United States      Office of Air Quality       EPA-340/1 -83-012
Environmental Protection  Planning and Standards     January 1983
Agency         Research Triangle Park NC 27711
Stationary Source Compliance Series	
A Compilation
of SO2 and IMOx
Continuous
Emission
Monitor
Reliability
Information

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                                                   EPA-340/1-83-012
A  Compilation of SO2 and NOx Continuous
   Emission Monitor Reliability Information
                               Prepared by:

                              James W. Peeler
                         Entropy Environmentalists, Inc.
                            Research Triangle Park,
                               North Carolina
                               Prepared for:

                               Louis R. Paley
                       Stationary Source Compliance Division
                                  and
                              Anthony Wayne
                                Region VII
                    United States Environmental Protection Agency
                         SSCD Contract No. 68-01-6317

                                  and

                            Darryl von Lehmden
                                  and
                              Thomas Logan

                          Quality Assurance Division
                    United States Environmental Protection Agency
                         QAD Contract No. 68-02-3431
                    U.S. ENVIRONMENTAL PROTECTION AGENCY
                     Office of Air Quality Planning and Standards
                      Stationary Source Compliance Division
                          Washington, D.C. 20460
                              January 1983
                                         U.Z. Environmental Protection Agency
                                           ;ic-i ;;, Library (5PL-16)
                                         '•:•'. j S, Dearborn Street, Room 1670
                                         ^icago,  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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                               EXECUTIVE SUMMARY



     As air pollution control agencies emphasize the implementation of

continuous emission monitoring (CEM)* programs and effective utilization of

CEM results, the reliability of the monitoring data (i.e., the availability,

accuracy, precision, and representativeness of monitoring results) increases

in importance for both the affected source owner/operator and the control

agency.  This report presents the latest information on the reliability of

S02 and NOX CEM results, i.e.: (1) achievable CEM availability, (2)

point-in-time CEM accuracy, and (3) the long-term capability of CEMs to

provide accurate emission data.

     The information in current literature shows that the CEM availability

(data capture rate) levels are between 6? and 95 percent for SC>2 and NOX

CEMs.  CEM availability is expected to vary on source-specific and

source-category bases and to increase with additional operational experience.

     Analysis of more than 119 relative accuracy tests (RATs) of S02 and

NOX CEMs shows that the four most common commercially available SC>2 and

NOX CEMs are capable of meeting the 20 percent "point-in-time" relative

accuracy specification (both on a concentration and lb/10° Btu basis) on

coal- and oil-fired steam generators with, and without wet FGD systems.

     The results of numerous RATs conducted after the initial demonstration of

compliance with the Performance Specifications show that both S02 and NOX

CEMs continue to be capable of obtaining accurate data on a long-term basis

under a wide variety of source conditions.  No general deterioration in the

S02 and NOX CEMs1 accuracy was apparent during the 24-month period

following the initial demonstration of compliance.
* Throughout this document, the acronym CEM is used to mean both  "continuous
emission monitor" and "continuous emission monitoring."  The  specific
connotation should be clear from the context in which it is used.
                                   iii

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                                TABLE  OF  CONTENTS
   I.   Introduction	   1








 II.   S02 and NOX CEM Availability	   3




       Background	   3




       CEM Availability Estimates	   5



       References	   g








III.   S02 and NOX CEM Accuracy	   9




      Background	   9




       Compilation of S02 and NOX RAT Results	  12




      Long-Term CEM Performance	  16
APPENDIX	  23

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                                I.   INTRODUCTION








      The  Environmental  Protection  Agency and  many State air pollution control




 agencies  are  currently  expanding  the  scope  and  implementation of S02 and




 NOX  continuous  emission monitoring programs for stationary sources.   Greater




 importance  is being  placed  on  CEM  results for evaluating  the  adequacy of  the




 operation and maintenance practices of  source processes and control  systems.




 In some cases,  such  as  those sources  subject  to the  recently  promulgated  NSPS




 (40  CFR 60, Subpart  Da)  requirements, S02 and/or  NOX CEM  results are used




 to determine compliance with emission limitations.   Clearly,  the increased




 utilization of  CEM reflects control agency  efforts to achieve sustained




 emission reductions  from stationary sources.




     As control agencies emphasize the  implementation of  CEM  programs and




 effective utilization of CEM results, the importance of obtaining  reliable




 monitoring data increases for  both the  affected source owner/operator and the




 control agency.  More specifically, the  level of  long-term monitor performance




 in terms of CEM availability,  accuracy,  precision, and representativeness is



 of fundamental  importance.




     Until recently, there has been a lac^c  of long-term monitor  performance




 evaluations.  Although  many CEMs have met the applicable  Performance




 Specification requirements during  an initial  performance  test, very  few




monitoring systems have been retested to demonstrate  long-term accuracy.  In




addition,  various CEM users have reported widely differing  values of CEM




availability (data capture rates).  However,  only very limited quantitative




information has been available to  determine the causes of  CEM unavailability




 (i.e., unreliable CEM equipment, inappropriate  applications of CEMs,  and/or




the inexperience of  CEM users).

