EPA-650/4-74-005-0
March 1976                      Environmental Monitoring Series
                        GUIDELINES FOR DEVELOPMENT
                 OF A QUALITY ASSURANCE PROGRAM:
                         VOLUME XV - DETERMINATION
                        OF SULFUR DIOXIDE EMISSIONS
                          FROM STATIONARY SOURCES
                           BY CONTINUOUS MONITORS
                                                 \
                                                  Ul
                                                  o
                                    Office of Research and Development
                                   U.S. Environmental Protection Agency
                                          Washington, D.C. 20460

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                   RESEARCH REPORTING SERIES


Research reports of the Office of Research and Development,  U.S. Environ-
mental Protection Agency, have been grouped into series . These broad
categories were established'to facilitate further development and applica-
tion of environmental technology.  Elimination of traditional grouping was
consciously planned to foster technology  transfer and maximum interface
in related fields.  These series are:

          1.  ENVIRONMENTAL HEALTH  EFFECTS RESEARCH
          2 .  ENVIRONMENTAL PROTECTION TECHNOLOGY

          3.  ECOLOGICAL RESEARCH
          4.  ENVIRONMENTAL MONITORING

          5.  SOCIOECONOMIC ENVIRONMENTAL STUDIES
          6.  SCIENTIFIC AND TECHNICAL ASSESSMENT REPORTS
          9.  MISCELLANEOUS

This report has been assigned to the ENVIRONMENTAL MONITORING
series. This series describes research conducted to develop new or
improved methods and instrumentation for the identification and quanti-
fication of environmental pollutants at the lowest conceivably  significant
concentrations.  It also includes studies to determine the ambient con-
centrations of pollutants in the environment and/or the variance of
pollutants as  a function of time or meteorological factors.
This document is available to the public for sale through the National
Technical Information Service,  Springfield, Virginia  22161.

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                                      EPA-650/4-74-005-0
    GUIDELINES FOR DEVELOPMENT
OF A  QUALITY ASSURANCE PROGRAM:
     VOLUME XV - DETERMINATION
    OF SULFUR DIOXIDE EMISSIONS
     FROM STATIONARY SOURCES
      BY  CONTINUOUS MONITORS
                     by
                 Pamela Wohlschlegel
                Research Triangle Institute
           Research Triangle Park, North Carolina 27709
                Contract No. 68-02-1234
                  ROAP No. 26BGC
               Program Element No. 1HA327
            EPA Project Officer: Steven M. Bromberg
          Environmental Monitoring and Support Laboratory
            Office of Monitoring and Technical Support
           Research Triangle Park, North Carolina 27711
                   Prepared for
            U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Research and Development
                Washington, D.C. 20460
                   March 1976

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                       EPA REVIEW NOTICE
This report has been reviewed by the Environmental  Monitoring and
Support Laboratory, Research Triangle Park, North Carolina, of the
U. S. Environmental Protection Agency 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 en-
dorsement or recommendation for use.

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                      TABLE OF CONTENTS


                                                          Page


List of Figures                                            iv

List of Tables                                             v

Abstract                                                   vl

1.0  INTRODUCTION                                          1-1

2.0  DETERMINATION OF SULFUR DIOXIDE EMISSIONS             2-1
     FROM STATIONARY SOURCES BY CONTINUOUS MON-
     ITORS

     5.11  Determination of Sulfur Dioxide Emissions       2-2
           from Stationary Sources by Continuous
           Monitors

           5.11.1  Performance Specification 2             2-4
           5.11.2  Plan Activity Matrix                    2-15
           5.11.3  Operational Procedures                  2-25
           5.11.4  Auditing Procedures                     2-75

3.0  FUNCTIONAL ANALYSIS                                   3-1

     3.1  Definition and Discussion of Error Sources       3-3

          3.1.1  In-Situ Monitoring Systems                3-3
          3.1.2  Extractive Monitoring Systems             3-12

LIST OF REFERENCES                                         R-l

Appendixes

A    PERFORMANCE SPECIFICATION 3                           A-l
B    GLOSSARY OF SYMBOLS                                   B-l

C    GLOSSARY OF TERMS                                     C-l
                             Xll

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                      LIST OF FIGURES
Figure                   Description                      Page


5.11.1   Method procedures relationships                   2-16
5.11.2   Operational flow chart                            2-26

5.11.3   Example of an extractive sulfur dioxide           2-43
         monitoring system

5.11.4   Sample data form for the analysis of the          2-53
         calibration gas mixture
5.11.5   Sample log sheet for calibration error            2-54
         test data
5.11.6   Sample data form for operational test             2-56

5.11.7   Sample data form for response time test           2-60

5.11.8   Sample form for data analysis report cal-         2-61
         culations

5.11.9   Sample control chart for use in determin-         2-72
         ing trends in zero drift

5.11.10  Sample operation and maintenance table            2-73

5.11.11  Sample audit data form                            2-78

5.11.12  Block diagram of a typical in-situ monitor-       3-4
         ing system
5.11.13  Block diagram of a typical extractive moni-       3-4
         toring system
5.11.14  Major components of  system errors in an in-       3-6
         situ monitoring system
5.11.15  Major components of system errors in an ex-       3-13
         tractive monitoring system
                             IV

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                       LIST OF TABLES

Table                    Description                     Page

5.11.1  Methods of monitoring variables                  2-14
5.11.2  Values for t __,.                                 2-67

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                         ABSTRACT

     Guidelines for the quality control of the continuous
measurement of sulfur dioxide emissions by Performance
Specification 2 are presented.  These include:
     1.  Good operating practices;
     2.  Directions on how to assess performance and to
         qualify data;
     3.  Directions on how to identify trouble and to im-
         prove data quality;
     4.  Directions to permit design of auditing activities.
     The document is not a research report.  It is designed
for use by operating personnel.
     This work was submitted in partial fulfillment of con-
tract Durham 68-02-1234 by Research Triangle Institute under
the Sponsorship of the Environmental Protection Agency.
Work was completed as of January, 1976.
                              Vl

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1.0  INTRODUCTION
       1-1

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                      1.0  INTRODUCTION

     This document presents guidelines for implementing a
quality assurance program for the measurement of sulfur
dioxide emissions from stationary sources by continuous
monitors.
     The objectives of this quality assurance program are to:
     1.  'Provide routine indications for operating pur-
         poses of satisfactory performance of personnel
    >
         and/or equipment,
     2.  Provide for pirompt detection and correction of
         conditions that contribute to the collection of
         poor quality data,
     3.  Collect and supply information necessary to
         describe the quality of the data.
To accomplish the above; objectives, a quality assurance program
must contain the following components:
     1.  Routine training and/or evaluation of operators,
     2.  Routine monitoring of the variables and/or
         parameters which may have a significant effect
         on data quality,
     3.  Development of techniques to detect defects,
     4.  Development of methods to qualify data,
     5.  Action strategies to increase the level of pre-
         cision in the reported data and/or to detect
         equipment defects or degradation and to correct
         same.
Implementation of a quality assurance program will result in
data that are more preferable in terms of precision and accuracy
and will enable the monitoring network to continuously generate
data of acceptable quality.
                            1-2

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This document is divided into three sections, as follows:
1.   1.0  INTRODUCTION—This section lists the overall objec-
     tives of a quality assurance program and delineates the
     program components necessary to accomplish the given
     objectives.
2.   2.0  DETERMINATION OF SULFUR DIOXIDE EMISSIONS FROM
     STATIONARY SOURCES BY CONTINUOUS MONITORS—This
     section includes the method description, plan
     activity matrix, operational procedures, and
     auditing procedures.  Subsection numbering is con-
     sistent with section 5.11 of a larger document,  The
     Quality Assurance Handbook for Air Pollution Measure-
     ments ,  Volume III, Stationary Sources Specific Methods.
3.   3.0  FUNCTIONAL ANALYSIS—This section includes an
     estimate of the precisions and biases of the various
     measurement components which collectively comprise
     the continuous monitoring method,  and an estimate of
     the total precision and bias of the method.
                       1-3

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2.0  DETERMINATION OF SULFUR DIOXIDE EMISSIONS
     FROM STATIONARY SOURCES BY CONTINUOUS
     MONITORS*
*
  The numbering in this section is consistent with
  section 5.11 of a larger document, The Quality
  Assurance Handbook for Air Pollution Measurements,
  Vol.  Ill—Stationary Sources Specific Methods.
                     2-1

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5.11  DETERMINATION OF SULFUR DIOXIDE EMISSIONS FROM
      STATIONARY SOURCES BY CONTINUOUS MONITORS
      This section describes a quality control/quality assur-
ance program designed specifically to ensure that sulfur
dioxide data generated from continuous stack monitoring systems
is of acceptable quality.  To present the program, the section
has been divided into the following subsections:
           5.11.1  Performance Specification 2,
           5.11.2  Plan Activity Matrix,
           5.11.3  Operational Procedures, and
           5.11.4  Auditing Procedures.
      A reprint of "Performance Specification 2--Performance
Specifications and Specification Test Procedures for Monitors
of SO- and NO  from Stationary Sources" is included in section
     £•       X.
5.11.1 for convenient reference.  The equipment specifications
and procedural guidelines detailed in this quality assurance
document were based on statements made in the Performance
Specification 2.  The scope of this document, however, does
not include discussions concerning oxides of nitrogen monitors
even though they are covered in Performance Specification 2.
Also contained in section 5.11.1 is a block diagram which
delineates the procedures for continuously measuring sulfur
dioxide emissions.
      The Plan Activity Matrix in section 5.11.2 includes the
characteristic checks for each of the operating procedures.
The operating procedures themselves are described in some de-
tail in section 5.11.3.  The audit procedures described in
section 5.11.4 provide a basis for assessing the performance
in each operational category.
      The method described in this document for the measure-
ment of sulfur dioxide emissions can be broken down into the
                            2-2

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following series of operational categories:
     1.  Definition of monitoring requirements and system
         hardware,
     2.  Installation and testing,
     3.  Preventive maintenance and routine testing.
Within each category both routine and nonroutine procedures
are required.  The routine procedures form the basic criteria
for monitoring sulfur dioxide at a given stack and obtaining
data.  The nonroutine procedures provide characteristic checks
for each of the routine procedures to insure that valid data
will be ultimately collected from the system and to properly
assess the quality of that data.  Such nonroutine procedures
are elements of an internal quality assurance or quality con-
trol program.  The audit procedures are elements of an exter-
nal quality assurance program (sometimes referred to simply
as quality assurance).  The purpose of section 5.11 is to
provide the user with guidelines for developing quality con-
trol and quality assurance programs for a given source mon-
itoring system.
                            2-3

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5.11.1  Performance Specification
             PERFORMANCE SPECIFICATION 2—PERFORMANCE

             SPECIFICATIONS AND SPECIFICATION TEST PRO-

             CEDURES FOR MONITORS OF SOO AND NO  FROM
                               *
             STATIONARY SOURCES
     Reproduced from Appendix B, "Performance Specifications,"

of 40 CFR Part 60, Federal Register, Volume 40, Number 194;

Monday, October 6, 1975.
  Only the determination of sulfur dioxide  (SO2) emissions
  by continuous monitors are discussed in this quality
  assurance document.
                            2-4

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5.11.1.1    Principle  and  Applicability
                    1. Principle and Applicability.
                    1.1  Principle. The concentration or sulfur
                 dioxide or oxides of nitrogen pollutants In
                 stack emissions is measured by a continu-
                 ously operating emission measurement sys-
                 tem. Concurrent with operation of the con-
                 tinuous  monitoring  system, the pollutant
                 concentrations are also measured with refer-
                 ence methods (Appendix A). An average of
                 the continuous monitoring system data is
                 computed for each reference method testing
                 period and compared to determine the rela-
                 tive accuracy of the continuous monitoring
                 system. Other tests of the continuous mon-
                 itoring system  are also performed  to deter-
                 mine  calibration- error,  drift, and response
                 characteristics of the system.
                    1.2  Applicability. This performance spec-
                 ification is applicable to evaluation of con-
                 tinuous monitoring systems for measurement
                 of nitrogen oxides or sulfur dioxide pollu-
                 tants. These specifications contain test pro—
                 cedures, installation requirements, and data
                 computation  procedures for evaluating the
                 acceptability of the continuous monitoring
                 systems.
5.11.1.2   Apparatus
                   2. Apparatus.
                   2.1  Calibration Gas Mixtures. Mixtures of
                 known concentrations of pollutant gas in a
                 diluent gas shall be prepared. The pollutant
                 gas shall be sulfur dioxide or the appropriate
                 oxide(s) of nitrogen specified by paragraph
                 6 and within subparts. For sulfur dioxide gas
                 mixtures, the diluent gas may be air or nitro-
                 gen. For nitric oxide (NO) gas mixtures, the
                 diluent gas shall be oxygen-free «10 ppm)
                 nitrogen, and for nitrogen dioxide (NO,) gas
                 mixtures the diluent gas shall be air. Concen-
                 trations of approximately 50 percent and 90
                 percent of span are required. The 90 percent
                 gas mixture Is used to set and  to check the
                 span and Is referred to as the span gas.
  2.2 Zero Gas. A gas certified by the manu-
facturer to contain less than 1 ppm of the
pollutant gas or ambient air may be-used.
  2.3 Equipment for measurement of the pol-
lutant gas concentration using the reference
method specified in the applicable standard.
  2.4 Data Recorder. Analog chart recorder
or other suitable device with Input voltage
range compatible with  analyzer system out-
put. The resolution of the  recorder's data
output shall be sufficient to allow completion
of the test procedures within this specifi-
cation.
  2.5 Continuous monitoring system for SO,
or NO* pollutants as applicable.
5.11.1.3    Definitions
                    3. Definitions.
                    3.1 Continuous Monitoring System. The
                  total equipment required for the determina-
                  tion of a pollutant gas concentration ln_ a
                  source effluent. Continuous  monitoring sys-
                  tems consist of major subsystems as follows:
                    3.1.1 Sampling  Interface—That portion of
                  an extractive continuous monitoring system
                  that performs one or more of the  following
                  operations:  acquisition, transportation, and
                  conditioning of a sample of  the source efflu-
                  ent or that  portion of an in-situ continuous
                  monitoring  system that protects the analyzer
                  from the effluent.
                    3.1.2 Analyzer—That portion of  the con-
                  tinuous monitoring system which senses the
                  pollutant gas and generates a signal output
                  that is a function of the  pollutant concen-
                  tration.
                    3.1.3 Data Recorder—That portion of the
                  continuous  monitoring system that provides
                  a permanent record of the output signal In
                  terms of concentration units
  3.2 Span. The value of pollutant concen-
tration  at which the continuous  monitor-
ing system Is  set to produce the maximum
data display output. The span shall be set
at the concentration specified In each appli-
cable subpart.
  3.3 Accuracy  (Relative).  The degree  of
correctness  with  which   the  continuous
monitoring system  yields the value of  gas
concentration  of a sample  relative to  the
value given by a defined reference method.
This accuracy  is expressed in terms of error,
which is the  difference  between the paired
concentration  measurements  expressed as a
percentage of  the mean reference value.
  3.4 Calibration'Error.  The  difference be-
tween  the pollutant  concentration  indi-
cated by the continuous monitoring system
and  the  known concentration of  the test
gas mixture.
  3.5 Zero Drift. The change in the continu-
ous monitoring system output over a stated
                                                  2-5

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5.11.1.3    Definitions   (continued)
                 period of time of normal continuous opera-
                 tion when the pollutant  concentration at
                 the time for the measurements Is zero.
                   3 6  Calibration  Drift.  The change in the
                 continuous monitoring system output over
                 a stated time  period of normal continuous
                 operations  when  the  pollutant concentra-
                 tion at the time of the measurements Is the
                 same known upscale value.
                   3 7  Response  Time.  The  time  interval
                 from  a step change In pol'utant concentra-
                 tion at the input to the continuous moni-
                 toring system to the time at which 95 per-
                 cent  of  the  corresponding  final  value Is
 reached  as displayed on  the  continuous
 monitoring system data recorder.
   3.8 Operational Period. A minimum period
 of time over which a measurement system
 is expected to  operate within certain  per-
 formance  specifications  without unsched-
 uled  maintenance, repair, or adjustment.
   3.9 Stratification. A condition identified
 by a difference In excess of 10 percent be-
 tween the average concentration  In the  duct
 or stack and the concentration at any point
 more than 1.0 meter from the duct or stack
 wall.
5.11.1.4    Installation  Specifications
                   4. Installation  Specifications.  Pollutant
                  continuous monitoring systems  (SO,  and
                  NOX) shall be installed at a sampling loca-
                  tion whare measurements can be made which
                  are directly representative  (4.1), or which
                  can be corrected so as to  be  representative
                  (4.2) of the total emissions, from the affected
                  facility. Conformance  with this requirement
                  shall be accomplished as follows:
                   4.1 Effluent gases may be  assumed to be
                  nonstratifled if a sampling; location  eight or
                  more stack diameters (equivalent diameters)
                  downstream of  any  air in-leakage is  se-
                  lected. This assumption and data correction
                  procedures under paragraph 4.2.1 may not
                  be  applied to  sampling locations upstream
                  of an air preheater in a stream generating
                  facility under Subpart D of this part. For
                  sampling locations where effluent gases  are
                  either demonstrated  (43)  or may be  as-
                  sumed to be nonstratified (eight diameters),
                  a point (extractive systems) or path  (in-sltu
                  systems)  of average concentration  may be
                  monitored.
                   4.2 For sampling locations where  effluent
                  gases cannot be assumed to  be nonstrati-
                  fied (less than eight diameters) or have been
                  shown under paragraph 4 3 to be stratified,
                  results obtained must be consistently repre-
                  sentative (e.g. a point of e.verage concentra-
                  tion  may shift  with  load changes) or the
                  data  generated by sampling at a point  (ex-
                  tractive  systems) or across a path  (in-situ
                  systems) must be corrected (4.2.1 and 4 2.2)
                  so as to  be representative of the total- emis-
                  sions from the  affected facility. Conlorm-
                  ance  with this requlremert may be accom-
 plished in either  of  the  following ways:
   4.2.1 Installation of a diluent continuous
 monitoring system (O» or CO, as applicable)
 in accordance with  the  procedures  under
 paragraph 4.2 of  Performance  Specification
 3 of this appendix.  If the pollutant  and
 diluent monitoring systems are not of the
 same tvpe (both extractive or both. In-sltu),
 the extractive system must use  a multipoint
 probe.
   4 2.2 Installation of  extractive  pollutant
 monitoring systems using multipoint sam-
 pling probes  or in-situ pollutant monitoring
 systems that sample or view emissions which
 are consistently representative of the. total
 emissions for the entire  cross  section.  The
 Administrator may require  data to be sub-
 mitted to demonstrate  that the  emissions
 sampled  or viewed are consistently  repre-
 sentative  for several typical facility process
 operating conditions.
   4.3 The owner or operator may perform a
 traverse to characterize any stratification of
 effluent gases that might exist in a stack or
 duct. If no stratification is present, sampling
 procedures under paragraph 4.1  may be ap-
 plied even though the eight diameter criteria
 is not met.
  4 4 When single point sampling probes for
 extractive systems  are Installed  within the
 stack or duct  under paragraphs 4.1 and  4.2.1,
 the sample may not be extracted at any point
 less than  1.0  meter from the stack or  duct
 wall. Multipoint  sampling probes  installed
 under paragraph 4.2.2 may  be located at any
points necessary to obtain  consistently rep-
resentative samples.
5.11.1.5   Continuous  Monitoring  System  Performance  Specifications


