-
tionary Source Compliance Division of the Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency and approved for
publication.  Approval does not signify that the contents necessarily
reflect the views and policies of the U.S. Environmental Protection
Agency.  Mention of trade names or commercial products is not intended
to constitute endorsement or recommendation for use.   [Copies of this
report are available from National Technical Information Services, 5285
Port Royal Road, Springfield, Virginia, 22161.]

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                                    ABSTRACT
     The U.S. Environmental Protection Agency,  Office of Air Quality Planning
and Standards, Stationary Source Compliance Division, as well as the Emission
Monitoring Science Laboratory,  Quality Assurance Division, and several regional
offices have sponsored continuous emission monitoring system (GEMS) performance
audits to determine the precision and accuracy of GEMS and to develop and eval-
uate the audit techniques.  Opacity,  SO2 and NOX GEMS at a variety of industrial
sources (electric utilities, manufacturing facilities, petrochemical processes,
kraft pulp mills, etc.) were audited  using NBS traceable filters, EPA reference
methods, and calibration gases  are reference standards.  This report provides a'
summary of the results of these audits.  The results demonstrate:

     o  80% of the opacity monitors audited met calibration error criteria (5%
        error) for low- and mid-range references values*; 65% of the monitors met
        these criteria for high range reference values.
     o  80% of the gas GEMS met the calibration error criteria (5% error).
     o  80% of the gas GEMS met the relative accuracy criteria (25% relative accu-
        racy) .
*  65% for hi-range reference values.

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              SUMMARY OF OPACITY AND GAS GEMS AUDIT PROGRAMS
PURPOSE

     Since promulgation of state and federal requirements  for  installation
and operation of continuous emission monitoring systems  (GEMS)  the  facil-
ities affected by these requirements have experienced  varying  degrees of
success in achieving and maintaining reliablity and accuracy for  these
systems.  The Environmental Protection Agency  (EPA) regional offices and
the Stationary Source Compliance Division (SSCD) have  sponsored GEM audit-
ing programs for both opacity and gaseous GEMS (NOX and  802) to determine
the accuracy, calibration, and operating status of the GEMS audited.  The
Emission Monitoring and Sampling Laboratory  (EMSL) sponsored the  develop-
ment of these audit procedures and many audits summarized  in this report
were conducted during this development process.  The purpose of this re-
port is to provide a summary of the results of these audits for agency
personnel responsible for assessing the quality assurance  (QA)  of GEMS
data and/or using GEMS excess emission reports in a compliance  program.
This information may be used to compare the performance  (reliability,
accuracy, etc.) of a single CEMS to the experience of  a  larger  popula-
tion as characterized by the summary of audit  results.
BACKGROUND

     The SSCD, the Environmental Monitoring Systems Laboratory  (EMSL)
and many EPA regional offices have conducted performance audits of CEMS
measuring the opacity of particulate emissions and the emission rate of
gaseous SO2 and NOX emissions from stationary sources of air pollution.
Facilities subject to NSPS, SIP, and PSD monitoring requirements, and
representing several major source categories have been audited.  The
opacity CEMS audit procedures used conform to those defined in the EPA
publication entitled "Performance Audit Procedures for Opacity Monitors"
(EPA 340/1-83-010, January 1983).  Gas CEMS were audited using two pro-
cedures: calibration gas audits which determine accuracy and the preci-
sion of a CEMS relative to calibration gases; and, relative accuracy
audits which determine the accuracy of a CEMS relative to measurements
by EPA Methods 6  (SO2) or 7 (NOX).

     The audits were conducted in some cases to determine the quality of
emission measurements made by the CEMS and determine the reliability of
CEMS to properly indicate excess emissions.  In some cases, regional of-
fices requested audits to verify data validity when previous excess emis-
sion reports indicated significant occurrences of CEMS malfunctions or ex-
cess emissions.  Many CEMS were audited because several years had passed
since a. performance specification test (PST), the only demonstration of

                                    1

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GEMS data quality assurance required by NSPS regulation, and by most  SIPs,
other than daily drift checks.  Other audits were conducted as part of an
EMSL sponsored project to develop audit procedures, and still others  were
conducted as part of state agency GEM training programs.

     The audits were conducted by Engineering-Science  (ES) and Entropy
Environmentalists usually with participation of regional, state, or lo-
cal agency personnel who were present to be trained in audit procedures.
Recently all EPA regional air compliance branches., and several state
agencies have received opacity GEMS audit equipment, and some of these
organizations have begun conducting performance audits.
OPACITY GEMS

     The opacity GEMS audit procedures evaluate the operating status and
the performance of each system.  The operating status is determined by
inspection of fault indicators for malfunctions, optical surfaces  for
dirt, and when possible, internal constants such as path length correc-
tion factor, and calibration value.  The performance evaluation verifies
the GEMS response to NBS traceable standards  (optical filters) to  assess
the linearity, precision, and accuracy of  the instruments when tested
against calibration filters.  This procedure uses an optical device to
simulate a clear stack or zero opacity condition.  The criteria used to
evaluate performance results are the calibration error and zero compen-
sation limits (3% and 4% opacity, respectively) found in 40 CFR 60, Ap-
pendix B, PS1.  In most cases where review of the operating status indi-
cated problems, the monitor also failed to meet the performance criteria.
In many of the cases, the problems were easily correctable.

