United States      Office of Air Quality       EPA-340/1 -83-009
Environmental Protection  Planning and Standards     January 1983
Agency        Research Triangle Park NC 27711

Stationary Source Compliance Series
Guidelines
for the Observation
of Performance
Specification Tests
of Continuous
Emission Monitors

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                                                 EPA-340/1-83-009
                      Guidelines for the
Observation of Performance Specification Tests
          of Continuous Emission  Monitors
                               Prepared by:

                         Entropy Environmentalists, Inc.
                              P.O. Box 12291
                            Research Triangle Park
                            North Carolina 27709
                               Prepared for:

                              Anthony Wayne
                                Region VII

                                  and

                               Louis R. Paley
                       Stationary Source Compliance Division

                     United States Environmental Protection Agency
                         SSCD Contract No. 68-01 -6317
                     U.S. ENVIRONMENTAL PROTECTION AGENCY
                      Office of Air Quality Planning and Standards
                       Stationary Source Compliance Division
                           Washington, D.C. 20460
                               January 1983
                                         U.S. Environmental Protection Agency
                                         7-:!or> 5, Library (5PL-16)
                                         •' 1' l'j. Dearborn Street, Room 1670
                                         Chicago, IL   60604

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The Stationary Source  Compliance  series of reports  is  issued  by the
Office of Air Quality  Planning  and  Standards,  U. S Environmental
Protection Agency,  to  assist  Regional  Offices  in  activities related  to
compliance with implementation  plans,  new source  emission  standards,
and hazardous emission standards  to be developed  under the Clean Air
Act.  Copies of Stationary Source Compliance  Reports are available -
as supplies permit  - from library Services, U.S.  Environmental
Protection Agency,  MD-35, Research Triangle Park, North Carolina
27711, or may be obtained, for  a  nominal cost, from the National
Technical Information  Service,  5285 Port Royal Road, Springfield,
Virginia  22151.

This report has been reviewed by the Office of Air  Quality Planning
and Standards, U.S. Environmental Protection  Agency, and approved for
publication as received from Entropy Environmentalists, Inc.   Approval
does not signify that  the contents necessarily reflect the views and
policies of the U.S. Environmental  Protection  Agency,  nor does mention
of trade names or commercial  products  constitute  endorsement  or
recommendation for  use.
                                 ii

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                                  ABSTRACT






     Mien stationary source  owners or  operators plan  to  conduct  Performance




Specification Tests of  installed continuous emission monitors, they are reo-'red




to notify the  applicable control  agency.   The  agency should  then appoi.iu  a




representative  to  observe the  tests.






     This document contains general guidelines for  the  agency observer  on  the




performance  of pretest negotiations, on-site observations, and  the  preparation




of his report.   Also, an  observer's checklist for these activities is included.
                                 111

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                      TABLE OF CONTENTS
1.0  Introduction	    1




2.0  Pretest Activities	    3




3.0  Onsite Observation	    7




4.0  Observer's Report	   11




     Appendix	   15

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                               GUIDELINES FOR THE




                  OBSERVATION OF CONTINUOUS EMISSION MONITOR




                        PERFORMANCE SPECIFICATION TESTS








 1.0  Introduction






     Vhen   stationary  source   owners   or   operators   conduct    Performance




Specification Tests  (PSTs)  of  installed  continuous emission  monitors (CEMs) as




required by New Source Performance  Standards (  NSPS), State Implementation  Plans




(SIP),  or  other  local  regulations,  the  agency  appoints a  representative to




observe  the  tests.   This manual  is intended  to  provide guidelines  for the




representative's role and general  responsibilities  as an  observer.   Detailed




explanations of the  PST and specific instructions  and  recommendations  for the




test report reviewer appear in  a separate manual entitled, "Monitor  Performance




Tests  for  Pollutant  and .Diluent  Gas Monitors:  Reporting  Requirements, Report




Format, and Review Procedures." The  observer  is  referred  to  this manual and to




the appropriate Federal  and State  regulations for detailed technical  information




concerning the tests.






     The source owner or operator  is  responsible  for planning  and conducting the




PST.   In most cases, a consultant  is hired  by  the owner  or  operator to perform




the  test.   Typically,   this  consultant   is   designated  as   an  authorized




representative of the source and,  throughout this document,  is  referred  to as



"tester" and "test consultant."






     The functions of the  agency observer are to  represent  the interests of the




agency  during  the  planning  and   performance  of  the   PST,  and   to  provide




appropriate documentation  of the PST  for  the test report reviewer.   The  observer




must  ensure that the PST is performed according to the procedures delineated in

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the  Performance  Specifications  (40 CFR  60,  Appendix  B) .  In  doing  so,  the




observer must work cooperatively with the source and  with  the test consultant.




He must be  specific  and  forthright  in  his  requests,  while being  respectful  of




the  positions  of  the   other   parties   involved.   Antagonistic   or  adversary




approaches will usually defeat themselves in these  situations.   Cooperation  is




in the best interest of  all  parties, and  will result in maximum success.






     The activities of  the  agency observer may  be  divided into  three phases:




pretest  activities, onsite  observation, and  preparation  of  the  observer's




report.  These activities are  discussed in the following sections.






     It  is  strongly recommended  that   all  of  the  observer's  activities  be




conducted by the  same individual; when more  than one person  are  involved,  all




persons  representing the  agency must   work  closely  together  to  ensure  an




effective agency role in the PST.






     The appendix  of this document  contains a  detailed  checklist  for  the  PST




observer.  Separate checklists for preliminary communications, pretest meetings,




and  onsite  observation  are   included.    The   observer   should   review  these




checklists  and use  them appropriately  to  document  all  phases  of  the  test




sequence .