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     This report presents additional, recently available information about the




long-term reliability of S02 and NOX CEM results.  The term "CEM




reliability" is considered to be the degree to which source operators and




control agencies may depend on CEM data to yield a consistent and valid




measure of S02 and NOX emission levels.  This report addresses  (1)




achievable CEM availability, (2) point-in-time CEM accuracy, and  (3) long-term




capability of CEM to provide accurate data.  The results and conclusions  in




this report are based on  CEM availability values reported  in current




literature, numerous performance specification test results, and  a  number of




performance audit results.   This document does not attempt  to  specify




achievable CEM  availability  and accuracy.

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                      II.   S02 and  NOX  GEM  AVAILABILITY








     This  section  presents background  information  on CEM availability,




including  definitions of  terminology and a brief discussion of the major CEM




availability  factors.   Several  estimates of availability are discussed  for




SC>2 and NOX monitoring  systems  installed at electric utility steam




generators.   These estimates  bracket the expected  range  of CEM availability




for contemporary gas  monitoring programs.








Background




     The term "CEM availability" is the data capture rate  exhibited  by  a




continuous emission monitoring  system.  It  is defined  as the  percentage of




time a monitoring  system  is operating  (i.e., sampling, analyzing,  and




recording emission data)  relative  to the total time  the  system is  required to




operate.  This percentage  does not incorporate the accuracy or precision of



the CEM data.




     The availability of  S02  and NOX CEM data affects  the  characterization




of emission levels and/or  process  and  control system performance at  a given




source.  No CEM system  can be expected to,  operate  continuously over  an




extended period of time.   Unforeseen malfunctions  of various  components and




necessary routine maintenance and  repairs  will reduce  the  availability.



Quantification of the achievable level of  CEM availability  will aid  the




control agency and the  source operator in determining  accurately both




acceptable monitor performance and when to  initiate  corrective action.

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     CEM availability is dependent on a variety of factors,  including the

following.


     (1)  Reliability of specific instrumentation,

     (2)  Instrument maintainability and availability of spare
          parts.

     (3)  User's operational, repair, and trouble-shooting expertise
          (and/or the availability of service from the monitor
          vendor).

     (4)  Environmental conditions (exposure to weather, corrosive
          gases, and/or dusty environments, etc.).

     (5)  Site conditions (accessibility, adequacy of power supply
          and other utilities, presence of mechanical vibration,
          existence of microwave and/or radio frequency
          interference, etc.).

     (6)  Effluent conditions (temperature, pressure, flow rate,
          particulate loading, etc.).

     7. User's dedication of manpower and prioritization of repair
        efforts during periods of monitor malfunction.


     In view of the number of factors that affect CEM availability,  the

infinite  combinations of these factors, and the varying degree of severity of

specific  problems encountered in  actual practice, CEM availability must  be

expected  to vary over time and from  source to  source.  CEM availability  is

expected  to increase over time on an  industry-wide basis as unreliable

instrumentation  is excluded  from  the  competitive  CEM market,  as unsuccessful

approaches to the installation and operation of CEMs are identified,  and as

monitor operators gain  necessary  experience and develop appropriate  quality

control programs and cost effective  preventive maintenance programs.  Because

of  these  time-dependent  factors,  the  averaging period of all  CEM availability

estimates must  be clearly identified  to  characterize adequately the  many

problems  that detract  from CEM availability.

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GEM Availability Estimates




     All of the factors discussed above increase the difficulty and decrease




the usefulness of developing "average" CEM availability percentages to




represent the level of monitor performance that can be reasonably achieved.  A




more realistic approach is to establish an expected or acceptable range of CEM




availability values.




     One notable attempt to characterize CEM availability was conducted by the




Utility Air Regulatory Group (UARG) in response to the EPA September 18,  1979




proposal of Subpart Da requirements.^  During the fall of 1978, UARG surveyed




71 electric utility companies.  Survey responses from 63 companies provided




information on a total of 539 emission monitoring channels (S02, NOX, 02,




C02, and opacity) installed at 237 generating units throughout the U.S.   In




this survey, in which monitor availability is expressed on a monthly basis, 55




responses indicated an average availability of 67 percent for S02 monitoring




channels, 50 responses indicated an average availability of 67 percent for




NOX monitoring channels, and 85 responses indicated an average availability




of 76 percent for 02 and/or C02 monitoring channels.  It is emphasized that




(1) the UARG survey included some monitors installed before the EPA




promulgation of CEM requirements, (2) considerable advancements in CEM




application technology and additional operating experience have been made since




the survey was conducted, and (3) the survey results reflect to an




indeterminate degree the relatively low level of control agency emphasis  on the




implementation of CEM programs that existed at the time the survey was




conducted.  Thus, although currently achievable CEM availability is expected to




be somewhat greater than that indicated by the "average" results of the 1978




UARG survey, these results are nevertheless indicative of a minimum level of




achievable CEM a/ailability.

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     CEM availabilities achieved by two utility companies actively  involved  in




CEM programs for some time are summarized in Table  1.  The two  companies  are




the Texas Utilities Generating Company2 and The Montana Power Company^.




The results over the five year period from 1977 to  1981 show significant




improvement in SC>2 and NOX availability.  The improvement is attributed to




increased overall experience of the monitor operators.  Table 1 also  shows that




five of the six monitoring systems exhibited approximately 95 percent




availability during 1980 and 1981.