Calibration Error Audit Results

     The results of the calibration error  performance audits for opacity
and gas GEMS are presented in Table 1.  Table 3 lists the facilities at
which opacity GEMS were audited.  The results indicate that approximately
80% of the opacity GEMS meet the PS1 calibration error limits for  both
the low and mid-range tests and 65% of the opacity GEMS meet the high-
range limit.
GAS GEMS

Gas GEMS Calibration Error Audit Results

     The gas  (NOX and SO2) GEMS audited for calibration error,  a  perfor-
mance  evaluation procedure, were evaluated for  linearity, precision, and
accuracy by comparing the GEMS response to known  values of  NBS  traceable
gases  injected  into the GEMS analyzer.  Only analyzers capable  of receiv-
ing audit  gases were audited.  Of  the gas GEMS  audited for  calibration
error,  80% met  the 15% control limit stated in  the  recent proposal of
Appendix F, Procedure 1  (FR, Vol.  44, No. 51, March 14, 1984, pp. 9678-
9682).  Table 2 summarizes the results of these audits and  Table  4 lists
the facilities  at which audits were conducted.  It  should be noted that
there  are  currently no promulgated requirements for calibration error
testing.

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Relative Accuracy Audit Results

     To date, 45 performance audits of 25 SO2 GEM systems installed on
electric utility and industrial boilers at 20 companies have been con-
ducted; some of the SC>2 GEMS were audited several times.  All of the  SC>2
GEMS are installed on coal-fired boilers, except for three:  two are
installed on industrial boilers firing combinations of coal and refuse
and one is installed on a recovery boiler.  Seven of the SO2 GEMS au-
dited were installed on coal-fired boilers equipped with wet FGDs.

     In addition, 21 performance audits of eight NOX GEMS installed on
electric utility and industrial boilers at seven companies have been
conducted.  It is noted that two of the NOX GEMS are installed on oil-
fired boilers.  Two of the NOX GEMS are installed on units equipped
with wet FGD systems.  Table 5 lists the facilities with GEMS which
were audited for relative accuracy.

     All of the SO2 and NOX GEMS relative accuracy performance audits
were conducted for monitors which had previously satisfied PST require-
ments.  It should be noted that most of the performance audits were an-
nounced well in advance of the testing.  In some cases source personnel
and/or monitor manufacturer representatives are known to have inspected
and/or made adjustments to the subject GEMS immediately prior to the
audit.

     Overall, the gas GEM performance audits provided the following re-
sults, which are also presented in Table 6 (802) and 7 (NOX):

     SO? GEMS

     o  The 25 installed SO2 GEMS met the applicable relative accuracy
       :specification for 38 of the 45 audits conducted (six of the nine
        relative accuracy test failures were consecutive tests of the
        same monitoring system).

     o  Twenty of the 25 SO2 GEMS audited met the performance criteria
        for each of the relative accuracy tests which they were sub-
        jected to.

     NO,, GEMS
     o  The eight installed NOX GEMS met the applicable realtive accu-
        racy specification for 1 5 of the 21 audits conducted  (two of
        the six relative accuracy test failures were consecutive tests
        of the same monitoring system).

     o  Three of the eight NOX GEMS audited met the accuracy  specifica-
        tions for all of the relative accuracy tests which were conducted,

     In evaluating the above results, it is important to note that:   (1)
there are no federally promulgated quality assurance requirements appli-
cable to the audited GEMS, and (2) there are not promulgated  requirements
for the GEM operators to periodically test installed GEMS or  to take  ne-
cessary corrective actions where unacceptable performance is  observed.

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CONCLUSIONS

     Based upon a comparison of a August 1983 version (93 monitor au-
dits) of Table 1, and the current updated version (213 monitor audits),
the Performance Audit Results indicate a slight increase in the percen-
tage of monitors which did not meet the performance audit specifications
as listed below.  One may conclude, however, that a large majority of
the opacity GEMS audited satisfied the performance audit criteria.
                                       % Monitors Out of Specification
                                       August 1983      September 1984
    Performance Audit Parameter          Summary           Summary

   Monitor Alignment                        3                  4
   Internal Span Error                     19                 22
   Internal Zero Error                      6                  6
   Zero Compensation Factor                15                 22
   Calibration Error:  Low-Range           11                 15
   Calibration Error:  Mid-Range           17                 22
   Calibration Error:  High-Range          25                 35
     No summary of calibration gas or relative accuracy audits has been
previously prepared for general distribution within EPA and no comparison
to previous results can be made.  As with opacity GEMS, the results of the
gas GEMS audit program indicate that the majority of the GEMS audited met
the audit criteria.