                  5. Continuous Monitoring System Perform-
                  ance Specifications.
                    The continuous monitoring system shall
                  meet the performance specifications in Table
                  2-1  to be .considered acceptable under  this
                  method.
                                                 2-6

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5.11.1.5    Continuous  Monitoring   System  Performance   Specifications
                                         TABLE  2-1.—Performance specification.*!
                                    Parameter
                                                                             Specification
                  1 Accuracy '                   ---    	 ~^0 pet of the mean value nf the reference method test
                         "" 	~       "   "                       daia
                  2. Calibration error '	
                           		  ...  .. _  < spot of each (50 pet, U0 pet) calibration gas mixture
                                              value.
3. Zero drift (2 h) i			  2 pet of span
4. Zero drift (24 h) 1			-	---  ---     Do.
5. Calibration drift (2 h) 1..	-	---  ---     Do
6. Calibration drift (24 h) i	-  	  2.5 pet  of span
7. Kesponso time			----	  15 nun maximum
8 Operational period.			-  168 h minimum.
                   i Expressed as sum of absolute mean value plus 95 pet confidence interval of a series of tests
5.11.1.6    Performance   Specification  Test  Procedures
                    6. Performance  Specification  Test  Proce-
                  dures. The following test procedures shall be
                  used  to  determine conformance with  the
                  requirements of paragraph 5.  For NOX  an-
                  requirements of paragraph 5.  For NCK  an-
                  alyzers that oxidize  nitric oxide  (NO)  to
                  nitrogen  dioxide  (NO2), the response time
                  test under paragraph 6.3 of this method shall
                  be performed using nitric oxide (NO) span
                  gas. Other tests for NO« continuous monitor-
                  Ing systems under paragraphs 6.1 and 6.2 and
                  all tests for sulfur dioxide systems shall be
                  performed using the pollutant span gas spe-
                  cified by each subpart.
                    6.1 Calibration  Error Test Procedure.  Set
                  up and calibrate  the complete  continuous
                  monitoring system according to the manu-
                  facturer's writen  instructions.  This may be
                  accomplished either In the  laboratory or In
                  the field.
                    6 1.1  Calibration Gas  Analyses, Triplicate
                  analyses of the gas mixtures shall be  per-
                  formed within  two weeks prior to use using
                  Reference Methods 6 for SO, and 7 for NO,.
                  Analyze each calibration gas mixture (50%,
                  90 %,) and record the results on  the example
                  sheet shown in Figure 2-1  Each sample test
                  result must be within 20 percent of the aver-
                  aged  result or  the tests shall  be repeated.
                  This step  may be omitted for non-extractive
                  monitors where dynamic calibration gas mix-
                  tures are  not used (6.1.2).
                    6.1.2  Calibration Error  Test  Procedure.
                  Make a total of 15 nonconsecutive measure-
                  ments by alternately using zero  gas and each
                  caliberatlon gas mixture concentration (e.g.,
                  0%, 50%, 0';",  90%,  50%, 90%, 50%, 0%,
                  etc ). For nonextractive continuous monitor-
                  ing systems, this test procedure may be per-
                  formed  by using two or more calibration gas
                  cells whose concentrations are  certified by
                  the manufacturer to be functionally equiva-
                  lent to these gas concentrations.  Convert the
                  continuous monitoring system output read-
                  ings to ppm and record the results on the
                  example sheet shown In Figure 2-2.
                    6.2 Field  Test for  Accuracy  (Relative),
                  Zero Drift, and  Calibration Drift. Install and
                  operate the continuous monitoring system In
                  accordance with the manufacturer's written
                  instructions and drawings as follows:
                    6.2.1 Conditioning Period  Offset the zero
                  setting  at least 10 percent  of  the span so
                  that negative zero drift can be quantified.
                  Operate the system for an initial 168-hour
                  conditioning  period in  Formal  operating
                  manner.
                   6 2.2 Operational Test Period  Operate the
                 continuous monitoring system for an  addi-
                                              tional  168-hour period  retaining  the  zero
                                              offset The system shall monitor the source
                                              effluent  at  all  times  except when  being
                                              zeroed, calibrated, or backpurged.
                                                6 2.2.1 Field  Test for Accuracy  (Relative).
                                              For continuous monitoring systems employ-
                                              ing extractive sampling, the probe tip for the
                                              continuous monitoring system and the probe
                                              tip for the Reference Method sampling train
                                              should be  placed at adjacent locations In the
                                              duct.  For  NOX continuous monitoring sys-
                                              tems,  make 27 NOX concentration measure-
                                              ments, divided Into nine sets, using the ap-
                                              plicable reference method. No more than one
                                              set of tests, consisting of three Individual
                                              measurements,  shall be performed In  any
                                              one hour. All  Individual  measurements of
                                              each set  shall  be performed concurrently,
                                              or within  a three-minute  interval and the
                                              results averaged. For SO2 continuous moni-
                                              toring systems, make nine SO2 concentration
                                              measurements using the applicable reference
                                              method.  No more than one  measurement
                                              shall be performed In any  one hour. Record
                                              the reference method test data and the  con-
                                              tinuous  monitoring  system concentrations
                                              on the example data sheet shown in Figure
                                              2-3.
                                                6.2 2.2 Field Test for Zero Drift  and Cali-
                                              bration Drift. For extractive systems, deter-
                                              mine the  values given by zero and span gas
                                              pollutant  concentrations at two-hour Inter-
                                              vals until  15 sets of  data are  obtained. For
                                              nonextractive measurement systems, the zero
                                              value  may be  determined  by mechanically
                                              producing  a  zero condition that provides a
                                              system check of the analyzer Internal mirrors
                                              and all electronic circuitry  including the
                                              radiation  source and detector assembly or
                                              by Inserting three or more calibration  gas
                                              cells and computing the zero point from the
                                              upscale measurements.  If  this latter tech-
                                              nique  is used,  a graph(s) must be retained
                                              by the owner or operator for each  measure-
                                              ment system that shows the relationship be-
                                              tween  the upscale measurements  and the
                                              zero point. The span  of the system shall be
                                              checked by using a calibration gas cell  cer-
                                              tified by the manufacturer to be function-
                                              ally equivalent to 50 percent of span concen-
                                              tration Record the zero and span  measure-
                                              ments (or  the computed zero  drift)  on the
                                              example data sheet shown in Figure  2-4.
                                              The  two-hour periods over which  measure-
                                              ments are  conducted need not be consecutive
                                              but may not overlap  All measurements  re-
                                             quired under this paragraph  may  be  con-
                                             ducted concurrent  with  tests under para-
                                             graph 6.2.2.1.
                                                   2-7

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5.11.1.6    Performance  Specifications  Test  Procedures  (continued)
                                                        Reference ''etriod Used
                                         ti^h-gange (span| Calibration Gas Mixture
                                         SiTple J 	pprc
                                         Sample Z	ppnt
                                         Sarple 3	ppm
                                         Average     _ppn
                                        Flgars 2-1. Analysis of CaHbratlon Gas
                                        RULES AND REGULATIONS
                            Calibration Gas Mixture Data (From Figure  2-1)
                            Mid  (50%) 	ppm       High (90%) 	ppm
         Calibration Gas
Run  #    Concentration,ppm
                                             Measurement System
                                               Reading, ppm	
                                  Differences,  ppm
                 10
                 11
                 12
                 13
                 14
                 15
                 Mean difference
                 Confidence interval
                 Calibration error =
                                                                            Mid    High
	Pean Difference  + C.I.	x 100
Average Calibration Gas Concentration        	I
                  Calibration gas concentration - measurement system reading
                 >
                 "Absolute value
                                   Figure 2-2.  Calibration Error Determination

-------
5.11.1.6    Performance  Specifications  Test  Procedure  (continued)
Test
Ho.
1
2
3
4
E
6
7
8
9
lean
test
lean
;bK C
\ccur
• Exp
" Mi
Date
and
Time









reference IT
value (S02
differences
onf idence
,,.r, - He
Reference Method Samples
so
Sample 1
(ppm)









ethod
** =
ntervals - «
Sampfe 1
(ppm)










+
NO
Sample 2
(ppii)









NO
Sanpfe 3
(ppm)









M3 Sa-npl e
Average
(ppm)









Mean reference method
test value (NO )
ppm (SO,), s
ppm
Analyzer 1-Hour
Average (ppm)*
SO, N0x

















D1 f ference
(ppm)
S02 N0x








1
Average of
the differences










ppm (NO..).
(50,). " *
an difference {absolute va ue) * 95% confidence Interval 1nn
Jcc' Mean reference method value " '"" -
lain and report method used to determine integrated averages.
an differences = the average of the differences minus the mean reference meth
ppm (NO ).
	 X {S02), » 	 « (NOX).
od test value.
                                   Figure 2-3. Accuracy Determination (SO^ and NOX)
                                                  Zero              Span      Callo'-c'tlon
                         Time             Ze-o      Drift     Sps-.      Drift        CrUt
                       Begin   End    Ca'.e    Feadlng    ('.Zero)   RejO'r-g     (tSpan)     ( S?=n- Ze'o)
                 Zero Dr~iff~=~ {Mean Zero Drift*	
                 Cal ib-'iition Crift - [.Xedn Span T5~nt't"'r~
   x 100 = 	
-! [Spa"] x 100 = .
                                 Figure 2-4.  Zero and" Calibration Drift (2 Hourp
                                            2-9

-------
5.11.1.6    Performance  Specification  Test  Procedures   (continued)
                   6.2.2.3 Adjustments. Zero and  calibration
                 corrections and adjustments are allowed only
                 at 24-hour Intervals or  at such  shorter  In-
                 tervals as the manufacturer's written  In-
                 structions  specify.  Automatic  corrections
                 made by the measurement system without
                 operator Intervention or initiation are allow-
                 able at any time. During the entire 168-hour
                 operational test period, record on the  ex-
                 ample sheet shown In Figure 2-5 the values
                 given by zero and span gas pollutant con-
                 centrations before and after adjustment at
                 24-hour Intervals.
                   6.3 Field Test for Response Time.
                   6 3.1 Scope of Test. Use the entire continu-
                 ous monitoring system as Installed, including
                 •sample transport  lines  If  used.  Flow rates,
                 line diameters, pumping rates,  pressures  (do
                 not allow  the pressurized calibration gas to
                 change the normal operating pressure In  the
                 sample line), etc., shall be at the nominal
values for normal operation as specified in
the manufacturer's written instructions. If
the analyzer Is used to sample more than one
pollutant source (stack), repeat this test for
each sampling point.
  6.3.2 Response  Time Test Procedure. In-
troduce zero gas into the continuous moni-
toring system sampling interface or as close
to the sampling Interface as possible. When
the system output  reading has  stabilized,
switch quickly to a known concentration of
pollutant gas. Record the time  from concen-
tration switching to 95 percent  of final stable
response. For non-extractive monitors, the
highest available calibration gas concentra-
tion shall be  switched into and out of the
sample path  and response  times  recorded.
Perform  this  test sequence three  (3) times.
Record the  results of  each  test  on the
example  sheet shown In Figure 2-6.
                      Date                      Zero                 Span           Calibration
                      and            Zero       Drift               Reading             Drift
                      Time        Reading     (AZero)      (After  zero  adjustment)    (ASpan)
                     Zero  Drift = [Mean Zero Drift*
  C.I.  (Zero)  	
                                      •i [Instrument Span] x  TOO  =

                     Calibration Drift = [Mean Span Drift*	
          +  C.I.  (Span)
                                      « [Instrument Span] x TOO  =
                       Absolute value
                                     Figure 2-5.  Zero and  Calibration Drift (24-hour)
                                               2-10

-------
5.11.1.6    Performance  Specification  Test  Procedures  (continued)
Date of Test

Span Gas Concentration
Analyzer Span Setting
Upscale
Average
Downscale

1
2
3
upscale
1
2
3
	 ppir.
ppm
seconds
seconds
seconds
response seconds
seconds
seconds
seconds
Average downscale response seconds
System average response time (slowe
^deviation from slower _ (averaoe
system average response

r time) = seconds.
upscale minus average downscale x ^gg, _
slower time \ 	
                                       Figure 2-6.  Response Time
5.11.1.7    Calculations,   Data  Analysis,  and  Reporting
                   7. Calculations, Data Analysis and Report-
                 ing.
                   7.1 Procedure  for determination of mean
                 values and confidence intervals.
                   71.1 The mean value  of  a data set is
                 calculated  according to equation 2-1.

                                   1 X r

                                  n  i=1     Equation  2-1
                 where:
                   xt=: absolute value of the measurements,
                   S = sum of the individual values,
                   x = mean value, and
                   n = number of data points.
                   712 The 95 percent confidence interval
                 (two-sided) Is calculated according to equa-
                 tion 2-2-
                             f      t	^	

                            n\/n—T
                                            Equation 2-2
                 where:
                    £x, = sum of all data points,
                    t975 = ti-a/2, and
                   C 1.95 = 95 percent confidence interval
                         estimate  of the  average mean
                         value.
                             Values for '.975
                           10
                             .
                           13 .........
                           14 ________
                           15 ........ _
                           16..
975
706
303
182
776
571
447
365
306
262
228
201
179
160
145
131
   The values  in this table are already cor-
 rected for n-1 degrees of freedom  Use n
 equal to the number of samples as data
 points.
   7 2  D:ita Analysis and Reporting
   721   Accur.icy (Relative) . For each of the
 nine le'crence method test points, determine
 tho average pollutant concentration reported
 by the continuous monitoring system. These
 average  concentrations shall be determined
 fioiu the continuous monitoring system data
 recorded under 722 by integia'ing or aver-
 amn^' the pollutant concentrations over each
 ot  the time intervals concurrent with each
 reference method  testing period Before pro-
 ceeding to the next step, determine the basis
 (wet  or  dry) or the continuous monitoring
 sjstem data and icference method test data
 concentrations. If the  bases  are  not  con-
 sistent, apply a moisture correction to either
 reference method  concentrations, or the con-
 tinuous  monitoring sj stern  concentrations
 as  appropriate  Determine the  correction
 fat tor liy moisture tests concurrent with the
 reference method testing periods Report the
 moisture test method and the correction pro-
 cedure emplojed.  For each of the  nine test
 runs  determine the difference for each test
 run by subtracting the respective leference
 method test concentrations (use average of
 eich  set of three  measurements for NCK)
 from the continuous monitoring system inte-
 grated or  averaged concentrations  Using
 these data, compute the mean difference and
 the 95 percent confidence interval of the dif-
 ferences  (equations 2-1 and 2-2). Accuracy
 is reported as the sum of the absolute value
of  the mean difference  and the 95 percent
confidence interval  of  the differences ex-
pressed as a percentage of the  mean refer-
ence method value. Use the example sheet
shown in Figure 2-3.
  722 Calibration  Error.  Using the data
from  paragraph C.I, subtract the measured
pollutant  concentration determined  under
                                              2-11

