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FOR IMPLEMENTING
• THE NSPS CONTINUOUS
8 MONITORING REGULATIONS
Manual 4 - Source Operating
and Maintenance Procedures
g for Continuous Monitoring Systems
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EPA-340/1-78-005d
RESOURCE MANUAL FOR IMPLEMENTING
THE NSPS CONTINUOUS
MONITORING REGULATIONS
Manual 4 - Source Operating
and Maintenance Procedures
for Continuous Monitoring Systems
by
F. Jaye, J. Steiner, and R. Larkin
Acurex Corporation/Aerotherm Division
485 Clyde Avenue
Mountain View, CA 94042
Contract No. 68-01-3158
EPA Project Officer: Louis Paley
Division of Stationary Source Enforcement
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Research Triangle Park, North Carolina 27711
April 1978
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STATIONARY SOURCE ENFORCEMENT SERIES
The Stationary Source Enforcement series of reports is issued by the Office
of General Enforcement, Environmental Protection Agency, to assist the
Regional Offices in activities related to enforcement of implementation
plans, new source emission standards, and hazardous emission standards to
be developed under the Clean Air Act. Copies of Stationary Source
Enforcement reports are available - as supplies permit - from the U.S.
Environmental Protection Agency, Office of Administration, Library
Services, 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 22161.
REVIEW NOTICE
This report has been reviewed by the Division of Stationary Source
Enforcement and approved for publication. Approval does not signify
that the contents necessarily reflect the views and policies of the
Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for
use.
n
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TABLE OF CONTENTS
Section Page
A INTRODUCTION 4-1
B REGULATIONS 4-1
C OPERATION AND MAINTENANCE PROCEDURES 4-2
1. Trained Personnel 4-2
2. Commitment to Get and Keep the Device Operating
Properly 4-3
3. Spare Parts and Supplies 4-3
4. Supporting Equipment 4-4
5. Access to Expert "Advice 4-7
6. Followup to Maintenance Problems 4-7
7. Periodic Review and Resolution of Problem Areas . . 4-7
D OPERATION CHECKS OF THE MONITORING SYSTEM 4-8
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A. INTRODUCTION
Manual 4 of the "Resource Manual for Implementing the NSPS Continuous
Monitoring Regulations" is written to help the Agency provide technical
advice or assistance to the sources and acquaint agency personnel with good
maintenance and operating practices. As has been pointed out in previous
Manuals in this series, proper maintenance and operation of the monitoring
system by the source is a critical factor in an effective monitoring program.
As the Agency implements a widespread continuous monitoring program, one of
the major tasks will be to educate source operators to maintain and operate
monitoring systems correctly. This Manual will familiarize the observer
with the Regulations as they relate to maintenance, with key components of
a sound maintenance program and with required and otherwise helpful
operational checks.
Other Manuals in the "Resource Manual for Implementing the NSPS
Continuous Monitoring Regulations" are:
Manual 1 Source Selection and Location of Continuous Monitoring
Systems
Manual 2 Preliminary Activities for Continuous Monitoring System
Certification (Installation, Notification and Performance
Evaluations)
Manual 3 Procedures for Agency Evaluation of Continuous Monitor Data
and Excess Emission Reports
B. REGULATIONS
The regulations generally require a source owner or operator to
install, calibrate, operate and maintain a monitoring system suitable for
that particular facility. Monitor systems are also required to be checked
for zero and calibration at least daily. However, other than this rather
general requirement, there are no specific requirements concerning how or by
what procedures a source should operate or maintain its equipment. However,
a good monitoring program cannot be conducted without a minimum of regular
maintenance and sound operating procedures.
4-1
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C. OPERATION AND MAINTENANCE PROCEDURES
Several key factors will determine the effectiveness of maintenance
procedures -- and ultimately the effectiveness of the monitoring system
itself.
The major factors in an effective maintenance program are:
• Trained personnel
• Commitment to keep the system operating properly
• Spare parts
• Supporting equipment
t Access to expert advice
t Followup to maintenance problems
• Periodic review and resolution of problem areas
1. Trained Personnel
Personnel can be trained in several ways. The usual procedure is to
cross-train source employees as measurement equipment technicians. At
least one of the employees should have several years of electronic mainten-
ance experience and be familiar with such process measurement equipment as
pressure transducers, flowmeters, and strip chart recorders. The other
employee should have a working knowledge of valves, sample piping, pumps,
filters, etc. In most cases, it is unlikely that a plant mechanic or
electrician can be cross-trained to do all maintenance and repair on a
continuous monitoring system effectively.