     A study of CEM data reported to the California South Coast and the Bay




Area Air Quality Management Districts^ provides further estimates of  SOp




and NOX CEM availability.  This study included data reported from November




1978 to April 1980 for 62 CEMs in the South Coast District, and data  reported




from July 1979 to December 1980 for 38 CEMs  in the Bay Area District.  A total




of 33 SC>2 CEMs had achieved an average availability of 97.2 percent,  and  a




total of 67 NOX CEMs had achieved an average availability of 96.7 percent.




These high availability figures may be the result of all the CEMs being




installed on gas or oil-fired steam generators with no FGD systems.   Therefore,




these results may not accurately represent the achievable CEM availability for



coal-fired boilers and/or units equipped with wet FGD systems.




     The results of these three investigations probably represent the ultimate




level of CEM availability; whereas, the results of the UARG 1978 survey




probably represent the minimum acceptable level of CEM availability.  The




minimum data collection requirements, which are included in EPA's June  11,  1980




promulgation of Subpart Da (i.e., 18 hours per boiler operating day,  and  22




days per 30 operating days, or approximately 75 percent) fall within  the  CEM




availability range bounded by the above references.

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                          TABLE 1.


                  REPORTED GEM AVAILABILITY
   Station      Unit    Monitor
                                     Percent Availability
                               1977   1978   1979   1980   1981
 Martin Lake
 Martin Lake
 Martin Lake
  Colstrip   1 and 2
                    **
  Colstrip   1 and 2
                    **
                       scu
                       so.
                       so.
                       NO,
86.1   88.6   100    97.7   97.4
       90.6   100    97.5   98.6
               49    94.1   36.9
                               84.1   92.5   95.7   96.6   96.2
88.9   90.1   94.8   96.5   95.7
**
Texas Utilities Generating Company,

Montana Power Company

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References


1 "Section IV - October/November 1978 Continuous Monitor Survey," An
Evaluation of the Continuous Monitoring Requirements of the September 19, 1978
Subpart Da NSPS Proposal, pp. 72-96.


2 Bill Bonner, "Continuous Emission Monitoring - Texas Utilities Generating
Company's Experience," Proceedings. Continuous Emission Monitoring: Design,
Operation and Experience Specialty Conference, pp. 62-69.


3 David K. Nation, "Continuous Emission Monitoring Experience at Colstrip
Units  1 & 2," Proceedings, Continuous Emission Monitoring: Design, Operation
and Experience Specialty Conference, pp. 25-38.


4 R.P. Hebert, W.C.  Kelly, and'w.J Mitchell,  "Assessment of the Reliability
of Continuous Emission Monitors Installed in  Two California Air Quality
Regions," Proceedings, Continuous Emission Monitoring: Design.  Operation and
Experience Specialty Conference, pp. 18-24.

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                       III.  S02 and NOX GEM ACCURACY

     Background information relevant to the measurement of gas CEM accuracy
and the interpretation of CEM relative accuracy test results is presented in
this section.  Also, a compilation of relative accuracy test results is
provided, giving both "point-in-time" CEM accuracies and capabilities of SC>2
and NOV CEMs to achieve the level of performance required by both the
      A
existing and proposed relative accuracy specifications of Appendix B (40 CFR
60).  Finally, the results of performance audits of S02 and NOX CEMs are
presented and discussed to provide a preliminary evaluation of long-term CEM
accuracy for a number of sources.


Background
     The accuracy of CEM data is of critical importance to both the control
agency and the source owner/operator.  To protect the  interests of both
parties, the CEM data must be sufficiently  accurate to  ensure valid
conclusions and decisions.  Clearly, the uncertainty-level of all conclusions
based on the data decreases as the  accuracy of the data improves.
     Measurement accuracy  is generally defined as the  degree of agreement of a
measured value with the "true" value (or the degree of agreement of the mean
of  a set of measurements with the corresponding  "true"  values).
Traditionally, the  accuracy of S02  and NOX  CEM data has been determined by
conducting relative accuracy tests  (RATs)  in accordance with the requirements
of  Performance Specification 2,  Appendix B, 40 CFR  60.  The  term "relative
accuracy" reflects  the  fact that the accuracy of the  CEM  data  is determined
relative to  the results obtained by performance  of  Reference Method  Test
procedures;  the Reference  Method results are  presumed  to  be  the  "true" values

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for this test.  Historically,  RATs have only been conducted during CEM


Performance Specification Tests (PSTs); however, requirements to perform


periodic RATs will probably be mandated as basic elements of most quality


assurance programs.  (See "A Compilation of Quality Assurance Procedures for


SC>2 and NOX Continuous Emission Monitoring Systems.")  Also RATs may be


conducted by the control agency as a central part of SC>2 and NOX CEM


performance audit programs.


     To place the interpretation of CEM RAT results into the proper


perspective, one must clearly understand how several procedural test

                               l
requirements and a number of constraints affect the representativeness of the


test results.  According to the existing Performance Specification 2  (Appendix


B, 40 CFR 60), the relative accuracy of S02 and NOX CEM data is determined


in units of concentration (ppm) from a series of nine measurements using


Method 6 for S02 and Method 7 for NOX.  (Concurrent moisture sampling  is


also conducted, if needed, to adjust either the wet basis  CEM data or  the dry


basis Reference Method data to the same moisture basis.)


