EPA-340/1 -86-011
Handbook for the Review
of Excess Emission Reports
Prepared by
Perrin Quarles
Perrin Quarles Associates, Inc.
Charlottesville, Virginia 22901
and
James W. Peeler
Entropy Environmentalists, Inc.
Research Triangle Park, North Carolina 27709
Under Contract No. 68-02-3960
Work Assignment 3-120
With Engineering-Science
Fairfax, Virginia 22030
Prepared for
EPA Project Officer: John Busik
EPA Work Assignment Managers: Louis R. Paley
and Mary Cunningham
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460
May 1986
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- ii -
Disclaimer
This report has been prepared for the Stationary Source Compliance
Division of the U.S. Environmental Protection Agency by Perrin Quarles Asso-
ciates, Inc. and Entropy Environmentalists, Inc. The opinions, suggestions,
and conclusions expressed herein are those of the authors, and do not neces-
sarily represent those of the U.S. Environmental Protection Agency.
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HANDBOOK FOR THE REVIEW OF EXCESS EMISSION REPORTS
TABLE OF CONTENTS
I. Introduction ..... 1
A. Content of Excess Emission Reports i
B. Format of EERs ! ! ! ] 2
C. Three Phase EER Review !.!!!!! 3
D. Flowchart: Three Phase EER Review '.'.'.'.'. 4
E. Flowchart: Phase-1 Review .....!!! 5
11 EER's Reviewer's Checklist for Opacity Excess Emissions Reports ... 6
A. Summary of Phase-1 Opacity EER Review Steps . 7
B. Explanation of Phase-1 Opacity EER Review Steps '. '. 9
(1) Step lj Identification Check 9
(2) Step 2s Timeliness Check ......... 10
(3) Step 3; General Content Evaluation 11
(4) step 4s Availability of Source Operating
Time Information ...... 12
(5) Step 5s Source Operating Time 13
(a) Total Hours Available in Quarter 13
(b) Calculation of Source Downtime 14
(c) Calculation of Source Operating Time 15
(6) step 6: Affirmative Statement of No CEMS Downtime .... 16
(7) Step 7: Summary of CEMS Performance Data . » 16
(a) General Information Check 16
(b) Calculation of CEMS Downtime 16
(c) Identification of CEMS Downtime During
Source Downtime ..... 19
(d) Evaluation of Reasons for CEMS Downtime 20
(e) Evaluation of CEMS Downtime by Reason
Category (optional) 20
(f) Calculation of Percent Unavailability (optional) ... 25
(8) Step 8: Affirmative Statement of No Excess Emissions ... 26
(9) Step 9: Opacity Excess Emissions Data 26
(a) Content Evaluation 26
(b) Emission Standard 28
(c) Emissions Data Summary 28
(d) Calculation of Duration of Exceedances 29
(e) Evaluation of Causes of Excess Opacity 31
(f) Evaluation of Excess Emissions by
Reason Category (optional) 31
(g) Calculation of Percent of Monitored Operating Time
(optional) 35
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(10) Step 10: CDS/GEMS Subset Data Coding 36
(11) Step 11: Completion of Phase-1 Review 36
III. EER Reviewer's Checklist for SO, Excess Emissions Reports 37
A. Summary of Phase-1 SO3 EER Review Steps 38
B. Explanation of Phase-1 SOa EER Review Steps . . . 40
(1) Step 1: Identification Check 40
(2) Step 2: Timeliness Check 41
(3) Step 3: General Content Evaluation 42
(4) Step 4: Availability of Source Operating
Time Information 43
(5) Step 5: Source Operating Time 44
(a) Total Hours Available in Quarter 45
(b) Summary of Source Downtime 45
(c) Calculation of Source Operating Time 46
(6) Step 6: Affirmative Statement of No GEMS Downtime .... 47
(7) Step 7: Summary of GEMS Performance Data 47
(a) General Information Check 47
(b) Calculation of CEMS Downtime 47
(c) Identification of CEMS Downtime During
Source Downtime 50
(d) Evaluation of Reasons for CEMS Downtime 51
(e) Evaluation of CEMS Downtime by Reason
Category (optional) 51
(f) Calculation of Percent Unavailability (optional) ... 56
(8) Step 8: Affirmative Statement of No Excess Emissions ... 57
(9) Step 9: SOa Excess Emissions Data 58
(a) Content Evaluation 58
(b) Emission Standard ...63
(c) Emissions Data Summary ..... 64
(d) Calculation of Duration of Exceedances ........ 64
(e) Evaluation of Causes of Excess Emissions 66
(f) Evaluation of Excess Emissions by
Reason Category (optional) 67
(g) Calculation of Percent Monitored Operating Time
(optional) 70
(10) Step 10: CDS/GEMS Subset Data Coding 71
(11) Step 11: Completion of Phase-1 Review 71
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ILLUSTRATIONS
EER Reviewer's Checklist for Opacity Excess Emissions Reports (EERs)
Example EER Reviewer's Checklist, Sections 1 S 2 10
Example EER Reviewer's Checklist, Section 3 12
Table 1 15
Table 2 19
Example EER Reviewer's Checklist, Section 4(a) 25
Table 3 30
Example EER Reviewer's Checklist, Section 4(b) .. 35
EER Reviewer's Checklist for SOa Excess Emissions Reports (EERs)
Example EER Reviewer's Checklist, Sections 1&2 ., 41
Example EER Reviewer's Checklist, Section 3 43
Table 1 46
Table 2 50
Example EER Reviewer's Checklist, Section 5(a) 57
Table 4 *.. 66
Example EER Reviewer's Checklist, Section 5(b) 70
APPENDICES
Appendix A: EER Reviewer's Checklist: Phase-1 Review 72
Appendix B: GEMS General Compliance Audit Data Sheet 75
Appendix C:
Table 1: Summary of Source Downtime 77
Table 2: Summary of GEMS Downtime 78
Table 3: Summary of Incidents of Excess Opacity 79
Table 4: Summary of Incidents of SO3 Excess Emissions . . 80
Appendix D: Opacity CEMS Components 81
Appendix E: Discussion of Source Reasons for Opacity CEMS Downtime . . 82
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HANDBOOK FOR THE REVIEW
OF EXCESS EMISSION REPORTS
I. Introduction
On October 5, 1984, the U.S. Environmental Protection Agency, Stationary
Source Compliance Division, issued guidance to EPA Regional Offices on the
review and use of excess emission reports (EERs). (See "Technical Guidance on
the Review and Use of Excess Emission Reports".) The "Handbook for the Review
of Excess Emission Reports" provides more specific information and recommenda-
tions on Phase-1 review and analysis of opacity and SOa EERs by State agencies
or EPA Regional Offices. Phase-1 review includes only the initial summari-
zation and analysis of excess emission reports received by a State or federal
agency.
Chapter II of the handbook provides guidance on the review of opacity
EERs; Chapter III provides guidance on the review of S03 EERs. Each chapter
contains all of the information usually needed for the analysis and summari-
zation of the data. Information relevant to both opacity and SO2 monitoring
systems appears in both chapters.
The detailed instructions in this handbook will assist the inexperienced
Phase-1 reviewer. A more experienced reviewer may need only to rely upon the
"Summary of Phase-1 Opacity EER Review Steps" (pages 7 - 8) or the "Summary of
Phase-1 SO3 EER Review Steps" (pages 39-40). A very experienced reviewer may
need to use only the EER Reviewer's Checklist. If unusual or unfamiliar
problems with interpreting the data arise, the more detailed explanation is
available in Chapters II and III.
The illustrations and example EER review in the handbook are based on
reports from Subpart D NSPS sources. However, the general approach and forms
may be easily adapted to many variations of State requirements and requirements
for other source categories where the EER is used as a targeting or screening
mechanism for enforcement follow-up.
The following general information may be useful to the reviewers
A. Content of Excess Emission Reports
Most EERs include:
o emissions data gathered by the continuous emission monitoring system
(GEMS);
o
o
information on the performance of the GEMS; and
information on the overall operation of the source.
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EER Review Handbook
May 30, 1986
Page 2
The EER should include specific times during which exceedances occurred
and specific times during which the monitoring system was not operating.
Although not currently required by regulation, these reports should also
identify times that the source or unit was not in operation. Other information
contained in the EER, regarding changes in the CEMS, or explanations of the
causes of CEMS downtime or excess emissions, for example, may also be very
important.
Federal regulations contain minimum data requirements for quarterly EERs.
The reviewer must determine whether the EER includes all the required informa-
tion. Because there is no uniform format, determining whether an EER is
complete may be a time consuming and difficult task. For NSPS sources, the
minimum data requirements include:
o identification of all excess emissions, their cause(s), and duration;
o magnitude of excess emissions;
o identification of all periods of CEMS downtime and nature of system
repairs; and
o statements, if applicable, that no excess emissions or CEMS downtime
occurred.
Additional information may be required by States or for specific source
categories. For purposes of illustration, the content requirements listed on
the EER checklist apply to Subpart D NSPS sources. These checklists may be
adapted by an agency or reviewer to reflect the requirements of any State or
source category.
B. Format of EERs
There is no uniform EER format required by EPA regulations. Sources
sometimes submit computer data printouts, without explanations or summaries.
These reports may be difficult for the EER reviewer to interpret and analyze.
Other sources submit summarized data but exclude information on specific
exceedances or periods of CEMS downtime. Most EER formats are used on a compa-
ny-wide basis for all plants regardless of the plant location or number of
monitors. Some formats may be recommended or required by State or EPA Regional
Offices. Sources frequently rely on EER formats provided by a vendor with a
computerized CEMS data acquisition system.
Although a data summary is not usually required, some sources submit
summaries in addition to raw data on excess emissions and CEMS performance.
This summary may provide an analysis similar or identical to the data summary
performed during EER review. To the extent possible, this summary should be
used by the reviewer to shortcut the data summary process. Periodic checks or
audits of the data summary provided by the source can be performed to ensure
the quality and accuracy of the data summary.
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EER Review Handbook
May 30, 1986
Page 3
A cover letter or forwarding memorandum is often submitted with the
quarterly reports. Summary information or other relevant information may be
presented in this letter or memorandum. This cover letter or memorandum should
be considered part of the quarterly EER.
Many sources submit data for more than one monitoring system in a single
quarterly submittal. The data submitted for each continuous emission monitor-
ing system is an "excess emission report" and should be reviewed independently.
Each EER should be associated with one pollutant-specific and unit-specific
continuous monitoring system. For example, a single quarterly submittal could
contain three EERs as demonstrated below.
o One opacity EER for Unit * 1. This boiler might have two opacity
monitors in a combiner system generating one quarterly EER.
One SO 3 EER for Unit # 2.
This boiler might have two SO3
a combiner system generating one quarterly EER.
monitors in
o One opacity EER for Unit # 2. This same boiler might also have one
opacity monitor generating one quarterly excess emission report.
The source is required by regulation to submit the data for each pollutant
and each stack separately. However, some sources combine process operating
information or describe boiler problems in a cover letter or separate memoran-
dum. Other sources report and describe GEMS problems separately from the
emissions data. In order to summarize and evaluate all of the data which is
relevant to one monitoring system, it is necessary for the reviewer to identify
carefully which boiler and control equipment problems and GEMS data and recor-
ding equipment problems are associated with emissions data from specific
monitoring systems.
C. Three Phase EER Review
EPA has recommended that the review of EERs occur in three phases (see
"Technical Guidance on the Review and Use of Excess Emissions Reports," October
5, 1984).
o Phase-1 review includes an evaluation of the report for timeliness
and completeness and the summarization of basic excess emissions and
GEMS performance data (if not submitted in the EER) .
o Phase-2 review includes verification of Phase-1 results and a compari-
son of the EER data with preselected targeting criteria to determine
if agency follow-up may be warranted. The Phase-2 reviewer also
approves the entering of EER data into the CDS or other computerized
database and makes a recommendation for follow-up action.
o Phase-3 review includes any follow-up to the EER including enforce-
ment activities, source contacts, etc.
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D- Flowchart; Three Phase EER Review
EER Review Handbook
May 30, 1986
Page 4
miTUl CEMJ FROGHAM IMPLEMENTATION
CONTINUING can
PROGRAM IMPLEMENTATION '
ESTAILBH
CEUJ AFFECTED
SOURCE INVENTORY
I
t
E.D.
SUBSET
ENTER COUM.IANCE STATUS DATA
AFFIRMATIVE DETERMINATION
NEGATIVE DETERMINATION
AGENCY
COMPLIANCE
AND
ENFORCEMENT
ACTION!
- CHASE I -
EER REVIEWED
AND SUMMARIZED
- PHASE 2 -
VERIFY PHASE 1
TARGET SOURCES
DATA ENTRY TO SUBSET
SUBSET
FOLLOW UP REQUIRED?
-PHASE 3-
CONOUCT FOLLOW-UP
EVALUATIONS AT
TARGETED SOURCES
COMPLIANCE/ENFORCEMENT ACTIONS REQUIRED?
E.O.
COS
FIGURE 1. AGENCY'S REVIEW AND USE OF OEMS DATA
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EER Review Handbook
May 30, 1986
Page 5
E. Flowchart: Phase-1 Review
Step 1;
Identification
Check
Step 2;
Timeliness
Check
Step 3;
General Content
Check
Step 5;
Calculate
Source Oper-
ating Time
Step 7;
Calculate and
Evaluate CEMS
Downtime
YES
Step 9;
Calculate and
Evaluate Excess
Emissions
Step 10;
Code Data for
GEM/CDS Subset
Step 11;
Forward EER for
Phase-2 Review
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EER Review Handbook
May 30, 1986
Page 6
II. EER Reviewer's Checklist for Opacity Excess Emissions Reports (EERs)
This chapter uses pages 1 and 2 of the EER Reviewer's Checklist (see
Appendix Af pages 72 - 73) to summarize opacity EERs. The example EER Re-
viewer's Checklist used in this manual may be adapted to reflect the specific
requirements for the source category or State regulation.
Phase-1 review includes a review of both emissions performance and CEMS
performance. Source operating data and CEMS performance data should be evalu-
ated first so that the reviewer can determine the percentage of monitored
operating time the unit was reporting exceedances. The purpose of reporting
emissions data is to determine the level of continuous compliance with appli-
cable emissions standards. If the reported data on CEMS performance or source
operation are unclear or show large periods of non-operation, the usefulness of
the reported excess emission data as an indicator of the source's overall level
of compliance is not necessarily diminished.
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EER Review Handbook
May 30, 1986
Page 7
A. Summary of Phase-1 Opacity EER Review Steps
Step 1
Identify the source, unit, monitor, pollutant and
quarter, and fill in Section 1.