-------
5.11.1.7    Calculations,   Data  Analysis,  and  Reporting^(Continued)
                  paragraph 6.1.1  (Figure 2-1) from the value
                  shown by the continuous monitoring system
                  for each of  the five readings at each con-
                  centration measured under 6.1.2 (Figure 2-2).
                  Calculate the mean of these difference values
                  and the- 95 percent confidence intervals ac-
                  cording to equations 2-1 and 2-2. Report the
                  calibration error (the sum of the absolute
                  value of the mean difference and the 95 per-
                  cent confidence  'interval | as a percentage of
                  each  respective  calibration gas concentra-
                  tion. Use example sheet sihown in Figure 2-2.
                    7.2.3  Zero Drift  (2-hour).  Using the zero
                  concentration values  measured  each two
                  hours during the field test, calculate the dif-
                  ferences between consecutive two-hour read-
                  Ings expressed in ppm. Calculate the mean
                  difference and the confidence Interval using,
                  equations 2-1 and 2-2. Report  the zero drift
                  as the sum of the absolute mean value and
                  the confidence interval as  a  percentage of
                  span. Use  example sheet shown  in Figure
                  2-4.
                   72.4  Zero Drift (24-hour). Using the zero
                  concentration values  measured  every  24
                  hours during the field test, calculate the dif-
                  ferences  between the zero  point after zero
                  adjustment and the zero value 24 hours later
                  just prior to  zero adjustment.  Calculate the
                  mean value of these points and the confi-
                  dence interval using equations 2-1 and 2-2.
                  Report the zero  drift (the sum of the abso-
                  lute mean and confidence1 interval)  as a per-
                  centage of span.  Use example sheet shown in
                  Figure 2-5.
                   7.2 5  Calibration  Drift  (2-hour).  Using
                  the calibration values obtained at two-hour
                  intervals during  the field test,  calculate the
                  differences  between consecutive  two-hour
                  readings expressed  as  ppm.  These  values
                  should be  corrected for the  corresponding
                  zero drift during that two-hour period. Cal-
                  culate the  mean and confidence interval of
                  these corrected difference values using equa-
                  tions 2-1 and 2-2. Do not use the differences
                  between  non-consecutive1 readings. Report
                  the calibration drift as the sum of the abso-
                 lute mean and confidence Interval as a per-
                 centage of span. Use the example sheet shown
                 in Figure 2-4.
                   72.6 Calibration   Drift (24-hour).  Using
 the calibration values measured every 24
 hours during the field test, calculate the dif-
 ferences between the calibration concentra-
 tion  reading after  zero and calibration ad-
 justment, and the calibration  concentration
 reading 24 hours later after zero adjustment
 but before calibration adjustment. Calculate
 the mean value of  these differences and the
 confidence interval  using equations 2-1 and
 2-2. Report the calibration drift  (the sum of
 the absolute mean  and confidence interval)
 as  a  percentage  of span.  Use the example
 sheet shown in Figure 2-5.
  7.2.7  Response  Time. 'Using  the  charts
 from  paragraph 6.3, calculate the time inter-
 val from concentration  switching to 95 per-
 cent to the final stable  value for all  upscale
 and downscale tests. Report the mean of the
 three upscale test times and the mean of the
 three downscale test times. The two  aver-
 age times should not differ by more than 15
 percent of the slower time.  Report the slower
 time as the system response time. Use the ex-
 ample sheet shown in Figure 2-6.
  7.2.8 Operational  Test Period. During the
 168-hour performance  and operational test
 period,  the continuous monitoring  system
 shall not require any corrective maintenance,
 repair, replacement, or adjustment other than
 that clearly specified as required in the op-
 eration and maintenance manuals as routine
 and expected during a  one-week period. If
 the continuous  monitoring system operates
 within the  specified performance parameters
 and does not require corrective  maintenance.
 repair, replacement or adjustment other than
 as specified above during the  168-hour test
 period, the operational period will be success-
 fully  concluded. Failure of the  continuous
 monitoring system to meet  this requirement
 shall call for a repetition of  the 168-hour test
 period. Portions of the test which were satis-
 factorily  completed  need  not  be  repeated.
 Failure to meet  any performance specifica-
 tions shall  call for a repetition of the one-
week performance test period and that por-
 tion of the testing  which is related to the
failed specification. All maintenance and ad-
 justments required  shall be recorded. Out-
put readings  shall  be  recorded  before and
 after all adjustments.
 5.11.1.3    References
                    8. References.
                    8.1 "Monitoring Instrumentation for the
                  Measurement of Sulfur Dioxide in Stationary
                  Source Emissions," Environmental Protection
                  Agency,  Research Triangle Park, N.C., Feb-
                  ruary  1973.
                    8.2 "Instrumentation for  the  Determina-
                  tion of Nitrogen Oxides Content of Station-
                  ary  Source Emissions," Environmental Pro-
                  tection Agency, Research Triangle Park, N.C.,
                  Volume  1,  APTD-0847, October  1971; Vol-
                  ume 2, APTD-0942, January  1972.
                    8.3 "Experimental Statistics," Department
                  of Commerce, Handbook 91, 1963, pp. 3-31,
                  paragraphs 3-3.1.4.
                    8 4 "Performance  Specifications for Sta-
                  tionary-Source Monitoring Systems for Gases
                  and Visible Emissions," Environmental Pro-
                  tection Agency, Research Triangle Park, N.C.,
                  EPA-650/2-74-013, January 1974.
                                                 2-12

-------
     5.11.1.9  Quality Control Program Specifications--
     5.11.1.9.1  Quality control programs — purpose.  Each
laboratory and field station shall maintain a quality control
program consistent with the procedures described in this
manual.  Such programs shall be designed to assure the qual-
ity and scientific reliability of laboratory and field data
used in EPA activities and documents.
     5.11.1.9.2  Quality control program—provisions.  Each
quality control program shall contain provisions for the
management of data quality, which shall include the following:
     1.  Requirements for the production of quality con-
         trol data and the use of quality control records;
     2.  Control of technical documents, testing methods,
         and calibration instructions, and changes
         thereto;
     3.  Control and calibration of test and analytical
         instruments and equipment used in certification
         testing;
     4.  Control of purchased equipment to include checks
         for analyzer conformance to specifications and
         continuing surveillance of that conformance;
     5.  Audit of routine calibration and preventive main-
         tenance schedules;
     6.  Establishment of an organizational structure to
         carry out these provisions.
     The intralaboratory quality control program shall provide
for the establishment and maintenance of total quality control
systems to assure continued precision and accuracy of the
instrument data including, as appropriate, requirements for:
     1.  The checks and audits listed in table 5.11.1,
     2.  Routine use of an appropriate reference method (either
         Method 6  or 8)  for replicate test data,
                            2-13

-------
       Table 5.11.1  Methods of monitoring variables
     Variable
                           Method of monitoring
1.   Calibration gas
2..   Zero drift
    Span drift
4.   Response time
5..
Dynamic calibra-
tion
6,
Replicate sam-
pling (audit)
7.
Data processing
check
Analyze calibration gases using
Method 6 as part of routine operat-
ing procedures or as the need is indi-
cated by other checks.  See section
5.11.3.5  page 2-51.

Make zero check and adjustment as
part of daily operating procedure.
See section 5.11.3.7  page 2-69.

Make span check and adjustment as
part of daily operating procedure
cind plot on control chart.  See sec-
tion 5.11.3.7  page 2-69.

Check response time as part of bi-
weekly operating procedure.  See
section 5.11.3.7  page 2-69.

Perform a dynamic three-point cali-
bration as part of bi-weekly opera-
tion procedure or as needed due to
major system modifications.  See
section 5.11.3.7  page 2-69.

Manually sample the stack gas, ana-
lyze the sample, and determine a
sulfur dioxide concentration as
directed by the appropriate reference
method.  See section 5.11.4  page 2-75

Manually check a randomly chosen week
of data for proper use of calibration
data, reasonableness of the averaged
data, and correct transfer functions.
See section 5.11.4  page 2-75.
                            2-14

-------
    3.  The use of X  (mean) or R  (range) or other
        control charts and tests for significance of
        differences to gain more information about
        troublesome or out-of-control tests or
        methods.
     Figure 5.11.1 illustrates in a block diagram the method
procedural relationships for Performance Specification 2 as
applies to the measurement of sulfur dioxide.
5.11.2* Plan Activity Matrix
     5.11.2.1  Purpose—Quality control procedures and
checks are designed to identify invalid data and to assure
that the reported data are of acceptable quality.  These pro-
cedures and checks should be integral parts of the normal
operational functions.  Special quality control checks or pro-
cedures may be required of the field operator if deemed neces-
sary by the supervisor in charge of the field operations.  The
need for such  exercises  would be a function of the type of
source and the adequacy of the monitoring system.
     Instructions for the continuous measurement of sulfur
dioxide are directed primarily toward 2-week performance tests
during which the compliance of the monitored source is deter-
mined.  The continuous data generated from the monitoring
system other than during the performance test period provide
a daily indication of the operation and maintenance of the
process and emission control equipment.  An auditing level of
one audit check every six months and three audits per performance
test period is recommended in this document.   All apparatus should
satisfy Performance Specification 2 (section 5.11.1),  and manufac-
turer's recommendations should be followed whenever possible.
     This section presents, in tabular matrix form, a synop-
sis of control procedures for important sources of variation
                           2-15

-------
r\i
                                                                                             Cfl
                                                                                             to
                                                                                             C
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-------
associated with the operating procedures.  Each important
measurement or control procedure is identified in a block at
the left of the tabular matrix.  The information in the blocks
across the page indicates for each procedure:  the acceptance
limits, the frequency of the check or measurement, the action
to be taken if requirements are not met, and the disposition
of records.  Stepwise instructions for performing each oper-
ation in the matrix appear in the corresponding subsection of
section 5.11.3, "Operation Procedures," or, in the case of
audit instructions, in section 5.11.4, "Auditing Procedures."
     The operational categories have been subdivided into the
following operational areas, which more readily lend them-
selves to a tabular formation:
     5.11.2.2  System Definition and Procurement
     5.11.2.3  Installation and Instrument Check
     5.11.2.4  Performance Testing
     5.11.2.5  Data Reduction, Validation, and Reporting
     5.11.2.6  Operating Procedures for Non-Compliance
               Monitoring
     5.11.2.7  Auditing Procedures.
                           2-17

-------
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5.11.3  Operational Procedures
     5.11.3.1  General Considerations—In the subsections
immediately following, specific procedures for measuring and
reporting sulfur dioxide emissions from stationary sources us-
ing continuous monitors are described.   The sequence of opera-
tions to be performed is given in figure 5.11.2.  Two sets of
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procedures which are performed periodically are listed A
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by the operator with proper guidance as indicated in the pro-
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every six months during non-compliance continuous operation are
assumed*
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records should include:
              1.   Operational  Data Logbook
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              5.   Equipment Logbook
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                            2-25

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     5.11.3.2  Preliminary Site Study—The optimum continuous
monitoring system for sulfur dioxide in stack gases can only
be defined after an in-depth study of the source in question
has been accomplished.  The more important parameters which
will influence the choice of a system include:
     1.  Moisture content of the stack gas;
     2.  Stack gas temperature, temperature fluctuations,
         stack gas velocity, and static pressure;
     3.  Existence of other gaseous components in the stack
         gas, e.g., oxides of nitrogen, sulfuric acid;
     4.  Possible physical location of the sampling system,
         an optimum sampling point, and physical dimensions
         of the stack;
     5.  Particulate loading evident in the effluent;
     6.  Range of sulfur dioxide emission rates;
     7.  Ambient temperature range;
     8.  Level of competence and experience of the personnel
         who will be charged with the operation and mainte-
         nance of the monitoring system; and
     9.  Availability of laboratory facilities.
     Most of the information asked for in the above list can
be obtained in a single1 visit to the plant site if not attain-
able from previously accumulated data from the same or similar
plants.  Portable instrumentation is available to measure some
of the stack gas characteristics, i.e., pressure gage and dial
thermometer.  The moisture content measurement can be made
using Method 4, Determination of Moisture Content in Stack Gases
(ref. 3).  The gaseous constituents of the stack gas can be
determined with an Orsat analysis or estimated from details of
the particular process in question.  The other parameters can
be sufficiently covered in discussions with the plant operator(s)
                            2-32

-------
     5.11.3.3  System Definition and Procurement—The
determination of the optimal monitoring system for a given
stack must be made only after the preliminary site survey and
a careful study of several other parameters have been exe-
cuted.  These parameters include:
     1.  Overall objective of the monitoring system program,
     2.  Expected operation and maintenance requirements
         which can be tolerated by the program,
     3.  Need for ease in calibration,
     4.  Auditing program requirements which may be enforced.
In defining the overall objective of the sampling system, the
simplicity or complexity desired in the monitoring system
should become evident.  The second parameter is definitely
dependent on parameter number 8 in section 5.11.3.2, the level
of competence and experience of the personnel to be charged
with the operation and maintenance of the system.  Along these
lines, too, is the number of hours per week or per month of
the personnel's time which will be alloted to this role.  The
need for ease in calibration will also be a function of the
operator's time and skills.  As a result of defining potential
audit requirements, only systems with the desired characteris-
tics for auditing  (i.e., reference gas inlets, etc.) will be
considered.
     As stated in section 5.11.1.2 the system apparatus will
consist, generally speaking, of equipment for the reference
method measurement of the sulfur dioxide concentration, cali-
bration media, a continuous monitoring system (several varie-
ties of which are discussed below), and a data recorder.  The
data recorder can be either an analog chart recorder or any
other suitable device with an input voltage range compatible
with the output of the analyzer system.  If a magnetic tape
recording system is selected, a backup strip chart recorder is
recommended to meet immediate operation, maintenance, and
                            2-33

-------
troubleshooting needs.
     Several types of continuous sulfur dioxide monitoring
systems are commercially available utilizing a wide range of
detection techniques.  There are two main classifications for
these systems:  in-situ and extractive.  The in-situ measure-
ment system has the monitor mounted directly on the stack
where it senses the pollutant in the effluent stream without
need for removing samples from the stack gas.  The majority
of the in-situ monitors are based on optical methods for tak-
ing the measurement at a point in the stack or taking a spa-
tially integrated measurement across the diameter of the stack.
The extractive monitor is one which requires the sample to
be drawn from the stcick and transported to the analyzer.
Depending upon the distance from the sampling point to the
analyzer and the analyzer's sample conditioning requirements,
the interface between the sampling point and the analyzer can
vary in complexity.  Several in-situ and extractive monitors
are discussed below with indications given as to the types
of interfaces which might be considered when appropriate.
     5.11.3.3.1  Dispersive spectroscopy.   Several instruments
are available which utilize dispersive spectroscopy to measure
the gases across the stack rather than drawing a sample out of
the stack.   One such instrument transmits a beam of light from
one side of the stack to the other so that it passes through
the gas stream.  The polychromatic light beam contains certain
wavelengths of light which are optically absorbed by various
constituents of the gas.  Hence, the reduction in the intensity
of the beam at a given wavelength as it is received at the
opposite side of the stack is proportional to the number of
molecules of the constituent absorbing at that wavelength.
The analyzer section of the instrument isolates the wavelengths
                                                          o
of interest (for SC>2 the corresponding wavelength is 3024 A)
and measures their individual intensities.
                            2-34

-------
     A monitoring system of this type, although theoretically
simple, must be designed to withstand and/or compensate for
changes in ambient temperature and severe vibrations which are
likely at various times of the year.  Other practical problems
which must be overcome include:
     1.  Calibration of the entire system.
     2.  Keeping the windows which separate the analyzer and
         the stack gas clean,
     3.  Jarticulate concentrations in the stack gas which
         will reduce transmission of the subject wavelength by
         blocking its path rather than by S02 absorption,
     4.  Maintaining constant intensity of the source lamps,
     5.  Guaranteeing that the detectors maintain the same
         detection sensitivity.
     Two common variations to the dispersive spectroscopy
"double-ended" instrumentation described above are the "folded
path" design and the "slotted pipe" design.  Unlike the "double
ended" system, the "folded path" system places both the source
and receiver at the same location.  The energy beam is trans-
mitted through a slotted probe and reflected back into the
instrument for analysis.  The "slotted pipe" extends either
between the transmitter and receiver or between the transmitter/
receiver combination and the reflector.  The purpose of the
slotted pipe is either to prevent misalignment or to restrict
the absorption pathlength to maintain linear detector response.
     One example of the more sophisticated "folded path"/
"slotted pipe" instruments is one which utilizes a flat zero/
read mirror.  When the mirror is in the read position, reflected
light is directed back to the spectrometer.  If SO2 is present
in the slotted pipe, it will absorb energy in regularly spaced
              o
bands of 3024 A.  The light reflected off the mirror is
reflected onto a diffraction grating which disperses the light
                            2-35

-------
allowing for a spatial display of the absorption spectra of
S02.  When the mirror is in the calibration position, the light
is directed into the spectrometer bypassing the sample probe
which serves as a zero check.  A temperature-stabilized gas
cell containing a known concentration of SC^ can then be
inserted into this same path to provide a span check.
     An alternative to changing the position of the mirror is
to utilize a second light source in the analyzer which does
not pass through the stack gas.  By inserting either a gas
cell of known concentration or a calibrated optical filter in
the path of the second beam, a calibration can be performed.
     A possible means of performing a dynamic calibration is
to insert standard verified sealed cells into the path of the
original beam which will incrementally add to the unknown
stack gas.  In this way a system operating curve can be deter-
mined.  The entire dynamic calibration procedure can be accom-
plished automatically using a timer actuated solenoid arm
 (ref. 5).  Care must be taken, however, that the certification
value for the cell is determined at temperatures equivalent
to existing stack gas conditions.   An alternative is for the
manufacturer to supply a calibration curve and to apply the
appropriate correction factors at each calibration,
     Another of the problems stated above which has been
examined by several manufacturers is that caused by the accumu-
lation of particles on the windows which would block transmis-
sion of the light beam.   A system designed to alleviate this pro-
blem is one which uses a specially designed forced-air purge system
to avoid dirt buildup on the windows and adjoining hardware.
The air for the system is supplied by a self-contained blower
which works continually (ref. 6).
                            2-36

-------
     The third problem stated above deals with the particulate
loading characteristic of the stack gas.  A relatively simple
way to avoid this problem is simultaneous detection of two
wavelengths of the polychromatic light beam in a double-ended
system or of the reflected light in the folded path system.
One wavelength, of course, is that which is absorbed by SC^-
The second is a reference wavelength not absorbed by any
stack gas constituent.  Any deterioration of the intensity at
the second wavelength is not due to absorption and must be
caused by interference from the particulates in the gas stream.
This deterioration at the second wavelength can be appropri-
ately assigned to the first wavelength as an addition to the
originally measured intensity.
      5.11.3.3.2   Second  derivative  spectroscopy.   Second deriv-
ative  spectroscopy is another  in-situ method  for measuring  SO_
in  stack  gas  emissions.   It  is  an  attempt  toward greater spec-
ificity and resolution by determining the  derivatives of the
intensity with respect to wavelength of  a  light beam which  has
passed through the stack gas.   The  optical  technique used  in
this  type of  instrument  is wavelength modulation where  the  wave-
length radiation  is modulated  sinusoidally  with time.
      One  instrument utilizing  this  technique has within it  a
grating monochrometer which  spectrally disperses the radiation
from  an ultraviolet source.  The wavelength of this monochro-
matic radiation is then  varied  with respect to time by  laterally
oscillating the entrance slit position electromechanically  at a
frequency of  45 hertz.   The  amplitude of the wavelength modu-
lation can vary depending on the peak-to-peak displacement
chosen between .25 and 1 mm.  The signal then enters an absorp-
tion  cell with a wavelength  centered about  a value set by  the
grating position  and slightly modulated  in  time at 45 hertz.
                            2-37