     The relative  accuracy of S02 and  NOX CEMs  is computed  as the sum  of


(1) the absolute value of the mean from the differences between the 9  pairs  of


concurrent  CEM and Reference Method results and  (2) the 95  percent confidence


interval associated with the observed  differences.  This sum is divided by  the


mean Reference Method value in order to express  the relative accuracy  as a


percentage.   The relative accuracy calculated using this procedure is  actually


expressed  in  terms of error; smaller relative accuracy values indicate better


monitor performance.  Performance Specification  2 requires the result  of the


RAT to be  less than, or  equal  to, 20 percent for acceptable CEM performance.


     Relative accuracy  is affected by  errors in  the  CEM data and  the  Reference


Method data.  The  Reference Methods are not totally precise because of the
                                  10

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 inherent variability  and  the  expertise  and  ability  of the  tester.   The




 confidence  interval of  the  RAT determination  reflects the  precision among  the




 paired  GEM  - Reference  Method results;  i.e.,  it  is  the sum of  (1)  the




 imprecision of the CEM  data,  (2)  the  inherent variability  of the Reference




 Method  results, and (3) the ability of  the  tester to  conduct the Reference




 Method  tests.  For a  particular RAT,  the  individual errors cannot  be




 quantified.  Therefore, the cause of  an excessive confidence interval value




 (e.g.,  poor testing practices or  poor CEM performance)  cannot  be objectively




 determined.  Thus, while meeting  the  relative accuracy  specification




 demonstrates that a CEM has provided  accurate data  during  the  test,  failure tc




 do so does  not necessarily demonstrate  that a CEM has provided  inaccurate




 data.




     The RAT covers an  approximate nine-hour  period and  represents only  the




 accuracy of the CEM data during that  test period and  at  the  effluent




 conditions  encountered during the RAT.  Thus,  the RAT provides  a




 "point-in-time" measure of CEM. accuracy.  A successful  RAT only demonstrates




 that the CEM is capable of obtaining  sufficiently accurate data for its




 intended use.  The CEM accuracy actually  achieved on  a day-to-day  basis  is




 primarily dependent upon (1) the validity,of  the calibration procedure




 employed for the CEM,  and (2) the manner  in which the  CEM  operator performs




 the daily calibration procedure.




     As a final note  regarding the interpretation of  RAT results,  it is




 important to recognize that revisions to  Performance  Specifications 2 and  3




 proposed first in the October 10, 1979, Federal Register,  and  subsequently




reproposed  in the January 26, 1981, Federal Register,  significantly change th




 scope of the RAT.  The presently promulgated  specifications  require that the




 relative accuracy of  pollutant SC>2 and NOX monitors be  determined  in units




of concentration (ppm).  There are no RAT requirements  on  the diluent (02  or





                                  11

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COp) monitor which is used to convert pollutant concentration measurements
to units of the standard (lb/106 Btu) at fossil fuel-fired steam
generators.  The proposed revisions require that the RAT determination be
conducted in units of the standard (Ib pollutant/106 Btu) and thereby,
provide a measure of the combined pollutant-diluent monitoring  system
accuracy.  The proposed revisions provide for evaluation of the accuracy of
the total CEM system (both pollutant and diluent monitors) in the  same units
of measurement that are used for reporting excess emissions to  the  control
agency.

Compilation of S02 and NOY RAT Results
     The results of M1 RATs  (in units of concentration)  of 22 installed  S02
CEMs and the results of 25 RATs (in  units of  concentration) of  15  installed
NOV CEMs are tabulated  in the  Appendix  of this  report.   In addition,  the
   A
results (expressed  in  units  of lb/106 Btu) of 34  S02 RATs and  the  results
of 19  NOX  RATs  are  provided  for a  subset of  the same population of
monitors.   Table  2  summarizes  the  results of these  tests in  terms  of meeting
 the existing  and  proposed  relative accuracy  specifications.
      In evaluating  the RAT results provided  in  the  Appendix  and summarized  in
 Table  2,  the  following qualifications  of  the data base should be kept in mind:

      (1)   All  tests were  performed at  coal-  and oil-fired steam
           generators;  some of the coal-fired installations were
           equipped  with wet  FGD systems.
      (2)   All RATs  were performed either  during the initial
           demonstration of compliance with Performance Specifications
           2 and 3 or during announced performance audit programs
           conducted by various control agencies.