Check date of receipt or envelope postmark. NSPS
sources shall submit EERs postmarked by the 30th
day of the end of the quarter. Record your finding
in Section 2.
Review all EER information and note any general
problems in Section 3.
If there is no information on source operating
time, enter "no" under "Source Operating Time" in
Section 3. For purposes of evaluating emissions
and GEMS performance, assume that the source was
operating throughout the quarter.
If there is specific information or partial infor-
mation, describe the information under "Source
Operating Time."
Step 5A
Determine Total Hours Available in Quarter:
Quarter (identify):
(1,1L,2,3 or 4)
Hours available:
If no information on source operating time is
available, go directly to Step 6, "Affirmative
Statement of No CEMS Downtime."
Calculate the total source operating time using
the formula below.
Source Down- I
tlac (Hours) )
Determine whether the source affirmatively states
that there were no periods of "CEMS Downtime, Re-
pair or Adjustment." If there is no CEMS down-
time, go to Step 8, "Affirmative Statement of No
Excess Emissions."
Step 7A
Evaluate CEMS performance information to determine
if the data meets applicable EER content require-
ments and fill in Section 3 under "CEMS Perfor-
mance Information."
Calculate total CEMS downtime using summary infor-
mation provided by the source or directly from the
EER;
or
Calculate the total CEMS downtime by using Table 2
(see Appendix C) entitled, "Summary of CEMS Down-
time."
Compare the specific times during which the CEMS
was inoperative with source operating downtime.
Where the two overlap, exclude these time periods
from the CEMS downtime.
Calculate the total duration of source downtime
using summary information provided by the source
or directly from the EER;
or
Calculate the total duration of source downtime by
using Table 1 (see Appendix C) entitled, "Summary
of Source Downtime."
Evaluate the causes of CEMS downtime and the na-
ture of system repairs or adjustments to determine
if the source has adequately explained reported
CEMS downtime. If the reasons are inadequate or
unclear, note the problem in Section 3 under "CEMS
Performance Information."
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EER Review Handbook
May 30, 1986
Page 8
Step 7E (optional)
Calculate the total OEMS downtime for each
reason category. Record the total duration
for each reason category in Section 4(a).
Step 7F (optional)
Calculate "Percent Unavailability" for total
CEHS downtime (and for each reason code) by
using the formula provided below. Enter the
result in Section 4(a).
CM DmntlM Curing
Sourc* Optttting
Tic* (Houril
Source
7- Operating
TUa (Hours)
or
Calculate the total duration of all excess opacity
by using Table 3 (see Appendix C) entitled,
"Summary of Incidents of Excess Opacity."
Evaluate the "nature and cause" of exceedances re-
ported. If there is no information provided re-
garding the cause of excess emissions, or if the
reasons are inadequate or unclear, note the pro-
blem in Section 3 under "Emissions Performance."
Determine whether the source affirmatively
states that there were no periods of excess
omissions. If there are no excess emissions,
go to Step 10, "CDS/CEM Subset Data Coding."
9F (optional)
Calculate the total duration of excess emissions
for each reason category. Record the total dura-
tion for each reason category in Section 4(b).
Evaluate all information relevant to excess
emissions for the following types of informa-
tion and fill in Section 3. This should in-
clude the following:
1. Reporting in Periods of the Applicable
Standard
2. Magnitude
3. [Conversion Factors]
4. Reporting of Malfunction Information
9G (optional)
Calculate the percent of time (while both source
and monitor were in operation) that excess emis-
sions were occurring. This is calculated by divi-
ding the duration of exceedances by the time in
which both the source and monitor have been opera-
ting during the quarter, then converting the re-
sult to a percentage:
/Total Duratlrr c>f
1 Excess Emissions
\ (Hours)
Monitored \
Operating Time 1
(Hours) /
Percent of
x 100 « Monitored Operating
Time (Hours)
Identify the opacity standard applicable to
the source and unit.
Time
in
Quarter
(Hours)
Source
Down-
time
(Hours)
CEHS Downtime
During Source
Operating Tina
([fours)
Monitored
- Operating
Tioe
(Hours)
Identify specific periods of excess opacity.
If the source provides only summary informa-
tion or "average" opacity readings over a
longer period of time, note this deficiency in
Section 3 under "Emissions Performance" for
possible agency follow-up.
Make this calculation for the "Percent of Moni-
tored Operating Time" for total exceedances and
for each reason category. Enter the results in
Section 4(b).
Code the EER data for entry into the CDS/CEMS sub-
set.
Calculate the total duration of all periods of
excess opacity, using summary information or
calculating directly from the report;
Forward the EER, EER Reviewer's Checklist, pro-
posed CDS/CEMS Subset data entry cards and other
relevant information for Phase-2 review.
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EER Review Handbook
May 30, 1986
Page 9
B. Explanation of Phase-1 Opacity EER Review Steps
(1) Step 1; Identification Check
Step It
Identify the source, unit, monitor, pollutant and quarter, and fill in
Section 1.
Determine the type of facility and type of monitors used to measure
emissions at the reporting facility. If this information is not in the excess
emission report, it may be found in a source file maintained by the agency or
a completed "GEMS General Compliance Audit Data Sheet" (see Appendix B). Basic
source identification information includes:
o the type of source (e.g., electric utility, coal or oil fired);
o location of the monitor (identification of unit and stack);
o type of control .equipment used (e.g., ESP, baghouse or scrubber);
o applicable emission standards; and
o the type of monitor (brand, number of transmissometers, type of data
recording system).
Note any unusual operating configuration. For example, a single monitor
may record data for emissions which feed into a single stack from three boilers
or control systems. Problems with any of three operating systems or three
control equipment systems may be the cause of exceedances recorded by the
monitor.
It is strongly recommended that each agency maintain a permanent file
of CEMS-related information for each facility for use during all stages of EER
review. This file should contain basic information such as: source permits;
CEMS General Compliance Audit Data Sheet (see Appendix B) or similar compliance
audit information; EERs and EER summaries for the previous two years; corres-
pondence or other documentation of EER follow-up; monitor audits or testing;
plant inspections, etc.
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EER Review Handbook
May 30, 1986
Page 10
(2) Step 2; Timeliness Check
Step 2;
Check date of receipt or envelope postmark. NSPS sources shall submit
EERs postmarked by the 30th day of the end of the quarter. Record your
finding in Section 2.
If the report is late, save the envelope in which the report was submitted
to demonstrate that the source failed to comply with the timeliness requirement.
Timeliness of submission is an important factor because:
o Late submission makes it more difficult to associate specific excee-
dances with on-going problems at the source and to ensure that
corrective action is promptly undertaken.
o Current information from all sources each quarter will enable the
agency to compare the performance of different sources and thereby
maximize the resources available to the agency for follow-up.
o Timely agency follow-up may result in greater all-around respon-
siveness of sources and should increase the credibility of the
agency's EER review program.
Example EER Reviewer's Checklist, Sections 1 S 2
EER REVIEWER'S CHECKLIST
I. Cogpany
Plant/Onlt
«o c.r.R.
(njutsx^> &Jvcjr *S-fzL
Part 60, Subpart 0)
Phase 1 Review
Phase 2 Review/
Subset Data Entry
Phase 3 Review/
CCS Action Entry
j I- Ljahjb
t'fl'fY*'. (Jt-MJb ~*_L
MF +IXLI&
Name Date
Name Cate
Name uate
/^ $f
Quarter Year
J. TJBallcess (Must be postnarXed within 30 days of quarter)
U) Date Postmarked Aptl'L if Ifff Cb) Daya Late
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EER Review Handbook
May 30, 1986
Page 11
(3) Step 3; General Content Evaluation
Step 3;
Review all EER information and note any general problems in Section 3,
More specific evaluation of the adequacy of the data will be conducted
when the data are summarized. However, some information may be included or
reporting problems may occur which are not directly related to data summary and
which should be noted in Section 3 of the EER Reviewer's Checklist. This
includes reports where:
o There were no excess emissions and no CEMS downtime and further
evaluation of the EER is unnecessary.
o There were changes in the operating, control equipment or continuous
emission monitoring systems. This information is very important and
any changes should be noted in the source information file as well as
Section 3 of the EER Reviewer's Checklist.
o Actual data in support of summary information are not reported in the
EER. This is. a reporting deficiency which should be noted by the
Phase-1 reviewer so that appropriate follow-up action can be taken
particularly if there is a significant amount of CEMS downtime or
exceedances.
o Specific information (for example, explanations for excess emissions)
appears only in the cover letter or memorandum and not with the EER
data. This problem makes it very difficult to analyze causes of
excess emissions and may also warrant agency follow-up.
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EER Review Handbook
May 30, 1986
Page 12
Example EER Reviewer's Checklist, Section 3
3. Completeness1 (Tor EERs which cover multiple monitors, specify monitor when noting problem)
j Source Operating Tiae
I
i CESS Performance Information
(a) Affirmative Stateaent of No Period
I of Downtime, Eepalr or Adjustment
(include no CEHS modifications)
(b) Data end Tlae Identifying
Specific Periods During Which
CEHS Has Inoperative
(c) Hature of Systea Repairs
or .
Inforaation
Excess Missions
(a) Affirmative Statement o£ No EEs
(b) Data Reported in Dnlts of
Applicable standards
(c) Date and Tine of Cosaenceaent
(d) Data and Ties of Completion
| (e) Magnitude
(f) Conversion Factors Used
(g) Identification of EEs Caused by
Start-up, Shutdown, or Malfunction
(b) Hature and Cause of Malfunction
(1) Malfunction Corrective Action
or Preventive Measures
No Preelen i
Problen 'Describe) /Comments
,
*
1324
1 f
; \joujrce.
'' /To n;
o rf.a^av->
* A revision of reporting requirements to require a sumarlzation of data, categorization of excess
emissions and CEHS problems according to new unlfom categories, and reporting of source operating time Is
nov under consideration. Although not specifically required, source operating time has been Included on
this sample fora because it is necessary to allow for data analysis Included In this checklist.
(4) Step 4; Availability of Source Operating Time Information
Federal NSPS regulations do not require the reporting of source operating
time, although a permit provision or similar plant-specific requirement may
apply. However, the availability of this information is very important and
should be noted on the EER Reviewer's Checklist.
Step 4;
If there is no information on source operating time, enter "no" under
"Source Operating Time" in Section 3. For purposes of evaluating emis-
sions and GEMS performance, assume that the source was operating through-
out the quarter.
If there is specific information or partial information, describe the
information under "Source Operating Time."
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EER Review Handbook
May 30, 1986
Page 13
Source operating data allows for the adjustment of data to account for
periods of time during which the source was not operating. Comparisons between
sources and tracking of individual source performance from quarter to quarter
are more accurate.
If no source operating time information is available, assume that the
source was in continuous operation. If the source was not operating for a
significant portion of the quarter, the calculation of percent excess emissions
and percent GEMS downtime using this assumption may significantly under-repre-
sent the actual percentages. A preliminary indication of actual source down-
time may be obtained by noting the number of incidents of excess emissions
associated with "startup" and "shutdown" of the facility.
An agency may, as a matter of policy, choose to contact the source to
obtain source operating data or to request routine submission of the data.
(5) Step 5; Source Operating Time
(a) Total Hours Available in Quarter
Because the number of days in each month varies, the time available in
each quarter varies. The following chart provides the total hours available
each quarter, including leap year.
Maximum Time Available in Quarter
Quarter
01
OIL*
02
03
04
* Leap year
Hours
2,160
2,184
2,184
2,208
2,208
Step 5A;
Determine Total Hours Available in Quarter:
Quarter (identify):
f
Hours available:
(1,1L,2,3 or 4)
If no information on source operating time is available, go directly to
Step 6, "Affirmative Statement of No GEMS Downtime."
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EER Review Handbook
May 30, 1986
Page 14
(b) Calculation of Source Downtime
Step SB;
Calculate the total duration of source downtime using summary informa-
tion provided by the source or directly from the EER;
or
Calculate the total duration of source downtime by using Table 1
(see Appendix C) entitled, "Summary of Source Downtime."
Sources may specify periods of operation or non-operation. Some sources
provide summary information only. Where the source identifies specific time
periods, summarize the total source downtime.
1. Use of Summary Table 1 (optional)
The reviewer may choose to calculate source downtime by using Table 1,
"Summary of Source Downtime." (See Appendix C.) If the data is not easily
computed from the EER directly, or is unclear or confusing,' making a record of
source operating downtime will facilitate review and will allow the Phase-2 or
Phase-3 reviewer to check the accuracy of the Phase-1 review, particularly
where the Phase-1 reviewer is inexperienced or where the EER reveals signifi-
cant emissions or GEMS performance problems.
.
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EER Review Handbook
May 30, 1986
Page 15
Table 1
SUMMARY OF SOURCE DOWNTIME
Company:
Unit:
Cuartor:
Incident
tjumcer
j5rtruwiLs*-s rswu> ₯ JUak. f
^. , ^.-.^
/^/- s^
START
Honth/Day/Time
' i '/IS* / ' 00
3- 3/Vi. 12: 30
"
STC?
Month/Day/Time
Duration
(Hours)
'/J4 ^:JD «2./.f
Reason
SLuJ-dJuj*^ '
^/^) ^-'00 \ /CC. i&u**± nzUKT-
i
i
i
j
j f
I
|
i
t
1
TOTAL SOURCE DOWNTIME:
334
hours
(c) Calculation of Source Operating Time
Step 5C;
Calculate the total source operating time using the formula below.
Time in
Quarter (Hours)
Source Operating
Time (Hours)
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EER Review Handbook
May 30, 1986
Page 16
(6) Step 6; Affirmative Statement of No GEMS Downtime
Step 6;
Determine whether the source affirmatively states that there were no
periods of "GEMS Downtime, Repair or Adjustment." If there is no GEMS
downtime, go to Step 8, "Affirmative Statement of No Excess Emissions."
This statement may appear in a cover letter or in the excess emission
report. Some sources report "0" GEMS downtime in a blank on the excess
emissions data form.
(7) Step 7; Summary of GEMS Performance Data
(a) General Information Check
Step 7At
Evaluate GEMS performance information to determine if the data meets
applicable EER content requirements and fill in Section 3 under "GEMS
Performance Information."
(b) Calculation of GEMS Downtime
Step 7B;
Calculate total GEMS downtime using summary information provided by the
source or directly from the EER;
or
Calculate the total .GEMS downtime by using Table 2 (see Appendix C)
entitled, "Summary of GEMS Downtime."
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EER Review Handbook
May 30, 1986
Page 17
Calculate duration in hours, expressed to the nearest tenth.
following table converts minutes of GEMS downtime to tenths of hours.