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In the absorption cell, the light is reflected back and forth
across the length of the cell several times until it is focused on
a detector which is generally a photomultiplier tube.  The
90 hertz component of the output signal from the photomulti-
plier tube is electronically analyzed using a fundamental
phase-lock amplifier technique.  The amplitude of the 90 hertz
signal is presented as an output dc voltage which is propor-
tional to the second derivative of intensity with respect to
wavelength.  Electronically dividing this signal by the total
output voltage of the PM tube results in a signal proportional
to gas concentration (ref. 7) .
     All of the problems stated in section 5.8.3.3.1 are
applicable to the second derivative spectroscopy method.  Cali-
bration at selected concentrations can be niade manually or
automatically using standard, sealed samples of SO- which are
inserted into the light path internally to provide measure-
ments corresponding to known concentrations.  The problem of
accumulation of particulates on the windows encasing the optics
can be handled in very much the same way as stated above.
Because the technique is sensitive to particulates in the
stack gas, a ceramic probe filter can be used so as not to
allow particulates to enter into the measurement.  All of the
electronics are located separately from the optics which are
in a sealed encasement.  With this situation then, preventive
maintenance on the electronic components can be performed
without disturbing the rest of the system.
     Two other parameters which should be discussed in relation
to second derivative spectroscopy are:  sensitivity to high
stack gas temperatures and interferences by other constituents
of the stack gas.  Designs available on the market today can
withstand stack gas temperatures up to 540°C.  Some specificity
can be lost in the ultraviolet absorption method when two
                             2-38

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different constituents have absorbed some amount of energy at a
given wavelength.  In other words, at wavelength X , several
constituents may add to the reduction in intensity.  However,
with this technique of optically determining the second deriv-
ative, the amount of loss of intensity due to SOj can readily
be differentiated from absorption by any other constituent.
     5.11.3.3.3  Extractive ultraviolet absorption.  One of
the more simple extractive methods is that which extracts a
sample of the stack gas, maintains the sample at the high
stack gas temperatures, analyzes the sample for the sulfur
dioxide content, and then discharges the sample back into the
flue gas.  Either a split beam or a dual beam source can be
used in the analysis.  Simply, the first beam, at a given
wavelength absorbed strongly by S02, passes through the sample
cell through which the sample of stack gases flows.  The
intensity of the light is detected by a wavelength phototube
along with the intensity of a second beam.  The second beam
has passed through an optical filter that transmits only the
reference wavelength which is not absorbed by sulfur dioxide
and then through the sample cell simultaneously with the
first beam.  The phototubes generate electrical signals which
are proportional to the intensity of each signal.  The loga-
rithms of the two signals can then be compared and a single
photometer signal outputted which is proportional to the
concentration.
     Advantages of such a system include:
     1.  Long sample lines are not required when the photometric
         system is mounted on the stack;
     2.  Systematic errors such as particulate buildup on
         the windows of the sample cell are avoided because
         of the use of a reference;
                            2-39

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     3.   System components are at a minimum so that trouble-
         shooting and the subsequent repair of equipment
         should require considerably less time than other
         more sophisticated systems;
     4.   Response is generally linear over a wide range;
     5.   The optics, the electronics, and the sample cell can
         be' isolated from each other which allows the operator
         to perform maintenance on any one of the three without
         affecting the others;
     6.   Zero calibration can be performed by simply back-
         flushing the probe and sample cell which simulates
         zero absorption;
     7.   Span calibration can be performed by dropping a
         reference cell of known concentration into the path
         of the light beam during the backflushing operation;
     8.   Due to the elevated temperatures of the sample at
         all times, problems due to condensation and cor-
         rosion of equipment may be avoided;
     9.   An air aspirator is used to extract the sample as
         opposed to a sample pump which is generally much
         less reliable for long-term monitoring;
    10.   A system such as this can be readily adapted to
         several different sources  (ref.  8) .
     5.11.3.3.4  Nondispersive infrared.   Most analyzers using
the nondispersive infrared (NDIR) technique consist of either one
light source with a light chopper or two identical sources
whose beams are directed through two different cells.  One of
the cells contains a gas which does not absorb infrared energy
at the same wavelengths at which sulfur dioxide absorbs infra-
red energy.  Passing through the other cell is the sampled
stack gas.  The beams pass through both of these cells and into
different half sections of a reference chamber.  Separating  the
                            2-40

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two half sections of the reference chamber is a flexible metal
diaphragm.  Both sections contain the same amount of SG>2 vapor
kept at the same atmospheric pressure.  The degree of absorp-
tion of infrared energy by the sample gas is directly propor-
tional to the amount of S02 in the sample gas.  The absorption
by the sample gas will proportionally reduce the absorption by
the S09 vapor in the corresponding half section of the refer-
      ^w
ence chamber.  The difference between the energy absorptions
in the two halves on the reference chamber, then, is a measure-
ment of the concentration of S0~ in the sample gas.
     The flexible metal diaphragm when used with a stationary
metal plate forms one side of two-plate variable capacitor.
The capacitance, which changes with the detention of the dia-
phragm, is measured.  The detention of the diaphragm is
proportional to the difference between the energy absorption
of the SC>2 vapor in the two sides of the reference chamber.
Hence, an electrical signal is generated which is propor-
tional to the concentration of SO,., in the sampled stack gas.
     The primary sources of error in the NDIR method are the
blocking of the transmission of the light beam by particulates
and the inadvertent,absorption of infrared energy by moisture
in the sample gas.  Both of these sources of error can be mini-
mized by adequate interfacing equipment, varieties of which
will be discussed below.
     The sampling interface used with an NDIR analyzer must be
capable of removing fly ash and particulate matter as well as
removing or determining the quantity of moisture in the sample.
Particulate matter will tend to collect on the windows of the
sample cell.   Water vapor will interfere inasmuch as the SO2
absorption band is overlapped by a water system in the
1200 cm"1 to 1400 cm"1 region.
                            2-41

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     One possible sampling interface is described in reference
6 and shown in figure 5.11.3.  The 0.5 micron filter used in
this system is adequate for removal of the small amount of
particulate in the emission from a source having a bag house
in use.  The filter is placed in the stack as a portion of the
sample probe.  Heat from the stack gas will keep the filter
hot and keep moisture from condensing as the gas is drawn
through the filter.  When stack gases are not filtered by a
bag house filter systeir. or equivalent, it is necessary to in-
stall a portable bag house-type filter ahead of the 0.5 micron
filter in the sample line.
     The sample gas transmission line shown in figure 5.11.3
is made up of 100-foot long Teflon segments with an individual
heating system for each segment.  The overall transmission
heating system should maintain a nominal 120°C (250°F) gas
temperature from the sample probe to the first heat exhanger.
     The heated gas from the transmission line is rapidly
cooled from 120°C  (250°F) to 1°C  (34°F) to remove all moisture.
To do this, a heat exchanger is usually employed to reduce the
gas temperature between 55 and 85°C (100 to 150°F) depending on the
atmospheric temperature.  The sample gas is then passed through
an electro-mechanical refrigeration unit to further reduce the
gas temperature.  Approximately 90 percent of the sample gas
is then removed from the conditioning system via the stack gas
pump.  The remaining sample gas is passed through a second
electro-mechanical refrigeration unit to reduce the gas temper-
ature to approximately 1°C  (34°F).  The reduction of tempera-
ture causes the moisture in the gas to condense into a liquid.
A collection device is employed in conjunction with the above
conditioners to remove the liquid from the system and holds the
liquid for later measurement as evidence of the moisture con-
tent of the stack  gas.
                             2-42

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                INSIDF.  GAS  STACK
        PROBE
             =L
                  FILTER
                DEKARON  TRANSMISSION  LINE
                            VACUUM
                             GAGE
                         NSTRUMENT
                        SAMPLE  PUMP
STACK  GAS
SAMPLE PUMP
                                            SPAN  GAS
                                              BOTTLE
 ZERO GAS
   BOTTLE
GAS  CONTROL  VALVE
                     NSTRUMENT ANALYZER
                    EXHAUST GAS MANIFOLD
                                         EXHAUST
Figure 5.11.3.
              Example of  an extractive  sulfur
              dioxide monitoring system.
                         2-43

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     The stack sampling probe, when inserted in the stack, may
be at either positive or negative pressure.  A system for
extracting the gas can either employ a pressure pump at the
stack, which would require the pump to operate at high temper-
atures, or a vacuum pump located after the conditioning equip-
ment.  In the example illustrated in figure 5.11.3, the latter
and more practical configuration is used.  The sample gas
leaving the pump is at a positive pressure sufficient to
satisfy the flow rate and pressure needs of all analyzers.
The pumped sample gas is then piped to the input of the gas
analyzer.
     5.11.3.3.5  Pulsed fluorescence.  In the pulsed fluor-
escence method, the extracted stack gas sample is passed in
front of a source of pulsed ultraviolet illumination equipped
with a monochromatic filter.  The molecules of sulfur dioxide
contained in the sample will be energized by the high intensity
light source and will emit a monochromatic illumination.  This
emitted light is linearly proportional to the concentration of
sulfur dioxide molecules in the sample.  It is usually sensed
by a photomultiplier tube through a narrow-band filter and a
proportional analog output is generated.
     The most commonly used region of ultraviolet radiation is
the 2300A to 1900A region.  In this region sulfur dioxide mole-
cules exhibit stronger absorption and their fluorescence is
less likely to be quenched by other constituents of a stack gas
(ref. 9).
     The quenching effects of oxygen, carbon dioxide and nitrogen
in concentration levels different from the ambient air levels
are discussed in reference 10. Calibration of pulsed fluores-
cence analyzers is accomplished using SOp-in-air reference
mixtures which alters the analyzer accuracy for other constituent
levels in the stack gas.  As shown in test results discussed in
                            2-44

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reference 9, a reduction in oxygen level below 21%  (ambient
level) will linearly increase the analyzer reading.  A rise in
the CO- level in the stack gas will decrease the analyzer reading
with respect to the true value.  The quenching effects due to
N2 are negligible in comparison to effects due to C>2 and CO-.
     The level of water vapor content of the stack gas must be
kept constant to avoid inconsistent quenching of the fluorescence.
As discussed in reference 9, studies have shown that the pulsed
fluorescent analyzer, which has included within its internal
components a dryer which reduces the moisture to a very low and
discernible level, will not require any external drying devices
to maintain insensitivity to the moisture in the stack gas.  In
the case of pulse fluorescent analyzers without internal drying
mechanisms, an external dryer or refrigeration unit must be used.
     As in the majority of the extractive continuous analyzers,
particulate removal is important so as not to clog the analyzer
plumbing or to block the detection of light.  Heated sample
lines are also vital in preventing water condensation and the
loss of sulfur dioxide from the sample.
     Calibration of the system can be accomplished by inputting
zero and span gases at the probe and/or at the analyzer.
     5.11.3.3.6  Flame photometric detection.  The flame photo-
metric principle utilizes the detection of light, centered at
394 nm, emitted by sulfur-containing compounds when burned in a
hydrogen-rich flame.  The burning creates an excited state
species of sulfur and the release of light energy upon the
return to ground state sulfur is the quantity measurable with
a photomultiplier tube optically shielded from the flame.   The
response of the detector,  which generally views the light
through a narrow band-pass interference filter,  is directly
related to the concentration of total sulfur entering the
detector per unit time.
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     The advantages of ci flame photometric detection system
include:  a high degree of sensitivity to sulfur compounds,
low maintenance and downtime,  and the fact that the system
is readily calibrated using NBS traceable permeation tubes
(ref.ll).  Disadvantages; include downtime due to "flame-out,"
excessive analyzer drift, and sensitivity to small variations
in gas pressures and flows.  In addition, the analyzers avail-
able on the market for source monitoring purposes must be
coupled with interface systems which have heated sample lines,
remove particulates, dry the sample, and dilute the sample to
within the measurement range of the air quality analyzer.  The
interface systems should also be equipped to remove all sulfur-
containing compounds other than SO-.
     Several of the disadvantages listed above are taken care
of in standard monitoring packages.  Ceramic filters installed
in the probe will remove the majority of the particulates and
portable bag-house type filters can be installed downstream
from the probe if more protection is necessary.  Downtime form
"flame-out" can be minimized with the use of an automatic flame
reignition system which senses the flameout condition and cor-
rects it by turning off or averting the hydrogen flow and reig-
niting the flame within 15 to 20 seconds.  The hydrogen is then
started up or redirected across the flame.  The problem of drift
can be avoided with daily or twice-daily calibrations.   Utiliz-
ing an automatic calibration system is the most feasible way
to meet this requirement.
     There are several different types of dilution systems
available.  The disadvantages of all of them are:
     1.  The depletion of moisture is not adequate for most
         analyzers which have a characteristic sensitivity
         to water vapor.
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     2.  A more complex gas control system is required to
         keep the flow rates constant.
An example jDf a dilution system is one which utilizes a perme-
able membrane.  The dilution ratio acquired from such a system
would depend on the volume flow of the carrier gas stream, the
surface area and temperature of the membrane, and the perme-
ability of the membrane to the component of interest.
5.11.3.3.7  Procurement guidelines.  Upon purchase of the analy-
zer and associated support equipment, certain procedures should
be followed which permit the operator to determine the adequacy
of the equipment.  The analyzer system must ultimately meet the
specifications outlined in section 5.11.1.4.  To determine the
acceptability of the analyzer, the operator must do one of two
things upon purchase of the instrument:  1. Acquire and review
the manufacturer's bench test data.  Even more preferable is
the viewing of the actual bench testing at the factory by the
operator prior to shipment of the equipment; or 2. Design and
perform a bench test which simulates actual operating conditions,
generate, and review output data.  The latter suggestion requires
immense experience on the part of the operator with the specific
equipment.  It is beyond the scope of this document to define
a specific bench testing process, the extent of which is depen-
dent on the time and economic factors specific to the system
at hand, e.g. the necessity for the system to successfully meet
the performance testing requirements within a given time sche-
dule would alter bench testing requirements.
     Prior to installation of the sampling interface and record-
ing equipment, the operator should simulate a typical operating
sampling condition, make several measurements, and study the
validity of the output data.  Whenever quantitative measurements
are not practical, the operator should make a visual inspection
of each component to locate obvious defects and/or malfunctions.
                           2-47

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     The calibration gas mixtures must be checked upon receipt
using Method 6 measurements.   Nominal concentrations of 0 per-
cent of span, 50 percent of span, and 90 percent of span
must be acquired.  The average concentration value for each
mixture, based on at least three measurements taken at least
24 hours apart, should not differ from the stated concentra-
tion value by more than 5 percent.
     Any of the components of the system which do not meet
acceptable quantitative or qualitative limits should be rejected
prior to installation.  Report and correct any malfunctions,
making this information available to all operating personnel.
     5.11.3.4  Installation and Instrument Check Guidelines--
Because each system is usually specifically designed to meet
the requirements at the stack in question, it is recommended
that the system design engineer or manufacturing representa-
tive take the responsibilities of installation and initial
system checkout at the site.   Also due to the uniqueness of
each system, it is advisable for the operator(s) of the system
to be present at the installation and to actively participate
in the system testing.  With this experience and a detailed
operations and maintenance manual, the operator should be able
to trouble shoot, define, and resolve most of the problems he
may encounter during continuous operation.  If the operator is
not skilled in the areas of electronics or chemistry, skilled
personnel should be available at all times to aid in resolving
problems with the minimum of downtime.
     Of utmost importance during the installation and initial
system testing is that each step and the results be well docu-
mented at the front of the Operation and Maintenance Logbook
which should be updated daily by the operator.  Installation
specifications as stated in Performance Specification 2 are
                           2-48

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reprinted in section 5.11.1.4.
     For sampling of sources where the effluent gases cannot
be assumed to be nonstratified, Performance Specification 2
(section 5.11.1.4) requires that one of the following mea-
sures be taken:
     1.  The procurement and installation of either a con-
         tinuous oxygen or a continuous carbon dioxide mon-
         itoring system which meets the requirements of Per-
         formance Specification 3  (reproduced in appendix A
         of this document).
     2.  The procurement and installation of extractive S02
         monitoring systems using multipoint sampling probes
         or in-situ pollutant monitoring systems that sample
         or view emissions which are consistently represen-
         tative of the total emissions for the entire cross
         section.
     The continuous measurement of oxygen can be accomplished
with analyzers utilizing either the paramagnetic technique or
a zirconium element.  Both of these systems require a clean,
dry sample which indicates the need for a sample interface
system such as described below in section 5.11.3.3.4.  There
are no major interferences when using either of these methods.
However, problems do exist if particulate matter is allowed to
build up in the lines or if there are leaks into the system.
     The continuous measurement of carbon dioxide is most com-
monly achieved with a nondispersive infrared analyzer.  The
problems and error sources associated with this technique are
discussed below in section 5.11.3.3.4.
     Research and development of multipoint probes has not yet
reached a point where they are readily available to the user.
Reference 4 provides a detailed description of errors due to
non-stratification and the ways in which the use of multipoint
probes will alleviate many of the inaccuracies caused by point
source continuous monitoring.
                           2-49

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     Some general statements which apply to most in-situ and
extractive systems unless specified otherwise are listed below.
In some cases the manufacturer will make recommendations as to
the correct procedures.  If not, the experience of the operator
and/or installation personnel will play an important role in
the success of the system.
     The statements are as follows:
     1.  Temperatures outside the ambient temperature limits
         of the analyzer may necessitate the use of special
         environmental control equipment.  This equipment
         should be set up and tested for an undisturbed oper-
         ating period of at least 1 month before installation
         as support equipment in the system.  The environment
         during the testing period should be similar to the
         extreme environmental conditions to be experienced
         at the analyzier location.  During this test period,
         the temperature at the analyzer location should be
         measured and recorded continuously or at intervals
         which suffice: in determining that the temperature
         requirements of the analyzer will be maintained.
     2.  Mount the analyzer horizontally or vertically as
         recommended by the manufacturer.
     3.  Depending on the specific location of the analyzer
         and the analyzer's sensitivity to vibration, pre-
         cautions may or may not need to be taken to dampen
         vibrations to which the analyzer may be subjected.
         One suggestion is to use foam rubber or the equiv-
         alent to isolate the instrument from the mounting
         platform.
     4.  Typically, sample handling systems for extractive
         monitors will incorporate the following:
                           2-50