Sources that do not employ skilled instrumentation maintenance
personnel usually have some sort of on-call and periodic maintenance contract
with the nearest vendor's field office or another company that specializes
in this kind of service. Under these circumstances, in-house personnel only
need to be trained to recognize whether the monitor is operating or not. A
major advantage of this type of arrangement for the source is that the
service vendor can be held responsible for supplying replacement parts. For
the Agency, however, this shared responsibility may complicate any enforce-
ment action that it might wish to take.
4-2
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The major drawback of contract maintenance service is response time.
It will frequently take several days to get the maintenance contractor out
to the source and get the monitoring systems running right. Since the
Agency only requires data summaries on a quarterly basis, the absence of
4 or 5 days' data is normally not catastrophic. However, if the system
continues to be unreliable and has frequent downtime, the total amount of
data obtained may not be adequate to assess the effectiveness of the source's
emission control program. This may not be a serious problem for a source
whose emission records show a very steady, well controlled operation that
is generally within the emission limitation. But for sources that frequently
exceed the standards or have a difficult time controlling their facilities
or their pollution control equipment, the Agency should consider taking
corrective action.
2. Commitment to Get and Keep the Device Operating Properly
One of the major problems facing the local Agency will be creating a
real commitment on the part of the source for keeping the monitoring system
operating correctly. The source owner, the operator, and all involved
personnel must ultimately be convinced that it is in their best interest to
keep the system operating. Once the basic commitment is there, the rest is
largely education and practice.
3. Spare Parts and Supplies
Whoever is responsible for maintaining the monitor should have a ready
supply of spare parts, as well as tools and support equipment. The spare
parts required are generally specified to some extent by the equipment
vendor. At the minimum, the ready supply should include chart paper, spare
pens or ink, a box of four or five spare fuses of each type and size used in
the equipment, a box of nuts, bolts, alien screws, and other screws of the
sizes used, spare air and sample filters, calibration or other gas fittings,
and any other fittings which are frequently connected and disconnected.
Instrument spares should include a spare light source for UV, visible, or
opacity monitors, and a spare infrared source of each type used.
4-3
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With solid state equipment, the replaceable electronic modules are
larger, so that it may not be economical to stock them as spares. However,
solid state equipment should be more reliable, so that the primary spare
parts requirements should come from the mechanical portions of the system.
The requirements for spare parts should be reviewed periodically to
determine which problems occur most frequently and how long replacement/
repair takes. Any part that needs to be replaced routinely as part of normal
operation should be stocked. Parts that do not normally need to be replaced
except once every 2 to 3 years probably do not need to be kept on hand.
Price and delivery time are other factors to consider. There is no part-
icular advantage to stock up nonroutine items that can be obtained in 24 to
48 hours from the vendor.
The last major considerations that affect parts stocking are relia-
bility and mean time to failure. If a system has six valves with an oper-
ating life of 20,000 hours (2.2 years of continuous use), the source can
expect to replace one of these valves every 4-1/2 months. One valve,
therefore, should probably be kept in stock. At the same time, a typical
analyzer has a mean time between failures of 2500 hours. This means that
some type of failure that will cause downtime can be expected at least every
2 months.
If each repair takes 1 week for diagnosis, parts delivery, and repair,
the effectiveness of the system will be 88 percent maximum, assuming that no
other data losses occur. Since we can assume that additional data losses
will normally happen, it will not take many failures, data losses, or extended
repair times to reduce the effectiveness level of the monitoring system
to 60 percent or lower. In this event, the Agency must decide whether this
level of effectiveness and quality of data is enough for adequate environ-
mental protection, or if back-up parts and systems should be required.
4. Supporting Equipment
The support equipment required by different types of monitoring
equipment varies widely according to the operating principle involved.
4-4
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All monitoring systems require a good mechanical tool kit with
wrenches, screwdrivers, alien wrenches, etc. Since most monitors have a
number of small nuts, bolts, or screws, a good maintenance kit also includes
jeweler's screwdrivers, small needle-nose pliers, and other equipment useful
for working with very small parts.
Several electronic hobby companies and electronic supply houses have
packaged $200 to $300 tool assortments that have all the small tools, inspec-
tion mirrors, soldering equipment, etc. required for monitoring system main-
tenance. One of these tool kits is a good initial investment in supporting
equipment.