The
Number
of Minutes
3
4-9
10-15
16-21
22-27
28-33
34-39
40-45
46-51
52-57
Tenths of Hours
.0
.1
.2
.3
.4
.5
.6
.7
.8
.9
1. Types of GEMS Downtime
Three types of GEMS downtime may be reported in the EER:
o periods during which the GEMS is inoperative;
o periods during which the GEMS is undergoing routine maintenance or
other repair; and
o periods during which the GEMS is operating, but is generating inaccu-
rate data.
All three types should be included as GEMS downtime. However, some
sources report the three types of GEMS downtime in different portions of the
EER. In particular, periods during which the GEMS is operating, but is genera-
ting inaccurate data are sometimes included with excess emissions data.
Scan the reasons for excess emissions to determine if the GEMS system is
the "cause" of any excess emissions and include these time periods as GEMS
downtime. Later, exclude these time periods from the total excess emissions
time (see Step 9C of this chapter).
Sources are not required to operate the GEMS when the source is not
operating. Do not include GEMS downtime which is reported during source down-
time (if source downtime information is available). If the EER does not
provide adequate information to make this determination, assume that all
reported GEMS downtime occurred during periods of source operation.
Note that the GEMS includes all parts of the system, not just the monitor
component. For example, failure to record data because of computer or data
recorder problems, unless data is available through back-up recorders or strip
charts, is considered to be a failure of the entire system and the time lost is
included in GEMS downtime.
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EER Review Handbook
May 30, 1986
Page 18
Sources must include the date and time identifying specific periods during
which the GEMS was inoperative. Quarterly totals or daily totals are not
adequate because they do not allow the reviewer to relate specific periods of
GEMS downtime to specific periods of excess emissions or source downtime.
2. Use of Summary Table for Analyzing GEMS Downtime
(optional)
Making a record of GEMS downtime may help the reviewer to evaluate
confusing or conflicting data and may allow the Phase-2 or Phase-3 reviewer
to check the accuracy of the Phase-1 review, particularly where the Phase-1
reviewer is inexperienced or where the EER reveals significant emissions or
GEMS performance problems. Use of a summary chart may also make it easier for
the reviewer to track corrective actions or reasons for GEMS downtime and
calculate a total GEMS downtime for each reason category.
Some sources provide only the total hours of GEMS downtime per quarter or
per day. If this is the only information available, if the source provides
summary information, or if the reviewer chooses to total the GEMS downtime
from the EER directly, fill in the blanks for total GEMS downtime in Section
4(a) of the EER Reviewer's Checklist.
Unless the total amount of GEMS downtime during source operation is very
small, failure to identify the specific times during which the GEMS was
inoperative or the nature of the problem or corrective action is a serious
reporting deficiency which should be noted for possible agency follow-up.
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EER Review Handbook
May 30, 1986
Page 19
Table 2
SUMMARY OF GEMS DOWNTIME
Company :
Unit:
Quarter:
Incident
Numcer
.
J.
A
F^n*
3
u*
START
Month/Day/Time
'/3- 3 '-00
'/; I.QD
'/A5~ /O 30
.^K^ Paitre*. f Li'mt,
$?
STOP
Month/Day /Time
"^ //-'OO
_!A3 la^OO
fj ^
^
Duration
(Hours;
Reason/Correc- Reason
tive Action Code
«2. Iflorie^ S/Sasx^aL ' £
5" \'fbt>*jr IOSS ! 5<_
/O lA/0 'ZeiAsxaUJ-s <2.
1 5-
2/0 /:*,
i
,
!
i
TOTAL GEMS DOWNTIME:
-i//^ ~?A:00
s/s- n ' -ID
HI
^L
j
1
OoT^C^f^^Ui -c-lu2-£,5 -"^
CffYHlnt/*!* r3/lO-i &
7 ' I
/ J'S hours
Reason Codes
a » Monitor equipment malfunction //
b - Non-monitor equipment malfunction O
c » Calibration/QA - g __
d ** Other known causes ^>
a * Unknown causes ** [O
Identification of GEMS Downtime During Source Downtime
Step 7C;
Compare the specific times during which the GEMS was inoperative with
source operating downtime. Where the two overlap, exclude these time
periods from the GEMS downtime.
This may be done either directly, using the EER, or indirectly, using
summary charts of source downtime and GEMS downtime already completed.
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EER Review Handbook
May 30, 1986
Page 20
(d) Evaluation of Reasons for GEMS Downtime
Step 7Dt
Evaluate the causes of GEMS downtime and the nature of system repairs or
adjustments to determine if the source has adequately explained reported
CEMS downtime. If the reasons are inadequate or unclear, note the
problem in Section 3 under "CEMS Performance Information."
The "cause" of the CEMS downtime or the "nature of system repairs or
adjustments" should be identified for all NSPS sources. Each separate incident
should be explained. An incident of CEMS downtime is any uninterrupted period
(of any time length) during which the CEMS is not operating or providing
accurate data.
(e) Evaluation of CEMS Downtime by Reason Category (optional)
Step 7E; (optional)
Calculate the total CEMS downtime for each reason category.
total duration for each reason category in Section 4(a).
Record the
An agency may choose to evaluate specific causes of CEMS downtime:
o when total CEMS downtime exceeds a specified cutoff; or
o to evaluate all causes of CEMS downtime for a specific quarter or
series of quarters to identify types of problems and typical levels
of downtime associated with specific types of problems.
The reason categories defined below are based on the revised reason
categories included in EER Regional Guidance developed by EPA in 1984. Addi-
tional reason categories may be added for other source categories or to accom-
modate variations in State regulations.
Sources may use their own reason codes or reason categories to report the
causes of monitor problems. If the reason codes differ from those used by the
agency, correlate source reason codes to the agency reason codes so that a
uniform code system is used.
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EER Review Handbook
Hay 30, 1986
Page 21
1. EPA Proposed Reason Categories
The reason categories proposed by EPA (with definitions and examples of
typical source explanations) are:
a- "Monitor equipment malfunction." This category
refers only to the actual monitoring equipment, and not to accessory equipment
such as strip chart recorders and computer data acquisition systems. The
actual monitoring equipment includes all of the apparatus necessary to measure
the opacity of the emissions at the monitor installation location(s) and to
convert the measurements to the equivalent opacity that would be observed at
the stack exit. The major components of the monitoring equipment are the
transceiver, reflector, signal cable, control unit and combiner system (see
Appendix D for an explanation of these components).
The opacity "monitoring equipment" also includes those components of the
measurement system that protect the optical components of the transmissometer
from the effluent stream. The equipment consists primarily of a purge air
system (i.e., power supply, blowers, air filters, and connecting hoses). The
equipment which provides temporary protection for the analyzer in the event of
failure of the purge air system usually consists of pneumatically or electroni-
cally activated shutter devices.
"Malfunction" refers to any period during which the monitor is not opera-
ting or is producing inaccurate data due to a failure of any component of the
opacity monitoring system. A "monitor equipment malfunction" does not include
periods of calibration, QA, or other normal or preventive maintenance. Also,
monitor equipment malfunction does not include GEMS downtime attributable to
"non-monitor equipment malfunctions," "other known causes," or "unknown causes"
as described below. Because the EER often lists only the activities undertaken
to correct a malfunction, the reviewer must be careful to distinguish between
normal maintenance procedures and corrective actions following a malfunction.
The time necessary to- complete corrective actions following a malfunction
should be included in the "monitor equipment malfunction" category.
"Monitor equipment malfunction" includes problems described by the sources as:
Transmissometer malfunction
Shutter failure
Blower shutdown
Repair filter alarm switch
Replaced defective alarm card
Optical density card failure
Stuck in span
Defective micro switch
Combiner stuck
D/A flag
Investigation of alarm
problem
Transceiver malfunction
Repaired shutter
Blower problems
Monitor misalignment
Replace opacity card
Replace OD P.C. board
Cal button stuck
Switch contacts failed
Combiner malfunction
D/A error
Troubleshooting for alarm
problem
Transceiver board damaged
Blower failure
Blower replacement
Alignment shift
Opacity PC board failure
Zero cal stack
Span shift
Not integrating properly
D/A alarm
Filter alarm switch malfunction
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EER Review Handbook
May 30, 1986
Page 22
b. "Non-monitor equipment malfunction" refers to all
equipment other than the monitor equipment that is necessary to transfer,
compute averages, and record opacity monitoring data. "Non-monitor equipment
malfunction" almost always refers to failures or problems with the strip chart
recorder, data losses or computer data acquisition system problems. However,
the time required to perform routine maintenance of these systems should be
excluded from this category and be included under "Calibration/QA." Some
opacity monitoring systems which include multiple opacity monitors installed in
different ducts and which utilize a computer system to calculate the equivalent
combined opacity at the stack exit may also utilize the computer to perform
automatic diagnostic checks of the data quality. In this situation, computer
system malfunctions (usually due to software problems) may cause accurate
monitoring data to be rejected. This type of problem should be classified as a
"non-monitor equipment malfunction."
"Ken-monitor equipment malfunction" includes problems described by the sources ass
Strip Chart Recorder
Problems
Recorder not functioning
Chart not recording
Replace chart recorder
Chart drive off
Chart drive running slow
Chart paper off track
Chart paper jammed
Chart not inking
Computer Data Acquisition
System Problems
Insufficient data flag on
D/AS
Reload program for alarm
problem
Malfunction data logger
Incorrect entry time update
Worked on incorrect alarm
printout
Program error reset time
Computer stopped replaced
I/O board
Reloaded program for D/A
alarm problem
Reinitialized system
Reinitialized for time
DP30 software check
Ran diagnostic tape
Incorrect D/A alarm printout
D/AS computer failed and
repaired
Computer downreplaced I/O bd.
after trying to reprogram
Printer failure
Lost info from terminal
Lost information in computer
Computer did not make calcula-
tion
c. "Calibration/QA" refers to any period during
which the monitoring system is out-of-service for the purpose of calibration,
routine or preventive maintenance, or other quality assurance related activity.
Corrective action immediately following a malfunction, however, should be
classified under the appropriate malfunction category.
Federal regulations specify that all source operators required to use
opacity monitors must check the monitor response at zero opacity (or at a low
range) and at an upscale value (span check) at least once per day. The regula-
tions also require that the monitor be adjusted when the zero and/or span check
results exceed specified limits.
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EER Review Handbook
May 30, 1986
Page 23
The time required to perform the daily zero and span checks is usually a
few minutes per day. The reporting of this time is not required and should not
be included in "Calibration/QA" or any other category, since the monitor is
performing a required activity. However, when the zero or span drift limits
are exceeded, a significant amount of time may elapse before the adjustments
are completed. Monitor downtime associated with completing the zero or span
adjustments should be included in "Calibration/QA."
In addition to zero and span checks and/or adjustments that are referred
to as "calibration," other activities referred to as "calibration" include:
o electronic checks of the transmissometer and/or data recording
devices;
o on-stack, multipoint checks of the transmissometer responses to
external filters (calibration standards); and
o off-stack or clear stack checks of both the transmissometer zero
value (sometimes called zero alignment), and multipoint checks/
adjustments of component or system responses to external filters
(calibration standards).
The simplest of these activities usually requires only a few minutes to
perform; however, the most complex activity (off-stack calibration check) may
take several days or more to complete. Despite the wide variation in the
amount of time required for "calibration" and the inconsistent use of termino-
logy by source personnel, all of the above activities except routine/daily
zero/span checks should be included as "Calibration/QA."
"Calibration/QA'r includes problems described by the sources ass
Optics cleaned
Cleaned reflector
Changed filters
General maintenance
Cleaning site pipe
Recorder maintenance
Reinitiate computer system
Software enhancements
Recalibrated combiner
Adjust zero/span responses
Off-stack zero check/
alignment
Station audit and off-
stack zero
Lens cleaned
Cleaned zero reflector
Replaced air filters
Preventive maintenance
Printer maintenance
Cleaned control unit/combiner
Run diagnostic tape
Partial calibration
On-stack audit checks
Major calibration
Bench calibration
Transceiver and combiner
recalibration
Cleaned transceiver windows
Cleaned purge air systems
Cleaning monitor
Cleaning ports
Changed chart paper
Replace fault lamp bulbs
Repair D/A alarm
Recalibrated control unit
Opacity system audit
Off-stack calibration
Routine maintenance of terminal
Scheduled long-term monitor
overhaul and calibration
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EER Review Handbook
May 30, 1986
Page 24
d. "Other known causes" covers all other known
reasons for monitoring downtime or inaccuracy. This catch-all category excludes
all malfunctions and all "Calibration/QA" activities. This category usually
includes, for example, the interruption of the monitoring equipment power
supply, human error and other relatively unusual events. This category also
includes monitor problems or inaccuracy associated with the inability to
perform routine maintenance because of severe weather conditions.
"Other known causes" includes problems described by the sources as:
Correct date/time changes
Waiting for parts shipment
Removed OD card to use in
another monitor
Moved monitor to new
installation
Control room power outage
Waiting for vendor service
Power rewiring on stack
Precipitator bus outage
Removed monitor due to duct
leak
Meter inadvertently left in
calibration position
Combiner shutdown by mistake
Power loss on stack
Developing new calibration
procedure
Failed to log monitor in
service on computer
e. "Unknown cause" is intended to cover circumstances in
which there is inaccurate or no data without an apparent explanation. If a
data recorder fails, producing inaccurate data, and the reason for failure is
not known, this would be categorized under "non-monitor equipment malfunction."
However, if data are clearly inaccurate, and a data recorder failure is sus-
pected but cannot be confirmed, it should be classified as "unknown cause."
The reviewer should also use "unknown cause" when an insufficient explanation
of the GEMS downtime is provided in the EER such that determination of the
appropriate reason category is not possible.
This category includes those instances where:
o no explanation is provided by source;
o the source states that the cause is unknown; or
the source explanation is inadequate, unclear or contradictory.
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EER Review Handbook
May 30, 1986
Page 25
(f) Calculation of Percent Unavailability (optional)
Step 7F; (optional)
Calculate "Percent Unavailability" for total GEMS downtime (and for each
I
i reason code) by using the formula provided below.
Section 4(a).
Enter the result in
CEMS Downtime During
Source Operating
Time (Hours)
Source
Operating
Time (Hours)
x 100
Percent
Unavailability
"CEMS Downtime During Source Operating Time (Hours)" is calculated in Step
7B. "Source Operating Time (Hours)" is calculated in Step 5C.
An agency may choose to calculate "Percent Unavailability" for sources
which have a high total percentage of monitor downtime or to develop data
related to CEMS performance in selected problem areas. "Percent Unavaila-
bility" may be used (in a manner similar to total duration, magnitude or number
of incidents) to target sources for agency follow-up or inspections.