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         a.  Valves to permit selection of gas sample,
             zero calibration gas or upscale calibration gas.
                              *-*
         b.  needle valve inlet in sample line for flow
             adjustment,
         c.  flow meter for flow measurement and/or indica-
             tion of flow stoppage,
         d.  filters and filter holders.
         Each of the above should be checked for cleanliness,
         proper operation, and no undue disruption of air flow.
     5.   The layout of the equipment can be very important to
         the operator's efficiency.  A suggestion in this area
         is that the recorder be near enough to the amplifier/
         control section so that the operator can easily
         observe the response to adjustments of the controls.
         In the majority of systems the recorder response
         should be observed rather than the meter response on
         the control panel.
     6.   The type of pump chosen for the gas sampling in an
         extractive system will dictate the location of the
         pump.   A simple water or air aspirator can be placed
         downstream of the analyzer and will exhibit distinct
         advantages over diaphragm and bellows pumps since
         aspirators have no internal working parts and are
         less prone to failure (ref. 12).
5.11.3.5  Performance Testing—The performance specification
test procedures presented in section 5.11.1.5 are reproduced
from Appendix B as published in the Federal Register, Octo-
ber 6, 1975.  The testing procedures include the following
independent tests:
          • Calibration test
          • Field test for accuracy (relative), zero drift,
            and calibration drift
          • Field test for response time
                           2-51

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     5.11.3.5.1  Calibration test.  This test consists of an
analysis of the calibration gas mixtures (if used rn the system
in question) and a calibration of the complete measurement
system either in the laboratory or in the field.  The latter
is preferred^  Nominal concentrations of 50 percent and 90
percent of span are recommended.  The method of analysis is
as directed by Method 6.   The analysis must be accomplished
within 2 weeks prior to start-up of the system with the
objective being to "demonstrate (the calibration gases)
to be accurate and stable,"  (section 5.11.1.2).  Alternate
methods may be acceptable if approved by the enforcement agency.
Record all results on a form as shown in figure 5.11.4.
     The entire system is calibrated with a series of five non-
consecutive readings for each concentration of span gas, e.g.,
50 percent, 90 percent, 50 percent, 90 percent, etc.  This
method is subject to the particular operation of the system in
question.  Alternative procedures may be acceptable as recom-
mended by the manufacturer and approved by the enforcement
agency.  Record all data on a form such as shown in figure
5.11.5.
     5.11.3.5.2  Field test for accuracy (relative), zero
drift and calibration drift.  This test extends over a 2-week
period after the measurement system has been installed and started
up per the manufacturer's directions.  First the operator must
offset the zero setting by at least 10 percent so that the
negative zero drift characteristic, if any, of the analyzer in
question can be quantified.  The system should be operated for
one week (168 hours)  in a normal operational manner.  This is
called the conditioning period.
     The conditioning period is immediately followed by a
168-hour operational test period when the system is on line at
all times except during calibration or backflushing of the
                           2-52

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           ANALYSIS OF CALIBRATION GAS MIXTURES
DATE
REFERENCE METHOD USED

INITIALS
Calibration Gas Mixture "A":
         Cylinder or cell designation
            Test No. 1 	 ppm
            Test No. 2 	 ppm
            Test No. 3 	 ppm
            Total               _   ppm
            Average = -° a  =	ppm
Calibration Gas Mixture "B":
         Cylinder or cell designation_
            Test No. 1 __ ppm
            Test No. 2 _ ppm
            Test No. 3
            Total      _ _ ppm
            Average = -°- a  =   	 ppm
 Figure 5.11.4  Sample data form  for the  analysis  of
                 the calibration gas mixture.
                       2-53

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                CALIBRATION ERROR TEST DATA
DATE
OPERATOR
CALIBRATION GAS MIXTURE "A":  (
   Reading
                                    ppm)
             Time
                      Measurement Sys.  Reading
                         Volts
                                    ppm
                                                  **
                                                       "'A
CALIBRATION GAS  MIXTURE "B":   (
                                     ppm)
   Reading
             Time
                      Measurement Sys.  Reading
                         Volts
                                     ppm
                                                  **
**
 Average value determined in analysis of calibration gas
 mixtures.
k
 d  =  Difference = Average Value (ppm) - Measurement Syst.
 Reading  (ppm)
   ngure  5.11.5   Sample  log  sheet for calibration
                    error  test  data.
                          2-54

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sample lines and other support equipment.  If, at any time
during this second period, monitoring is interrupted for main-
tenance procedures, the operational testing time up to the
interruption must be noted in the records and repeated (sec-
tion 5.11.1.6).
     The field test for accuracy requires that a minimum of
nine SO- concentration measurements be taken in accordance
with the procedures stated in either Method 6 or 8 depending
upon the regulations for the particular source in question.
The sampling period should be 1 hour.  In all sampling cases
the Reference Method sampling probe should be placed as near
as possible to the sampling point of the system in question.
Record this test data on a form such as demonstrated in figure
5.11.6.
Note: It is recommended that a chemist be available on site
      to analyze the sample immediately following the sample
      recovery.  This will greatly enhance the efficiency of
      the testing procedures.
     If the basis (wet or dry)  for the continuous measurement
system is inconsistent with the Reference Method measurements,
simultaneous moisture tests should be performed and a correc-
tion factor determined.  Report the moisture test procedures
and data along with the correction factor calculations in the
performance test logbook.  The column labeled "Reference Method
ppm" in figure 5.11.6 is designed for recording the reference
method data after the correction factor has been applied.
     The field test for the 2-hour zero drift and 2-hour span
drift consists of an accumulation of 15 sets of data at 2-hour
intervals each.   The zero and span values can be produced by
pre-tested calibration gases, simulated using equivalent gas
cells,  or simulated electrically or mechanically within the
analyzer if approved by the enforcement agency.  The 2-hour
intervals must not overlap and do not have to be consecutive.
                           2-55

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                             OPERATIONAL TEST DATA
START:
   DATE_
   TIME
                   END:
                      DATE_
                      TIME
                                        OPERATOR(S)
ACCURACY DETERMINATION:
  Test
  No.
Oper.
Init.
Date
Time
Ref.  Method
   (ppm)
                                              Analyzer Average
                                            Interval   Volts
                                                              ppm
di
                                                         d.2
    d  = Difference = Analyzer  Average Value (ppm)  - Reference  Method Value  (ppm)
         Figure 5.11.6  Sample data form  for operational  test.
                                    2-56

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                           OPERATIONAL TEST DATA
2-HOUR ZERO AND CALIBRATION DRIFT DATA:
        Oper.
        Init.
Date
                          Time
                      Begin
               End
 Zero
Reading
AZ
AZ'
'  Span
Reading
Span
Drift
  10
  11
  12
  13
  14
  15
   Figure 5.11.6  (Cont.)   Sample data form for  operational test,
                                  2-57

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Record the readings  (fig. 5.11.6).  Definitions of symbols is
found in Appendix B of this document.
     During the field testing, zero and span calibration cor-
rections and adjustments are permitted only once every 24 hours.
Intervals shorter than 24 hours may be approved if recommended
by the manufacturer.  The values given by zero and span before
and after the 24-hour interval adjustments are made should
be measured and recorded as shown in figure 5.11.6  Automatic
calibration systems may be used and their corrections can be
made at any time.
     5.11.3.5.3  Field test for response time.  This test
should be accomplished with the entire system in normal oper-
ation as specified by the manufacturer's instructions.  Zero
gas is introduced at the probe or as close to the probe as
possible.  When the output reading has stabilized,  a span gas
mixture of known concentration is injected at the same point
that the zero gas had been injected.  The recorded response
time is the time between the switching to a span gas and a
stable output at the span gas value.  The span gas used for
this test should be 70 to 90 percent of span.  This sequence
of operation should be repeated three times and the results
recorded on a log sheet as shown in figure 5.11.7.
     5.11.3.6  Data Reduction, Validation, and Reporting—Of
utmost importance during the performance testing is that all
test data are logged correctly and directly upon acquisition
of the data.   The figures referred to in the previous sections
should all be included in a single performance testing logbook
in chronological order.   Having the data contained in a single
notebook will expedite the next steps which are data reduction,
validation,  and reporting.  Figure 5.11.8 shows a simple layout
for a form on which the necessary calculations can be made for
reporting the test data.   Section 5.11.1.6 should be referred
to in making those calculations.
                           2-59

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      DATE
      OPERATOR
                      RESPONSE  TIME TEST DATA
          Test No.
Concentration
    (ppm)
   Upscale
Response Time
  (seconds)
           SUM 16
           AVERAGE
          Test No.
Concentration
    (ppm)
  Downscale
Response Time
  (seconds)
Figure 5.11.7   Sample  data  form for  response time  test.
                              2-60

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               DATA ANALYSIS REPORT CALCULATIONS
 DATE
 OPERATOR
 CALIBRATION ERROR DETERMINATION "A"
      Mean difference =  —— = 	 ppm
      95% Confidence interval = C.I-95 = .2776 \5(Sum 2)-(Sum I)2
                                 (Mean difference + C.I.g5
      Calibration error  for  "A" =   Avg.  calib. gas conc.   -  100
                                               percent
 CALIBRATION ERROR DETERMINATION "B1
      Mean difference =  —— = 	 ppm
      95% Confidence  interval = C.I.g5 = .2776 V5 (Sum 4)-(Sum 3)2
                                              percent
                                 Mean difference
      Calibration error  for  "B" =
+ C.I.
                                                       95
                                   Avg. calib. gas conc.


                                  	  	 percent
         x  100
Figure 5.11.8  Sample form for data analysis  report
                 calculations.
                             2-61

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              DATA ANALYSIS REPORT CALCULATIONS
 ACCURACY DETERMINATION
      Mean  difference == —3— = 	 ppm
      95%  Confidence interval = C.I-95 = .0906 ^9(Sum 6)-(Sum 5)
      Mean reference method value =
                Mean difference + C.I.gg
      Accuracy  =  Mean ref. method value  *  100

               = 	 percent
 ZERO DRIFT (2-hour)
      Mean zero drift  =       = 	 ppm
      C.I. (zero)95 = .0382 Vl5 (Sum 9)-(Sum Q)2
      Emission standard  =  	

                   Mean  zero drift + C.I.(zero)Q5
      Zero Drift =
                         Emission Standard
                             percent
                                                   100
Figure 5.11.8 (Cont.)   Sample form for  data analysis
                          report calculations.
                            2-62

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              DATA ANALYSIS REPORT CALCULATIONS
 CALIBRATION DRIFT  (2-hour)
      Mean calibration drift = S"" 10 = 	 ppm
      C.I.(span)   =  .0382 \15 (Sum 11)-(Sum 10)2  =
               95
      Emission standard =
                         Mean span drift + C.I.(span)„,.
      Calibration drift = 	=—,	=	5	3	  x ion
                                Emission standard         ±fjtj
                       = 	 percent


 ZERO  DRIFT  (24-hour)
     Mean zero drif i = —£LJ±- = 	 pprn
     C.I.(zero)g5 = .1427  V 7(Sum 13 )-(Sum 12 )2   =
     Emission standard = 	 ppm


                  (Mean zero drift!+ C.I.
                                        (zero) qt-
      Zero drift = 	=—=	=	r—3	5	—  x  100
                         Emission standard
                             percent
Figure 5.11.8  (Cont.)  Sample  form for data  analysis
                          report  calculations.
                            2-63

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              DATA ANALYSIS  REPORT CALCULATIONS
 CALIBRATION DRIFT (24-hour)
     Mean calibration drift = Sum 14 = 	 ppm
      C.I.(span)95 = .1427 V 7(Sum 15)-(Sum 14;2



      Emission standard = 	 PPm


                         Mean  span drift + C.I.(span)g5
      Calibration drift =
                                Emission standard


                               	 percent
100
 RESPONSE TIME
      System reponse time = slower response time =
      Percent deviation from slower time


                         _ avg.  upscale - avg. downscale
                                                        x
                                   slowest time
                                       percent
Figure 5.11.8 (Cont.)   Sample form for data analysis
                          report caculations.
                            2-64

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     The personnel responsible for doing the data analysis for
the performance test should date the data analysis form and
initial it.  Preferably this personnel will have participated
in the field testing, hence will be familiar with the data and
its origin.
     The first determination which must be made is that of
the calibration error which applies to the calibration gas
mixtures.  In figure 5.11.8 the terms "A" and "B" refer to
the raid-range gas mixture and the span range gas mixtures,
respectively.  For each error determination the mean dif-
ference between the actual value of the gas mixture  (as
resulted from a Method 6 test on the mixture within at
least one week prior to the calibration test)  and the value of
the gas mixture measured by the continuous analyzer system.
These are calculated using the following equation:
                          = n   i "i
where     X. = individual difference values
          ^ = sum of the individual values
           X = mean difference value
and        n = number of data points .
More specifically, the mean difference for each calibration
value is calculated in this way  (i.e., d = X)
      23 (Measurement  system reading . -actual value of "A")
                            2-65

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 and
       5
      2J (Measurement system reading.-actual value of "B")
The 95 percent confidence interval, as defined in section

5.11.1.6,  is calculated using the following equation:
              r- T    -    f '=>    /„ T v ^  _  r Y  \            (4)
              C.I.g^ -	     -*/n|i X..  ; - ( i AJ )            ^;
where     £X. = sum of all data points,

        t.975 = tl-a/2

and    C.I. q,- = 95 percent confidence interval
                estimate of the mean value of the differences.


The value for t Q7[- is dependent on the number of data  points
               • _/ / o
which, in the case of the calibration test,  is five  (n=5)  for

each mixture.  A  table from which t 9?5 can  be drawn  for
values of n up to 16 is given below  (table 5.11.2 ).

The calibration error for each gas mixture is determined  in

the following manner:


                         (Mean differencej+ C.I.  gr           /c\
   Calibration error =    .  calib. gas  concentration  x  10°'
   The value  CIqr-  defined in section 5.11.1.6 is actually the
   value  which,  when added to the mean,  defines the upper limit
   of the 95  percent confidence interval.
                                2-66

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              Table 5.11.2   Values for t
                                         .975
n
2
3
4
5
6
7
8
9
t.975
12.706
4.303
3.182
2.776
2.571
2.447
2.365
2.306
n
10
11
12
13
14
15
16

t.975
2.262
2.228
2.201
2.179
2.160
2.145
2.131
Av/^^X^N^V^(XJ^X^^^^^N^)?
This error is reported in percent and is not to exceed 5 per-
cent of each calibration gas mixture value  (sec. 5.11.1.4).

     The accuracy determination, reported in percent, is based
on the values recorded on the Operational Test Data Form
(fig. 5.11.6) as a result of the Method 8 sampling and analysis,
The equation used for the determination is:
                    Mean difference + C.I.
                                          .95
        Accuracy   Mean reference method value
                                               x 100
                                                   (6)
where
and
Mean difference =
Mean reference
   method value
the average difference between
the Reference Method measurement
values and the corresponding
interval averaged data from
the continuous measurement
system,

the value calculated using
equation  (1).
                            2-67

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     The accuracy should not exceed  20 percent as  specified
in section 5.11.1.4.
     The 2-hour zero drift, 2-hour calibration drift,  24-hour
zero drift, and 24-hour calibration  drift values are each
calculated using the same equation:
                     Mean drift
             Drift = -
+ C.I. qD-
          x 100              (7)
                       Emission standard

where     Drift is reported in percent of emission
                   standard,
          C.I.  Q[- is calculated as shown in equation (4) ,
              • y D
and       Emission standard is that which applies to the
                   source in question.

The limits of the drifts, as set forth under Performance
Specification 2 in section 5.11.1.5, are as follows:

     Zero drift  (2 hour)	£ 2 percent of span

     Zero drift  (24 hour)   	<_ 2 percent of span

     Calibration drift  (2 hour) ...   <_ 2 percent of span

     Calibration drift  (24 hour) .  .  . <_ 2.5 percent of span

The response time calculation is based on data documented on
the form such as shown  in figure 5.11.7.  The system response
time is determined by the slower average response time  (either
the measured upscale response time  or the downscale response
time) and should not exceed 15 minutes.  The specifications
(section 5.11.1.4) require that the response time be reported
                            2-68

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as the percent deviation from the slower time which is calcu-
lated in this way:
   Percent deviation _ Avg. upscale - avg. downscale x ,QQ   ,
    from slower time            slower time
     5.11.3.7  General Operation and Maintenance Procedures for
Non-Compliance Monitoring--The performance test as described
above serves three purposes.  They are:
     1.  Determines the adequacy of the installed system
         in meeting the performance specifications
         detailed in section 5.11.1.4.
     2.  Provides a 2-week period of uninterrupted data
         collection which, if the system meets the per-
         formance specifications, can be used to deter-
         mine the compliance of the stack being monitored
         to existing regulations.
     3.  Provides a basis for determining the operation
         and maintenance procedures which will be required
         by the continuous system as it is installed at
         the location in question.
This section of the quality assurance document will expound on
various aspects of purpose number 3.  Because Performance
Specification 2 is applicable to such a wide variety of sul-
fur dioxide monitoring systems,  only general guidelines on
operation and maintenance can be provided here for the moni-
toring system when it is not being subjected to the performance
test and is not being used for compliance monitoring.
     Unless otherwise specified, the data from the continuous
monitoring system should be reduced, validated and reported on
a regular basis.  Generally one hour average computations are
required.  These computations should be made using four equally
                            2-69

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spaced points over a 60 minute period commencing on the hour.
     The system must be automatically checked for zero and span
drift and adjusted accordingly at least every 24 hours.  When
the system is not equipped with automatic calibration at zero
and span, then a manual check should be made at least twice
weekly or as recommended by the manufacturer.  A dynamic
calibration, the input of at least two non-zero calibration
gases and appropriate adjustments made, and a response time
check should be performed routinely once every two weeks.
Depending upon the drift characteristics of the particular
system in question, each of these statements may or may not
have to be altered as the operator gains experience with the
analyzer, interface system, and source effluent.
     In all cases, calibration gases should be inputted as
close to the sampling probe as possible so that the calibra-
tion will include the interface system.  For those systems
where this is not possible, the use of Method 6 or 8 measure-
ments at least once per month is recommended.  Calculations
and comparisons of the Reference Method data with the corres-
ponding continuous system data would follow the procedures
discussed above in sections 5.11.3.5 and 5.11.3.6.
     When a dynamic calibration is performed at least twice
a month, the use of Method 6 or 8 (refs. 1 and 2) measurements
once per quarter is suggested.  This would involve taking at
least four samples, analyzing them, and comparing the data with
the continuous measurement data for the corresponding time period,
The comparison calculations would again follow the procedures
set forth above.
     Manufacturer's recommendations should be followed in per-
forming preventive maintenance on the system in the first
weeks of operation.  If the system exhibits excessive drifts
                           2-70