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2. 0  Pretest Activities






     The source  owner  or  operator  is  required  to  notify the  agency of  his




intention to  conduct the  PST.   (NSPS  sources  are  required  to  give 30  days




notice;  requirements  for  SIP  sources may  vary.)   The  notice  indicates  chat




arrangements for  the test  are  underway  and  that  the  source  is prepared  to




schedule the  test.  Once  source  notification  has  been  received,  an  agency




representative should be  designated  to observe the test.






     Initially,  the observer should establish contact  with the  source owner  or




operator and inform him  that  he  plans to observe the test.  Ihe  source is  then




responsible  for  notifying  the observer  of  all  PST  activities (i.e.,  test




schedule,  pretest   meeting,   etc.).    This   initial   agency-source  contact




establishes the lines of communication among all parties  from  the  outset  of the




test sequence.   At this time,  the  observer should  query the source  owner  or




operator for  information  pertaining  to  the  source  (e.g.,  identification  and




location, plant  and  monitor design  and  operating  parameters, pollutants  to  be




measured, sampling locations, data  from  previous  PST,  etc.), and pertaining to




the tester (e.g., identification and location, sampling equipment  and  laboratory




information, test methods to  be  used,  etc.).






     After the source is contacted,  the  observer should familiarize himself with




the  operating  principles  of  the   installed   CEM,   the  source  process  and




anticipated  operating  conditions,  and   the  requisite  test  methodology.   The




observer should also review available  information  from  control agency  records of




the  monitor  (and/or  relevant   source   emission   tests).  He  should  discuss




procedural  details  not  specified  in  the  Reference  Methods  and   Performance




Specifications   with   the   source   and   the   tester,   and   achieve   an




agency-source-tester concurrence prior to initiation  of the test.

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     The observer  should  attend any pretest meeting held by the source. Although




there is no requirement for  pretest meetings, these meetings  and  other informal




gatherings of source, testing, and  agency personnel  provide  opportunities  for




clarification  and  negotiation  of  issues,  and  for   the   dissemination   of




information  about  the test  protocol and  its  possible  problems.   Typically,




pretest meetings are scheduled  for the convenience of the source and the tester;




however, most sources are  quite  willing  to accotnodate the  observer's schedule




provided that they  know  in  advance  that  he plans to  attend  and  if  a schedule




satisfactory for all three  parties can be  arranged .






     The source and/or the tester must formulate a test  protocol  and submit it




to  the  observer  for review and approval  before the initiation of  the  PST.  The




observer must  make  clear any  special  requests he has  for  the  tester  or  the




source  at  this time.  He  should also review  and  approve (or  disapprove)  any




modifications to  the  standard  procedures  or other  procedures not  prescribed in




the Performance  Specifications  proposed  by  the  tester.  The  observer   should




include all  draft versions and the finalized protocol  in  his  report.






      The observer must know the  limits  of his authority. Undoubtedly, the  test




observer will be called  upon to determine the acceptability   of test  procedures,




sampling methodology, etc.   If  the  observer  does  not have  authority for  such




decisions,  he must be able to  contact  an agency representative  who has  such




authority.   Failure to establish this  line of authority in  advance  will  hinder




the satisfactory completion  of the  test  program,  which is  the goal  of the




 source, the tester, and  the agency.






      The test  schedule  should  be  finalized  during  the pretest  negotiations.




 However, this  test schedule  is dependent  upon many  variable factors:  boiler




 operation,  monitor  operation, process conditions,  etc.  Testing  cannot  begin

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until  satisfactory  conditions are  achieved  simultaneously  for  all  of  these




variables, and despite the most careful  planning, delays  in the test  schedule




are common. The tester  and  the observer must therefore be ready when appropriate




conditions are achieved. Once the  PST has commenced,  test problems may  ' r.jse




additional delays.   To  complete the tests, the tester may continue his work well




into the  evening and for most of  the night, provided  that proper lighting  is




available.   The  observer   should  consult with  the  tester  during  the  pretest




negotiations as  to  his firm's policy regarding  the length of  the  test  day.




Thus, the observer  must be  flexible and accommodate the tester's schedule.






     If additional  testing, modified  sampling procedures,  or additional  quality




assurance procedures, etc. are  necessary to accommodate  particular  regulatory




provisions,   monitor-specific   problems,    and/or    unusual    source-specific




circumstances, the  observer  must  inform the  source  and  tester of  any  such




deviations from standard  procedure  as early as  possible.   Failure to do so  may




compromise the test results and create problems.






     Before the PST,  the observer should  review the "Onsite  Observation"  portion




of the observer's  checklist  contained  in the  appendix  of  this  document.   The




checklist is designed to apply to all types of continuous monitor PSTs .  For the




checklist to be  useful, the  observer must be  familiar  with the portions of it




that apply  to his  particular situation, and  he should  note  in advance  those




portions of the checklist that must be completed.






     The checklist  is intended to facilitate the job of the  observer; it is not




a  complete,  self-contained  report  in itself.   Although  its  length may  seem




cumbersome, it provides a   format for the recording  of  information  the observer




may  wish  to  use.  Tne  observer  himself, however,  must  finally decide  vhich




information is important and  which  is not.

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     In conclusion,  responsibilities  and  activities  of  the agency  and  the

observer during  the pretest  period may be summarized as follows:


     1.  The agency should designate  an observer  upon  receiving  notice  from the
         so ur ce.

     2.  The  observer   should   contact   the   source   and   obtain   pertinent
         information.

     3.  The observer  should review all available pertinent information, both on
         the source and  on the  PST methodology.