Example EER Reviewer's Checklist, Section 4(a)
4. Data Summary for Opacity EEKs
(a) Opacity CEHS Performance
Causes of CEHS Downtime'*
(a) Monitor Equipment Malfunctions
(b) Non-monitor CEHS Equipment Malfunctions
(e.g., computer, data recorder, etc.)
aj;t.
' . 1
Ootutr loss
r
no rta.Stn^ Ciivcw-J
>_/
"Percent unavailability" is calculated by th« following fomulas:
[CEK3 OovnttM Dutinq Sourc* ^
I Operating Tijn (Hour*) *
!ourc* \*p«t»tintj l
Tl»* (Hour*) /
Percent
Un»v»ilability
Tlaa in
tt»r (Hours)
Sourc* Down-
ti**i (Hour*)
ourCQ
Operating Tlaa (Itoura)
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EER Review Handbook
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Page 26
(8) Step 8; Affirmative Statement of No Excess Emissions
Step 8:
Determine whether the source affirmatively states that there were no
periods of excess emissions. If there are no excess emissions, go to
Step 10, "CDS/GEMS Subset Data Coding."
This statement may be found either in a cover letter or in the report.
(9) Step 9; Opacity Excess Emissions Data
(a) Content Evaluation
Step 9A;
Evaluate all information relevant to excess emissions for the following
types of information and fill in Section 3. This should include
the following:
1. Reporting in Periods of the Applicable Standard
2. Magnitude
3. [Conversion Factors]
4. Reporting of Malfunction Information
1. Reporting in Periods of the Applicable Standard
The regulations specify that opacity data (for periods during which the
standard was exceeded) must be reported in six-minute time >periods. Most
monitors are set to provide a six-minute average automatically. The time
period used may be stated on the EER form. If it is not specified, the opacity
data should be reported in six-minute increments or multiples of six-minute
increments (i_.e., 6, 12, 18, 24, or 36 minutes of opacity). Because the
emission limit is a whole number, the average readings during each 6-minute
period should be rounded to the nearest whole number (i.e., 21% opacity).
If only the time of commencement and the time of completion of a period of
excess opacity is provided, the reviewer may need to determine the total number
of minutes involved to determine whether the data is reported in six-minute
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EER Review Handbook
May 30, 1986
Page 27
periods. For example, a report may state that an excess emission began at 2:12
and ended at 2:24. The incident lasted for 12 minutes, or two six-minute
periods. Thus, the example data is reported in six-minute periods, the speci-
fied opacity data averaging period for NSPS sources.
2. Magnitude of Excess Emissions
The magnitude of an emission which exceeds the opacity standard appears as
a specific numerical value which represents the average opacity over the
six-minute period. Most sources report the average opacity that was measured
during the six-minute periods. If the allowable opacity is 20%, the magnitude
may be expressed as "43%" opacity. The value should be precise; magnitude
should not be expressed as "greater than 40%," for example.
The magnitude of excess emissions is not analyzed during Phase-1 EER
review. For purposes of summarizing exceedance data, the reviewer should
consider any reported emissions greater .than 20% to be a violation of a 20%
opacity standard. Whether or not an emission which only marginally exceeds the
standard is "significant" will be determined when appropriate EER follow-up is
evaluated. An evaluation of the magnitude of excess emissions is useful in
later stages of EER review to determine the severity of the impact of non-com-
pliance and the appropriate agency response.
3. Conversion Factors
[Conversion Factors not applicable to opacity data]
4. Reporting of Malfunction Information
For NSPS, Subpart D sources, periods of excess emissions which occur
during (1) startup or shutdown of the plant or unit, or (2) malfunction of the
process or control equipment must be separately identified.
The nature and cause of the "malfunction" must also be specifically
identified. It is not adequate to state that an excess emission is caused by a
"malfunction." More specific information must be provided.
If you are unsure whether a description of a malfunction is adequate,
please note that there may be a problem in Section 3 of the EER Reviewer's
Checklist. Any corrective actions or measures taken to prevent future malfunc-
tions should also be described.
Examples of descriptions which are incomplete or inadequate include:
o "malfunction"
o "breakdown"
o "problem with boiler."
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EER Review Handbook
May 30, 1986
Page 28
(b) Emission Standard
Step 9B;
Identify the opacity standard applicable to the source and unit.
This information can be found in the cover letter or
memo,
itself, in the "General Compliance Audit Data Sheet," or with
in the EER
other file
information on the source. The emission standard for NSPS electric utilities
is 20% opacity (6-minute average) except for one 6-minute period per hour of
not more than 27 percent opacity" (40 C.F.R. § 60.42a).
The opacity standard applies "at all times except during periods of
startup, shutdown, malfunction, " (40 C.F.R. § 60.11(c)). "Startup" is
defined as "the setting in operating of an affected facility for any purpose;
"shutdown" is defined as "the cessation of operation of an affected facility
for any purpose; and "malfunction" is defined as "any sudden and unavoidable
failure of air pollution control equipment or process equipment or of a process
to operating in a normal or usual manner. Failures that are caused entirely or
in part by poor maintenance, careless operation, or any other preventable upset
condition or preventable equipment breakdown shall not be considered malfunc-
tions" (40 C.F.R. § 60.2).
The Phase-1 reviewer should include all periods of excess emissions in the
total excess emissions for the quarter whether or not they may be "excusable"
under the standard or fall within the hourly exception. This allows the
Phase-1 data summary to serve primarily as a screening mechanism. These issues
will be resolved by Phase-2 or Phase-3 reviewers.
(c) Emissions Data Summary
Step 9C;
Identify specific periods of excess opacity. If the source provides
only summary information or "average" opacity readings over a longer
period of time, note this deficiency in Section 3 under "Emissions
Performance" for possible agency follow-up.
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EER Review Handbook
May 30, 1986
Page 29
Regulations require that the date and time of commencement and the date
and time of completion of all periods of excess emissions be reported in the
EER.
(d) Calculation of Duration of Exceedances
Step 9D;
Calculate the total duration of all periods of excess opacity, using
summary information or calculating directly from the report;
or
Calculate the total duration of all excess opacity by using Table 3
(see Appendix C) entitled, "Summary of Incidents of Excess Opacity."
Although opacity is generally reported in six-minute periods, or multiples
of six-minute periods, .the duration should be calculated in hours, expressed to
the nearest tenth. The following table converts minutes and six-minute periods
to tenths of hours.
Number
of Minutes
3
4-9
10-15
16-21
22-27
28-33
34-39
40-45
46-51
52-57
Number of
6-minute Periods
0
1
2
3
4
5
6
7
8
9
Tenths
of Hours
.0
.1
.2
.3
.4
.5
.6
.7
.8
,9
Exclude any excess emissions which are "caused" by monitor problems. This
time should be included as GEMS downtime. Exclude any excess emissions which
occur during source .downtime. If necessary, check source downtime information
in the EER or in Table 1 (if used) to identify periods of overlap.
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EER Review Handbook
May 30, 1986
Page 30
1. Use of a Summary Table (optional)
The reviewer may choose to calculate excess emissions by using Table 3,
"Summary of Incidents of Excess Opacity." When the data are not easily com-
puted making a summary record of excess emissions may facilitate review and may
allow the Phase-2 or Phase-3 reviewer to check the accuracy of the Phase-1
review, particularly where the Phase-1 reviewer is inexperienced or where the
EER reveals significant emissions or GEMS performance problems. Use of this
summary chart may also make it easier for the reviewer to track the reasons for
excess emissions and calculate a total exceedance time for each reason category.
Some sources provide only the total hours of exceedances per quarter or
per day. This is a reporting problem which requires agency follow-up. If this
is the only information currently available, if the source provides summary
information, or if the reviewer chooses to total the exceedance data from the
EER directly, note total excess emissions in Section 4(b).
Table 3
SUMMARY OF INCIDENTS OF EXCESS OPACITY
Company:
unit:
Quarter:
ov*tx- rpb.
1 !.
to. -f
70:30
3b-
: 30
6.5"
I/it.
n :M
l3-ao\
10
4.100
5"
IJ*L
TOTAL EXCESS EMISSIONS:
Reason Codes
hours
Startup/shutdown '"'
Sootblowing - ^)_
Control Equipment Failures / (.
Process Problems "i U
Fuel Problems O
Other Known Problems O
Unknown Problems.- <
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EER Review Handbook
May 30, 1986 ,
Page 31
(e)
Evaluation of Causes of Excess Opacity
Step 9E;
Evaluate the "nature and cause" of exceedances reported. If there is no
information provided regarding the cause of excess emissions, or if the
reasons are inadequate or unclear, note the problem in Section 3 under
"Emissions Performance."
(f) Evaluation . of Excess Emissions
(optional)~'
by Reason Category
Step 9F; (optional)
Calculate the total duration of exceedances for each reason category.
Record the total duration for each reason category in Section 4(b).
An agency may decide to evaluate specific causes of excess emissions when
total exceedances exceed a specified cut-off or to evaluate all causes of
excess emissions for all sources for a specified quarter or series of quarters
to identify types of problems or typical levels of exceedances associated with
specific problems.
1- EPA Proposed Reason Categories
The reason categories defined below ,are based on the categories which were
proposed by EPA in the "Technical Guidance on the Review and Use of Excess
Emission Reports" (October 5, 1984). Additional categories may be added for
other source categories or to accommodate variations in State regulations.
Many sources currently use their own reason codes or reason categories to
describe the causes of excess emissions. If the reasons are different from
those used by the agency, the reviewer should correlate source reason codes to
the agency reason code so that a uniform code system is used for agency review
of all EERs.
For example, a source may have separate reason codes for each of the
following control equipment problems: "Precipitator Control Problems," "Rapper
-------
EER Review Handbook
May 30, 1986
Page 32
Problems,n or "Precipitator Fields Low Power." Each of these causes would be
included under the proposed reason code which includes "Control Equipment
Problems."
The EPA proposed reason categories (with definitions and examples of
typical source explanation) are:
a. "Startup/Shutdown", as defined in 40 C.F.R.
S 60.2, means "the setting in operation of an affected facility for any
purpose" and "the cessation of operation of an affected facility for any
purpose." Excess emissions which are caused by startup and shutdown necessi-
tated by process or control equipment problems should be categorized as start-
up/shutdown. If certain excess emissions during startup or shutdown are caused
by a control equipment failure or a process problem, that portion of the
exceedance should be reported as a control equipment failure or a process
problem. all other excess emissions should be reported under "Startup/Shut-
down," even though there may have been some additional intervening cause.
This category includes the process of shutting down but does not include
the period of downtime after the completion of this process. Although there
are wide variations from facility to facility, the process of starting up
typically lasts between 6 and 12 hours. The process of shutting down typically
lasts between 4 and 8 hours. Note any single period of startup or shutdown
that lasts longer than the typical startup or shutdown.
"Startup/Shutdown" includes problems described by the sources as:
Boiler off
Light off
Boiler taken down
Boiler coming off line
Outage
Oil light off
Dew point from natural
gas fuel (if exceedances
last for from 1-6 hours)
Poor oil atomization
Started mill
Cyclone light off
Firing boiler
Coal mill startup
Oil firing problems
Unit trip due to loss of
condensate
Recovery from coal stoppage
Pulverizer mill
Putting boiler on line
Unit tripped
b. "Sootblowing" refers to the periodic removal of
soot, slag and/or fly ash from the firebox walls or the tubes of fuel-burning
equipment by the use of compressed air, steam or water.
"Sootblowing" includes problems described by the sources as:
Cleaning cycle Blowing flues Cleaning air preheater
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EER Review Handbook
May 30, 1986
Page 33
c« "Control Equipment Problems" include any on-site
control equipment failures or other problems. This category also includes
emissions caused by control equipment maintenance. It does not include fuel
processing or conveying equipment, boiler, or other industrial process equipment.
It is intended to cover all failures whether they are excusable or inexcusable
as malfunctions under 40 C.F.R. § 60.2, and even though the underlying reason
for the failure is not known.
"Control Equipment Problems" Include problems described by the sources as:
Precipitator electrical
malfunction
Precipitator rapper system
Precipitator de-energized
for maintenance
Ash handling problems
(could be process problem)
Precipitator power supply
tripped
Precipitator dangling
electrode
Rappers not working
Baghouse full
Broken bags
Ash lines leaks
Air blower problems
Baghouse control arm broken,
baghouse into bypass
Precipitator tripped
ESP trouble
High fly ash
Ash lines plugged
Pulling hopper ash
Valve and control problems
Ash water supply problems
& "Process Problems" include on-site equipment
failures other than control equipment. Operational problems are also included.
When distinguishing between process and control equipment, any equipment
necessary for the process is considered process equipment, even though it may
have a role in emissions control (e.g., the I.D. fan).
"Process Problems" include problems described by the sources as:
Load changes
Piling
Gas no coal steam S.H. leak
Insufficient combustion air
Tripped feeder
Damper problems
Boiler combustion upset
Flame scanner and interlock
problems
Upset
High load piling
Steam leak
Unstable firing conditions
Combustion control problems
Air register problems
Ran I.D. fan to balance
wheel
Working on stokers
Working on furnace draft
Working on boiler
Coal mill problems
Fan problems
Plugged air heater
quality or
involved.
problems,"
the supply
variations
emissions,
e. "Fuel Problems"
cover any problem relating to the
Both opacity and SO2 exceedances may be
fuel
condition of the fuel.
Blending or cleaning problems would also be characterized as
as would the use of high sulfur fuel because of an interruption in
of complying fuel, or because of a supplier's error, etc. While
in sulfur content of fuel will more frequently create excess SO2
sulfur content may also affect particulate emissions.
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EER Review Handbook
May 30, 1986
Page 34
"Fuel Problems" include problems described by the sources as:
Hat coal Heavy slag/klinkers Slag in boiler
High ash content in boiler (or problem with boiler)
Low btu content Fuel out of spec.
f. "Other Known Problems" are intended to cover all
known causes of excess emissions not already covered.
"Other Known Problems" include problems described by the sources as:
Tests Fuel tests Operator error
Power interruption
g. "Unknown Causes" apply to all excess emissions
for which the operator must guess at the reason (even though his guess might be
a good one). It would not apply to an equipment failure even though the reason
for failure is not known.
This category includes problems where:
o the source does not know the cause of the excess emissions;
o the source does not state any cause for the excess emissions; or
o the cause reported by the source is unclear, ambiguous or contra-
dictory.