                                  12

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               TABLE 2.
SUMMARY OF SO2 AND NOX RELATIVE ACCURACY TEST RESULTS
Monitor Pollutant
LSI SM810



DuPont 460



Contraves Goerz
GEM-100


EDC DIGI 1400



CSI Monitor
All Monitors



so2
S02
NOX
NOX
SO2
S02
NOX
NOX
so2
S02
N°x
N0x
so2
S02
NOX
NOX
so2
SO2
SO2
NOX
NOX
FGD
Controls
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO -
YES
NO
YES
NO
NO
YES
NO
YES
Existing RA Requirements
No. of No. of % of Tests
Monitors Tests <_20% RA
7
2
4
2
6
1
5
0
2
1
2
0
1
1
2
0
1
17
5
13
2
11
9
6
9
6
3
5
0
3
4
3
0
1
2
2
0
2
23
18
16
9
91%
89%
50%
100%
100%
67%
100%
— — —
67%
50%
67%
— — ~
100%
100%
50%
— ™ —
100%
91%
78%
69%
100%
2
Proposed RA Requirements
No. of No. of % of Tests
Monitors Tests ^20% of RA
6
2
3
2
6
1
5
0
1
1
1
0
1
1
2
~"
1
15
5
11
2
9
7
4
7
6
3
5
0
1
4
1
0
1
1
2
~~
2
19
15
12
7
100%
86%
25%
100%
100%
100%
100%
— — —
100%
50%
100%
_. _ —
0%
100%
	
__ _ —
100%
95%
80%
75%
100%
 Performance Specification 2, Appendix B, 40 CFR 60  (RA test performed in units of pollutant
    concentration - ppm)
2 Proposed  revisions  to Performance  Specifications  2  and 3,  Federal Register,  Vol.  46,  No.  16
            26.  1981  (RA test performed  in units  of the standard - lbs/10b  Btu)

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     (3)  Source maintenance personnel and/or monitor manufacturer

          service representatives are known to have made adjustments

          to the subject CEMs prior to the RATs in some cases.




In view of the above, the RAT results may not necessarily represent the

performance of similar CEMs under dissimilar conditions.  In addition, valid

statistical inferences regarding the ability of randomly selected CEMs to meet

relative accuracy specifications cannot be derived from the data base.

     Within the limitations of the available data base, analysis of the
                              /
included RAT results indicates:




     (1)  There is no apparent significant difference between the

          capabilities of S02 and NOX CEMs to meet RAT

          specifications.  (NOX  CEMs may have a slightly higher

          failure rate; however, this finding may be due to the

          limited data.)

     (2)  There is no apparent significant difference between the

          capabilities of CEMs installed at oil- and coal-fired

          facilities to meet RAT specifications.

     (3)  There is no apparent significant difference between the

          capabilities of CEMs installed at FGD equipped and non-FGD

          equipped facilities to meet RAT specifications.  (S02

          monitors did perform better at non-FGD sources; however,

          NOX monitors generally performed better at FGD equipped

          sources.  Again, these results may be attributable to the

          limited data.)
                                  14

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(4)   CEMs manufactured by Lear Siegler, DuPont, Contraves Goerz,




     Environmental Data Corporation, and Columbia Scientific




     Industries have been shown to be capable of meeting RAT




     requirements of £20 percent, both in units of concentration




     (ppm) and in units of the standard (lb/106 Btu).




(5)   Of the 53 S02 and NOX RATs that had results in both .




     units of concentration (ppm) and units of the standard




     (lb/106 Btu), (1)6 CEMs failed to meet both the




     concentration and system relative accuracy specifications,




     (2) 3 CEMs failed only the concentration relative accuracy




     specification, and (3) 2 CEMs failed only the system




     relative accuracy specification.  Therefore, changing the




     RAT specifications from the existing concentration basis to




     the proposed system basis would affect the status of only 5




     CEMs (approximately 9 percent of the population) with




     respect to compliance with the relative accuracy




     specification.




(6)   The minimum 95 percent confidence interval value observed




     in the results of 41 SC>2 RATs in units of concentration




     was 1.4 percent of the mean SC>2 concentration value; the




     minimum 95 percent confidence interval value observed in




     the results of 34 S02 RATs in units of lb/106 Btu was




     2.2 percent of the mean SC>2 emission value.




(7)   The minimum 95 percent confidence interval value observed




     in the results of 25 NOX RATs in units of concentration




     was 2.0 percent of the mean NOX concentration value; the




     miniraun 95 percent confidence interval value observed in




     the results of 19 NOX RATs in units of lb/106 Btu was




     1.3 percent of the mean NOX emission value.





                              15

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Long-Tertn GEM Performance




     The results of RATs conducted for 20 S02 CEMs at varying time  intervals




after the initial successful demonstration of compliance with Performance




Specification 2 are shown in Figure 1.  The same type of results for 7 NOY
                                                                         X



CEMs are shown in Figure 2.  For some of the S02 and NOX CEMs, more than




one RAT was conducted subsequent to the initial PST; at one source, a total of




7 RATs have been conducted over a period of 42 months.




     In evaluating the long-term RAT results, the following qualifications




should be kept in mind:









     (1)  All of the S02 and NOX CEMs are installed at coal-fired




          steam generators except for the 2 NOX CEMs installed at




          oil-fired  facilities.  Five of the S02 CEMs and two of




          the NOX CEMs are installed  on sources equipped with wet




          FGD systems.




     (2)  All of the RATs performed  after the initial demonstration




          of compliance  with Performance Specifications 2 and 3 were




          announced  CEM  performance  audits.




     (3)  Source maintenance personnel and/or monitor manufacturer




          service representatives are  known  to have inspected and/or




          made adjustments to the subject CEMs prior to the RATs in




          eight  cases.