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                                                   TABLE 1
                                        OPACITY MONITOR AUDIT RESULTS

Lear
Siegler
Number Number (%)
Within Out of
Audit Analyses Specs.0 Specs.0
Number of Monitors Audited
PERFORMANCE AUDIT RESULTS
Monitor Alignment
Internal Span Error
Internal Zero Error
Zero Compensation Factor
Calibration Error Analysis:
Low-Range
Mid-Range
High-Range
OPERATING STATUS AUDIT RESULTS
Fault Lamps
AGC Circuit
Stack Exit Correlation Error
Panel Meter Status
Reference Signal Error
Optical Dust Accumulation
1

129
97
116
105

112
113
97

136
135
97
31
130
105
I 39

4 (3%)
26 (19%)
8 (6%)
23 (17%)

14 (10%)
24 (17%)
40 (29%)

3 (2%)
1 «1%)
33 (24%)
88a(63%)
3 (2%)
23 (17%)
Contraves
Goerz
Number Number (%)
Within Out of
Specs. c Specs. c
Dynatron
Number Number (%)
Within Out of
Specs.0 Specs.0
48

47
28 b
45
NA

41
36
27

48
NA
34b
36
NA
40

0
12
3
NA

10
15
24

0
NA
4
11
NA
6

(0%)
(25%)
(6%)


(21%)
(31%)
(50%)

(0%)

(8%)
(23%)

(13%)

22
21
26
NA

18
16
14

26
NA
22
22
NA
22
28

3
6
1
NA

9
11
13

2
NA
6
5
NA
3


(11%)
(21%)
(4%)


(32%)
(39%)
(48%)

(7%)

(21%)
(18%)

(11%)
Esterline
Angus
Number Number (%)
Within Out of
Specs.0 Specs.0


2
3
3
NA

3
3
2

3
NA
3
2
NA
3
3

1
0
0
NA

0
0
1

0
, NA
0
1
NA
0


(50%)
(0%)
(0%)


(0%)
(0%)
(50%)

(0%)

(0%)
(50%)

(0%)
% Total
No. Mon-
itors
Tested
Out of
Specs .


4
22b
6
22

15
22
35

2
<1
22b
54a
<1
16
Lear Siegler panel meter readings of opacity were generally accurate, but values for optical density and cir-
cuit current were typically erroneous.
Contraves Goerz internal OPLR and span values were not documented at seven facilities and error parameters
could not be quantified for those systems.
Specifications criteria for performance audit results are those found in 40 CFR 60, Appendix B, PS 1; for
operating status results,  the criteria are those specified by individual CEM manufacturers.

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                                                    TABLE 2

                                         CALIBRATION GAS AUDIT RESULTS
                                              FOR S02 AND NOX CEMS
                               Lear Siegler
                                Calibration
                                   Error
                   DuPont
                 Calibration
                    Error
                           Beckman
                         Calibration
                            Error
                                     Bendix
                                   Calibration
                                      Error
                                            %  Total
                                            No.  of
                                           Monitors
                                         Tested >15%
SO2 GAS MONITOR CALIBRATION

Number of Monitors Audited
     Low-Range
     Mid-Range
     High-Range
3
7
7
1
2
2
3
3
3
0
0
0
0
0
0
0
0
0
 7
14
14
    GAS MONITOR CALIBRATION

Number of Monitors Audited
     Low-Range
     Mid-Range
     High-Range
4
4
6
2
1
0
NA
NA
NA
NA
NA
NA
0
0
0
0
0
0
25
12
 0

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                                               TABLE 3

                             OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                             MAY 25, 1984
       Company
   Station
                        No. of
Unit   Monitor Type    Monitors    Date
                                       Location
REGION I

New England Power &
  Service Company

New England Power &
  Service Company

REGION III
West Penn Power Co.

Getty Marketing &
  Refining Company

REGION IV

Duke Power Company

Carolina Power & Light

Georgia Power Company

REGION V

Commonwealth Edison

Energy CO-OP

Inland Steel
Salem Harbor
South Street
Mitchell

Delaware City
Allen

Button

Plant McDonna



State Line

FCCU

4AC Plant
1,2,   EDC 1100C
 3

121,   LSI RM7A
122
 3     Dynatron 1 100

1,2,   LSI RM41
 3
       LSI RM41

       LSI RM41

4,5    LSI RM41



       Contraves-400

       LSI RM41
                   2

                   3
401-
404
LSI RM41
4

4

1



2

1

4
                            3/83   Salem, MA
                            8/83   Providence, RI
        10/82   Courtney, PA

         1/83   Delaware, DE
7/81    Belmont, NC

7/81    Wilmington, NC

9/81    Atlanta, GA



5/81    Hammond, IN

5/81    East Chicago, IN

5/81    East Chicago, IN

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                                                    TABLE  3—Continued