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or if accuracy tests prove the system to be malfunctioning,
preventive maintenance procedures should be reevaluated and
rewritten in view of the operating experience as discussed
below.
     5.11.3.7.1  Use of control charts.  The use of control
charts is highly recommended for three reasons:
     1.  They provide an "at-a-glance" description of
         the operation of the system.
     2.  They are a visual aid in maintaining consistency
         in the operation and maintenance procedures.
     3.  Trends in the monitoring data are obvious with
         the continued use of control charts and oncoming
         problems can often be foreseen and avoided.
     One example of a possible use of control charts is in
determining zero drift trends with a chart as shown in
figure 5.11.9.  In this example, the UCL (upper control limit)
and LCL (lower control limit) used are +5.0 percent and
-5.0 percent, respectively.  Recommended operating policies
could inlcude the following:
     1.  No single 24-hour zero drift value from the last
         adjustment should exceed 5 percent without
         the immediate performance of troubleshoot
         ing and correction procedures; and
     2.  Trouble shooting and correction procedures
         should be performed if four consecutive checks
         result in drifts of the same sign.
     In addition to determining zero drift trends, other pos-
sible applications of control charts include the visual depic-
tion of the mean,  the range, or the standard deviation of the
following measurement values over several sets of tests;
            • accuracy checks
            • calibration gas checks
                            2-71

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   4J

   §  + 5.0%

   4-1
   W

   •<->" + 3.3%
   JJ
   to
   us
   4J
   >W
   -H
4J
d
a)
u
      -  3.3%
CHECK NO.  j
                       ACTION LIMIT
                                                        •UCL
                       WARNING LIMIT
                         ACTION LIMIT
                                                           •LCL
                                                      10
DATE /TIME
OPERATOR
PROBLEM AND

CORRECTIVE

ACTION
    Figure 5.11.9   Sample  control chart for  use in
                     determining trends in zero  drift.
                           2-72

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           •  zero/calibration drift  (2-hour)
           •  zero/calibration drift  (24-hour)

     5.11.3.7.2  Use of operation and maintenance tables.  The
use of operation and maintenance tables is recommended to
increase the operator's efficiency, to provide a visual dis-
play of the requirements of the system, and to provide a
simplistic means of updating and adding to the routine pro-
cedures as the operator gains experience with the system in
question. Figure 5.11.10 gives an example of such a table.
     The operation and maintenance table should be formu-
lated by the operator who will have the major responsibility
for the system.  The basis for the table should be:  the
maintenance manuals supplied by the various component manu-
facturers, interaction with the factory representatives at
the installation of the system and, most important, personal
experience gained during the performance testing and any
time thereafter.  If possible,  the operator should visit the
manufacturing facility prior to the shipment of the system
and witness the bench testing.  Valuable information can be
acquiesced at this time which may otherwise be acquired only
after several weeks of operation and hours of troubleshooting.
     After the original operation and maintenance table is
formulated, its usefulness can be extended by a continuous
update of the information contained in the table.  For
instance, upon survey of a month's data, the operator may
determine that either more or less frequent calibration is
eminent for greater data validity.  Or, another case might
be extreme drift in the calibration values which would indi-
cate that restandardization of the calibration gas is
necessary.
                            2-73

-------
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5.11.4  Auditing Procedures
        The proper planning and implementation of an auditing
program allows the enforcement agency to estimate data
quality in terms of precision and accuracy at a given level
of confidence.  To realize maximum benefits from an auditing
program, the auditing procedures should be conducted inde-
pendently of the routine operation of the sampling network.
That* is, the audit checks should be made by individuals other
than the regular operator and using calibration standards
supplied and tested by the auditing agency.  Furthermore, the
audit checks should be performed without any special prepar-
ation or adjustment of the system.
     In conjunction with the special checks required during
performance testing and assuming that all routine calibration
and maintenance checks are performed judiciously, three
auditing checks will be sufficient to properly assess data
quality.
     1.  A visual check of the sampling interface,
         analyzer, and data recording system.
     2.  The extraction and analysis of at least four
         samples using the procedures outlined in
         Method 6 or 8 (refs. 1 and 2)  and a comparison of
         this data with the corresponding data for the
         same sampling period as recorded by the con-
         tinuous analyzer system.
     3.  A data processing check to evaluate data
         reduction and computation errors.
     An auditing level of three checks (n=3) per performance
test period and one check (n=l)  every 6 months during non-
compliance monitoring is used here for illustration purposes.
This assumes that sampling is carried out continuously for
non-conformance monitoring purposes and that the 2-week
                           2-75

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performance test period and compliance monitoring are
synonymous.  This would result in a minimum auditing level
of three checks (n=3) for a lot size of 12 (N=12) for data
reported quarterly.  The enforcement agency will specify the
actual auditing level required to meet specific monitoring
needs.
     Direction for performing each of the checks are given
here.
     5.11.4.1  Visual Checks—The auditor should prepare a
standard check sheet for each individual system which lists
all of the major components of the system and the parameters
which can and should be visually assessed.  Such parameters
would include:
          • Proper operation of the data recording
            system.
          • Proper location and position of the
            sampling probe.
          • Any major changes in the sample
            interface system.
          • Cleanliness of system components.
          • Undue deterioration of system
            components,.
The list would, of course, be more specific in the items
listed but these are general guidelines for what should be
included.  Any changes made in the system or information
resulting from an increased familiarity with the system
should be reflected in revisions of the list.
     5.11.4.2  Redundant Monitoring Using Appropriate Refer-
ence Method--The auditor or auditing crew, other than the
regular operator(s) of the system, must extract at least four
samples using the sampling techniques discussed in reference
1 for sampling periods of 1 hour each.  The manual method
probe tip must be placed adjacent to the continuous system
probe tip.  The samples should be analyzed by the auditor or
                            2-76

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an independent laboratory.  The data are documented and  sub-
mitted for assessment.  Data from the continuous system  which
was recorded simultaneously with the manual sampling should
be reduced- from the stripchart or magnetic tape recording
system.
     Results from both the Method 8 sampling and the continu-
ous system measurements should then be logged on an Audit
Data Form, an example of which is shown in figure 5.11.11.
The calculations given on the Audit Data Form correspond to
those specified in section 5.11.1.6.  If the accuracy calcu-
lated on the audit data form exceeds 20 percent, corrective
action should be taken by the regular operator(s)  to deter-
mine the cause of the extreme inaccuracies and the auditing
schedule should be changed to allow for more frequent audits.
     An alternate to the manual extraction and analysis of
samples is the measurement of calibration standards.  These
calibration standards used in implementing an audit check
should be prepared independently of the normal operations
and analyzed by Method 6 within 2 weeks prior to use or
demonstrated to be accurate and stable in some equiv-
alent manner.  The results of the analysis should be well
documented and available for use in the assessment of the
data from the continuous monitoring system.
     The calibration standards should be inputted at the
sampling probe or as close to the sample probe as possible.
In the case of in-situ optical sensors, special calibration
cells can be tested prior to the audit and inserted in the
optical pathlength of the sensor as specified by the manu-
facturer.  Allow the system to stabilize and record the
measurement.
     The use of three different upscale values of calibration
standards is recommended for audit purposes.  The following
                            2-77

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                      AUDIT DATA FORM
AUDITOR
REPORT DATA_

LABORATORY
  Test
  No.
Date
      Time
  Method 8
Samples  (ppm)
Analyzer  1-hour
 average  (ppm)
                                           di
where
  d.
   1
              Difference = 1 hour average minus the
              Method 8 average for the 1th extraction
          S, = Sum of the  differences

          S- = Sum of the  squares of the differences
          S, = Sum of the  Reference Method  values
Mean Difference
                                         ppm
95 Percent Confidence Interval
          C.I.95 = .4593
Mean Reference Method Value
                                     ppm
Accuracy
                        100
                                        percent
Check if accuracy < 20%
                                      n
 Figure  5.11.11   Sample  audit  data>form.
                            2-7!

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control limits should be exercised in analyzing the audit
data:  If the difference between any one continuous measure-
ment system value and the predetermined calibration standard
value is greater than 20 percent of the latter value or if
the average of the three differences exceed 10 percent, checks
should be made to determine the cause of the inaccuracies,
corrective action(s) taken, and the audit procedures repeated.
     The actions which must be taken might include:
     1.  Perform a regular zero and span check with the
         calibration standards used routinely.
     2.  If, after number 1 has been performed, the
         audit value still proves inconsistent with
         the known concentration value, a dynamic cali-
         bration should be performed with the calibra-
         tion standards used routinely.
     3.  Repair the system or perform maintenance, as
         required,  based on the calibration results.
     4.  Resume normal operation only after the results
         of an audit check prove satisfactory.
     5.11.4.3  Data Processing Check—Independent checks for
data processing errors should be incorporated into every
auditing program.  The checks should be made by an individual
other than the operator responsible for the original data
reduction, calculations, and reporting.  The procedures for
making the data processing checks are highly dependent upon
the sophistication of the data acquisition system.  In this
section, two types of systems will be discussed and general
procedural guidelines set forth.  They are stripchart
recording systems and magnetic tape recording systems.
     5.11.4.3.1  Stripchart recording systems.  The auditor
must check the following items if the continuous analyzer is
interfaced with a stripchart recording system:
                            2-79

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     1.  Accuracy with which the operator reads the
         data from the stripchart and records the data
         on a logsheet.
     2.  Equations used to transform the analog volt-
         age data to meaningful parts per million
         units.
     3.  Averaging process to obtain the required one-hour
         averages.
     4.  Method of data validation using calibration data
         as recorded on stripcharts and determinations
         of system malfunctions.
     Because most of the transfer equations which would be
required for a continuous SO,, monitoring system are relatively
simple, most errors will be the result of carelessness on the
part of the person reducing the data from the stripchart.
Systematic errors should be eliminated by careful training of
the operator as to the treatment of roundoffs and illegible
data.
     The auditor should reduce data for a randomly chosen
1-week period.  The check should be made starting with the
raw stripchart data and ending with the recording of the 1-hour
average SCU measurements in concentration units of parts per
million on a form similar to or the same as those forms used
routinely by system operator.  A comparison of the auditor's
measurement values with the originally determined values should
show a difference of less than + 3 percent.   If determined
necessary by the enforcement agency, all data since the last
audit may have to be checked and corrected if the difference
exceeds + 3 percent.
     5.11.4.3.2  Magnetic tape recording system.  If the data
acquisition system consists of a magnetic tape recorder,  then
                           2-80

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the first parameter listed in section 5.11.4.3.1 is not applic-
able.  It can generally be assumed that the error in reducing
data from magnetic tape by a computer is minimal.  However,
the latter two parameters which have to do with transfer
questions and data validation are very much applicable.  The
auditor must determine if the programming handles the raw data
such that the final output reflects the measured quantities.
Some of the more sophisticated systems will use the calibra-
tion data to generate new adjustment equations and will apply
these equations directly to the raw data.  The auditor must
study the raw data (in voltages)  and manually apply the appro-
priate equations to arrive at the average sulfur dioxide con-
centration over the recording interval in concentration units.
The auditor's data should not differ more than 1 percent from
the computerized data report.  If the difference is greater
than 1 percent, the entire system must be analyzed and the dis-
crepancies found and rectified.
                           2-81

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3.0  FUNCTIONAL ANALYSIS
          3-1

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                 3.0  FUNCTIONAL ANALYSIS

     Performance Specification 2 defines the performance speci-
fications and specification test procedures for continuous
monitors of sulfur dioxide and oxides of nitrogen from sta-
tionary sources.  As stated before, this quality assurance docu-
ment is treating only the determination of sulfur dioxide.  The
performance specification states that SO2 monitoring systems
must meet certain requirements but does not specifically state
the components of the system.  For this reason, the func-
tional analysis will be general and will exemplify a systems
approach which might be taken to formulate a functional analy-
sis of a particular system.
     This test method has been subjected to no collaborative
tests and relatively few performance tests (refs. 13 through 17),
so quantitative components is not available.  Engineering judg-
ments, based on considerable experience with both stack or air
quality sulfur dioxide analyzers and the associated sampling
and interface systems, were used in lieu of collaborative test
data in some of these areas of variable evaluation.  The sub-
ject of error analysis is discussed in references 18 and 19.
     Continuous systems for monitoring sulfur dioxide in
stack emissions can consist of several different component
combinations.  Basically though, the systems can be divided
into two categories, in situ and extractive.  Both types of
systems are shown graphically in figures 5.11.12 and 5.11.13,
respectively.
                             3-2

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3.1  DEFINITION AND DISCUSSION OF ERROR SOURCES

     The various phases of the continuous measurement will
each contain numerous sources of error.  Some errors can be
eliminated by a conscientious system operating staff, while
others are inherent within the system and can only be con-
trolled.  The paragraphs below discuss the components of error
for both types of systems.  The standard deviation stated in
this section are estimates given for illustrative purposes
only, and have not been substantiated by sufficient field data
to be stated as fact.

3.1.1  In-Situ Monitoring Systems
     Based on the fact that in-situ monitoring systems avoid
the need for extracting a gas sample from the stream, such
systems do not manipulate the sample of gas being measured.
This statement can lead to two conclusions:  1. in-situ
systems are simpler than extractive systems, and 2. the sources
of error will be fewer.  Both of these conclusions are valid
but must be discussed further for one to fully understand all
implications.
     First, the in-situ systems are generally simpler in that
they contain fewer major components and are usually based on
straightforward electro-optical principles.  The sophistica-
tion of the system comes into play in the engineering, design,
and fabrication of a system which can withstand the adverse
environment after installation and which will, indeed, provide
a measurement which is indicative of the concentration of SOp
in the total emissions.
     Second, the sources of error will be fewer with an in-situ
system.  However, in defining the error components, the
analyst will determine that the error due to each of these
                           3-3

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            ZERO
            CALIB.
            SOURCE
       SPAN
      CALIB.
      SOURCE
STACK
 GAS
STREAM
 IN-SCTU
   SO i
ANALYZER
>to

DATA
RECORDING
SYSTEM

•~
REPORT
   Figure 5.11.12
    Block diagram of a typical in-situ
    monitoring  system.
                       ESP AN
                       JALIB.
                        GAS
 STACK
  GAS
 STREAM
 SAMPLE
EXTRACTION
 SYSTEM
   SAMPLE
CONDITIONING
   SYSTEM
       Preferred System Design
       Alternate System Design
                   REPORT
                               :  ZERO
                               ! CALIB.
                                 GAS
                          SPAN  I
                          CALIB. !
                         ...GAS...J
   SO 2
ANALYZER
                      DATA
                   RECORDING
                     SYSTEM
    Figure  5.11.13
     Block diagram of a typical extractive
     monitoring  system.
                           3-4

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components is greater than with extractive systems, and that
the overall system error for both types of systems will
usually prove to be comparable.
     Error sources for in-situ monitoring systems include:
     1.  Measurement method errors, a ;
     2.  Calibration inadequacies and the associated
         drift problems, a ;
                          \-f
     3.  Data recording errors, a , and
     4.  Data processing errors, a .
These major components of the total system error are illus-
trated with a block diagram in figure 5.11.14 and are dis-
cussed below.
     3.1.1.1  Measurement Method Errors, a --Assuming that
most in-situ monitors are of the electro-optical variety, the
following list of error sources is generally applicable.
     1.  Accumulation of particulate matter on windows.
         A primary problem with in-situ monitors is the
         accumulation of particulate matter on the windows
         of the analyzer case.  The particulate matter
         will block the transmission of light through the
         windows resulting in a negatively biased response
         by the photodetector.  Two different methods are
         now used by commercially avilable instruments in
         an attempt to overcome the problem.  The use of
         dedicated fans that are directed across the face
         of the windows to avoid the accumulation of
         particulates is one method.   This method has
         proven partially inaffective due to the unreli-
         ability and inefficiency of the fanning system
         causing a negative error in the final measure-
         ment.  The second method is the use of a detection
         module which separates the beam into two sets of
                             3-5

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                                               i 
-------
component wavelengths  (ref. 20).  One range of
wavelengths is absorbed solely by S02 and the
second range is not absorbed by any of the con-
stituents of the stack gas.  The result of this
system is to totally discount the effect of the
particulate blocking of the transmitted and
reflected light.  Errors due to this second
method would be realized if the chosen wave-
lengths were indeed absorbed to some degree by
a stack gas constituent and would produce a
negative bias in the response of the photo-
detector.
Misalignment of the optical components.  The
misalignment of light sources, mirrors, diffrac-
tion gratings, and photodetectors is another  major
source of error in in-situ systems.  Design
objectives for any in-situ system must include
the fabrication of an instrument with as few
moving parts as possible and that is insensitive
to the constant vibrations and drastic tempera-
ture differences to which the instrument will be
subjected when installed on a stack.  A mis-
alignment of the optical components will cause
a loss of light intensity which will in turn
result in a negative bias in the system measure-
ments .
Detector insensitivity.  The detector must contain
filters so as to block detection of wavelengths
other than the wavelengths of interest.  In the
event of faulty filters or a secondary problem,
loss of detector sensitivity, the output readings
from the system will be biased.   Assuming that the
                    3-7

-------
         deteriorated  filters  will  allow other  wave-
         lengths  of light  to pass  through the analyzer
         secton and be included with  the proper wave-
         lengths  in determining an  intensity propor-
         tional to the concentration  of  sulfur  dioxide,
         the  existence of  deteriorated filters  will
         cause a  positive  bias in  the output signal.
         In the event  of a loss of  sensitivity  of the
         detector to the intensity  of the light passing
         through  the analyzer, the  output signal will
         be negatively biased.
     4.   Interferences by  other constituents of the
         stack gas. Water vapor and  other constituents
         of the stack  gas  can  cause interference in the
         electro-optical measurement  of SG>2 with an in-
         situ monitor. Careful selection of the absc-rp-
         tion peak chosen  for  a particular application
         can minimize  interferences.
     5.   Change in the absorption  characteristics of
         the sulfur dioxide component of the stack gas.
         According to  one  study, references 7 and 15,
         temperature variations of  the gas sample in  the
         slot can broaden  the  spectrum seen by  the spec-
         trometer.  Reported  in the study was that a  6°C
         change  in stack gas  temperature alters the output
         signal by 3 percent.   Such a radical  temperature
         effect will most  likely occur only at  very high
         stack gas temperatures and,  if the stack gas  tem-
         perature range is known,  appropriate  correction
         factors  can be applied to the data.
     The standard deviation of the measured SG>2 concentration
as a result of error due to each of the above-mentioned
                            3-i