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EER Review Handbook
May 30, 1986
Page 35
(g) Calculation of Percent of Monitored Operating Time
(optional) ' ~~~
Step 9G; (optional)
Calculate the percent of time (while both source and monitor were in
operation) that excess emissions were occurring. This is calculated
by dividing the duration of exceedances by the time in which both the
source and monitor have been operating during the quarter, then con-
verting the result to a percentage:
/Total Duration of
! Excess Emissions
\ (Hours)
Monitored \
Operating Time 1
(Hours) /
Percent of
x 100 - Monitored Operating
Time (Hours)
Where:
Time
in
Quarter
(Hours)
Source
Down-
time
(Hours)
CEHS Downtime
_ During Source
Operating Time
(Hours)
Monitored
= Operating
Time
(Hours)
Make this calculation for the "Percent of Monitored Operating Time" for
total exceedances and for each reason category. Enter the results in
Section 4(b).
Example EER Reviewer's Checklist. Section 4(b)
Opacity Missions Perform
Conjjc.Ui. 6-^nut. ferlod,, Calculate Duration
Causes of Excess anisslons**
(a) Process Start-up/Shutdown
fb) Sootblowing
(c) Control Equipment Problems
(d) Process Problems
(c) Fuel Problems
(f) Other Known Problems
(tj) Unknown Causes
(h) Total
Total Duration
of EE's (Hours)
ll.fT
JL
IL,
3b
<3 3-(5"~
81
Percent of Monitored
Operating Time3
0/7 *
o.\ %
0.1 %
<>2 . / %
- \
»
1.4 *
5^t
Coments
£Sp rtr/ifc
E*s»-~ prob^J
" LL k*i
-------
EER Review Handbook
May 30, 1986
Page 36
(10) Step 10; CDS/GEMS Subset Data Coding
Step 10:
Code the EER data for entry into the CDS/CEMS subset.
(11) Step 11; Completion of Phase-1 Review
Step 11:
Forward the EER, EER Reviewer's Checklist, proposed CDS/CEMS Subset data
entry cards and other relevant information to the designated Phase-2
reviewer for Phase-2 review.
-------
EER Review Handbook
May 30, 1986
Page 37
EER Reviewer's Checklist for SO, Excess Emissions Reports (EERs)
This section uses pages 1 and 3 of the EER Reviewer's Checklist (see
Appendix A, pages 72 and 74) to summarize S02 EERs. The example EER Reviewer's
Checklist used in this manual may be adapted to reflect the specific require-
ments for the source category or State regulation.
Phase-1 review includes a review of both emissions performance and CEMS
performance. Source operating data and CEMS performance data should be evalu-
ated first so that the reviewer can determine the percentage of monitored
operating time the unit was reporting exceedances. The purpose of requiring
the reporting of emissions data is to determine the level of continuous com-
pliance with applicable emissions standards. If the reported data on CEMS
performance or source operation is unclear or shows large periods on non-oper-
ation, the usefulness of the reported excess emission data as an indicator of
the source's overall level of compliance is not necessarily diminished.
-------
EER Review Handbook
May 30, 1986
Page 38
Summary of Phase-1 SO, EER Review Steps
Identify the source, unit, monitor, pollutant and
quarter, and £111 in Section 1.
Check date of receipt or envelope postmark. NSPS
sources shall submit EERs postmarked by the 30th
day of the end of the quarter. Record your finding
in Section 2.
Review all EER information and note any general
problems in Section 3.
Calculate the total source operating time using
the formula below.
Step 6
Determine whether the source affirmatively states
that there were no periods of "CEMS Downtime, Re-
pair or Adjustment." If there is no CEMS down-
time, go to Step 8, "Affirmative Statement of No
Excess Emissions."
If there is no information on source operating
tiae, enter "no" under "Source Operating Time" in
Section 3. For purposes of evaluating emissions
and CEMS performance, assume that the source was
operating throughout the quarter.
If there is specific information or partial infor-
mation , describe the information under "Source
Operating Time."
Step 5A
Determine Total Hours Available in Quarter:
Quarter (identify):
(1,1L,2,3 or 4)
Hours available:
If no information on source operating time is
available, go directly to Step 6, "Affirmative
Statement of No CEMS Downtime."
Evaluate CEMS performance information to determine
if the data meets applicable EER content require-
ments and fill in Section 3 under "CEMS Perfor-
mance Information."
Calculate total CEMS downtime using summary infor-
mation provided by the source or directly from the
EER;
or
Calculate the total CEMS downtime by using Table 2
(see Appendix C) entitled, "Summary of CEMS Down-
time."
Compare the specific times during which the CEMS
was inoperative with source operating downtime.
Where the two overlap, exclude these time periods
from the CEMS downtime.
Calculate the total duration of source downtime
using summary information provided by the source
or directly from the EER;
or
Calculate the total duration of source downtime by
using Table 1 (see Appendix C) entitled, "Summary
of Source Downtime."
Evaluate the causes of CEMS downtime and the na-
ture of system repairs or adjustments to determine
if the source has adequately explained reported
CEMS downtime. If the reasons are inadequate or
unclear, note the problem in Section 3 under "CEMS
Performance Information."
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EER Review Handbook
May 30, 1986
Page 39
Step 7E (optional)
Calculate the total CEMS downtime for each
reason category. Record the total duration
for each reason category in Section 5(a).
Step 7F (optional)
Calculate "Percent Unavailability" for total
CEMS downtime (and for each reason code) by
using the formula provided below. Enter the
result in Section 5(a).
CESS Downtlee During
Source Operating
Tine (Hours)
Source
~ Operating
Tin (Hours)
x 100
or
Calculate the total duration of all excess emis-
sions by using Table 3 (see Appendix C) entitled,
"Summary of Incidents of Excess Opacity."
Evaluate the "nature and cause" of exceedances re-
ported. If there is no information provided re-
garding the cause of excess emissions, or if the
reasons are inadequate or unclear, note the pro-
blem in Section 3 under "Emissions Performance."
Step 8
Determine whether the source affirmatively
states that there were no periods of excess
emissions. If there are no excess emissions,
go to Step 10, "CDS/CEM Subset Data Coding."
Step 9F (optional)
Calculate the total duration of excess emissions
for each reason category. Record the total dura-
tion for each reason category in Section 5{b).
Evaluate all information relevant to excess
emissions for the following types of informa-
tion and fill in Section 3. This should in-
clude the following:
1. Reporting in Periods of the Applicable
Standard
2. Magnitude
3. Conversion Factors
4. Reporting of Malfunction Information
Identify the emission limitation and averaging
period applicable to the source and unit.
Identify specific periods during which the emis-
sions exceeded the applicable standard. If the
source provides only summary information or
"average" opacity readings over a longer period of
time, note this deficiency in Section 3 under
Emissions Performance" for possible agency fol-
low-up.
Step 9G (optional)
Calculate the percent of time (while both source
and monitor were in operation) that excess emis-
sions were occurring. This is calculated by divi-
ding the duration of exceedances by the time in
which both the source and monitor have been opera-
ting during the quarter, then converting the re-
sult to a percentage:
/Total Duration of
( Exc««« Fa las ions
\ (Hour a)
Monitored \
Operating Tiaw 1
/
Percent of
Monitored Operating
TlM (Hour*)
Mhcrat
TlM
in
Quarter
< Hours)
So tire*
Down-
tins
(Hours)
CEMS DowntiM
During Source
Operating Tl«»
(Houra)
Monitored
Operating
TiM
(Hour*)
Make this calculation for the "Percent of Moni-
tored Operating Time" for total excess emissions
and for each reason category. Enter the results
in Section 5(b).
Code the EER data for entry into the CDS/CEMS sub-
set.
Calculate the total duration of all periods of
excess emissions, using summary information or
calculating directly from the report;
Forward the EER, EER Reviewer's Checklist, pro-
posed CDS/CEMS Subset data entry cards and other
relevant information for Phase-2 review.
-------
EER Review Handbook
May 30, 1986
Page 40
B. Explanation of Phase-1 SO, EER Review Steps
(1) Step 1; Identification Check
Step 1;
Identify the source, unit, continuous emission monitoring system,
pollutant and quarter, and fill in Section 1.
Determine the type of facility and continuous emission monitoring system
used to measure emissions at the reporting facility. If this information is
not contained in the excess emission report, it may be found in a source file
maintained by the agency or a completed "GEMS General Compliance. Audit Data
Sheet" (see Appendix B). Basic source identification information includes:
o the type of source (e.g., electric utility, coal or oil fired)
o where the monitor is located (identification of unit and stack);
o type of control used (low sulfur fuel, fuel blending, flue gas
desulfurization (FGD) (i.e., wet or dry scrubber);
o the emission standards and averaging time applicable to the source;
and
o the type of GEMS (manufacturer, model number, type of data recording
system, etc.).
Note any unusual operating configuration. For example, some sources may
measure both scrubbed and unscrubbed emissions discharged from separate stacks
and prorate the measurement results according to flow rates in the two stacks.
Other sources may utilize varying combinations of different fuels (i.e., coal,
oil, gas) and/or supplementary fuel (i.e. , wood refuse)., etc. Those sources
must use special methods for determining the actual emissions rate in units of
the standard.
It is strongly recommended that each agency maintain a permanent file
of GEMS related information for each facility for use during all stages of EER
review. This file should contain basic information such as: source permits;
GEMS General Compliance Audit Data Sheet (see Appendix B) or similar compliance
audit information; EERs and EER summaries for the previous two years; corres-
pondence or other documentation of EER follow-up; monitor audits or testing;
plant inspections, etc.
-------
(2) Step 2; Timeliness Check
EER Review Handbook
May 30, 1986
Page 41
Step 2;
Check date of receipt or envelope postmark. NSPS sources shall submit
EERs postmarked by the 30th day of the end of the quarter. Record your
finding in Section 2.
If the report is late, save the envelope in which the report was submitted
to demonstrate that the source failed to comply with the timeliness requirement.
Timeliness of submission is an important factor because:
o Late submission makes it more difficult to associate specific excee-
dances with on-going problems at the source and to ensure that
corrective action is promptly undertaken.
o Current information from all sources each quarter will enable the
agency to compare the performance of different sources and thereby
maximize the resources available to the agency for follow-up.
o Timely agency follow-up may result in greater all-around respon-
siveness of sources and should increase the credibility of the
agency's EER review program.
Example EER Reviewer's Checklist, Sections 1 & 2
EER REVIEWER'S CHECKLIST
(40 C.F.R. Part 60, Subpart D)
Phase 1 Review
Phase 2 Review/
Subset Data Entry
Phase 3 Review/
CDS Action Entry
bSF 4/aa/Ss-
Name ' Date
Name Date
1. Company
Plant/Unit
fawr A/Wf
Timeliness (Must be postmarked within 30 days of quarter)
(tt) Date Po3tiaarl(«l Ap>u'l /f'/
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EER Review Handbook
May 30, 1986
Page 42
(3) Step 3: General Content Evaluation
Step 3;
Review all EER information and note any general problems in Section 3,
More specific evaluation of the adequacy of the data will be conducted
when the data are summarized. However, some information may be included or
reporting problems may occur which are not directly related to data summary and
uh )<**! eVirviilfl TIP r>rvt-*»rJ -in Rent-ion 3 of the EER Reviewer's Checklist. This
which should be noted in
includes reports where:
There were no excess emissions and no CEMS downtime and further
evaluation of the EER is unnecessary.
There were changes in the operating, control equipment or continuous
emission monitoring systems. This information is very important and
any changes should be noted in the source information file as well as
Section 3 of the EER Reviewer's Checklist.
Actual data in support of summary information are not reported in the
EER. This is a reporting deficiency which should be noted by the
Phase-1 reviewer so that appropriate follow-up action can be taken
particularly if there is a significant amount of CEMS downtime or
exceedances.
Specific information (for example, explanations for excess emissions)
appears only in the cover letter or memorandum and not with the EER
data. This problem makes it very difficult to analyze causes of
excess emissions and may also warrant agency follow-up.
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EER Review Handbook
May 30, 1986
Page 43
Example EER Reviewer's Checklist, Section 3
3. Completeness (For EERs which cover aultlple sonitors, specify aonltor when noting problem!
Source Operating Time
CEHS Performance Information
(a) Affirmative Statement of No Period
of Downtime, Repair or Adjustnent
(Include no CEHS modifications)
(b) Date and Time Identifying
Specific Periods During Hhlcn
CDB Has Inoperative
(c) Nature of System Repairs
or Adjustments
Excess Emissions (EEs) Information
(a) Affirnative Statement of No EEs
(b) Data Reported In Units of
Applicable Standards
(c) Date and Time of Commencement
(d) Date and Time of Completion
(e) Magnitude
(f) Conversion Factors Osed
(g) Identification of EEs Caused by
Start-up, Shutdown, or Malfunction
(h) Nature and Cause of Malfunction
(1) Malfunction Corrective Action
or Preventive Measures
No Problem
y
y
/
*s
^
I/
^
S
s
^
Problem (Describe) /Comments
?jf kit. dOuJH±il*jLs -'U.Kj'f-1. IS 2.
1
(4) Step 4; Availability of Source Operating Time Information
Federal NSPS regulations do not require the reporting of source operation
time, unless a permit provision or similar plant-specific requirement applies.
However, the availability of this information is very important and should be
noted on the EER Reviewer's Checklist.
Step 4;
If there is no information on source operating time, enter "no" under
"Source Operating Time" in Section 3. For purposes of evaluating emis-
sions and GEMS performance, assume that the source was operating
throughout the quarter.
If there is specific information or partial information, describe the
information under "Source Operating Time."
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EER Review Handbook
May 30, 1986
Page 44
Source operating data allow for the adjustment of data to account for
periods of time during which the source was not operating. Comparisons between
sources and tracking individual source performance from quarter to quarter is
more accurate.
If no source operating time information is available, assume that the
source was in continuous operation. If the source was not operating for a.
significant portion of the quarter, the calculation of percent excess emissions
and percent GEMS downtime using this assumption may significantly under-repre-
sent the actual percentages. A preliminary indication of actual source opera-
ting time may be obtained if excess emissions are caused by "startup" or
"shutdown" of the facility.
An agency may, as a matter of policy, contact the source directly to
obtain source operation data or to request routine submission of the data.
(5) Step 5; Source Operating Time
(a) Total Hours Available in Quarter
Because the number of days in each month varies, the time available in
each quarter varies. The following chart provides the total hours available
each quarter, including leap year.
Maximum Time Available in Quarter
Quarter
01
OIL*
02
03
04
* Leap year
Hours
Step 5A;
Determine total hours available in quarter:
Quarter (identify):
Hours available:
(1,1L,2,3 or 4)
If no information on source operating time is available, go directly to
Step 6, "Affirmative Statement of No GEMS Downtime."