                                        OPACITY MONITOR  PERFORMANCE  AUDITS  CONDUCTED
                                                        MAY 25,  1984
oo
Company
REGION V — Continued
North Indiana Public
Service
ALCOA
Hoosier Energy
Indiana & Kentucky Gas
and Electric
Dairy land Power Coop
Wisconsin Electric
Station
D.H. Mitchell
Warrick
Petersburg
Clifty Creek
J.P. Madge tt
Oak Creek
Unit
4/5,
6/11
1-4
1,2
1-5
1
7,8
Monitor Type
LSI RM41
Contraves-400
Contraves-400
Dynatron 1 100
LSI RM41
Contraves-400
No. of
Monitors
2
3
2
2
1
4
Date
5/81
5/81
5/81
5/81
12/83
10/83
Location
Gary, IN
Newburg, IN
Petersburg, IN
Madison, IN
Alma, WI
Oak Creek, WI
             Power Company

           Wisconsin Electric
             Powe r C ompa ny

           Wisconsin Power  &
             Light Company

           Wisconsin Public
             Service Company

           University of
             Wi sconsi n-Madi son
Pleasant
  Prairie

Columbia
Weston
1      Contraves-400
      Contraves-400
      Contraves-400
Charter Street   1-5    Contraves-400
10/83   Kenosha,  WI
10/83   Portage,  WI
10/83   Rothschild,  WI
                                 12/83   Madison, WI

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             TABLE 3--Continued

OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                MAY 25, 1984
Company
REGION V — Continued
Central Illinois
Light Company
A.E. Staley Company
Amoco Oil Company
Commonwealth Edison
Commonwealth Edison
Commonwealth Edison
Commonwealth Edison
Commonwealth Edison
Commonwealth Edison
Commonwealth Edison
Commonwea 1th Edi son
Commonwealth Edison
Indianapolis Power &
Light Company
Station
Edwards
Decatur
FCCU
Crawford
Waukegan
Waukegan
Joliet
Power ton
Fisk
Will County
Will County
Kincaid
Stout
Unit
2
20
500
7,8
6-8
6
6-8
5,6
19
2-4
4
1,2
60,
70
No. of
Monitor Type Monitors Date
LSI RM41
Dynatron 1 1 00
LSI RM41
Contr aves-400
LSI RM41
LSI RM41
LSI RM41
Contr ave s-4 00
Contr aves -400
Contr ave s-4 00
Contr aves -400
Contr ave s-4 00
Durag D-R280AV
(Teco)
1
1
2
2
3
1
3
1
1
3
1
1
2
12/83
12/83
12/83
11/81
11/81
12/83
11/81
11/81
11/81
11/81
12/83
11/81
7/82
Location
Peoria, IL
De ca tur , I L
Whiting, IL
Chicago, IL
Waukegan, IL
Waukegan, IL
Joliet, IL
Pekin, IL
Chicago, IL
Joliet, IL
Joliet, IL
Kincaid, IL
Indianapolis, IN

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                                        TABLE 3—Continued

                           OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                           MAY 25, 1984
Company Station
REGION V — Continued
Rochester Public Util . Silver Lake
Rochester Public Util. North Broadway
Northern States Power Riverside
Northern States Power Alan King
Northern States Power Black Dog
Potlatch Company
Diamond International
Conwed Company
Blandin Paper Company
Ohio University
Ohio Power Muskingum Riv.
Ohio Power Cardinal
Cleveland Electric Lakeshore
Unit
1-4
2,3
6,7
1
1-4
7,8,
9
1-4
4
5,6

5
1,2
17,
Monitor Type
Dynatron 1 100
LSI RM41
LSI RM41
LSI RM41
LSI RM41
LSI RM41
LSI RM41
Dynatron 1100
Contraves-400
Contraves-400
LSI RM41
Contraves-400
Dynatron 1 100
No. of
Monitors
3
1
2
1
1
3
1
1
2
1
1
2
2
Date
10/82
10/82
10/82
10/82
10/82
10/82
10/82
10/82
10/82
7/82
7/82
7/82
7/82
Location
Rochester, MN
Rochester, MN
Minneapolis, MN
Bayport, MN
Burnsville, MN
Cloquet, MN
Cloquet, MN
Cloquet, MN
Grand Rapids, MN
Athens , OH
Beverly, OH
Brilliant, OH
Cleveland, OH
Illuminating Company
18

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             TABLE 3—Continued

OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                MAY 25, 1984
Company
REGION V — Continued
Cleveland Electric
Illuminating Company
Jones & Laughlin
Steel Company
PPG Industries
Cincinnati Gas and
Electric Company
Emery Industries
Corning Glass Works
Ford Motor Company
Ford Motor Company
Ohio Edison
Basic Refractories
Station
Eastlake
Cleveland
Works
Bar her ton
Miami Fort