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sources cannot be assigned in this document because of the
lack of sufficient field test data to support individual vari-
able analysis.  However, a standard deviation of the measured
SOp concentration resulting from all measurement method errors
is estimated to be 10 percent of the true concentration
in parts per million.  This estimate is given for illustrative
purposes only.  The standard deviation for a specific system
must be determined from performance test data and field
operation data for that system.
     3.1.1.2  Calibration Inadequacies and the Associated
Drift Problems, (^--Calibration techniques on an in-situ
                 O
monitor are generally complicated if performed manually and
are less reliable if performed automatically.  Supporting this
statement are the following problems existing in the calibra-
tion of in-situ monitors:
     1.  The manufacture and testing of calibration cells
         for use in calibrating in-situ monitors is more
         complex than the use of cylinder gas in cali-
         brating extractive monitors.  The pathlength
         from the cell to the photodetector and the
         amount of SO- in the cell are both variables in
         determining the span gas concentration as
         measured by the analyzer.
     2.  The pathlength between the photodetector and the
         light reflected back through the sample stack
         gas must generally be blocked during calibration.
         This procedure requires at least one moving part
         which must be able to function properly regard-
         less of ambient conditions, i.e., vibration,
         extreme temperatures, etc.
     3.  If the reference gas cell is calibrated at a given
         stack gas temperature and is used at another tem-
         perature without correction, the data will be
         erroneous.
                             3-9

-------
     4.  If the monitor must be calibrated manually, a
         qualified^ technician must climb the stack to the
         location of the monitor to perform the calibration,
         "Qualified" technician infers that the operator
         must be trained in the routine calibration and
         maintenance of the system so that he is aware of
         any mechanical or electrical problems should they
         occur (ref. 21).
     5.  Zero and span drift due to the analyzer's sensi-
         tivity to pressure and temperature changes between
         manual or automatic checks will alter the data
         accuracy.  In most cases the data cannot be accu-
         rately adjusted based on subsequent calibration
         data.
     For illustrative purposes only an estimated standard
deviation, a , of 8 percent is assumed for the true SO-
            C_-                                         ^-*
concentration as a result of error due to calibration
inefficiencies.
     3.1.1.3  Data Recording Errors, o --In continuous moni-
toring, data recording errors can result from inadequate
response of the mechanical stripchart recording to varying
sulfur dioxide concentration.  If magnetic tape recording
systems are used, errors in the recorded signal can result
from improper amplification of the analyzer output or mal-
functions in the recorder.  Because of the advanced state-
of-art in data acquisition systems, a standard deviation,
a ,  of 2 percent is estimated  (for illustrative purposes
only)  for the effects of data recording errors on the mea-
surement of sulfur dioxide by an in-situ monitor.
     3.1.1.4  Data Processing Errors, a —Data processing
errors can be avoided through extreme conscientiousness of
                           3-10

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the data processing personnel.  Errors may occur, though, in
making accurate estimates of average values-on illegible
stripchart recordings.  Other error sources are:
     1.  Misreading of calibration data from strip-
         chart recording or raw magnetic tape recording
         data.  This can take the form of data being read
         as span data when the system has -not actually
         stabilized at a span reading.
     2.  Carelessness in reading discrete measurement
         values with the utmost accuracy.
     3.  Mistakes such as manually reading the correct
         data and transposing the numerical figures
         upon recording the data.
     4.  Calculation errors in determining average con-
         centrations over an extended sampling period.
     5.  Time shifting of magnetic tape data resulting
         from improper input of start-time data into the
         computer or from loss of data without battery
         carryover for recorder time synchronization with
         real time (the latter is also applicable to strip-
         chart records).
     An estimate of the standard deviation of the measurement
value as a result of data processing errors, a , is 3 per-
cent (for illustrative purposes only).
     3.1.1.5  Total Standard Deviation, a—All of the error
terms discussed above can be considered independent for
analysis purposes,  hence the total bias in the continuous
measurement of sulfur dioxide by in-situ monitors is the
algebraic sum of the biases of the individual terms.  The
                        2
variance of the data, a  , is the sum of the variances of
the individual error terms as follows:
                           3-11

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                 2     2 ^   2 ^   2 ^   2
               aT  = °m  + CTc  + ar  + ap

Using the estimated example values given in the previous para-
          2
graphs, a   = .0177 or a  = 13.3 percent of the true concen-
tration of sulfur dioxide.  An exact value of o  for a particu-
lar system can only be determined after a sufficient quantity
of field data has been taken and analyzed.
3.1.2  Extractive Monitoring Systems
     The variable analysis of extractive monitoring systems
can only be accomplished with accuracy after a comprehen-
sive definition of the system components has been made.  As
depicted in figure 5.11.15, the major components of system
error can be divided into five categories:
     1.  Sampling interface errors, a, ;
                                      e
     2.  Method measurement errors, a  ;
                                     m
                                      e
     3.  Reference sample errors, a  ;
                                    e
     4.  Data recording errors, a, ; and
                                  e
     5.  Data processing errors, a
                                  pe
Each of the above categories are discussed separately in the
paragraphs below.
     3.1.2.1  Sampling Interface Errors, af —The sampling
                                          •"-e
interface consists of the components of a measurement system
which extract and in some way modify the gas sample to be
analyzed as a representative sample of the total stack gas.
In accomplishing the objective of the interface system,
which is to supply a sample with characteristics compatible
with the analyzer in use, the interface system may perform
any of the following operations in addition to the extrac-
tion:  transportation, filtration, or conditioning of the
sample in terms of temperature or water content reduction.
                           3-12

-------
DATA
PROCESSING
ERRORS

DATA
RECORDING
ERRORS
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                                     3-13

-------
     Obvious sources of error in most types of interface
system include:
     1.  Loss of sample due to leaks or adsorption in
         the sampling probe or sample lines,
     2.  Malfunction of control valves,
     3.  Loss of sample in water vapor reduction
         'technique,
    >4.  Incorrect sample flow due to plugging by
         particulates which can occur through the use of
         ineffective filtering, failure to change filters
         at reasonable intervals, or incorrect position-
         ing of the probe filter.
     5.  Inaccurately assumed dilution ratio if dilution
         system is used,
     6.  Improper operation of condensation or water
         vapor removal system which results in higher
         actual concentration of water vapor in sample
         entering analyzer than is assumed,
     7.  Improper maintenance of sample gas temperature
         compatible with the analyzer, and
     8.  Chemical reaction with interface construction
         materials.
     Most of the above sources of error can be eliminated with
a comprehensive operation and maintenance program designed to
meet the requirements of the specific system in use  (ref. 10).
An estimated standard deviation  (for illustrative purposes
only) of the final measurement due to interface system errors,
af , is 10 percent of the actual sulfur dioxide concentration.
  e
     3.1.2.2  Measurement Method Errors, am —Just as with the
                                           e
in-situ monitoring systems discussed in section 3.1.1.1, each
                            3-14

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of the analyzing techniques used in extractive monitoring sys-
tems have certain inherent error sources.  Because of the wide
variety of techniques this document will list only a few of
these error sources which may or may not be applicable to all
analyzers.  The common error sources are:
     1.  Interferences by other constituents of the stack
         gas.   Water vapor, nitric oxide, sulfuric acid,
         and hydrogen sulfides are some constituents of
         the stack gas which may interfere with the
         measurement of sulfur dioxide thereby reducing
         the specificity of the measurement method.
         Although this error source may be considered
         dependent upon the efficiency of the condi-
         tioning system with respect to the interfering
         species, it is assumed that the inefficiency
         of the conditioning system below specified
         limits contributes to a,,  and that those same
                                 Ci
         specified limits are used in determining
         errors due to the sensitivity of the analyzer
         to the minimum amount of the interfering species
         which comes under a  .  This assumption allows
         both  error sources to be considered independent
         for purposes of variable analysis in this document.
     2.  Plugging of the internal sample lines.  The
         flow rate through the analyzer can be hampered
         by undue plugging of the sample lines internal
         to the analyzer resulting from accumulation of
         particulate matter and water vapor beyond the
         minimum efficiency specifications of the inter-
         face  components.
     3.  Improper operation of internal sample dryers.
         The malfunction of internal sample dryers not
                           3-15

-------
         compensated for with external components can
         cause interference above the amount adjusted
         for by the analyzer.
     4.  Initial setup and calibration of system.  Dis-
         cussions on the influence of setting up and
         calibrating a system at a large full-scale
         value relative to existing emission levels have
         shown that the analyzer accuracy can be greatly
         reduced (ref. 17).
     5.  Zero and calibration drift.  Zero and span drift
         due to the analyzer's sensitivity to pressure
         and temperature changes between manual or auto-
         matic checks will alter the data accuracy.  In
         most cases the drift is random and the data can-
         not be accurately adjusted based on subsequent
         calibration data.
     An estimated (for illustrative purposes only) standard
deviation of 8 percent of the true measurement value is used
here for illustrative purposes as representative of the error
due to the analysis technique.
     3.1.2.3  Reference Sample Error, a  —The analysis of
sulfur dioxide by extractive continuous monitors is subject
to error from inaccuracies in the calibration gases used
for either manual or automatic calibration and in the calibra-
tion technique.  Most extractive measurement systems are
calibrated with cylinder gas.  Error in the assumed concen-
tration value of the reference gas will result in a bias of
the measurements for the lifetime of the cylinder.  Error in
the calibration technique is a function of the similarity
between the pathway of the sample stack gas through the
system and the pathway of the calibration gas.  Ideally,
                            3-16

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the calibration gas should be input at the sample probe and,
upon entering the analyzer, would go through the same inter-
nal sample lines to the final measurement cell.
     The standard deviation of the true measurement value due
to calibration error, a  , is estimated at 8 percent of the
                       ce
true measurement value.
     3.1.2.4  Data Recording Errors, a  --As is the case with
in-situ monitoring, data recording errors can result from
inadequate response of the mechanical stripchart recorder to
varying sulfur dioxide concentration.  If magnetic tape
recording systems are used, error in the recorded signal can
result from improper amplification of the analyzer output
or malfunctions in the recorder.   Because of the advanced
state-of-art in data acquisition systems, a standard
deviation,  a  , of 2 percent is  estimated for the
            re
effects of data recording errors on the measurement of
sulfur dioxide by an extractive monitor.
     3.1.2.5  Data Processing Errors, a  —As with in-situ
                                       Pe
monitoring systems, data processing errors can be avoided
through extreme conscientiousness of the data processing
personnel.   Errors may occur, though, in making accurate
estimates of average values on illegible stripchart record-
ings.   Other error sources are:
     1.  Misreading of calibration data from strip-
         chart recording or raw magnetic tape
         recording data.   This can take the form of
         data being read as span data when the system
         has not actually stabilized at a span
         reading.
     2.  Carelessness in reading discrete measurement
         values with the utmost accuracy.
                           3-17

-------
     3.  Mistakes such as manually reading the correct
         data and transposing the numerical figures
         upon recording the data.
     4.  Calculation errors in determining average
         concentrations over an extended sampling
         period.
     5.  Time shifting of magnetic tape data resulting
         from improper input of start time data into
         the computer or from loss of data without
         battery carryover for recorder time synchroni-
         zation with real time (the latter is also
         applicable to stripchart records).
     An estimate of the standard deviation of the measurement
value  as a result of data processing errors, a  , is 3 per-
                                              Pe
cent.
     3.1.2.6  Total Standard Deviation, qm —All of the error
                                         ie
terms  discussed above are independent, hence the total bias
in the continuous measurement of sulfur dioxide by extractive
monitors is the algebraic sum of the individual terms.  The
variance of the data, a^ ^, is the sum of  the variances of
                       le
the  individual error terms as follows:
Using the estimated values given in the previous paragraphs,
a  2 =  .0183 and a   =13.5 percent of the true concentra-
 ie               -"-e
tion of sulfur dioxide.  This value is comparable to  results
from evaluations of several monitoring systems which  range
between 10 and 15 percent  (see refs. 13 through 17).
                            3-18

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LIST OF REFERENCES
         R-l

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                    LIST OF REFERENCES
1.   J.  W.  Buchanan and D.  E.  Wagoner,  Guidelines for Develop-
    ment of a Quality Assurance Program,  "Determination of
    Sulfur Dioxide Emissions  from Stationary Sources,"  EPA-
    650/4-74-005-e, Office of Research and Development, U.S.
    Environmental Protection  Agency,  Washington, D.  C.;
    November 1975.

2.   J.  W.  Buchanan and D.  E.  Wagoner,  Guidelines for Develop-
    ment of a Quality Assurance Program,  "Determination of
    Sulfuric Acid Mist and Sulfur Dioxide Emissions  from Sta-
    tionary Sources," EPA Contract Number 68-02-1234, Program
    Element Number 1HA327, Office of  Research and Develop-
    ment,  U.S. Environmental  Protection Agency,  Washington,
    D.  C.; November 1975.

3.   Franklin Smith and Denny  E. Wagoner,  Guidelines  for
    Development of a Quality  Assurance Program,  "Determina-
    tion of Moisture in Stack Gases,"  EPA Contract Number
    68-02-1234, Program Element Number 1HA327, Quality Assur-
    ance and Environmental Monitoring Laboratory, National
    Environmental Research Center, Research Triangle Park,
    North Carolina, August 1974.

4.   E.  F.  Brooks, C. A. Flegal, L. N.  Harnett, M. A. Kolpin,
    D.  J.  Luciani, and R.  L.  Williams, "Continuous Measure-
    ment of Gas Composition from Stationary Sources," EPA-
    600/2-75-012, U.S. Environmental  Protection Agency,
    Office of Research and Development, Washington,  D.  C.;
    July 1975.

5.   Dr. Harry C. Lord, "Verification  of In-Situ Source Emis-
    sion Analyzer Delta, " paper presented at ASTM/NBS/EPA
    Symposium, Calibration in Air Monitoring, Boulder,
    Colorado, August 1975.

6.   Dr. Harry C. Lord, Dale W. Egan,  Paul E. Paules, Dr.
    Geoffrey B. Holstrom,  "Instantaneous, Continuous,
    Directly On-Stream Boiler Flue Gas Analysis," paper
    presented at Instrument Society of America,  24th Annual
    Power Industry Symposium, New York City, May 1971.

7.   Robert N. Hager, Jr.,  "Derivative Spectroscopy with
    Emphasis on Trace Gas Analysis,"  Analytical Chemistry,
    Volume 45, Number 13,  pages 1131A-1138A, November 1973.
                           R-2

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 8.  James B.  Homolya,  "Coupling Continuous Gas Monitors to
     Emission  Sources," Chemical Technology, Volume 4,
     Number 7, July 1974.

 9.  William Zolner,  Edward Cieplinski,  Denis Helm, "Source
     Level SC>2 Analysis Via Pulsed Fluorescence," Thermo
     Electron  Corporation,  Waltham, Massachussets 02154.

10.  J.  A. Jahnke,  J.  L. Cheney, and J.  B.  Homolya, "Inter-
     ferences  in SC>2  Fluorescence Monitoring Instruments,"
     Environmental  Protection Agency, Environmental Research
     Center, Research Triangle Park, North Carolina;  1976.

11.  Robert K. Stevens, Lewis F. Ballard,  and Clifford E.
     Decker, "Field Evaluation of Sulfur Dioxide Monitoring
     Instruments,"  U.S. Environmental Protection Agency,
     Air Pollution  Control  Office, Raleigh, North Carolina.

12.  K.  J. McNulty, J.  F. McCoy, J. H.  Becker,  J. R.
     Ehrenfeld,  and R.  L. Goldsmith, "Investigation of
     Extractive Sampling Interface Parameters," EPA-750/2-
     74-089, Environmental  Protection Technology Series,
     Environmental  Protection Agency, Research Triangle
     Park, North Carolina,  October 1974.

13.  James Buchanan,  "A Quality Assurance  Program for  the
     Environmental  Protection Agency Wet Limestone Scrubber
     Demonstration  Project,  Shawnee Steam-Electric Plant,
     Paducah,  Kentucky," Final Report for  Contract Number
     60-02-1398,  Task Order  No.  20,  Industrial  Environmental
     Research  Laboratory, Environmental  Protection Agency,
     Research  Triangle  Park,  North Carolina;  December  1975.

14.  Fredric C.  Jay,  "Monitoring Instrumentation for the
     Measurement of Sulfur  Dioxides in  Stationary Source
     Emissions,"  EPA  Study  Number EPA-R2-73-163,  Contract
     Number EHSO 71-23,  Environmental Protection Agency,
     Research  Triangle  Park,  North Carolina;  February  1973.

15.  Robert K.  Stevens  and  William F. Herget,  "Analytical
     Methods Applied  to Air  Pollution Measurements,"
     Chemistry and  Physics  Laboratory, National Environmental
     Research  Center, U.S.  Environmental Protection Agency,
     Research  Triangle  Park,  North Carolina;  Ann Arbor
     Science Publishers, Inc., P.O.  Box  1425,  Ann Arbor,
     Michigan;  1974.
                           R-3

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16.  James B. Homolya, "Data Output for Monitoring SC>2
     Emissions from a Stationary Source," International
     Conference and Exhibit at Houston, Texas, Instrument
     Society of America Reprint, Pittsburgh, Pennsylvania
     15222.

17.  W. L. Bonam and W. J. Fuller, "Certification Experience
     Extractive Monitoring Systems," paper presented at the
     ASTM Symposium on Calibration Source Monitors, Boulder,
     Colorado; August 1975.

18.  Philip R. Bevingtcn,  Data Reduction and Error Analysis
     for the Physical Sciences, McGraw-Hill, New York; 1969.


191  D. C. Baird, Experimentation;  An Introduction to
     Measurement Theory and Experiment Design, Prentice-Hall,
     New Jersey; 1962.

20.  Robert J. Bambeck and Hermann F.  Huettemeyer, "Operating
     Experience with In-Situ Power Plant Stack Monitors,"
     paper presented at the 67th Annual Meeting of the Air
     Pollution Control Association, Denver,  Colorado;  June
     1974.