     (4)  In many cases,  the initial  RAT results were determined in




          units  of concentration; these results are used even though




          all subsequent  RAT values were determined in units of




          lb/106 Btu.
                                   16

-------
                                             FOR SO2 CEM PERFORMANCE AUDITS
                                             CONDUCTED AFTER SUCCESSFUL PERFORMANCE SPECIFICATION TESTS  (PSTs)
Monitor
Type
1
2
3
4
-v
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
LSI
LSI
LSI
DuPont
Contraves
Goerz
EDC
DuPont
CSI
LSI
LSI
EDC
LSI
LSI
LSI
LSI
DuPont
LSI
LSI
Contraves
Goerz
Contraves
Goerz
FGD
Yes
Yes
No
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
•
4
0 2 4 6 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 38 40 42






Pass;Pass
PassjPass












LSI = Lear Siegler SM810;  DuPont = DuPont 460;   Contraves Goerz = Contraves Goerz GEM-100;
CSI = Columbia Scientific Industries;  EDC = Environmental Data Corporation DIGI 1400.

-------
                                       FOR NOX CEM PERFORMANCE AUDITS CONDUCTED
                                       AFTER SUCCESSFUL PERFORMANCE SPECIFICATION TESTS  (PSTs)





3
r
J



Monitor
Typo

J.JO 1
LSI
LSI
LSI
hiUC
EDC
LSI

FGD
Vt\ c

Yes
No
NO
Mc-v

NO
NO

0 2 3 4 5 f, 7 H 9 10 11 12 13 14 ] 5 16 17 18 19 20 21 22 23 24 25
Pa*"1" i** pQ'jj^^PLiG" ^^ Friil >»- Pass







LSI - Loar Sicqlor SMfUO;   EDC  =  Environmental  Data Corporation DIGI 1400.

-------
     (5)  All RATs performed after the initial PST were conducted by




          personnel from Entropy Environmentalists, Inc. in




          accordance with all applicable regulatory testing




          requirements and in accordance with Entropy's internal




          quality assurance program.  Thus, a significant level of




          experimental control is applicable to all test results




          obtained after the initial PST.









The non-routine adjustments of the subject CEMs made just prior to the




performance of the announced RATs may have influenced the level of monitor




performance achieved.  These non-routine adjustments and services probably




increased the apparent capability of the CEMs to obtain valid data.  The fact




that all RATs performed after the initial PST were conducted by essentially




the same testing personnel ensured the consistency of the test results and




eliminated interlaboratory- variance effects.




     Overall, the gas CEM performance audits provided the following results:









     (1)  The 20 installed S02 CEMs met the applicable relative




          accuracy specification for 25 of the 33 audits conducted (H




          of the 8 relative accuracy test failures were consecutive




          tests of the same monitoring system).




     (2)  15 of the 20 S02 CEMs audited passed all of the relative




          accuracy tests.




     (3)  The 7 installed NOX CEMs met the applicable relative




          accuracy specification for 9 of the  13 audits conducted  (2




          of the 4 relative accuracy test failures were consecutive




          tests of the same monitoring system) .




     (4)  4 of the 7 NOX CEMs audited passed  all of  the relative




          accuracy tests that were conducted.





                                    20

-------
     In evaluating the above results,  it  is  important  to  note  that:  (1)  there




are no promulgated quality assurance requirements  applicable to  the  audited




CEMs, and (2) there are no promulgated requirements  for the GEM  operators  to




periodically test installed CEMs or to take  necessary  corrective actions where




unacceptable performance is observed.




     Although other results can be derived from the  long-term  CEM accuracy




data obtained to date, there is insufficient information  upon  which  to base




any significant statistical analysis.  Additional  RATs of these  and  other




installed SC>2 and NOX CEMs are currently being planned and conducted.  The




results of these future tests will enhance the existing data base, both  in




terms of the number of monitors represented  and the  length of  time for which




results are available for the same monitors.  However, the inclusion of  these




additional results is not expected to dramatically affect the  overall




characterization of CEM reliability.
                                  21

-------
     APPENDIX
RELATIVE ACCURACY
  TEST RESULTS

-------
AVERAGE MONITOR PERFORMANCE DATA
Monitor
LSI
LSI
LSI
LSI
DuPont
DuPont
DuPont
DuPont
DuPont
Contraves
Contraves
Contraves
EDC
EDC
EDC
CSI
Fuel
Coal
Coal
Coal
Coal
Coal
Coal
Oil
Coal
Oil
Coal
Coal
Coal
Coal
Coal
Oil
Coal
Pollutant
Gas
so2
SO2
N0x
NOX
so2
SO2
S02
NOX
NOX
so2
SO2
NOX
SO2
so2
NOX
so2
FGD
System
YES
NO
YES
NO
YES
NO
NO
NO
NO
YES
NO
NO
YES
NO
NO
NO
Pollutant
Concentration
Relative
Accuracy
(%)
13.9
11.5
11.1
17.2
16.7
10.1
10.1
16.6
13.3
30.6
16.4
17.5
14.1
18.0
13.2
8.9
95~%
Confidence
Level
(%)
4.6
4.2
5.4
6.1
11.9
5.5
3.1
4.0
5.2
9.0
3.5
3.7
4.6
3.5
4.9
4.0
System
[lbs/106 Btu]
Relative
Accuracy
(*)
13.4
12.3
13.9
24.4
11.2
10.8
13.4
16.4
14.4
47.3
7.5
13.1
11.9
32.0
12.5
9.1
95%
Conf idenc
Level
(%)
5.2
4.1
5.3
7.2
7.2
6.0
3.6
3.8
5.1
12.0
4.6
7.8
5.5
6.7
6.5
4.1
                    A-2