Greenville
Plant
Sharonville
Transmission
Plant
Cleveland
Works
Sammis
Maple Grove
Works
No. of
Unit Monitor Type Monitors
5A, Dynatron 1 100 2
5B
BOF Dynatron 1100 2
6,12 Dynatron 1100 2
6 LSI RM41 1
1 LSI RM41 1
141, Contraves-400 2
142
1,2 Contraves-400 2
2 Contraves-400 1
7 Dynatron 1 100 1
Lime Dynatron 1100 2
Kiln
Date
7/82
7/82
7/82
7/82
7/82
7/82
7/82
7/82
7/82
8/82
Location
Cleveland, OH
Cleveland, OH
Barber ton, OH
North Bend, OH
Cincinnati, OH
Greenville, OH
Cincinnati, OH
Cleveland, OH
Straton, OH
Beltsville, OH

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                                                     TABLE 3—Continued

                                        OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                                        MAY 25, 1984
to
Company
REGION V — Continued
Bowling Green State
University
Toledo Edison
Toledo Edison
Detroit Edison Company
Detroit Edison Company
Michigan State Univ.
Board of Water & Light
Consumers Power Co.
Co ns ume rs Powe r Co .
Consumers Power Co.
Upper Peninsula
Station
Heating Plant
Acme
Bayshore
St. Clair
Marysville
Power Plant
#65
Eckert
JC Weadock
DE Karn
Campbell
Presque Isle
Unit

4,16
1,2
3
11,
12
1
4
7,8
2
3
8
Monitor Type
Dynatron 1 100
Dynatron 1 100
Dynatron 1100
LSI RM41
LSI RM41-11
LSI RM41
Dynatron 1 1 00
Pynatron 1100
LSI RM4
LSI RM41
LSI RM41
No. of
Monitors
1
2
1
1
1
1
1
1
2
2
1
Date
8/82
8/82
8/82
9/83
9/83
9/83
9/83
9/83
9/83
9/83
9/83
Location
Bowling Green,
OH
Toledo, OH
Toledo, OH
St. Clair, MI
Marysville, MI
East Lansing, MI
Lansing, MI
Essexville, MI
Essexville, MI
West Olive, MI
Marque tte, MI
             Generating Company

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                                          TABLE 3--Continued
                             OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                             MAY 25,  1984
Company
REGION VI
Sun Refinery &
Marketing Company
Ford Motor Company
Murphy Oil Corporation
Public Service Company
of New Mexico
Houston Lighting &
Power Company
Gulf Refinery &
Marketing Company
Arkansas Power & Light
Station
Tulsa Refinery
Tulsa Glass
Plant
Meraux Refnry
San Juan
W.A. Parish
Port Arthur
White Bluff
No. of
Unit Monitor Type Monitors
FCCU LSI RM41 1
LSI RM41 2
42 Dynatron 1 100 1
FCCU
1,2, LSI RM41 4
3,4
7 Contraves-400 1
FCCU LSI RM41 1
1241
1,2 LSI RM41 2
Date Location
6/83 Tulsa, OK
6/83 Tulsa, OK
6/83 Meraux, TX
7/83 Waterflow, NM
8/83 Thompson, TX
8/83 Port Arthur, TX
8/83 White Bluff, AR
  Company

REGION VII

Omaha Public Power

Fremont Dept. Util.
North Omaha

Fremont
1-5    Contraves-400      3

 1      LSI RM41           1
9/81    Omaha, NE

9/81    Fremont, NE

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                                          TABLE 3—Continued

                             OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                             MAY 25,  1984
Company
REGION VII — Continued
Iowa Public Services
Cornbelt Power
Iowa Electric Light
& Power
Iowa Electric Light
& Power
Iowa Sou Utility
Interstate Power
Independence Power &
Light
Missouri Public Serv.
St. Joseph Power &
Light
Kansas City Power &
Light
Station
George Neal
Humboldt
Boone
Prairie Creek
Ottumwa
Lansing
Blue Valley
Sibley
Lake Road
Hawthorne
Unit
1,2
1-4
1
1-4
1
3,4
1-3
1-3
5,6
(5)*
1,2,
5
Monitor Type
LSI RM41
Contraves-400
LSI RM41
LSI RM41
LSI RM41
LSI RM41
Dynatron 1 100
Contraves-400
Contraves-400
LSI RM41
No. of
Monitors
2
2
1
3
1
2
3
1
2
3
Date
9/81
9/81
9/81
9/81
9/81
10/81
10/81
10/81
10/81
(3/83)*
10/81
Location
Sioux City, IA
Humboldt, IA
Boone , IA
Cedar Rapids, IA
Ottumwa , IA
Lansing, IA
Independence, MO
Sibley, MO
St. Joseph, MO
Kansas City, MO
*  Parentheses indicate multiple audits.