     4.  The observer, as agency representative, should clarify his authority to
         the source and  tester.   If the necessary authority resides outside the
         observer, contingency plans  should be  made for  contacting  the  agency
         representative  who  is  authorized to make decisions.

     5.  The observer  should attend the pretest meeting, if possible.

     6.  Before  the initiation of the  PST, the  observer  should  review the test
         protocol, negotiate necessary changes, and  approve it.

     7.  The observer  should obtain the test schedule and make appropriate  plans
         to attend.

     8.  The observer  should review the observer's  checklist  and  utilize  it for
         the onsite observation.

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3.0  Onsite Observation






     The observation  of  the  PST is perhaps the most important of the observer's




responsibilities   following   the  establishment  of  the  test  protocol.    The




observer must perform all  preparatory activities  to maximize  the effectiveness




of his observation.   He  must  complete the  gathering of preliminary information




prior to the initiation of  testing  so  that  he can give his  full  attention  to




the performance of the test.






     The observer should arrive onsite on time  for any pretest  activities  and




should attend any informal meetings  with the  tester and the source immediately




before the test to settle  last minute details.   He may  be asked  to observe  and




approve non-standard  procedures to be employed  during  the  test.   Consequently,




the observer should  allow ample  time  for these  activities and  for any  other




pretest  inspections  he  may wish to perform, the observer  should  obtain  and




examine: (1) the  results of any  tests for  which the  monitor manufacturer  is




allowed to certify conformance  with  the applicable specifications (i.e., design




specification tests  for transmissometers, some  calibration  error  checks  for




some  gas  monitors),  (2) the  results  of   calibration  gas  analysis  and/or




manufacturer's certification of  calibration  gas  cell  values,  and  (3)  the



required pretest  calibration results for the  tester's  sampling equipment.






     Once testing commences, the  observer  should  watch all  aspects of the test,




including test procedures, monitor  operation, and source operating  conditions.




It is unnecessary and time consuming for  the  observer  to make his own  separate




records of  the data; he can observe the  tester's record and  initial  the data




sheets  to  ensure that the data recorded   are the data  reported.  The  observer




must make  judicious  use of  the  checklist to  note his observations;  however,




time  spent  completing  the  checklist is  time  not  spent observing.  Therefore,

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the observer is  advised  to  review the  checklist in advance of the  test  and  to




mark the  appropriate  information to be  completed;  if this  is  not done,  the




observer could spend the majority of the test period working on the checklist.






     The observer  should  be  considerate  of the  tester  during  the  PST;  the




tester's attention will be focused  on  getting  the  job  done, and  during  some




phases  of the  testing,  distractions  could  jeopardize   his   work.   When  the




observer has questions for  the tester, he  should wait until an appropriate time




to  ask  them,  unless  it  is imperative that the  questions be resolved  before




testing proceeds.  Also, the observer  should be respectful  of the  source's and




tester's equipment. Most  sampling equipment is quite expensive, and much of it




is easily damaged .  In general, a "hands-off" posture is the safest approach.






     Regardless  of the care  taken  to  resolve  all  procedural  questions  in




advance, unforeseen situations are  encountered  frequently  during  the  actual




test  period.  In such  instances,  the  observer  must  approve  or disapprove  a




source's or tester's  proposed solution on the  spot.  If  he does not  have the




authority to make  such  decisions, he  should contact  an  agency representative




having  the necessary authority.   Any delays  at  this  critical  stage will  result




in wasting valuable time and money.






     At  the  conclusion of the   test,  the  observer  may  wish  to  inspect the




tester's data  sheets  and  initial  them.   Such  a request should be made  in the




spirit  of cooperation.   Indeed,  the tester  may wish to  receive  feedback from




the observer, and often such an  interchange  can prove mutually beneficial. The




observer  should  remember that  his ultimate goal  is  to  obtain  reliable  PST data




for the agency, and he should  be  willing  to  share his subjective and objective




observations and information.

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     In conclusion,  the observer's activities during the test may be summarized

as follows :


     1.  The  observer  should   arrive  onsite   well   in  advance  of  the
         scheduled beginning of the  test  to make  final  preparations for
         accurate observation of both source and tester operations.

     2.  The observer  should  review  data  and/or  test  results  from  any
         manufacturer's certification of conformance  with specifications
         and of any calibration  gas  analysis.

     3.  The observer  should  devote  his  primary  energies  to  a careful
         observation of the test procedures.

     ij.  The observer  should be considerate of the source and the tester
         and work with them to  achieve the  desired  results.

     5.  The observer  should  be prepared  to  rule  on problems  that may
         arise during the course of the  test.

     6.  The observer  should confer  with the  tester at the conclusion of
         the test to  exchange appropriate  information and to discuss the
         data quality and possible  deficiencies.

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4.0  Observer's Report






     At the conclusion of the  test  program, the observer must  prepare  a  report




containing  all  pertinent  information  from his  observation activities.   The




observer's report  aids  the test report  reviewer.   Although the  soundest  and




most expedient practice  is for the  test observer to review the  report, this  is




not always feasible.   Therefore, the observer  should  prepare a  complete  report




that can serve as  an  independent documentation of the test.






     The  outline  below  suggests  an  organization  for  an  observer's report.