-------
                 LSI  MONITOR PERFORMANCE
      SOURCES  WITH PGD EMISSIONS CONTROL SYSTEMS
ource
^ode
^-l
3-1
?-l
?-l
?-l
?-l
?-2
?-2
?-2
?-2
?-2
?-2
3-2
3-2
?-l
?-l
?-2
3-2
Test P
Date
06/80
07/81
12/81
06/80
07/81
12/81
06/80
05/81
07/81
12/81
06/80
05/81
07/81
12/81
05/82
05/82
04/82
04/82
ollutant
Gas
S02
SO2
so2
NOX
NOX
NOX
so2
SO 2
SO2
S02
NOX
NOX
NOX
NOX
so2
NOX
S02
NOX
Fuel F
Burned f
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(*)
17.5
10.7
7.3
5.8
7.6
15.8
18.8
14.6 *
8.6
9.9
17.0
12.7
2.5
13.1
28.3 *
13.5
*
9.6
11.6*
95%
Confidence
Level
(%)
3.5
4.3
4.8
4.6
6.1
7.7
7.5
5.8
3.9
"2.2
6.1
4.6
2.2
6.8
3.5
4.9
6.0
5.9
System
[lbs/106 Btu]
Relative
Accuracy
(X)
	
13.2
9.8
	
6.8
18.6
	
16.0 *
12.2
4.3
	
14.4
5.0
24.6
26.7 *
16.4
11.3*
*
11.6
95%
Confidence
Level
(X)
	
5.0
5.4
	
3.8
8.8
	
5.9
4.2
3.5
	
5.2
2.4
7.0
4.9
5.0
7.3
5.0
6 Reference Method runs instead of 9 runs
                              A-3

-------
            LSI MONITOR  PERFORMANCE
SOURCES WITHOUT FGD EMISSIONS CONTROL  SYSTEMS
Source
Code
C-34
C-34
C-34
C-34
C-34
C-34
C-5
C-5
G-9
H-l
M-5
M-5
R-l
R-l
S-l
S-2
S-3
Test F
Date
10/77
10/78
12/79
10/77
10/78
10/79
08/80
08/80
09/81
12/81
10/80
10/80
12/81
12/81
03/82
02/82
03/82
ollutant
Gas
SO2
so2
SO2
NOX
NOX
NO
X
SO2
NOX
SO2
so2
SO2
NOX
SO 2
NOX
SO2
so2
so2
Fuel
Burned
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Goal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(*)
19.7
2.2
10.1
15.6
22.7
25.6
9.5
8.3
9.0
8.9
18.4
7.3
18.5
23.5
3.8
4.1
22.5
95%
Confidence
Level
6.0
1.4
4.3
3.8
6.7
7.5
3.8
5.3
2.7
4.7
9.0
3.2
3.5
10.2
2.0
2.2
6.3
System
fibs/106 Btul
Relative
Accuracy
(*)
	
12.8
9.8
	
32.4
26.7
	
	
5.6
7.7
15.5
10.2
14.2
28.1
16.0
11.1
17.7
95%
bonf ide
Level
	
2.3
2*. 6
	
8.0
6.7
	
	
4.8
4.8
8.3
3.2
3.6
10.9
3.3
2.2
4.6
                         A-4

-------
         DUPONT MONITOR  PERFORMANCE




SOURCES WITHOUT FGD EMISSIONS CONTROL  SYSTEM

Source
Code
A- 3
N-7
N-8
N-8
N-9
N-9
N-10
N-10
T-2
Q-4
Q-4

Test
Date
08/80
02/81
12/80
12/80
11/80
11/80
12/80
12/80
02/82
01/82
03/82

Pollutant
Gas
NOX
NOX
SO 2
NOX
SO 2
NOX
SO 2
NOX
so2
SO2
so2

Fuel
Burned
Coal
Oil
Oil
Oil
Oil
Oil
Oil
Oil
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy C
(X)
16.6
9.0
11.7
17.5 1
14.1
10.0
4.5
16.6
9.3
3.5
17.5
95X
;onfidence
Level
(X)
4.0
6.0
3.4
6.5
2.7
3.6
3.3
4.7
8.4
2.8
5.4
System
[lbs/106 Btu]
Relative
Accuracy C
(X)
16.4
11.6
15.5
13.4
17.8
13.6
7.0
19.0
10.1
10.2
12.1 '
95X
Confidence
Level
(X)
3.8
6.1
3.5
8.6
4.0
1.3
3.4
4.5
8.3
3.8
5.9
                             A-5