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EER Review Handbook
May 30, 1986
Page 45
(b) Summary of Source Downtime
Step 5B;
Calculate the total duration of source downtime using summary infor-
mation provided by the source or directly from the EER;
or
Calculate the total duration of source downtime by using Table 1
(see Appendix C) entitled, "Summary of Source Downtime."
Sources may specify periods of operation or non-operation. Some sources
provide summary information only. Where the source identifies the specific
time periods, summarize the total source downtime.
1. Use of Summary Table 1 (optional)
The reviewer may choose to calculate the source downtime by using the
Table 1, "Summary of Source Downtime." (See Appendix C.) When the data are.not
easily computed from the EER directly, or must be interpreted because they are
unclear or confusing, making a record of source operating downtime will
facilitate review and allows the Phase-2 or Phase-3 reviewer to check the
accuracy of the Phase-1 review, particularly where the Phase-1 reviewer is
inexperienced or where the EER reveals significant emissions or GEMS perfor-
mance problems.
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EER Review Handbook
May 30, 1986
Page 46
Table 1
SUMMARY OF SOURCE DOWNTIME
Company:
Unit:
Quartan
M
ro
$*
Incident
H umfcer
;
,3-
START
. Month/Day/Tine
'/5~ I'-OO
3/IL, 1.3'OD
STOP
Month/Day/Time '
'/a 4 J-oo
3/ao w?3 ' 60
Duration
(Hours)
*2./8
Ibt,
Reason
Jd^tsteuj^
d&ru&vjL na^t
TOTAL SOURC3S DOWHTIMEt
hours
(c) Calculation of Source Operating Time
Step 5C;
Calculate the total source operating time using the formula below.
Time in
Quarter (Hours)
; Source Down-
! time (Hours)
I Source Operating
i Time (Hours)
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EER Review Handbook
May 30, 1986
Page 47
(6) Step 6; Affirmative Statement of No GEMS Downtime
Step 6;
Determine whether the source affirmatively states that there were no
periods of "GEMS Downtime, Repair or Adjustment." If there is no GEMS
downtime, go to Step 8, "Affirmative Statement of No Excess Emissions."
This statement may appear in a cover letter or in the excess emission
report. Some sources report "0" GEMS downtime in a blank on the excess
emissions data form.
Step 7; Summary of GEMS Performance Data
(a) General Information Check
Step 7A;
Evaluate GEMS performance information to determine if the data meets
applicable EER content requirements and fill in Section 3 under "GEMS
Performance Information."
(b) Calculation of GEMS Downtime
Step 7B;
Calculate total GEMS downtime using summary information provided by the
source or directly from the EER;
or
Calculate the total GEMS downtime by using Table 2 (see Appendix C)
entitled, "Summary of GEMS Downtime."
-------
EER Review Handbook
May 30, 1986
Page 48
Calculate total downtime in hours, expressed to the nearest tenth.
following table converts minutes of GEMS downtime to tenths of hours.
The
Number
of Minutes
3
4-9
10-15
16-21
22-27
28-33
34-39
'40-45
46-51
52-57
Tenths of Hours
.0
.1
.2
.3
.4
.5
.6
.7
.8
.9
1. Types of GEMS Downtime
Three types of GEMS downtime may be reported in the EER:
o periods during which the GEMS is inoperative;
o periods during which the GEMS is undergoing routine maintenance or
other repair; and
o periods during which the GEMS is operating, but is generating inaccu-
rate data.
All three types should be included as GEMS downtime. However, "some
sources report the three types of GEMS downtime in different portions of the
EER. In particular, periods during which the GEMS is operating, but is genera-
ting inaccurate data are sometimes included with excess emissions data.
Scan the reasons for excess emissions to determine if the GEMS system is
the "cause" of any excess emissions and include these time periods as GEMS
downtime. Later, exclude these time periods from the excess emissions time
(see Step 9B of this chapter).
Sources are not required to operate the GEMS when the source is not
operating. Do not include any GEMS downtime which occurs during source down-
time. If the EER does not provide adequate information to make this determin-
ation, assume that all reported GEMS downtime occurred during periods of source
operation.
Note that the GEMS includes all parts of the system including:
o sample acquisitions equipment, ,
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EER Review Handbook
May 30, 1986
Page 49
o sample conditioning equipment,
o pollutant analyzer,
o diluent analyzer, and
o data handling/recording equipment.
For example, failure to record data because of computer or data recorder
problems is a failure of the entire system and the time is included as CEMS
downtime.
Sources must include the date and time identifying specific periods during
which the CEMS was inoperative. Quarterly totals or daily totals are not
adequate because they do not allow the reviewer to relate specific periods of
CEMS downtime to specific periods of excess emissions or specific periods of
source downtime.
2. Use of Summary Table for Analyzing CEMS Downtime
(optional)
Making a record of CEMS downtime may help the reviewer to evaluate
confusing or conflicting data and may allow the Phase-2 or Phase-3 reviewer
to check the accuracy of the Phase-1 review, particularly where the Phase-1
reviewer is inexperienced or where the EER reveals significant emissions or
CEMS performance problems. Use of a summary chart may also make it easier to
track corrective actions or reasons for CEMS downtime and calculate a total
CEMS downtime for each reason category.
Some sources provide only the total hours of CEMS downtime per quarter
or per day. If this is the only information available, if the source provides
summary information, or if the reviewer chooses to total the CEMS .downtime
from the EER directly, fill in the total CEMS downtime in Section 5 (a) of the
EER Reviewer's Checklist.
Unless the total amount of CEMS downtime during source operation is very
small, failure to identify the specific times during which the CEMS was
inoperative and the nature of the problem or corrective action is a serious
reporting deficiency which should be noted for possible agency follow-up.
-------
Table 2
EER Review Handbook
May 30, 1986
Page 50
Company:
Unit:
Quarter!
SUMMARY OF GEMS DOWNTIME
tjtj f i-ial
U
Incident
Number
/
^
3
4
r
(a
START
Month/Day/ Time
!//(/ . f-00
Va-3 ?-.oo
3-/I. IS or,
*/« lJ.:oo
%£. *'«>
tflt I'-CO
STOP
Month/Day/Time
V;r J4't>o
'/J-3 U'-oO
^/t, ^?4-'-<50
^/J ;^"-oo
^V/7 ^4:OT
Vf/y IJ.-OQ
Duration
(Hours)
7,2-
^
L,
3
31 '
A
Reason/Correc-
tive Action
1*M.riwJ
tttf 2£&&&jel
Pnl*. c(ea.*jid_
Sh>rru- : pouxs- fui
U-HJc^tu)*-,
J~J>oif. Ca.tiLif.hn
A'-Njut, rff>a^u.at.
Pro*-*, oltasHffJ
Reason
Code
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EER Review Handbook
May 30, 1986
Page 51
(d) Evaluation of Reasons for GEMS Downtime
Step 7D;
Evaluate the causes of GEMS downtime and the nature of system repairs
or adjustments to determine if the source has adequately explained
reported GEMS downtime. If the reasons are inadequate or unclear,
note the problem in Section 3, under "GEMS Performance Information."
The "cause" of the GEMS downtime or the "nature of system repairs or
adjustments" should be identified for all NSPS sources. Each separate incident
should be explained. An incident of GEMS downtime is any uninterrupted period
(of any time length) during which the GEMS is not operating or providing
accurate data.
Evaluation of GEMS Downtime by Reason Category (optional)
Step 7E: (optional)
Calculate the total GEMS downtime for each reason category.
the total duration for each reason category in Section 5(a).
Record
An agency may choose to evaluate specific causes of GEMS downtime:
o when total GEMS downtime exceeds a specified cutoff; or
o to evaluate all causes of GEMS downtime for a specific
quarter or series of quarters to identify types of problems
and typical levels of downtime associated with specific
types of problems.
The reason categories defined below are based on the revised reason
categories included in EER Regional Guidance developed by EPA in 1984. Addi-
tional reason categories may be added for other source categories or to accom-
modate variations in State regulations.
Sources may use their own reason codes or reason categories to report the
causes of monitor problems. If these reason codes differ from those used by
the agency, the reviewer should correlate source reason codes to the agency
reason codes so that a uniform code system is used.
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EER Review Handbook
May 30, 1986
Page 52
1. EPA Proposed Reason Categories
The reason categories proposed by EPA (with definitions and examples of
typical source explanations) ares
a. "Monitor equipment malfunction" includes the
equipment needed to measure SO2 and diluent (O3 or CO2) effluent concentrations.
It does not include strip chart recorders and data acquisition systems.
The monitoring equipment includes
analyzer, and (3) the sample interface.
(1) the SO, analyzer, (2) the diluent
The SO2 analyzer senses SO2 within the
effluent sample and generates an output proportional to the gas concentration.
The diluent analyzer senses O2 or CO2 within the effluent sample and generates
an output proportional to the gas concentration. The nature and type of sample
interface equipment varies for extractive or in situ GEMS.
Extractive CEMS's withdraw and transport samples from the effluent stream
to the pollutant and diluent analyzers. The sample interface equipment for
extractive monitoring systems may include (1) in-stack or out-of-stack parti-
culate filters, (2) sampling probe(s), (3) sample transport lines, (4) condi-
tioning systems for the removal of moisture and/or particulate from the sample
stream, (5) sample pumps, (6) devices for controlling sampling rate and/or
sample pressure, and (7) devices allowing for the introduction of calibration
gases (e.g., pressure regulators, valves, tubing, and timing/sequencing de-
vices) . It should be noted that some extractive GEMS analyzers are designed to
sample at multiple locations in a sequential fashion. In these cases, some of
the sample interface components are specific to each monitoring location (e.g.,
sampling probes and sample lines); other sample interface components and the
analyzers are essentially time-shared between the various measurement points.
Some CEMS's monitor the concentrations of multiple effluent species (e.g., SO2,
NO, O2, CO2). Where such systems are used, additional sample interface
equipment ensures that (1) proper sample conditioning is achieved for each
analyzer and (2) all necessary sampling operations occur in the proper order
when measurements of the various effluent constituents are made in a sequential
fashion. Extractive CEMS's may also be equipped with protective devices, such
as (1) high-pressure blowback or purge systems to prevent excessive particulate
or moisture accumulation on various sample interface components and (2) protec-
tive enclosures that are heated and air conditioned to ensure that the analyzers
are maintained at a constant temperature.
In-situ CEMS's project a beam of light through a portion of the effluent
stream and thereby sense the concentrations of the components of interest.
Cross-stack, in situ CEMS's project the light beam across all or most of the
stack or duct and are similar to opacity CEMS's in design. Thus, for most in
situ CEMS's, virtually all of the sample interface components are eliminated.
However, for most cross-stack, in situ CEMS's "monitoring equipment" may also
include those components of the measurement system that protect the optical
components of the analyzer from the effluent stream. The equipment consists
primarily of a purge air system (i.e., power supply, blowers, air filters, and
connecting hoses). The equipment which provides temporary protection for the
analyzer in the event of failure of the purge air system usually consists of
pneumatically or electronically activated shutter devices.
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EER Review Handbook
May 30, 1986
Page 53
A "malfunction" is any period during which the monitor is not operating or
is producing inaccurate data due to a failure of any GEMS component. A "moni-
tor equipment malfunction" does not include periods of calibration, QA, or
normal or preventive maintenance. Also, monitor equipment malfunction does not
include GEMS downtime attributable to "non-monitor equipment malfunctions,"
"other known causes," or "unknown causes." Because the EER often lists only
the activities undertaken to correct a malfunction, the reviewer must distin-
guish between normal maintenance procedures and corrective actions following a
malfunction. The time necessary to complete corrective actions following a
malfunction should be included in the "monitor equipment malfunction" category.
"Monitor equipment malfunction" includes problems described by the sources as:
Pulled 02 probe replaced sample cell
S02 monitor stayed in cal-gas mode
replaced cal gas valve and repaired
cal-filter problem
Lamp burned out replaced
Erratic 02 readings replaced filter
Sample line plugged cleaned
Replaced leaking sample valve
Found loose calibration fitting - repaired
Replaced S02 monitor probe seal
Replaced UV lamp on S02 monitor
Faulty zero mirror on S02 analyzer
replaced
Internal S02 span cell reading high ~
flowed gases and recalibrated
Excessive S02 monitor drift recalibrated
and returned to service
Low 02 sample gas flow rate recalibrated
and returned to service
S02 monitor reference voltage swinging
cleaned optics and returned to service
S02 readings unreasonable calibrated
with gases and returned to service
Low temperature and 02 readings re-
calibrated and returned to service
Internal span cell reading high
Replaced plugged probe filter and returned
to service
S02 readings too high checked cali-
bration, removed span cells, adjusted
calibration and returned to service
High sample vacuum -- replaced probe filter
Dry stack probe plugged cleaned probe
High sample vacuum cleaned sample lines
and moisture traps, adjusted purge air
blowback
Leak in scrubber inlet fitting ~ replaced
fitting and cleaned probe
No calibration gas due to accidental
leakage ordered and installed gas,
checked for system gas leakage
Temperature fault calibrated heater
board and 02 board
Found bad sequence relay replaced relay
contact, recalibrated monitor
Calibration error found broken
rotameter replaced rotameter and
recalibrated system
Stack sample conditioning not heating
correctly low amperage found
looking for break in line ~ work
hindered by broken wet stack drain
02 reading wrong on wet and dry stack
recalibrated 02 monitor
Auto calibration not working calibra-
tion gas regulator was improperly set
Found low range 02 gas empty replaced
gas and recalibrated
Gas calibration showed S02 monitor 3%
high recalibrated temperature com-
pensation circuit
Readings out of tolerance recalibrated
MA loop from S02 monitor
Calibration readings high on test
made range adjustment
S02 reference alarm found bad UV lamp
and replaced
O2 probe pulled from stack to weld new
holder ~ large hole found in probe
casing replaced probe
Temperature difference between monitor
stack reading too great calibrated
temperature compensation circuit and
flowed calibration gas
Temperature reading off Found loose
TC connection checked span cell and
flowed gas
Internal span cells replaced and re-
calibrated
S02 reading unreasonable and reference
voltage swinging. Replaced P.M.T.
socket and UV tube. U3 chip loose on
TC contact. Replaced R2 on TC contact.
Recalibrated and returned to service.
Reference alarm reference level too
high. Replaced DV tube and checked span
cell. Adjusted monitor for proper
readings.
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EER Review Handbook
May 30, 1986
Page 54
b. "Non-monitor equipment malfunction" includes all
equipment other than the monitor equipment that is necessary to transfer,
compute averages, and record SOa emissions data. "Non-monitor equipment
malfunction" almost always refers to failures or problems with the strip chart
recorder, data losses or computer data acquisition system problems. However,
the time required to perform routine maintenance of these systems should be
excluded from this category and be included under "Calibration/QA."