While the observer will  finally determine  the most  appropriate report  format,




the report must document thoroughly the activities of the observer, the source,




and  the  tester  to be  useful  to the  reviewer.   Although  recording  the  test




details is tedious, it is necessary to enable the reviewer to evaluate  the test




report accurately.  The  observer must make notations of problems  encountered,




and also state the acceptability of procedures. The observer should be  specific




and concise, regardless  of the report format chosen.
                                   11

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                               Observer's  Report




I.  Background Information

     - Source identification  (station, unit)

     - Tester identification

     - Observer identification

     - Test date

     - Monitor description  and  location

     - Pertinent source  operational parameters

     - Other useful  background  information


II.   Pretest Communications

     - Summary of pretest meeting, if one was held

     - Copies of all protocols  proposed during pretest negotiations

     - Complete copy of  finalized protocol

     - Notations on  communications among all parties before testing

     - Notations of  any  deviations in standard methodology approved by observer

     - Notations of any special tests or  additional  procedures  recommended  by
       observer


III.   On site Observations

     - Observer's checklist and data from  tests, well  annotated  with pertinent
       information and notations

     - Additional  descriptions  of checklist items meriting further discussion

     - General  notes from onsite observations not found on the checklist

     - Notes on information-sharing activities conducted  at conclusion  of test
       program  (i.e., did  the observer  initial the  tester's  data  sheets;  did
       the  tester  have access to the observer's notes; etc.)
                                 12

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IV.   Summary and  Conclusions

     (The observer may wish to  present this  information at  the  beginning,
rather than at  the end, of his  report.)

     - Concise  listing of any observations or  information that  may  affect
       test results.

     - Conclusions on  the part  of the observer as to the validity  of  the
       test  procedures employed  and  the  general  successfulness  of  the
       test.
                                      13

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APPENDIX

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     CONTINUOUS EMISSIONS MONITOR (CEM)
     PERFORMANCE SPECIFICATION TEST (PST)

                OBSERVATION REPORT
Plant:	

Unit: 	

Date of PST:

Observer:  _

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CONTENTS:







TEST SUMMARY FORM	i





INSTRUCTIONS	ii




PRELIMINARY COMMUNICATION SUMMARY	1-A





PRETEST MEETING SUMMARY	1-8




ONSITE OBSERVATION FORMS	1-C




     GENERAL SITE INFORMATION	1-C




     PERFORMANCE SPECIFICATION 1	3-C




     PERFORMANCE SPECIFICATION 2	4-C




         CALIBRATION ERROR	4-C




         RESPONSE TIME	5-C




         24-HOUR DRIFT	6-C




         2-HOUR DRIFT	7-C




         RELATIVE ACCURACY	8-C




              METHOD 6	8-C




              METHOD 4	12-C




              METHOD 7	14-C





     PERFORMANCE SPECIFICATION 3	17-C




         RESPONSE TIME	18-C




         24-HOUR DRIFT	19-C




         2-HOUR DRIFT	20-C




     GENERAL COMMENTS	21-C

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     CONTINUOUS EMISSIONS MONITORING PERFORMANCE SPECIFICATION TEST
                                  OBSERVATION REPORT
PLANT NAME:

UNIT TESTED:

LOCATION:
                                                                 DATE OF PST:
OBSERVED BY:
                             SUMMARY OF TEST PROCEDURES
         Test
SO,
                                                                     Opacity
                                                         Moisture
  Reference method
  Calibration error
  Response time
  2-h drift
  24-h drift
  Calibration check
  Other:
 REPORT CONTENTS
       Preliminary communications summary
       Pretest meeting report or notes
       Observer's data sheets
       Supplemental observation report
       Other:	
                                                          Code
                                                      1.  Acceptable
                                                      2.  Unacceptable
                                                      3.  Indeterminate
                                                      4.  Not observed
                                                      5.  Not performed

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                       CONTINUOUS EMISSION MONITOR (CEM)
                                  OBSERVER'S FORMS
INSTRUCTIONS FOR OBSERVER:

PART 1 (Pages 1-A through 4-A):  Preliminary Communication Summary

    Part 1,  the Preliminary Communication Summary,  is to be filled in by the source. Detach
pages 1-A through 5-A and fill in  the name and address of the person or agency to whom you wish
the form returned in the space provided at the beginning of the first page. Forward the Communica-
tion Form to the source and request that he/she complete  and return it as soon as possible.

PART 2 (Pages 1-B through 5-B):  Pretest Meeting Summary

    Part 2,  the Pretest  Meeting  Summary, which begins immediately after the Communication
Summary and continues  through  page 8-B,  is intended to be an outline of the information  that
should  be collected prior to the actual  testing. This section is to be filled in by the observer during
the pretest meeting.

PARTS (Pages 1-C to End): Observer's Data Sheets

    Part 3,  the Observer's Data  Sheets, is to be filled  in by the observer during the actual test
period. The form is designed so that it may be used for general PST observations of several  different
types of sources, and some of the questions may not be  applicable to a specific source or observa-
tion. It is not expected that the observer will be able to  collect all of the information outlined on
the data sheets.  Record only that information that corresponds to activities actually observed.