-------
      DUPONT  MONITOR PERFORMANCE




SOURCES WITH  FGD EMISSIONS  CONTROL SYSTEM
Source
Code
B-2/3
B-2/3
B-2/3
Test
Date
01/81
11/81
04/82
Pollutar
Gas
so2
SO2
so2
t Fuel
Burned
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(X)
passed
10.1
23.2
95%
Confidence
Level
(X)
	
3.5
16.8
System
[lbs/106 Btu]
Relative
Accuracy
(%)
6.7
7.2
19.7
95%
Conf iden
Level
(%)
2.3
3.0
16.4
                       A-6

-------
             CONTRAVES MONITOR PERFORMANCE




        SOURCES WITH FGD EMISSIONS CONTROL  SYSTEM
Durc
3ode
3-1
3-1
3-1
D-l
3 Test
Date
09/80
07/81
12/81
03/82
>ollutant
Gas
so2
SO2
S02
so2
Fuel
Burned
Coal
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(X)
5.8
9.2
55.2
52.0 *
> 95*
r Confidence
Level
(%)
5.3
5.0
19.2
6.3
System
[lbs/106 BtuJ
Relative
Accuracy
(X)
18.8
9.5
99.0
61.8 *
95%
Confidence
Level
(X)
10.0
3.5
24.5
10.0
6 Reference Method runs instead of 9 runs
                              A-7

-------
       CONTRAVES MONITOR PERFORMANCE




SOURCES WITHOUT FGD EMISSIONS  CONTROL SYSTEM

Source
Code
F-4S
F-4S
F-4N
F-4N
F-4N
F-4N

J Test I
Date
04/81
04/81
04/81
04/81
09/81
09/81

=ollutani
Gas
so2
NOX
so2
NOX
so2
NOX

: Fuel
Burned
Coal
Coal
Coal
Coal
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(%)
3.7
15.6
29.1
32.3
16.4
8.9
95%
Confidence
Level
(X)
1.8
2.5
3.7
2.0
4.9
6.7
System
[lbs/106 Btu]
Relative
Accuracy
(X)
	
	
	
	
7.5
13.1
95%
Conf idef
Level
(X)
	
	
	
	
4.6
7.8
                          A-8

-------
             EDC MONITOR PERFORMANCE




SOURCES  WITHOUT  FGD  EMISSIONS  CONTROL  SYSTEM

Source
Code
E-123
E-45
J-l

j Test 1
Date
08/80
08/80
12/81

'ollutant
Gas
N0x
N°x
so2

Fuel
Burned
Oil
Oil
Coal
Pollutant
Concentration
Relative
Accuracy
21.2
5.1
18.0
95%
Confidence
Level
6.9
2.8
3.5
System
[lbs/106 Btu]
Relative
Accuracy
17.1
7.8
32.0
95*
Confidence
Level
7.8
5.2
6.7
                               A-9

-------
          EDC MONITOR PERFORMANCE




SOURCES WITH FGD EMISSION CONTROL SYSTEM
Sourc
Code
K-3
K-3
e Test
Date
06/80
07/81
Pollutanl
Gas
so2
SO2
: Fuel
Burned
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
(X)
19.6
8.6
95%
Conf idenc
Level
(X)
	
4.6
System
[lbs/106 Btu]
Relative
e Accuracy
(X)
	
11.9
95%
Confidence
Level
(X)
	
5.5
                        A-10

-------
          CSI  MONITOR PERFORMANCE
SOURCE WITHOUT  FGD  EMISSION CONTROL SYSTEM

'XX IT* C^
'ode
3-4
M

! Test P
Date
01/82
03/82

Dllutant
Gas
so2
so2

Fuel
Burnec
Coal
Coal
Pollutant
Concentration
Relative
Accuracy
4.7
13.1
95%
Confidence
Level
3.4
4.5
System
[lbs/106 Btu]
Relative
; Accuracy
10.5
7.7
95%
Confidence
Level
3.3
4.9
                         A-11

-------
 r
TECHNiCAL REPORT DATA
EPA- 340/1-83/012
4. ! 1 fi_t AND SUBTITLE 	
A Compilation of 502 ancl N0x Continuous Emission
Monitor Reliability Information
James W. Peeler
9. PERFGHMING 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 1
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-6317
13. TYPE OF REPORT AND PERIOD COVER
FINAL - IN-HOUSE
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES 	 	 — 	 	
    This  report  presents the latest information  on the reliability of S02  and  NO
    CEM results,  i.e.:  (1) achievable CEM availability,  (2) point-in-time  CEM
    accuracy,  and (3)  the long-term capability of  CEMs to provide accurate emission
    data.
"• KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Continuous Emission Monitoring
18. DISTRIBUTION STATEMENT
Release to Public
b.lDENTIFIERS/OPEN ENDED TERMS
Reliability Information
Data Analysis
19. SECURITY CLASS (This Report)
unclassified
20. SECURITY CLASS I This page)
unclassified
c. COSATI Field/Group

21. NO. OF PAGES
42
22. PRICE
EPA Form 2220-1 (R«v. 4-77)   PREVIOUS EDITION is OBSOLETE
                                              A-12

-------
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U.S. Bnylrome      Prot

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,   -  -   Dcp-r.-t,om Street, Room i670

    clo, IL   60604

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 Agency                                   Washington, D.C  20460
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