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                                                    TABLE  3—Continued

                                       OPACITY MONITOR  PERFORMANCE  AUDITS  CONDUCTED
                                                        MAY 25,  1984
                  Company
                            Station
                                         No. of
                 Unit   Monitor Type    Monitors	Date
                                              Location
U1
REGION VII—Continued

Kansas City Power &
  Light

Kansas City Power &
  Light

Kansas City Power &
  Light

Columbia Water & Light

Iowa-Illinois Gas &
  Electric

Nebraska Public Power
  Dist.

Nebraska Public Power
  Dist.

Hastings Utility Dept.

Iowa Power Company
Quindera


la tan


LaCygne


Columbia

Riverside


Sheldon


Gerald G'man


Energy Center

Council Bluff
                                                     1,2     Contraves-400
                                                      1      LSI  RM41
                                                     (D*

                                                      1      LSI  RM41
6,7    Est An DR110B

7-9    Contraves-400


1,2    Est An DR28AU


 1      LSI RM41
                                                                               1
                                                      1      LSI  RM41            1

                                                     1-3     Contraves-400      3
                                  10/81   Kansas City, MO
                                  10/81   Weston, MO
                                 (3/83)*

                                  10/81   LaCygne, KS
10/81    Columbia, MO

10/81    Bettendorf, IA


11/81    Hallam, NE


11/81    Sutherland, NE


11/81    Hastings, NE

11/81    Council Bluff,
          IA
           *   Parentheses  indicate multiple  audits.

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                                          TABLE 3—Continued

                             OPACITY MONITOR PERFORMANCE AUDITS CONDUCTED
                                             MAY 25,  1984
       Company
   Station
                         No. of
 Unit   Monitor Type    Monitors    Date
                    Location
REGION VII—Continued

Union Electric Power
  Company

Union Electric Power
  Company

Dundee Cement

St. Joseph Power &
  Light Company

Missouri Portland
  Cement

River Cement Company

Union Electric Power
  Company

Kansas City Power &
  Light

Empire District
  Cement Company
Sioux


Labadie


Clarksville

Lake Road


Sugar Creek
  Kiln

Festus Plant

Rush Island


Montrose


Asbury
 1,2    LSI RM41
(1,2)*

 1-4    LSI RM41
        Contraves-400
8
        Contraves-400      1

 5,6    Contraves-400      2
1
        Contraves-400      1

 1,2     LSI RM41            4


 2, 3     LSI RM41            2


  1      LSI RM41            1
  2/82   West Alton, MO
(3/83)*

  3/82   Labadie, MO
  5/82   Clarksville,  MO

  5/82   St.  Joseph,  MO


  5/82   Sugar Creek,  MO


  5/82   Festus,  MO

  5/82   Festus,  MO


  6/82   La Due,  MO


  6/82   Joplin,  MO
*  Parentheses indicate multiple audits.

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             TABLE 3--Continued

OPACITY MONITOR PERFORMANCE  AUDITS  CONDUCTED
                MAY  25,  1984
Company Station
REGION VII — Continued
City Utility of James River
Springfield
REGION VIII
U.S. Steel Geneva Works
U.S. Steel Geneva Works
REGION X
Columbia Cement
St. Regis Paper Mill Seattle
Ideal Cement Company
Unit Monitor Type
4, 5 • Dynatron
2 Dynatron 1 100
OHS Prototype LSI
1, 2 Dynatron 1 100
3 LSI RM4
LSI RM4
No. of
Monitors
2
1
1
2
1
1
Date
4/83
9/82
9/82
6/80
7/83
7/83
Location
Springfield, MO
Provo, UT
Provo, UT
Bellingham, WA
Seattle, WA
Tacpma , WA

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                                                           TABLE 4

                                        CALIBRATION ERROR PERFORMANCE AUDITS  CONDUCTED
                                                     FOR S02 AND NOX GEMS
oo
Company
Austell Box Board Company
City of Lakeland
St. Regis Paper Company
Big Rivers Electric
Corporation
TVA
TVA
South Mississippi Power
Association
Carolina Power & Light
Company
Farmland Industries
Alabama Electric Coop
Texas Chemical Company
Trademark Nitrogen
Public Service Company
Station
Austell
Mclntosh
Cantonment
Mill
Green
Bull Run
Colbert
RD Morron
Roxboro
Tombigbee
Aurora
Wynha
Monitor
Unit Type
	 LSI SM810
3 LSI SM810
4 LSI SM810
1,2 LSI SM810
1A, 1B LSI SM810
1-4 LSI SM810
2 LSI SM810
4 LSI SM810
	 DuPont 460
2,3 DuPont 460
	 DuPont 460
	 Beckman 951
3 Bendix
No. of
Monitors
1
1
1
2
2
1
1
1
1
1
1
1
1
Parameter
Audited
S02/NOX/02
SO2/NOX
S02/NOX
SO2/NOX
S02/NOX
S02/NOX
SO2/NOX
NOX
SO2
SO2
S02
NOX
SO2/NOX
Date
11/83
8/83
8/83
6/83
5/83
11/83
11/83
10/83
8/83
11/83
10/83
8/83
10/83
Location
Austell, CA
Lakeland, FL
Cantonment, FL
Henderson, KY
Knoxville, TN
Tuscumbia, AL
Purvis, MS
Roxboro , NC
Bartow, MS
Leroy, AL
Aurora, NC
Tampa, FL
Georgetown, SC
       of  South Carolina