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  CONTINUOUS EMISSIONS MONITORING (GEM) PERFORMANCE SPECIFICATION TEST
                       PRELIMINARY COMMUNICATION SUMMARY
'COMPLETE AND RETURN TO:
 (OBSERVER)
                                    Phone contact date:
                                    Mailing date:  	
                                    Return date:  	
THE FOLLOWING INFORMATION IS TO BE PROVIDED BY PLANT PERSONNEL AND THE FORM RETURNED TO THE
OBSERVER:
1.   Plant name: 	

2.   Mailing address:
3.  Site location:
 4.  Source(s) to be tested:
 5.   Plant contacts:
     Plant manager:
     Environmental coordinator:
     CEM Contact:  	
     Test team leader: 	
Phone:
Phone:
Phone:
Phone:
 •Communication form (pages 1-A through 4-A) to be completed and returned 30 days prior to pretest meeting.
                                                 1-A

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                           PRELIMINARY COMMUNICATION SUMMARY
6.   Process description:

    A.    Raw materials and/or fuel used:

    B.    End product(s):  	
    C.    Maximum production capacity:
          Normal emission operating range:    S02: .

     D.    Other:  _	

7.   Dates for:



     A.    Initial startup

     B.    Maximum production rate reached

     C.    60 days after maximum production reached

     D.    180 days after startup

     E.    Preevaluation/pretest meeting

     F.    Conditioning period for:

          1.   Opacity

          2.   S02

          3.   NOX

          4.  Diluent (02,CD2)

           5.  Other


 8.  Monitors to be tested:
              NOX:
                Date
          Planned/Scheduled
          Actual Date
   Anticipated
conditioning date:
     Anticipated
performance test dates:
                                                       2-A

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                            PRELIMINARY  COMMUNICATION SUMMARY
 9.  Does the test contractor participate in an external audit program?
    Yes:   	      No:   	

    If so, are the audit samples (A) Gaseous (cylinders)?   	

                         or  (B) Liquid S02/NOX?     	
    If not, is the test contractor willing to participate in an external audit program?   Yes:  	   No:
10.  Schematic diagram of monitor location:
    (Include stack/duct cross section dimensions, straight runs before and after location I with distances in diameters), and locations
    of air in-leakages).
                                                         3-A

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                       PRELIMINARY COMMUNICATION SUMMARY
11. Tests are to be performed by:




   Name:  	
    Address:
    Phone:  	







    Contacts' names:




    Name:  	
    Address:
    Phone: .







    Name: .





    Address:
    Phone:
                                              4-A

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                                PRETEST MEETING SUMMARY
              CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
General CEM information:                                             Date:

1.   Plant:	
    Is this the initial PST?       Yes 	    No

         If not, when was the last PST performed?  	
         Describe problems encountered during last PST:
2.   Pretest meeting participants:
    Name:                                              Affiliation:
3.   Performance test procedures:
                            Standard Test                                 Departures From
                         (Reference Method)                                Standard Test
    Opacity
    so2
    N0x
    Diluents
   Moisture	


   CO       	

                                                1-B

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                                 PRETEST MEETING SUMMARY
               CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
4.  Testing
Organization and person performing test*/proposed test date

Calibration error
Response time
Zero/calibration drift-2-h
Zero/calibration drift-24-h
Accuracy
Opacity/Date





Pollutant/Date





Diluent/Date





5.  General CEM system characteristics

Manufacturer
Model No.
Serial No.
Dates for:
1. System startup:
2. Zero alignment on cool,
clear flue:
3. Anticipated conditioning
period:
4. Anticipated operational
test period (DTP):
Final alignments prior to DTP ?
7
Data recorder type :
System span value :
% zero offset:
4
Daily span-check method :
Daily zero method :
Automatic zero compensation?
Measured "wet" or "dry":
Opacity















SO 2















NOX















Diluent















Other















Other




j










   *lf different from Preliminary Communication Summary, update here.

    Operational test period of 168 hours
    Specify-strip chart, computer, data logger, mag tape or other
    100% of system output
    Cell or gas injection
    Means for simulating zero value for daily zero check     2-B

-------
                                PRETEST MEETING SUMMARY
              CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
6.    Fuel analysis or process feed rate?
7.    "F" factor, if appropriate:
8.    Calibration gas verification method:
     S02:
     Diluents (02, C02):
      Other (e.g., CO):
9.    Is there provision for injecting calibration gas at probe? (If not, explain)
                                                3-B

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                                     PRETEST MEETING SUMMARY
                CONTINUOUS  EMISSIONS MONITOR OBSERVER'S DATA SHEET
11.  Do all monitors meet the location and stratification requirements as outlined by the applicable parformance specifications?
       Yes:	      No:


This was determined by:
A. Physical location Yesi
Per regulation (40 CFR SO Appendix B)
B, Testing Ya«:
If determined by testing «?*p'ain t"st? ind attach msu'tv , ,

No-.
Nn-



12.  Does monitor installation site meet vendor operating environment requirements (temperature, humidity, vibration, etc.)?*
13.  Describe the relative accuracy reference method sampling system location in relation to the monitor location.*
14.  Are there adequate provisions for the reference method test (i.e., access, sampling ports, sufficient work area, suitable work en-
    vironment, etc.)?*
15. Major points of action to be resolved before test date:                              Resolution/Date
 'Resolution of these questions may require preliminary onsite inspection.
                                                        4-B

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                                                            PRETEST MEETING SUMMARY
                                         CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
           10.  Calibration gas cylinder or cell information
en
do
Pollutant1
so2
so2
so2
NOX
NOX
NOX
o2/co2
oz/co2
o2/co2
Range2
Zero
Mid
Span
Zero
Mid
Span
Zero
Mid
Span
Carrier3









Container









Vendor5
ppm Value
Gas









Cell









Date6









Triple Analysis
ppm Value









Date6









Cylinder
IQit









                If NOX, specify NO or N02; if diluent, circle 02 or
                As applicable.
               o
                Specify carrier gas contained in cylinder or cell.
                Specify vendor cell, regulated cylinder, instrument air, or other.
                Supplied by vendor when calibration mixture purchased or assigned value of calibration cell.
                Give date on which vendor certification and/or triplicate reference method test performed.
                Average of three valid reference method tests on cylinders only.