21.  F. Dale Huillet, "The Monitoring of SO2, NO, CO,  and
     Opacity with an In-Stack Dispersive Spectrometer," Scott
     Paper Company, Everett, Washington.
                            R-4

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APPENDIX A
     A-l

-------
 46268
      RULES  AND REGULATIONS
  Performance Specification 3—Performance
specifications  and specification test  proce-
dures for monitors of CO2 and O2 from sta-
tionary sources.
  1. Principle and Applicability.
  1.1  Principle. Effluent gases are continu-
ously sampled and are analyzed for  carbon
dioxide or oxygen  by a  continuous monitor-
ing system. Tests of the system are performed
during a minimum operating period to deter-
mine  zero drift,  calibration  drift, and re-
sponse time characteristics.
  1.2  Applicability, This performance speci-
fication  is applicable to evaluation of  con-
tinuous monitoring systems for measurement
of carbon dioxide or oxygen. These specifica-
tions  contain test procedures, installation re-
quirements, and  data  computation  proce-
dures for evaluating the acceptability of the
continuous  monitoring  systems  subject  to
approval  by  the  Administrator.  Sampling
may include either extractive or non-extrac-
tive (in-situ)  procedures.
  2. Apparatus.
  2.1  Continuous Monitoring  System  for
Carbon Dioxide or  Oxygen.
  2.2  Calibration  Gas  Mixtures.  Mixture  of
known concentrations  of carbon  dioxide  or
oxygen in nitrogen or  air. Midrange  and  90
percent  of span carbon dioxide  or  oxygen
concentrations are required. The 90 percent
of span gas mixture  is to be used  to set and
check the analyzer span and is  referred  to
as span  gas.  For  oxygen  analyzers,  if the
span  is higher than  21  percent O2, ambient
air may be used in place of the 90  percent of
span  calibration  gas  mixture.  Triplicate
analyses of the gas mixture (except ambient
a)r)  shall  be  performed  within  two weeks
prior  to  use using Reference  Method  3  of
this part.
  2.3 Zero Gas. A gas  containing less than 100
ppm of carbon dioxide or oxygen.
  2.4  Data Recorder. Analog chart recorder
or other suitable  device with input voltage
range  compatible with  analyzer system out-
put. The resolution  of  the recorder's  data
output shall be sufficient to allow completion
of the test procedures within  this specifica-
tion.
  3. Definitions.
  3.1  Continuous  Monitoring  System.  The
total equipment required for the determina-
tion of  carbon dioxide or oxygen  in a given
source effluent. The system consists of three
major subsystems:
  3 :  1 Sampling Interface  That portion of
the continuous monitoring system that per-
forms one  or  more of the following  opera-
tions: delineation, acquisition, transporta-
tion,  and conditioning of a sample  of  the
source effluent or protection of the analyzer
from  the hostile aspects of the sample or
source environment.
  312 Analyzer  That portion of the  con-
tinuous monitoring system which senses the
pollutant gas and generates a signal output
that is a function of the pollutant concen-
tration.
  3.1.3 Data Recorder. That portion  of  the
continuous monitoring system that provides
a permanent record of the output signal in
terms of  concentration units.
  3.2  Span  The value of oxygen or carbon di-
oxidt! concentration at which the continuous
monitoring system is  set  that produces  the
maximum data display output. For the pur-
poses  of  this method, the span shall  be set
no less than 1.5  to 2.5 times the normal car-
bon dioxide or normal oxygen concentration
in tha stack gas of the affected facility.
  3.3  Midrange. The value of oxygen or car-
bon dioxide concentration that as representa-
tive  yt the normal conditions  in  the stack
gas of the affected facility at typical operat-
ing rates.
  3.4  Zero  Drift. The  change in the contin-
uous monitoring system output over a stated
periol of time of normal  continuous  opera-
tion .vhen the carbon dioxide or oxygen con-
centration at the time for the measurements
is zero.
  3.5  Calibration Drift. The  change  in  the
conti luous monitoring system output over a
stated time period of normal continuous op-
eration when  the carbon  dioxide or oxygen
continuous monitoring system is measuring
the concentration of span gas.
  3 6  Operational Test Period.  A minimum
period of time over which  the continuous
monitoring system is  expected to operate
withii certain  performance  specifications
without unscheduled maintenance, repair, or
adjustment.
  3 7  Response time. The time interval from
a step change  in concentration at the input
to th« continuous monitoring system  to the
time at which 95 percent of the correspond-
ing final value Is displayed on the continuous
monitoring system data recorder.
  4. Installation Specification.
  Oxygen or carbon dioxide continuous mon-
itoring  systems shall be installed at a loca-
tion where measurements are directly repre-
sentative  of  the total effluent from  the
affected facility or representative of  the same
effluent sampled by a SO2 or NO, continuous
monitoring  system.  This requirement shall
be  complied with by use of applicable re-
quirements in Performance Specification 2 of
this appendix as follows:
  4.1  Installation of Oxygen or Carbon  Di-
oxide Continuous Monitoring  Systems Not
Used  to Convert Pollutant Data. A  sampling
location shall be selected in accordance with
the  procedures  under  paragraphs  4.2.1  or
4.2.2, or Performance Specification  2 ol this
appendix.
  4.2  Installation of Oxygen or Carbon  Di-
oxide Continuous Monitoring Systems Used
to Convert Pollutant Continuous Monitoring
System Data to Units of Applicable Stand-
ards. The diluent continuous monitoring sys-
tem (oxygen or carbon  dioxide) shall be in-
stalled at a sampling location where  measure-
ments that can be made are representative of
the effluent gases sampled by the pollutant
continuous monitoring  system(s). Conform-
ance  with this requirement  may be accom-
plished in any of the following ways:
  421 The sampling location for the diluent
system shall be near the sampling location for
the pollutant continuous monitoring system
such  that  the same approximate  polnt(s)
(extractive  systems)  or path  (in-situ sys-
tems)  in the  cross section is sampled  or
viewed.
  4.2.2 The diluent and pollutant continuous
monitoring systems may be installed at dif-
ferent locations if the effluent gases at both
sampling locations are nonstratified  as deter-
mined under paragraphs 4.1 or 4.3,  Perform-
ance  Specification  2  of this appendix and
there is no in-leakage occurring between the
two sampling locations. If the effluent gases
are stratified  at  either location, the  proce-
dures  under  paragraph 4.2.2,  Performance
Specification 2 of this appendix shall be used
for installing continuous monitoring systems
at that location.
  5. Continuous Monitoring System  Perform-
ance Specifications.
  The continuous monitoring  system shall
meet the performance specifications In Table
3—1 to be considered acceptable under this
method.
  6. Performance Specification  Test  Proce-
dures.
  The following test procedures shall be used
to determine conformance with the require-
ments of paragraph 4. Due to the wide varia-
tion existing in analyzer designs and princi-
ples of  operation, these procedures are not
applicable to all analyzers. Where this occurs,
alternative procedures, subject to the  ap-
proval of the  Administrator,  may be em-
ployed. Any such alternative procedures must
fulfill the  same  purposes  (verify  response,
drift, and accuracy) as the  following proce-
dures, and  must clearly demonstrate con-
formance  with specifications In Table 3-1.

  6.1 Calibration Check. Establish a cali-
bration curve for the continuous moni-
toring system using zero,  midrange, and
span concentration gas mixtures. Verify
that the resultant  curve of analyzer read-
ing compared  with the calibration gas
value is consistent with the expected re-
sponse curve as described by the analyzer
manufacturer. If  the expected response
curve is not produced, additional cali-
bration gas measurements shall be made,
or additional steps undertaken to  verify
                                 FEDERAL REGISTER  VOL.  40,  NO. 194—MONDAY, OCTOBER 6, 1975

                                                          A-2

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                                                  RULES  AND  REGULATIONS
                                                                                46269
the accuracy of the response curve of the
analyzer.
  6.2 Field Test for Zero Drift and Cali-
bration  Drift.  Install and  operate  the
continuous monitoring system in accord-
ance with the manufacturer's written in-
structions and drawings as  follows:
  TABLE 3-1.—Performance  specifications
       Parameter
                           Specification
1. Zero drift (2 h) i  	  <0.4 pet Ch or CO;
2. Zero drift (24 h) 1	  <05pct Chor COj.
3. Calibration drift (2 h) ' _.  <0 4 pet 02 or CCh.
4 Calibration drift (24 h) 1.  <0.5 pet 02 or CO;
5. Operational period	  168 h minimum
6. Response time	-  10 nun
  i Expressed as sum of absolute mean value plus 95 pet
confidence interval of a series of tests.
  6 2.1 Conditioning Period. Offset the zero
setting at least 10 percent of span so that
negative zero drift may be quantified  Oper-
ate the  continuous monitoring system  for
an initial 168-hour conditioning period in a
normal operational manner
  6.2.2. Operational Test Period. Operate the
continuous monitoring system for an addi-
tional 168-hour period maintaining the zero
offset. The system shall monitor the source
effluent  at  all times  except  when  being
zeroed, calibrated, or taackpurged.
  6.2.3 Field Test for Zero Drift and Calibra-
tion  Drift.  Determine  the  values  given  by
zero and midrange gas concentrations at two-
hour intervals until 15 sets of data are ob-
tained. For non-extractive continuous moni-
toring systems, determine  the  zero  value
given by a mechanically produced zero con-
dition or by computing the zero value from
upscale measurements using calibrated gas
cells  certified by the manufacturer. The mid-
range checks shall  be performed  by using
certified  calibration  gas cells  functionally
equivalent to less than 50  percent of span.
Record these readings on the example sheet
shown in Figvire 3-1. These  two-hour periods
ne
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46270
RULES AND REGULATIONS
3ata Zero Span
Set/'" Time Zero Drift Span Drift
to. Begin End Dat
-------
                      RULES AND REGULATIONS
                                                                                          46271
Datt of Test
Span Gas Concentration
Analyzer Span Setting
                    1.
Upscale             2.
                    3.
                                    _ppm
                                     seconds
                                     seconds
                                     seconds
              Average upscale  response
Downscal;
                       1.
                       2.
                       3.
seconds
seconds
seconds
              Average  downscale  response
                                                    seconds
                                                      seconds
                                                   seconds
System average response time (slower time) = _
 , j.«v,<*t,cft'  frora slower ...  average  upscale minus average downscale
                                "
system average response
                                     slower time
                         Figure  3-3.  Response
                  [PR Doc.75-26565 Filed lC-3-75;&45 am]
      FEDERAL REGISTER, VOL. 40, NO. 194—MONDAY, OCTOBER 6, 1975
                               A-5

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APPENDIX  B
   B-l

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                         APPENDIX B
                     GLOSSARY  OF  SYMBOLS
This is a glossary of the symbols used in this document.

Symbols used and defined in the reference method  (section

5.11.1) are not repeated here.

A        Given wavelength of light.

d        Difference between average measured concentration
         value of calibration gas A and the continuous
         measurement system reading during calibration error
         test.

d        Difference between average measured concentration
         value of calibration gas B and the continuous
         measurement system reading during calibration error
         test.

SUM 1    Sum of the d^ values determined in a calibration
         error test.
                                                2
SUM 2    Sum of the sc[uares of the d^ values (d^  ) used in
         the calibration error calculation.

SUM 3    Sum of the dB values determined in a calibration
         error test.
                                                2
SUM 4    Sum of the squares of the dg values (dB  ) used in
         the calibration error calculation.
d.       Difference between the reference method  value  (ppm)
 1       and the average analyzer measurement for the ±tn
         interval in sin accuracy test.
d.2      Square of d^ value for ith interval.

SUM 5    Sum of the d^ values for nine accuracy test
         measurements.
                                                2
SUM 6    Sum of the sc[uares of the di values (di  ) used in
         a calculation of continuous system accuracy.

SUM 7    Sum of the reference method measurements determined
         in an accuracy test and used in the calculation of
         system accura.cy.

AZ       Difference in zero reading from zero reading taken
         two hours before.
  2
AZ       Square of AZ value.
                             B-2

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C        Calibration drift calculated using the 2-hour span
         drift (ppm) minus the zero drift  (ppm) for the
         corresponding time period.
 2
C        Square of 2-hour calibration drift value.

SUM 8    Sum of the AZ values taken in a series of 2-hour
         zero drift tests.
                                                2
SUM 9    Sum of the squares of the AZ values  (AZ ) taken in
         a series of 2-hour zero drift tests.

SUM 10   Sum of the calibration drift (C) values calculated
         from a series of calibration drift tests.
                                                          2
SUM 11   Sum of the squares of calibration drift values  (C )
         calculated after a series -of 2-hour calibration
         drift tests.
AZ?.     Difference in zero reading from zero reading taken
         24 hours before.
AZ242    Square of the 24-hour zero drift value.
C~,      Calibration drift calculated using the 24-hour span
         drift (ppm) minus the zero drift  (ppm) for the
         corresponding time period.
C,-,.2     Square of the 24-hour calibration drift value.

SUM 12   Sum of the 24-hour zero drift values taken from a
         series of 24-hour drift tests.

SUM 13   Sum of the squares of the 24-hour zero drift values
         taken from a series of 24-hour zero drift tests.

SUM 14   Sum of the 24-hour calibration drift values.

SUM 15   Sum of the squares of the 24-hour calibration drift
         values (C242)•
SUM 16   Sum of the upscale response time measurement values
         (seconds).
SUM 17   Sum of the downscale response time measurement
         values (seconds).
n        Sample size for the auditing.

UCL      Upper quality limit determined from performance test
         data and used in assessment of routine calibration
         data.

LCL      Lower quality limit determined from performance test
         data and used in assessment of routine calibration
         data.
                            B-3

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d.       Difference between continuous system 1-hour average
 1       data minus the Method 8 value for the ith measure-
         ment.

S,       Sum of the differences (d^) calculated from a series
         of Method 8 measurements compared with continuous
         system data.
                                                  2
S~       Sum of the squares of the differences (dj_ )

S-,       Sum of the reference method values calculated from
         a series of measurements.
CR       Mean reference method value calculated from audit
         data.

a        Standard deviation of in-situ continuous method
         measurement due to measurement method errors.
a        Standard deviation of continuous method measurement
         due to calibration inadequacies and the associated
         drift problems in in-situ monitoring systems.

a        Standard deviation in in-situ measurement due to
 r       data recording errors.

a        Standard deviation of in-situ measurement due to
 "       data processing errors.

a_       Standard deviation of the in-situ measurement which
         is a function of the component errors.

a^       Standard deviation of extractive system measurement
  e      due to sampling interface errors.
a        Standard deviation of extractive continuous method
 me      measurement due to measurement method errors.
a        Standard deviation of continuous method measurement
 °e      due to calibration inadequacies and the associated
         drift problems in extractive monitoring systems.

a        Standard deviation of extractive measurement due to
 re      data recording errors.
a        Standard deviation of extractive measurement due to
 ^e      data processing errors.

a™       Standard deviation of the extractive measurement
  e      which is a function of the component errors.
                           B-4

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APPENDIX  C
   C-l

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                         APPENDIX C


                     GLOSSARY OF TERMS


The following glossary lists and defines the statistical

terms as used in this document.
Accuracy
Bias


Lot
Measurement method
Measurement process
Population
Precision
Quality audit
Quality control
check
Sample
A measure of the error of a process
expressed as a comparison between the
average of the measured values and the
true or accepted value.  It is a func-
tion of precision and bias.

The systematic or nonrandom component
of measurement error.

A specified number of objects to be
treated as a group, e.g., the number
of field tests to be conducted by an
organization during a specified period
of time (usually a calendar quarter).

A set of procedures for making a
measurement.

The process of making a measurement,
including method, personnel, equipment,
and environmental conditions.

The totality of the set of items, units,
or measurements, real or conceptual,
that is under consideration.

The degree of variation among succes-
sive, independent measurements (e.g.,
on a homogeneous material) under con-
trolled conditions, and usually
expressed as a standard deviation or
as a coefficient of variation.

A management tool for independently
assessing data quality.

Checks made by the field crew on certain
Items of equipment and procedures to
assure data of good quality.

Objects drawn, usually at random, from
the lot for checking or auditing
purposes.
                           C-2

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
 1 REPORT NO
 EPA-650/4-74-005 o
                                                            3. RECIPIENT'S ACCESSIOWNO
4. TITLE ANDSUBTITLE
 GUIDELINES FOR DEVELOPMENT  OF A QUALITY ASSURANCE
 PROGRAM:   DETERMINATION OF  SULFUR DIOXIDE EMISSIONS
 FROM  STATIONARY SOURCES BY  CONTINUOUS MONITORS
             5. REPORT DATE

                 Marrh 1Q76
             6. PERFORMING ORGANIZATION CODE
7 AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 P. S.  Wohlschlegel
9 PERFORMING ORGANIZATION NAME AND ADDRESS

 Research  Triangle Institute
 Research  Triangle Park, NC   27709
             10 PROGRAM ELEMENT NO.

                 1HA327
             11 CONTRACT/GRANT NO.


                 68-02-1234
 12 SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
 Environmental  Monitoring and  Support Laboratory
 Office  of  Research and Development
 U.S. Environmental Protection Agency
 Washington,  D.  C.   20460	
             14. SPONSORING AGENCY CODE
                 EPA-ORD
 15. SUPPLEMENTARY NOTES
16. ABSTRACT

       Guidelines  for the quality  control  of the continuous measurement of  sulfur
 dioxide emissions by Performance  Specification 2 are  presented.  These include:

       1.  Good  operating practices;

       2.  Directions on how to assess  performance and to  qualify data;

       3.  Directions on how to identify trouble and to  improve data qualityi

       4.  Directions to permit design  of  auditing activities.

       The document is not a research report.   It is designed  for use by operating
 personnel.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                                                         c.  COSATI Field/Group
 Quality Assurance
 Quality Control
 Air Pollution
 Gas Analysis
                             13H
                             14D
                             13B
                             07D
                             14B
18 DISTRIBUTION STATEMENT

Release to Public
19. SECURITY CLASS (This Report)

  Unclassified
                                              20. SECURITY CLASS (This page)
                                                 Unclassified
21. NO. OF PAGES

     123	
     e
EPA Form 2220-1 (9-73)
                                            C-3

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