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                                                   TABLE  5

                                     RELATIVE ACCURACY  PERFORMANCE AUDITS
                                        CONDUCTED FOR SO2 AND NOX CEMS
Company
REGION I
Boise Cascade
Central Maine Power
REGION III
Arco Polymers
Philadelphia Electric
Company
Virginia Electric
and Power Company
Virginia Electric
and Power Company
Station Unit Monitor Type
	 Recovery LSI SM81 0
Boiler C
Wyman 4 EDC-DIGI-1400
Beaver Valley 3 DuPont 400/
Thermox 02
Cromby 1 Contraves GEM-100
Possum Point 4 DuPont 400/
Thermox O2
Possum Point 4 CSI Prototype/
Thermox O2
Parameters
SO2/O2
N0/C02
SO2/02
SO2/NO/C02
SO2/02
SO2/O2
Date Location
10/82 Rumford, ME
10/82 Yarmouth, ME
1/81 Monaca, PA
11/81
4/82
11/82
4/83
7/83
4/83 Phoenixville,
PA
1/82 Dumfries, VA
3/82
1/82 Dumfries, VA
3/82
REGION IV

Carolina Eastman
Company
3,4
LSI SM810/CM50
SO2/NO/02    10/77   Columbia, SC
             10/78
             12/79

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                                                      TABLE 5—Continued



                                             RELATIVE ACCURACY PERFORMANCE  AUDITS

                                                CONDUCTED FOR SO2 AND  NOX CEMS
to
o
Company Station
REGION IV — Continued
South Mississippi Power RD Morrow
Association





South Mississippi Power RD Morrow
Association






REGION V
Commonwealth Edison Collins
Commonwealth Edison Collins
Central Illinois Public Newton
Service




Unit Monitor Type Parameters Date

1 LSI SM810/CM50 SO2/NO/O2 7/81
12/81
5/82
11/82
2/83
5/83
8/83
2 LSI SM810/CM50 S02/NO/O2 5/81
7/81
12/81
4/82
1 1/82
2/83
5/83
8/83

1-3 EDC-DIGI-1 400 NO/CO2 7/80
4,5 EDC-DIGI-1 400 NOX/CO 7/80
1 Contraves GEM-1 SO2/CO2 9/80
7/81
12/81
3/82
6/82
9/82
Location

Purvis, MS






Purvis, MS








Morris, IL
Morris, IL
Newton, IL






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         TABLE 5—Continued

RELATIVE ACCURACY PERFORMANCE  AUDITS
   CONDUCTED FOR S02 AND  NOX GEMS
Company
REGION V — Continued
Indianapolis Power and
Light
Hamiltion Department of
Public Service
Blandin Paper Company
Potlatch Company
Upper Peninsula
Detroit Edison
Wolverine Power
REGION VI
Oklahoma Gas and
Electric
Houston Power and Light
Station Unit
Petersburg 3
Hamilton 9
Generating
Station
5C.
i O
	 9
Presque Isle 8
Monroe 3,4
Advance Steam 3
Plant
Muskogee __ 5
W.A. Parrish 8
Monitor Type
EDC-DIGI-1 400
LSI SM810/CM50
Contraves GEM-1
LSI SM810/CM50
LSI SM810/CM50
Contraves GEM-1 00
Contraves GEM-1 00
LSI SM81 0/CM50
KVB
Parameters
SO2/CO2
SO2/O2
S02/C02
so2/o2
SO2/O2
S02/C02
SO2/CO2
S02/NO/02
S02/NOX/
CO 2
Date
7/81
9/81
9/82
9/82
4/83
9/83
9/83
9/83
10/80
8/83
Location
Petersburg, IN
Hamilton, OH
Grand Rapids ,
MN
Cloquet, MN
Marquette, MI
Monroe, MI
Advance, MI
Muskogee , OK
Thompsons , TX

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                                                      TABLE 5—Continued

                                             RELATIVE ACCURACY PERFORMANCE AUDITS
                                                CONDUCTED FOR SO2 AND NOX GEMS
to
Company
REGION VII
Iowa Power
Interstate Power
Nebraska Public Power
Union Electric Power
Union Electric Power
Union Electric Power
Union Electric Power
Station
Council Bluffs
Lansing
Gerald G'man
Sioux
Labadie
Labadie
Labadie
Unit
3
4
1
2
2
3
1
Monitor Type
EDC-DIGI-1400
LSI SM810/CM50
LSI SM810/CM50
DuPont 460/
LSI CM50
LSI SM810/CM50
LSI SM810/CM50
LSI SM810/CM50
Parameters
S02/C02
S02/02
S02/NO/02
SO2/O2
SO2/02
S02/02
S02/O2
Date
12/81
12/81
12/81
2/82
2/82
3/82
3/82
Location
Council Bluffs,
IA
Lansing, IA
Sutherland, NE
W. Alton, MO
Labadie, MO
Labadie, MO
Labadie, MO