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                                    ONSITE TEST SUMMARY
              CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
GENERAL PERFORMANCE SPECIFICATION INFORMATION

Plant;	    DTP Start Date:-

                                                    OTP Start Time:-

 1.   Observers:                                        Affiliation:
 2.   Test performed by: (If different from those specified in pretest meeting)
 3.  Were pretest meeting notes reviewed?   Yes:	     No:

 4.  Were velocity traverse data taken?      Yes:	     No:

     By whom?	——	

     When taken?  	—	
 5.  Actual zero and calibration schedule:
                                                1-C

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                          ONSITE TEST SUMMARY
          CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
6.  Comments:
                                   2-C

-------
                                                  ONSITE TEST SUMMARY
                            CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 1 (OPACITY)

 Day in operational test period sequence
 Were initial 24 h readings taken after system was calibrated?
 Were zero readings taken before cleaning and adjustment?
 Value before zero cleaning and adjustment
 Amount of zero compensation before cleaning and
  adjustment
  Value after zero ad|ustment
 Were span readings taken after cleaning and zero
   adjustment, but prior to span adjustment?


 Value before span adjustment
  Value after span adjustment
Day 1
Day 2
Day 3
Day 4
Day 5
                                                                                            2»
Day 6
Day?
Day8
  NOTE: Complete checklist for portions of test actually observed.

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                                ONSITE TEST SUMMARY
             CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2

1
Manufacturer and model of monitor
What method was used to perform sampling
of calibration gas?'
Is a stainless steel regulator used for each
calibration gas? If not, explain. 2
Are stainless steel and Teflon®calibration
gas sampling system components (lines,
valves, fittings) used? If not, explain. 2
Were calibration gas/cells certified by:
1. The manufacturer?
2. Other? (Please explain ft
What was the concentration of the span
gas/cell?
Is the span value in agreement with the
applicable subpart?
S02







NOX


/^//////'^///////'//
Wwffl/- 't'''-'.'','
'l^p/^y' - '''^ '' '
/mM:^'
M»v



  'Attach a sketch of sampling train.
 'Explain m comments section.

CALIBRATION ERROR TEST
                                                           Comments:

1. Was calibration error test performed in
the field or in the laboratory?*
2. Were 15 nonconsecutive readings taken?*
3. Was entire continuous monitoring system
(probe, sample conditioning system,
transport system, etc.) subjected to
calibration error test?*
S02



NOX



                                                           Comments:
 "If the answer to either part of 3 is "No", please explain:
                                           4-C

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                            ONSITE TEST SUMMARY
           CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2

RESPONSE TIME

What was the concentration of the gas or
gas cell used?
Identification number of the tank or gas
cell.
For NOX monitors which oxidize NO to
N02, was NO used for response time?
Was entire continuous monitoring system
(including sample conditioning system)
used? If not, please explain in Comments
section.
What was the response time? (seconds)
so2





NOX





                                                  Comments:
                                     5-C

-------
                                                  ONSITE TEST SUMMAMY
                            CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ZERO AMU CALIBRATION ORIFT-24 H
    culls used?
  Wait juiu itiitliiiiji

  ValiiL' bufurc /eiu a

  Vdluu dltvr mo adjustment.

  Wuie span

24 h intervals?
or calibration
ive, was span
instrument span?
ractive, was span
instrument span?
s taken altar
?
before adjustment
Ilient.
tut.
i dfter zero
r to span
line nt.
lent.
Day 1
S02 NOX



_ 	 -
•"'•••T'.'^rr/?''?'^'''

-' ' ,' '///'.
,•'%$
'ss'tC?/?????/'
''''' //>''', ''''.

Day 2 f
S02 NOX





' ~ "

Day 3
S02 NOK




- 	
_ ..

Day 4
S02 NOX



- - - -
. . 	

	
Day 5
S02 NOX



' '/
/ ' - ' / • '*

	 	
	
Day 6
S02 NOX



~, , ~ • . , rf/r/>
.' .,///', ,
t''/

—
— - - -
Day 7
S02 NOX
	

•/"/-/' y> •//-• •
^^
•' '•y't':-,',

— -
— — - -
Da
S02
	

; .''/''//,
' ^//

	
                                                                                                                         NOX
 Value belore span adjustment

 Value after span adjustment.

NU11  Complete checklist lor portions of test actually observed.
t   Were dd|ustments made only at 24 h intervals?
       Yes:         No:   	  If no. explain	-
                                                                  3. Fur in situ monitors usiny incremental addition metliod, what are the
                                                                    calibration cell values?
                                                                  4. Comments:
 2.  What is the manufacturer's recommended procedure lor mo and span

-------
                           ONSITE TEST SUMMARY
          CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2

ZERO AND CALIBRATION DRIFT-2-H

Were 2-h drift readings taken so that no
adjustments were made?
Were a total of 15 nonconsecutive 2-h
drift periods completed?
How many were observed?
If the system was extractive, was span
gas/cell 80 to 90% of the instrument span?
If the system was nonextractive, was span
gas/cell 45 to 55% of this instrument
span?
so2





NOX





                                                      Comments:
                                       7-C

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                                      ONSITE TEST SUMMARY
                CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST
REFERENCE METHOD 6

 1.  How many runs were made?  	

 2,  Probe type (material):  	
 3.  Were glass ball joints greased?

 4.  What type of grease?   	
 5.  Date of last dry gas meter calibration?

 6.  Calibration factor of dry gas meter:  _

 7.  Were impingers iced down?  	
 8.  Barometric pressure measured? 	   If not, how were the data obtained?
 9.  Was the first midget impinger filled with 15 ml of 80% isopropanol (100 ml of 80% isopropanol for large impingers)?
10.  Were the next two midget impingers filled with 15 ml of 3% \\2®2 '10° mt- of H2°2 for Iar3e impingers)?
11.  What leak check procedure was used?
12. Were laboratory QA samples accepted?   	 Yes     	  No

    Serial Numbers: (1)	   (2)	   (3)	   (4).