For electrical troubleshooting, a good instrumentation multimeter,
either digital or analog, is recommended. As a rule, the multimeter used
by the plant electrician in working with 440-volt, 3-phase, 100-amp power
circuits will not be particularly useful in servicing the monitoring sytem.
Good, general purpose multimeters can be obtained for about $100 and up.
Portable multimeters with battery power packs can be very useful. Most
monitoring system instruction manuals will suggest measurement equipment
for their particular monitors.
Supporting equipment also includes the calibration materials required
for the daily zero and calibration check. Extractive monitoring systems
will require both zero and calibration gases. With the exception of the
oxygen monitors, the ambient air can serve as the simplest source of a
sample stream containing "zero" pollutant. In most cases an S02 monitor
will be calibrated at 1000 or 1500 ppm, so 0.5 ppm of S02 in the air will
not affect accuracy. Greater accuracy can be obtained by running the air
through an activated charcoal filter. Most calibration gas vendors can
also supply bottles of zero gas. In general, however, this precaution is
not required.
For an oxygen monitor, the base (and least expensive) zero gas is a
bottle of commercially pure nitrogen gas, which can be readily obtained with
less than 0.1 percent oxygen from almost any vendor. This zero gas is
perfectly usable to "zero" any other monitors in the system, so it is not
4-5
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necessary to have two zero gas systems. However, if a sensitive (1 to 5
ppm) hydrocarbon monitor is included in the system, water or liquid pumped
nitrogen must be used. Sources should not accept oil pumped gases.
Calibration gases are readily available from a number of vendors.
The source can either buy certified gases from vendors or perform reference
method tests to verify the calibration gas mixtures. EPA is working with
NBS and the gas-producing companies to establish a traceability and relia-
bility program for stationary source calibration gases. In purchasing
vendor-certified gases, it would be wise to deal with vendors of known
reliability until EPA's traceability program is completed and operational.
For those sources wishing to provide their own gas analysis, less expensive
gases may suffice.
Calibration gases must be rechecked every 6 months. But unless
gases are bought in quantity, a typical cylinder of calibration gas will be
used up in less than 6 months, so that the recheck requirements may be
unnecessary.
As a general rule, it is not effective to mix several pollutants
into one calibration gas. This procedure is usually more costly, makes
analysis more difficult, and adds to the uncertainty of the usable lifetime
of the mixture. The source should be advised to use individual calibration
gases
Performance Specification 2 specifies the calibration gas require-
ments for various pollutants. Ambient air may be used to calibrate oxygen
monitors.
In situ monitors, including opacity monitors, do not have a common
external source of zero or calibration concentrations. Zero and calibration
functions are usually built into these monitors by the manufacturers. Most
vendors supply some type of calibration cell or filter which will produce
defined upscale reading for checking calibration. The zero check is
generally an artificial one, since a true zero reading can only be obtained
when the source is inoperative.
4-6
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5. Access to Expert Advice
No matter how proficient the source's personnel may become in oper-
ating and maintaining their equipment, there will come a day when a malfunc-
tion has them stumped and outside help will be needed to solve the problem.
In most cases, the source will go to the original vendor for assistance,
but the source of help is unimportant as long as the system is back online
in a reasonable time. What the observer should ask is whether or not the
source has specific guidelines and procedures to follow if a serious mal-
function occurs. Do the maintenance people know how and from whom to get
help? Have they set up the necessary contract/purchasing agreements so they
can get help quickly?
6. Followup to Maintenance Problems
In any complex industrial facility, equipment failures and maintenance
are an expected cost of doing business. The prudent plant engineer maintains
records on the maintenance requirements of each machine. One file is a
short-term reminder to check with his technicians about the cause of the
last breakdown and the repairs required to fix it. When examining causes,
the engineer should ask whether the failure is a random failure, one caused
by some controllable stress, or one due to a design or installation problem.
For example, an infrared light source should have a life of about 5000 hours
under normal conditions. At a 10-percent higher line voltage, the life may
by 50 percent shorter. Keeping accurate records of the maintenance performed
throughout the plant will make it possible to identify these kinds of
problems.
7. Periodic Review and Resolution of Problem Areas
Periodic review of maintenance problems is also very important.
Records for a year or more should be examined to pinpoint trouble spots. For
example, if a part that should last for a year or two is replaced twice with-
in a year, it may well be because of misapplication or faulty installation
rather than a defective part. Problems of misapplication generally call for
solution by an engineer, as opposed to the maintenance technician or his
4-7
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foreman. These problems may be solved by use of different components or
procedures, or may require major capital equipment changes.