The simplest SOa CEMS's record SO2 and diluent (i.e., O2 and CO2) concen-
tration measurements using strip chart recorders. Emission levels in units of
the standard (Ib SO2/10 Btu) may be computed manually . using appropriate
conversion factors and equations, based on the concentration measurements.
However, most CEMS's utilize an automated method of determining emissions in
units of the standard. Thus, some CEMS's use an analog computer and record
emissions in units of the standard on a strip chart recorder. Other systems
convert the analog output signals of the SO2 and diluent analyzers to a digital
signal, which is then processed either by a dedicated or time-shared computer.
Regardless of the approach and type of equipment that is used with a particular
CEMS, a malfunction of this equipment that results in the loss of monitoring
data should be classified as "non-monitor equipment malfunction."
"Non-monitor equipment malfunction" includes problems described by the sources as:
Computer Data Acquisition System Problems Strip Chart Recorder Problems
Printer will not function stepping motor
blowing fuses
Cooling fan stopped bearing problem
overheated computer
Incorrect data entry from terminal
Installed new software version
Software damaged replaced disk
Updated current software for calibration
values
Computer down replaced I/O board and
restarted
Printer failure
Program error lost data
Reinitialized system
Ran diagnostic software check
Recorder not functioning
Chart not recording
Replace chart recorder
Chart drive off
Chart drive running slow
Chart paper off track
Chart paper jammed
Chart not inking
c. "Calibration/QA" includes any period during which
the monitoring system is out-of-service for the purpose of calibration, routine
or preventive maintenance, or other quality assurance related activity.
Corrective action and associated recalibration and/or calibration checks
immediately following a malfunction, however, should be classified under the
appropriate malfunction category.
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EER Review Handbook
May 30, 1986
Page 55
e Federal "gelations specify that all source operators required to use SO
GEMS must check both the pollutant and diluent responses at zero concentration
(or at a low range) and at an upscale value (span check) at least once per day.
Approval of alternate procedures requiring only a span check (i.e., deleting
the zero check) for some cross-stack in situ monitors has been granted in some
cases. The regulations also require that the monitor be adjusted when the zero
and/or span check results exceed specified limits.
The time required to perform the daily zero and span checks is usually a
few minutes per day; however some cross-stack in situ GEMS may require as lona
as one hour per day for these checks. The reporting of this time is not
required and should not be included in "Calibration/QA" or any.'other category,
since the monitor is performing a required activity. However, when the zero or
span drift limits are exceeded, a significant amount of time may elapse before
the adjustments are completed. Monitor downtime associated with completing the
zero or span adjustments should be included in "Calibration/QA."
In addition to zero and span checks and/or adjustments that are referred
to as calibration," other activities often referred to as "calibration"
inducts:
o electronic checks of the pollutant and diluent monitors and/or data
recording devices;
o injection of two or more calibration gases and adjustment of the
analyzer(s) and/or GEMS responses to the correct value; and
o in situ monitors only; off-stack or clear stack checks of the zero
value or comparisons and adjustments of component'or system responses
relative to independent effluent measurements.
The simplest
perform; however,
time to complete.
for "calibration"
activities except
tion/QA."
of these activities usually requires only a few minutes to
the more complex activities may take a significantly longer
Despite the wide variation in the amount of time required
and the inconsistent use of terminology, all of the above
routine/daily zero/span checks should be included as "Calibra-
"Calibration/QA" includes activities described by the sources as:
Washed sample line, cleaned sampling probes
and performed sample line leak check
S02 monitor dynamic cal check
Flowed cal gases and adjusted temperature
compensation
Unit removed from service for general
maintenance
Flowed gas and recalibrated
Check calibration with gas cells
Checked and adjusted temperature com-
pensation circuit
Preventive maintenance on sample pump
changed oil
SO2 system preventive maintenance
calibrated S02 analyzer
Quarterly gas audit
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EER Review Handbook
May 30, 1986
Page 56
d. "Other known causes" includes other known reasons
for monitor downtime or inaccuracy, excluding all malfunctions and "Calibra-
tion/QA" activities. This category includes the interruption of the monitoring
equipnnnt power supply, human error and other relatively unusual events. It
also includes monitor problems or inaccuracy associated with the inability to
perform routine maintenance because of severe weather conditions.
"Other known causes" Includes problems described by the sources as:
Halting for vendor service
Power rewiring on stack.
Removed monitor due to duct leak
Monitor left in calibration mode
Out of calibration gas on order
Correct date/time changes
Waiting for parts shipment
Moved monitor to new installation
Control room power outage
Power loss at monitor
Developing new calibration procedure
Failed to log monitor on computer
e. "Unknown cause" includes inaccurate or no data
without an apparent explanation. If a data recorder fails, and the reason for
failure is not known, this would be categorized under "non-monitor equipment
malfunction." However, if data are clearly inaccurate, and a data recorder
failure is suspected but cannot be confirmed, it should be classified ^as
"unknown cause." Unknown cause" also includes CEMS downtime explanations which
are insufficient to determine the appropriate reason category.
This category includes those instances where:
o no explanation is provided by source; .
o the source states that the cause is unknown; or
o the source explanation is inadequate, unclear or contradictory.
(f) Calculation of Percent Unavailability (optional)
Step 7F; (optional)
Calculate "Percent Unavailability" for total CEMS downtime (and for
each reason code) by using the following formula. Enter the result
in Section 5(a).
CEMS Downtime During
Source Operating
Time (Hours)
Source
Operating
Time (Hours)
x 100
Percent
Unavailability
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EER Review Handbook
May 30, 1986
Page 57
"GEMS Downtime During Source Operating Time (Hours)" is calculated in Step
7B. "Source Operating Time (Hours)" is calculated in Step 5C.
An agency may choose to calculate "Percent Unavailability" for sources
which have a high total percentage of monitor downtime or to develop data
related to GEMS performance in selected problem areas. "Percent Unavailability"
may be used (in a manner similar to total duration, magnitude or number of
incidents, for example) to target sources for agency follow-up or inspections.
Example EER Reviewer's Checklist, Section 5(a)
S- Data Suimary for SO, or MO EERs (Use Separate Forms for Each Monitor)
Type of Pollutant -20',
!a) CDS Performance (Includes Aggregate Downtime for Pollutant and Diluent Monitors!
Causes of CEMS Downtime**
'a) Monitor Equipment Malfunctions
(b) Non-monitor CEMS Equipment HaHunctions
le.e. , computer, data recorder, etc.)
Ic) Calibratlon/QA
(d) Other Known Causes
!»>) Unknown Causes
(f) Total
Total Down-
III
-
L,
(*
3
\Z<*
Percent
Unavailability _
6./,
"~ *
0.3 %
0.3 %
O.Z- %
6.7,
Comments
PrDlat. CJjUL*-ljcL-
Pcrut-6>L, (&44-/
Step 8; Affirmative Statement of No Excess Emission;
Step 8;
Determine whether the source affirmatively states that there were no
periods of excess emissions. If there are no excess emissions, go to
Step 10, "CDS/GEMS Subset Data Coding."
This statement may be found either in a cover letter or in the excess
emission report.
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EER Review Handbook
May 30, 1986
Page 58
(9) Step 9t SO, Excess Emissions Data
(a) Content Evaluation
Step 9A;
Evaluate all information relevant to excess emissions for the following
types of information and fill in Section 3. This should include
the following:
1. Reporting in Units of the Applicable Standard
2. Magnitude
3. Conversion Factors
.4. Reporting of Malfunction Information
1. Reporting in Units of the Applicable Standard
The regulations specify that monitoring data must be reported in units of
the applicable standard using the applicable conversion procedures specified in
subparts. For S0a monitors, emissions from a facility must be reported in
terms which are relative to the production rate of the facility.^ Excess
emissions are reported in terms of number of pounds of pollutant emitted per
million Btu. For example, a source will report "1.5 lbs/10 Btu" for a speci-
fied period.
For Subpart D NSPS sources SO2 data (for periods during which the standard
was exceeded) are currently reported in three-hour time periods. (Other source
categories may use a 24-hour rolling average to calculate excess emissions; for
purposes of this manual, example SO2 data is assumed to be reported in three
hour "blocks.") Many data acquisition systems are designed to provide a
three-hour average of SO2 emissions for a specific three-hour period automati-
cally. The three-hour periods used by the source must be identified and must
remain consistent from day-to-day.
2. Magnitude of Excess Emissions
If the source fails to report an exact level of emissions during a time
period otherwise identified as being in violation of the applicable emission
standard, this should be noted in Section 3 of the EER Reviewer's Checklist.
This is a serious deficiency which may warrant agency follow-up.
The actual magnitude of excess emissions is not analyzed during Phase-1
EER review. Whether or not a level of emissions which only marginally exceeds
the standard is "significant" will be determined when appropriate EER follow-up
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EER Review Handbook
May 30, 1986
Page 59
is evaluated. An evaluation of the magnitude of excess emissions is useful in
later stages of EER review to determine the severity of the impact of non-com-
pliance and the appropriate agency response.
3. Conversion Factors
At fossil fuel-fired steam generators a pollutant monitor (measuring SO
°f N°x concentrations) and a diluent monitor (measuring O2 or CO2 concentra-
tions I are used in conjunction with the F-Factor method of calculating
emissions in units of lbs/10 Btu to determine the level of emissions. There
are a number of formulations of the F-Factor approach. The appropriate
method to be used depends on whether O2 or CO2 measurements are obtained, and
whether pollutant and diluent concentrations are obtained on a wet or dry
basis. Other source categories may require or allow the use of alternative
conversion factors.
The Phase-1 reviewer should note whether an F-factor and an equation (or
other conversion procedures) are provided in the report. If no equation is
provided, note this deficiency in Section 3 of the EER Reviewer's Checklist
Other information in the source file may provide adequate information regarding
conversion factors used in the emissions calculation. A determination
regarding follow-up, if appropriate, should be made during Phase-2 or Phase-3
review.
If the source provides information on the conversion factors used to
determine emissions, the Phase-1 reviewer may wish to compare this information
with the formulas provided in the summary tables below. However, this
comparison is optional; the agency may choose to review the accuracy of the
conversion method used during Phase-2 or Phase-3 review or during a general
GEMS compliance audit.
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EER Review Handbook
May 30, 1986
Page 60
F-Factor Calculation Equations
227.0%H + 95.7%C + 35.4%S + 8.6%N - 28.5%Q]
Fd
GCV
(metric units)
Fd =
106 [3.64%H + 1.53%C + 0.57%S + 0.14%N - 0.46%O]
GCV
(English units)
Fc
20.0%C
GCV
(metric units)
Fc =
321 X 1()3%C
GCV
(English units)
p -
347.4%H + 95.7%C + 35.4%S + 8.6%N - 28.5%O
(metric)
Fw =
IP6 [5.56%H + 1.53%C + 0.57%S + O.I4%N - 0.46%O2 + 0.21%H2O*]
GCVW
(English)
Fw =
XjFi (consistent basis)
*Note: The %H2O term may be omitted if %H and %O include the unavailable hydrogen
and oxygen in the form of
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EER Review Handbook
May 30, 1986
Page 61
F-Factors For Various Fuels a'b
Fuel T\pe
Coal
Anthracite
Bituminous
Lignite
Oil
Gas
Natural
Propane
Butane
Wood
Wood Bark
Fd
DSCF
I06 Btu
10140(2.0)
9820(3.1)
9900 (2.2)
9220 (3.0)
8740 (2.2)
8740 (2.2)
8740 (2.2)
9280(1.9)*
9640(4.1)
F» Fc
WSCF SCF
10* Btu 1Q6 Btu
10580(1.5) 1980(4.1)
10680(2.7) 1810(5.9)
12000 (3.8) 1920 (4.6)
10360(3.5) 1430(5.1)
10650 (0.8) 1040 (3.9)
10240(0.4) 1200(1.0)*
10430(0.7) 1260(1.0)
1840(5.0)
1860(3.6)
Fo
1.070 (2.9)
1.140(4.5)
1.0761 (2.8)
1.3461 (4.1)
1.79 (2.9)
1.10(1.2)*
1.479 (0.9)
1.5 (3.4)
1.056 (3.9)
^Numbers in parentheses are maximum deviations (Cc) from the midpoint F-factors.
To convert to metric system, multiply the above values by 1.123 X |(T4 to obtain scm I06 cal.
Note: All numbers below the asterisk (*) in each column are midpoint values. All-others
are averages.
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EER Review Handbook
May 30, 1986
Page 62
F-Factors and Emission Rate Calculations
Factor
Fd
Fc '
Units
DSCF
10* Btu
DSCF
106 Btu
Measurement
Required For
Excess Air
Determin ition
%o (dry
basis)
*C02 (dryor
wet basis)
Calculations
r-cri 20'9
L CsFd 2(J 9 _ %Q2
F-r F 10°
C 9tCO2
Comments
Cs determined on
dry basis
Q on dry or wet
basis consistent with
CO2 measurement
WSCF
I0& Btu
%02
(wet
basis)
E
20.9
20.9(1 -Bwa)-%02
The "wet" F-factor,
Cws and %O2 on
wet basis
Bwa = average
moisture content of
ambient air
DSCF
100 Btu
(wet-
basis)
E = CwsFd
20.9
20.9(|-Bws)-%O2
Fd used to calculate
E with %O2 and Cws
on a wet basis and
gas moisture content
known
_ 20.9 Fd
'° '" " Io 100 Fc
_20.9-T0O2
%C02
Miscellaneous
factor useful
for checking
Orsat data
Note: The wet F-factor, Fw, may not be used in any application which involves the addition or
removal of moisture from the combustion effluent. As a result, it is not suitable for wet
scrubber applications without additional correction.
Note also: Bwa = Amount of moisture in ambient air. which value can be established by any of the
following four methods.
a) Fixed constant value of 0.027 allowed
b) Continuous measured value
c) Monthly value based on previous history
d) Annual value based on previous history
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EER Review Handbook
May 30, 1986
Page 63
4- Reporting of Malfunction Information
_ For NSPS, Subpart D sources, periods of excess emissions which occur
during (1) startup or shutdown of the plant or unit, or (2) malfunction of the
process or control equipment must be separately identified.
The nature and cause of the "malfunction" must also be specifically
identified. It is not adequate to state that an excess emission is caused by a
malfunction." More specific information must be provided.
If you are unsure whether a description of a malfunction is adequate,
please note that there may be a problem in Section 3 of the- EER Reviewer's
Checklist. Any corrective actions or measures taken to prevent future malfunc-
tions should also be described.