    If not accepted, please explain.
                                                    8r
                                                   -o

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                              ONSITE TEST SUMMARY
            CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST
METHOD 6 TESTING
NOTE: No more than one S02 accuracy test may be run per hour.
Run Number
Date
Probe heated?
Probe free of condensate?
Initial leak check run? (Optional)
Was probe purged immediately prior
to each test?
Sample starting time
Flow rate constant? (1 L/min)
5-min readings taken for:
A. Flow rate
B. DGM volume
C. DGM temperature
0. Was temperature leaving last
! impinger 68" F or less?
1 Sample end time
: Total volume sampled
Final leak test? (Mandatory)
Sample purge time (Total) > 10 minutes
Was purge air filtered? (Optional)
Concurrent moisture test?
CEM reading
1


















2


















3


















4


















5


















6


















7


















8


















9


















10


















11


















12




1










1


                                       3-C

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                               ONSITE TEST SUMMARY
             CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST

REFERENCE METHOD 6
SAMPLE RECOVERY
Run number
Date
Sample containers clean
Container type
Glass
Polyethylene
Teflon
Other {Soecifyl ..

1st impinger
(IPA discarded)
Last 3 impingers, connecting glass
rinsed with 01 water and
combined in recovery
containers
Containers labelled, sealed, and
content level marked
Container code or ID number
1











2











3











4











5











6











7











8











9











10











11











12











 Additional comments: (Include description of general environment of cleanup area)
                                          10-C

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                                    ONSITE TEST SUMMARY
               CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET

PERFORMANCE SPECIFICATION 2
ACCURACY TEST
REFERENCE METHOD 6
SAMPLE DISPOSITION:


   1.   Were samples titrated onsite?     Yes:	     Mo: 	

   2.   If no, were they analyzed

            	 A)  At the base laboratory of the test team; or
            	 B)  (Subcontracted to) another laboratory?

   3.   Who analyzed the samples?
            Name of analyst:  .	.	
            Name of firm:    		.	_—	
   4.   Did anyone observe the analyses?     Yes:	     No:

                                    Who: 	
   5.   Are the data and/or results available?  Yes  	     No:

       If yes, from whom?  	—
   6.   Were audit samples included?     Yes:	     No:

                                 Actual values:    S02	
                                  Observed values:

   Comments:   	
                                                 11-C

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                                     ONSITE TEST SUMMARY
               CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST
REFERENCE METHOD 4
NOTE:  Concurrent with Method 6 and/or Method 7
 1.  Probe type (material):
 2.  Were glass ball joints greased?

 3.  What type of grease?  	
 4.  Date of last dry gas meter calibration:

 5.  Calibration factor of dry gas meter—

 6.  Were impingers iced down?	
 7. Barometric pressure measured?
    If not, how were these data obtained?
 8. Was silica gel or Drierite used in last impinger

 9. What leak test procedure was used?  	
? (SpecifyI
10. How was moisture determined?
         Volumetrically
                                                or Gravimetrically
                                               12-C

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                              ONSITE TEST SUMMARY
            CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST
REFERENCE METHOD 4
NOTE: Concurrent with Method 6 and/or Method 7
Run Number
Date
Probe heated?
Probe free of condensate?
Initial leak check run? (Optional)
Was probe purged immediately prior
to each test?
Sample starting time
Flow rate constant?
5-min readings:
A. Flow rate
i
B. DGM volume
C. DGM temperature
0. Was temperature leaving last
impinger 68° F or less?
Sample end time
Total volume sampled
Final leakiest? (Mandatory)
1














2














3














4














5














6














7














8














9














10














11














12


I











                                         13-C

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                                     ONSITE TEST SUMMARY

               CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET

PERFORMANCE SPECIFICATION 2

ACCURACY TEST

REFERENCE METHOD 7

NOTE:  No more than one NOX accuracy test may be run per hour
 Run Number
1
                                                                                     10
                                                     11
12
  Date
  Probe material?
  Was probe heated?
  Barometric pressure taken?
  If not, how was this information obtained?
  Were ball joints greased?
  Type of grease
  Flask evacuated to 75 mm Hg
    absolute or less? (3 in. Hg)
  Leakage rate under vacuum less
    than 10 mm Hg in 1 min? (0.4 in. Hg)
  System purged before sampling?
  Flask pressure and temperature taken
    before sampling?
  Time required to fill flask
  Three flasks shot in three minutes?
  Sample flask shaken for 5 min?
   CEM reading
                                                   U-C

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                               ONSITE TEST SUMMARY
             CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
ACCURACY TEST
REFERENCE METHOD 7
SAMPLE RECOVERY
Run Number
Sample held for 16 h before recovery?
Sample shaken for 2 min before
recovery?
Flask temperature and pressure
recorded before vented?
Sample containers clean?
Container type
Glass
Polyethylene
Teflon
Other (Flask)
Rinsed twice with 5 ml 01 water?
pH adjusted to between 9 and 12?
Containers labelled, sealed, and
content level marked?
1











2











3











4











5











6











7











8










I
9











10











11











12











 What was the environment of the cleanup area?
                                         15-C

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                                     ONSITE TEST SUMMARY
                 CONTINUOUS EMISSION MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 2
SAMPLE DISPOSITION:

1.  Were samples titrated onsite?     Yes:	     No:  	
2.  If no, were they analyzed
         	 A)  At the base laboratory of the test team; or
         	 B)  (Subcontracted to) another laboratory?
3.  Who analyzed the samples?
         Name of analyst:	.	
         Name of firm:	
4.  Did anyone observe the analyses?    Yes:	     No:
                                 Who: 	
5.   Are the data and/or results available?  Yes:	     No:
    If yej, from whom?  	
6.   Were audit samples included?     Yes:	   No:

                               Actual values:      NOX

                               Observed values:    NOX

COMMENTS:  	
                                                  16-C

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                                  ONSITE TEST SUMMARY
             CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 3 (DILUENTS) (02, C02)

1.   Manufacturer and model of monitor:	
2.  Serial number of monitor:

3.  Gas sampled:	
 4.  Were ORSAT analyses performed to verify diluent monitors?
 5.   If bags were used to collect 0 RSAT samples, of what material were the bags made?	

 6.   Was a calibration curve established to verify the expected response curve as described by the analyzer manufacturer?
 7.  Were calibration gases (if used) injected at probe?
                                                   17-C

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                            ONSITE TEST SUMMARY
          CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 3

RESPONSE TIME
Diluent
Gas or cell concentration used
Low
Medium
High
Was entire continuous monitoring system used? If not, explain.*
What was the response time?
°2





co2





 'Comments:
                                        18-C

-------
                                  CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
         PERFORMANCE SPECIFICATION 3
         ZERO AND CALIBRATION ORIFT-24-H

Were all readings taken at 24 h intervals?
Were zero and span gases or calibration
cells used?
If the system was extractive, was span
gas/cell 80 to 90% of instrument span?
It the system was nonextractive, was span
gas/cell 45 to 55% of instrument span?
Were zero readings taken before adjustment?
Value before zero adjustment.
Value after zero adjustment.
Were span readings taken after zero
adjustment, but prior to span
adjustment?
Value before span adjustment.
Value after span adjustment
Day 1
'/r/S'/r'7'-/77''r/
'yw//yyfa,,



'S'////^//
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                            ONSITE TEST SUMMARY
           CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET
PERFORMANCE SPECIFICATION 3

ZERO AND CALIBRATION DRIFT-2-H
Diluent
Were 2-h drift readings taken so that no adjustments were made
during drift period?
Were a total of 15 nonconsecutivs drift periods completed?
How many were observed?
If the system was extractive, was span gas/cell 80 to 90% of
instrument span?
If the system was nonextractive, was span gas/cell 45 to 55%
of instrument span?
°2





co2





 Comments:
                                       20-C

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                             ONSITE TEST SUMMARY
           CONTINUOUS EMISSIONS MONITOR OBSERVER'S DATA SHEET

GENERAL COMMENTS ON ENTIRE SAMPLING PROJECT:
                                       21-C

-------
Did observer sign observed data sheets?    Yes:   	   No:
Did observer sign strip charts/computer printouts?     Yes:   	    No:
Was the test team supervisor given the opportunity to read over this data sheet?




Did he do so? 	
Test team supervisor signature:




Observer's name:   	





Titie:  	
Affiliation:
 Observer's signature:





 OatE:  	

-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-340/1-83/ 009
4. TITLE AND SUBTITLE
Guidelines for the Observation of Performance
Specification Tests of Continuous Emission Monitors
1. AUTHOR(S)
Entropy Environmentalists, Inc.
>. PERFORMING ORGANIZATION NAME AND ADDRESS
Entropy Environmentalists, Inc.
P.O. Box 12291
Research Triangle Park, NC 27709
12. SPONSORING AGENCY NAME AND ADDRESS
OAQPS
Stationary Source Compliance Division
Waterside Mall, 401 M Street, SW
Washington, DC 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
January 1983
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
1 1 . CONTRACT/GRANT NO.
68-01-6317
13. TYPE OF REPORT AND PERIOD COVERED
FINAL - IN-HOUSE
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT

   When stationary source owners or operators  plan to  conduct Performance Specifi-
   cation Tests of installed continuous emission  monitors,  they are required to
   notify the applicable control agency.   The  agency should then appoint a represen-
   tative to observe the tests.

   This document contains general guidelines for  the agency observer on the performance
   of pretest negotiations, on-site observations, and  the preparation of his report.
   Also, an observer's checklist for  these activities  is included.
7. KEY WORDS AND DOCUMENT ANALYSIS
L. DESCRIPTORS
Air Pollution
Performance Specification Tests
H.
8. DISTRIBUTION STATEMENT
Release to Public
b.lDENTIFIERS/OPEN ENDED TERMS
Guidelines for Observer
Checklist for Observer
19. SECURITY CLASS /This Report)
unclassified
20. SECURITY CLASS (This page)
unclassified
c. COSATI Field/Group

21. NO. OF PAGES
64
22. PRICE
 :PA Form 2220-1 (R«». 4-77)   PREVIOUS EDITION is OBSOLETE

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-------
 United States                              Office of Air Quality Planning and Standards
 Environmental Protection                   Stationary Source Compliance Division
 Agency                                   Washington, D C.  20460
Official Business                            Publication No EPA-340/1-83-009                                                                                              D  .  „    .
Penalty for Private Use                                                                                                                                                     Postage and
$300                                                                                                                                                                    Fees Paid
                                                                                                                                                                         Environmental
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                                                                                                                                                                         Agency
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                                                                         If your address is incorrect, please change on the above label,
                                                                         tear off, and return to the above address
                                                                         If you do not desire to continue receiving this technical report
                                                                         series,  CHECK HERE D , tear off label, and return it to the
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-------