D. OPERATION CHECKS OF THE MONITORING SYSTEM
According to regulation requirements, the source operator must perform
zero and calibration checks on the monitoring system at least once each
24-hour period. If the unit is beyond the required 2 percent tolerance --
uncorrected by data adjustment -- the operator must adjust the unit until it
is within the limits and note this in his log. If he cannot make the adjust-
ment, the normal course of action is to call the maintenance man. This
decision is relatively easy -- the system is either working or not working.
However, there are a number of malfunctions, both large and small,
that may not be detected by the zero and calibration procedure. These
malfunctions will either invalidate the data or cause the equipment perform-
ance to degrade rapidly leading to complete failure. For example, a leak in
a sample extraction line which, because of a large stack filter pressure
drop, pulls in outside air and dilutes the sample, may give a low reading
that invalidates the data. If an oxygen or CO^ monitor uses the same sample
line, this leak may be indicated by very high or low Oo to COo readings. A
simple $30 pressure-vacuum gage on the sample line will also detect this
problem.
An example of a malfunction that may degrade the performance of the
monitoring system is the failure of a window purge air blower on an opacity
or in situ gas monitor. The failure of the blowers, the clogging of a
filter, or a hose kink that cuts down the purge airflow will allow the
particulate or, possibly, condensible gases in the stack to deposit on the
optical windows and cut down the light transmission. In an opacity monitor,
this may show up as an increasing baseline emission value or as an inability
to provide sufficient zero adjustment. In a gas monitor, the dirty window
may attenuate the reference and sample light beams badly enough to interrupt
the signal that the detector and electronics needs to operate correctly. In
this case, the unit will become very sluggish and may not respond to source
changes.
4-8
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A unit that is out of zero or calibration gas or whose internal
calibration and zero check cells and filters are inoperative will, of
course, fail to zero or calibrate correctly.
Many of these functions and malfunctions can be readily observed by
the addition of some simple pressure switches or gages. A $30 differential
pressure gage across a fitting or a filter can indicate the presence of
flow in a blower line. A low-pressure drop may signal a broken filter or
a very low flow; a high-pressure drop may mean a clogged filter. Similarly,
a pressure gage on a sample line can show whether a pump is operating
correctly or incorrectly, whether or not valves are correctly positioned, or
whether or not adequate flow of sample, zero, or calibration gas is being
maintained.
It is not necessary that these gages be completely accurate, since,
in most cases, only the fact of an abnormal reading is important, not its
magnitude. If a sample line should be at 4 psig and shows 1 or 7 psig or
even a vacuum, then something abnormal has occurred and should be investigated.
4-9
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
340/1-78-005 d
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Resource Manual for Implementing the NSPS Continuous
Monitoring Regulations. Manual 4 - Source Operating
and Maintenance Procedures for Continuous Monitoring
5. REPORT DATE
April 1. 1978
6. PERFORMING ORGANIZATION CODE
7.
8. PERFORMING ORGANIZATION REPORT NO.
F. Jaye, J. Steiner, R. Larkin
9. PERFORMING ORG \NIZATION NAME AND ADDRESS
Acurex Corporation/Aerotherm Division
485 Clyde Avenue
Mountain View, CA 94042
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-3158
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
EPA Office of Enforcement
Division of Stationary Source Enforcement
Washington, D.C. 20460
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Manual 4 - Source Operating and Maintenance Procedures for Continuous Monitoring
Systems - is one of a series of four manuals that comprise the "Resource Manual
for Implementing the NSPS Continuous Monitoring Regulations." The other manuals are:
Manual 1 - Source Selection and Location of Continuous Monitoring Systems
Manual 2 - Preliminary Activities for Continuous Monitoring System Certification
Installation, Notification and Performance Evaluations)
Manual 3 - Procedures for Agency Evaluation of Continuous Monitor Data and
Excess Emission Reports
Manual 4 provides information on good maintenance and operation practices for
continuous monitoring systems. Purpose of the manual is to familiarize agency
personnel with maintenance requirements of the NSPS regulations, with the key
components of a sound maintenance program and with the required and otherwise
helpful operational checks.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COS AT I Field/Group
Stationary Source
Continuous Emission Monitoring
New Source Performance Standards
Continuous Emission
Monitoring
13 B
14 D
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)'
llnrl a<;<:if ipri
21. NO. OF PAGES
Q
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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