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                          TABLE  6
  RELATIVE ACCURACY TEST RESULTS  FOR S02 CEM PERFORMANCE AUDITS
CONDUCTED AFTER SUCCESSFUL PERFORMANCE SPECIFICATION TESTS (PSTs)
to
u>






MONITOR
TYPE
1. L S I
2. L S I
3. DuPONT
4. CONTRAVES
5. E D C
6. CONTRAVES
7. K V B
8. L S I
9. DuPONT
ia c s i
1L L S I
12. L S I
13. E D C
IA. L S I
15. L S I
16. L S I
1 7. L S I
18. DuPONT
19. L S I
20. L S I
2 1. CONTRAVES
22. CONTRAVES
21 L S I
24 CONTRAVES
25. CONTRAVES
FGD
YES
YES
YES
YES
YES
YES
YES
NO
NO
NO
NO
NO
HO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ELAPSED TIME SINCE PST (MONTHS)
024 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42
PASS PASS PASS PASS PASS PASS PASS PASS PASS
PASS PASS PASS FAIL FAIL PASS PASS
PASS PASS PASS PASS PASS
PASS PASS FAIL FAIL FAIL FAIL
PASS PASS
PASS PASS
PASS PASS
PASS PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS FAIL
PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS PASS
PASS FAIL
PASS ' PASS
PASS FAIL
PASS ' PASS
PASS pAS;

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                           TABLE  7
  RELATIVE ACCURACY TEST RESULTS FOR NOV CEM PERFORMANCE AUDITS
                                       A
CONDUCTED AFTER SUCCESSFUL PERFORMANCE SPECIFICATION TESTS (PST§)
MONITOR
TYPE
I.
2.
3.
LSI
LSI
LSI
4,. LSI
5.
E D C
6. E D C
7.
8.
LSI
E D C
FGD
YES
YES
NO
NO
NO
NO
NO
NO
ELAPSED TIME SINCE PST (MONTHS)
0 24 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42
PASS PASS PASS FAIL PASS PASS PASS PASS PASS
PASS PASS PASS PASS PASS FAIL PASS
PASS FAIL FAIL
PASS PASS
PASS PASS
PASS PASS
PASS FAIL
PASS FAIL

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.
 EPA  340/1-84-016
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  SUMMARY OF OPACITY AND GAS  GEMS AUDIT PROGRAMS
                                                            5. REPORT DATE
                                                              September 1 984
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
  Joseph Van Gieson, Engineering-Science
  Louis R.  Paley,  P.E., OAQPS,  SSCD
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Engineering-Science
  10521 Rosehaven Street
  Fairfax, VA  22030
10. PROGRAM ELEMENT NO.
   Work Assignment 130
11. CONTRACT/GRANT NO.
   68-01-6312
12. SPONSORING AGENCY NAME AND ADDRESS
  U.S.  Environmental Protection  Agency
  OAQPS,  SSCD
  401 M Street, S.W.
  Washington,  O.C.   20460
13. TYPE OF REPORT AND PERIOD COVERED
   in-house
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
        The  U.S.  Environmental Protection Agency, Office  of  Air Quality Planning
  and Standards, Stationary Source  Compliance Division,  as  well as the Emission
  Monitoring  Science Laboratory,  Quality Assurance Division,  and several regional
  offices have sponsored continuous emission monitoring  system (GEMS) performance
  audits  to determine the precision and accuracy of GEMS and  to develop and  eval-
  uate  the  audit techniques.  Opacity,  SO2 and NOX GEMS  at  a  variety of industrial
  sources  (electric utilities, manufacturing facilities,  petrochemical processes,
  kraft pulp  mills, etc.) were audited  using NBS traceable  filters, EPA reference
  methods,  and calibration gases  are reference standards.   This report provides  a
  summary of  the results of these audits.  The results demonstrate:

        o  80% of the opacity monitors audited met calibration error criteria (5%
          error) for low- and mid-range references values*; 65% of the monitors  met
          these  criteria for high range reference values.
        o  80% of the gas GEMS met the calibration error  criteria (5% error).
        o  80% of the gas GEMS met the relative accuracy  criteria (25% relative accu-
          racy) .
  *   65%  for hi-range reference  values.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
              c. COSATI Field/Group
  Quality Assurance
  Continuous Emission Monitor
  Air  Pollution
18. DISTRIBUTION STATEMENT
                                               19. SECURITY CLASS (This Report)
                                                                          21. NO. OF PAGES
                                              20. SECURITY CLASS (This page)
                                                                          22. PRICE
EPA Farm 2220-1 (Rav. 4-77)   PREVIOUS EDITION is OBSOLETE

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