Examples of descriptions which are incomplete or inadequate include:
o "malfunction"
o "breakdown"
o "fuel problem."
(b) Emission Standard
Step 9B;
Identify the emission limitation and averaging period applicable to
the source and unit.
This information can be found in the cover letter or memo, in the EER
itself, in the "General Compliance Audit Data Sheet," or with other file
information on the source. The emission standards for SO,, emissions from NSPS
electric utilities are:
o .80 Ib. per million Btu from liquid fossil fuel
o 1.2 Ib. per million Btu from solid fossil fuel.
If a combination of fuels is.used, the emission standard is determined by
a formula specified in the applicable regulations. The standard determined
through the use of this formula should appear in the excess emission report or
in the source file (§ 60.43).
For sources subject to an SO2 standard, periods of excess emissions are
usually defined as "any three-hour period during which average emissions
(arithmetic average of three contiguous one-hour periods) exceed the standard
(§ 60.45(g)(2)).
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EER Review Handbook
May 30, 1986
Page 64
The emission standards apply "at all times except during periods of
startup, shutdown, malfunction,..." (40 C.F.R. § 60.11(c)). "Startup" is
defined as "the setting in operating of an affected facility for any purpose;
"shutdown" is defined as "the cessation of operation of an affected facility
for any purpose; and "malfunction" is defined as "any sudden and unavoidable
failure of air pollution control equipment or process equipment or of a process
to operate in a normal or usual manner. Failures that are caused entirely or
in part by poor maintenance, careless operation, or any other preventable upset
condition or preventable equipment breakdown shall not be considered malfunc-
tions" (40 C.F.R. § 60.2).
The Phase-1 reviewer should include all periods of excess emissions in the
total excess emissions for the quarter whether or not they may be "excusable"
under the standard. This allows the Phase-1 data summary to serve primarily
as a screening mechanism. These issues will be resolved by Phase-2 or Phase-3
reviewers..
(c) Emissions Data Summary
Step 9C;
Identify specific periods during which the emissions exceeded the
applicable standard. If the source provides only summary information
or "average" SO2 emission levels over a longer period of time than the
recommended averaging period, note this deficiency in Section 3 under
"Emissions Performance" for possible agency follow-up.
Regulations require that the date and time of commencement and the date
and time of completion of all periods of excess emissions be reported.
(d) Calculation of Duration of Exceedances
Step 9D;
Calculate the total duration of all periods of excess emissions, using
summary information or calculating directly from the report;
or
Calculate the total duration of all excess emissions using Table 4 (see
Appendix C) entitled, "Summary of Incidents of SO2 Excess Emissions."
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EER Review Handbook
May 30, 1986
Page 65
_ Exclude any excess emissions which are "caused" by monitor problems. This
time should be included as CEMS downtime. Exclude any excess emissions which
occur during source downtime. If necessary, check source downtime information
in the EER or in Table 1 (if used) to identify periods of overlap
1. Use of a Summary Table (optional)
The reviewer may choose to calculate excess emissions by using Table 4
Summary of Incidents, of SO2 Excess Emissions." When the data is presented in
a manner which is not easily computed, making a summary record of excess
emissions may facilitate review and may allow the Phase-2 or Phase-3 reviewer
to check the accuracy of the Phase-1 review, particularly where the Phase-1
^eWer/S inexPerienced °r where the EER reveals significant emissions or
CEMS performance problems. Use of this summary chart may also make it easier
for the reviewer to track the reasons for excess emissions and calculate a
total exceedance time for each reason category.
Some sources provide only the total hours of exceedances per quarter or
per day. This is a reporting problem which requires agency follow-up. If this
is the only information currently available, if the source provides summary
information, or if the reviewer chooses to total the exceedance data from the
EER directly, note total excess emissions in Section 5(b).
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HER Review Handbook
May 30, 1986
Page 66
Table 4
SUMMARY OF INCIDENTS OF SO, EXCESS EMISSIONS
Company t
Unit:
Quarter:
rtivY.our-
. nssr
Incident
Number
J
3-
3
A
5"
START
Honth/Day/Tljne
'/? 4, -co
'bl 0:00
1/30 ICT-00
% 18:00
3/fe- T-oo
STOP
Month/Day/Tlme
V«? 3-oo
MJI fe oo
l/30 J-/'. 00
=3/6' O-OO
3/-r /z:oo
Duration
(Hours)
-2 /
t
1
!<,
3
Reason/Correc-
tive Action
BrokX* r'tc-^r-'ef
KKA- l-f
-------
EER Review Handbook
May 30, 1986
Page 67
(f} Eval^ation of Excess Emissions by Reason Category
(optional) r~~ ''
Step 9F; (optional)
Calculate the total duration of excess emissions associated with each
reason category. Record the total duration for each reason category
in Section 5(b). .
to agency may decide to evaluate specific causes of excess emissions when
total exceedances exceed a specified cut-off or to evaluate all causes of
excess emissions for all sources for a specified quarter or series of quarters
to identifv tvces of problems or typical levels of exceedances associated with
1- EPA Proposed Reason Categories
The reason categories defined below are based on the categories which were
by EPA in the "Technical Guidance on Agency Review of Excess Emission
^ ^ f Follow-up Actions" (October 5, 1984). Additional categories may be
Sons ° source categories or to accommodate variations in State regula-
Many sources currently use their own reason codes or reason categories to
describe the causes of excess emissions. If the reasons differ from those used
by the agency, the reviewer should correlate source reason codes to the agency
reason codes so that a uniform code system is used for agency review of all
JbERs
The EPA-proposed reason categories for SO2 exceedances (with definitions
and examples of typical source explanation) are:
a. "Startup/Shutdown", as defined in 40 C.F.R.
§ 60.2, means "the setting in operation of an affected facility for any pur-
pose and the cessation of operation of an affected facility for any purpose "
Excess emissions which are caused by startup and shutdown necessitated by
process or control equipment problems should be categorized as startup/shut-
down. However, SO2 exceedances are generally not associated with process
startup and shutdown unless source operating constraints require that the
scrubber be started up after the process has reached certain minimum operating
levels or when the scrubber must be removed from service prior to shutting down
the process. If certain excess emissions during startup or shutdown are caused
£>y a control equipment failure or a process problem, that portion of the
exceedance should be reported as a control equipment failure or a process prob-
lem. All other excess emissions should be reported under "Startup/Shutdown "
even though there may have been some additional intervening cause.
-------
EER Review Handbook
May 30, 1986
Page 68
"Startup/Shutdown" include problems described by the sources
Process startup (FGD off-line until minimum
operating level reached)
FQ) removed from service prior to boiler shutdown
Scrubber off-line until minimum flue
gas temperature reached during boiler
startup
b. "Control Equipment Problems" include any
on-site control equipment failures or other: problems. This category also
includes emissions caused by control equipment maintenance. It would only
apply to facilities which use flue gas desulfurization as its control method.
It does not include fuel processing or conveying equipment, boiler, or other
process equipment. It is intended to cover all failures whether they are
excusable or inexcusable as malfunctions under 40 C.F.R. §' 60.2, and even
though the underlying reason for the failure is not known.
"Control Equipment Problems" include problems described by the sources as:
Scrubber module removed from service because
of excessive pressure due to pluggage
Reduced scrubber efficiency due to pH problems
Automatic scrubber control system malfunction
Clogged scrubber spray nozzles
Excessive scrubber bypass flow due to booster
fan failure
Modules inoperative due to frozen lines in
scrubber liquid system
Scrubber removed from service due to
loss of seal water to all pumps
Module removed from service due to
broken recycle line
Low level in presaturator tank caused
presat. pumps to trip. The resulting
high temperature took the modules off.
c. "Process Problems" include on-site equipment
failures other than control equipment failures. Operational problems are also
included. When distinguishing between process and control equipment, any
equipment necessary for the process is considered process equipment, even
though it may have a role in emissions control (e.g., the I.D. fan).
"Process Problems" include problems described by the sources as:
Emergency power demand scrubber bypass
increased during load change
I.D. fan: failure temporary
emergency scrubber by-pass
-------
EER Review Handbook
May 30, 1986
Page 69
d. "Fuel Problems" include any problem relating to
the quality or condition of the fuel. Both'opacity and SO3 exceedances may be
involved. Blending or cleaning problems would also be characterized as "fuel
problems," as would the use of high sulfur fuel because of an interruption in
the supply of complying fuel, or because of a supplier's error, etc. While
variations in sulfur content of fuel will more frequently create excess SO
emissions, sulfur content may also affect particulate emissions. 2
"Fuel Problems" include problems described by the sources as:
Fuel shipment out of specification
Fuel sulfur higher than expected
Fuel blending problem
expanded low sulfur fuel supply
low sulfur coal conveyor malfunction
-- insufficient auxiliary fuel
e. "Other Known Problems" include all known causes
of excess emissions not already covered.
"Other Known Problems" include problems described by the sources as:
Fuel tests Operator error
Tests
Power interruption
f- "Unknown Causes" apply to all excess emissions
for which the operator must guess at the reason (even though his guess might be
a good one). It does not apply to an equipment failure even though the reason
for failure is not known.
This category includes problems where:
o the source does not know the cause of the excess emissions?
o the source does not state any cause for the excess emission; or
o the cause reported by the source is unclear, ambiguous or contradic-
tory.
-------
EER Review Handbook
May 30, 1986
Page 70
(g) Calculation of Percent Monitored Operating Time (optional)
Step 9G; (optional)
Calculate the percent of time (while both source and monitor were in
operation) that excess emissions were occurring. This is caJculated by
dividing the duration of exceedances by the time in which both the source
and monitor have been operating during the quarter, then converting the
result to a percentage:
.Toral Duration of
j Excess Emissions -J-
\ (Hours)
Monitored \
Operating Time I
(Hours) /
Percent of
x 100 =» Monitored Operating
Time l!'ours)
Whore:
Time
in
Quarter
(Hours)
Source
Down-
time
(Hours)
4
CEMS Downtime
During Source
Operating Time
(Hours)
Monitored
= Operating
Time
(Hours)
Make the calculation for the "Percent of Monitored Operating Time"
'for total excess emissions and for excess emissions associated with
each reason category. Enter the results in Section 5(b).
Example EER Reviewer's Checklist, Section 5(b)
(b) Emissions Performance (Data Reported aa Consecutive 3-Hour Periods)
Causes o£ Excess Emissions**
(a) Start-up/Shutdown
(b) Control Equipment Problems
(c) Process Problems
(d) FUel Problems
(e) Other Known Problems
(() Unknown Causes
(q) Total
Total Duration
of EE's (Hours)
21
2.1
3
Af
Percent of Monitored
Operatlno Time
- \
/.^%
I.-L,*
~~ \
*
0. 2s\
£&, %
Cements
F(rb
-------
EER Review Handbook
May 30, 1986
Page 71
Step 10; CDS/CEMS Subset Data Coding
Step 10;
Code the EER data for entry into the CDS/CEMS subset.
Step 11; Completion of Phase-1 Review
Step 11;
Forward the EER, EER Reviewer's Checklist, proposed CDS/CEMS Subset data
entry cards and other relevant information to the designated Phase-2
reviewer for Phase-2 review.
-------
-------
Appendix A;
Appendix A
Page 72
EER REVIEWER'S CHECKLIST
(40 C.F.R. Part 60, Subpart D)
Phase 1 Review
Phase 2 Review/
Subset Data Entry
Phase 3 Review/
CDS Action Entry
Name
Date
Name
Date
Name
Date
1. Company
Plant/Unit
Quarter
Year
2.
3.
Timeliness (Must be postmarked within 30 days of quarter)
(a) Date Postmarked (b) Days
Completeness1 (For EERs which cover multiple monitors, specify monitor when noting problem)
Source Operating Time 1
GEMS Performance Information
(a) Affirmative Statement of No Period
of Downtime, Repair or Adjustment
(include no CEMS modifications)
(b) Date and Time Identifying
Specific Periods During Which
CEMS Was Inoperative
(c) Nature of System Repairs
or Adjustments
Excess Emissions (EEs) Information
(a) Affirmative Statement, of No EEs
(b) Data Reported in Units of
Applicable Standards
(c) Date and Time of Commencement
(d) Date and Time of Completion
(e) Magnitude
(f) Conversion Factors Used
(g) Identification of EEs Caused by
Start-up, Shutdown, or Malfunction
(h) Nature and Cause of Malfunction
(i) Malfunction Corrective Action
or Preventive Measures
No Problem
Problem (Describe)/Comments
-------
Appendix A
Page 73
4. Data Summary for Opacity EERs
(a) Opacity CEHS Performance
Causes of CEHS Downtime**
(a) Monitor Equipment Malfunctions
(b) Non-monitor CEMS Equipment Malfunctions
(e.g., computer, data recorder, etc.)
(c) Calibration/QA
(d) Other Known Causes
(e) Unknown Causes
(f) Total
Total Down-
time (Hours)
Percent ,
Unavailability''
%
%
%
%
%
%
Comments
"Percent unavailability" is calculated by the following formulas:
[CEHS Downtime During Source
I Operating Ti»a (Hours)
Source Operating)
Tim (Hours) /
100
Percent
Unavailability
Mheret
Tim in
Quarter (Hours)
Source Down-
time (Hours)
Source
Operating TiM (Hours)
(b) Opacity Emissions Performance (Data Reported as Consecutive 6-minute Periods; Calculate Duration in
Hours to Nearest Tenth)
Causes of Excess Emissions**
(a) Process Start-up/Shutdown
(b) Sootblowing
(c) Control Equipment Problems
(d) Process Problems
(e) Fuel Problems
(f) Other Known Problems .
(a) Unknown Causes
(h) Total
Total Duration
of EE's (Hours)
Percent of Monitored
Operating Time
%
%
%
%
%
%
%
%
Comments
"Percent of Monitored Operating Time" is calculated by dividing the total hours of exceedances by the
time in which both the source and monitor have been operating during the quarter, then converting the result
to a percentage:
/Total Duration of
I excess Eaissions
\ (Hours)
Monitored \
Operating Tine I
(Hours) /
Percent of
x 100 - Monitored Operating
Time (Hours)
Nherei
Time
in
Quarter
(Hours)
Source
Down-
time
(Hours)
4
CEMS Downtime
During Source
Operating Tiae
(Hours)
Monitored
Operating
Time
(Hours)
4
Assume all reported CEMS downtime occurs during periods of source operation unless explicitly stated.
** Proposed definitions for these categories appear in "Technical Guidance on the Review and Use of Exces^
Emission Reports."
-------
Appendix A
Page 74
5- Data Summary for S(£ or NO EERs (Use Separate Forms for Each Monitor)
Type of Pollutant
(a) GEMS Performance (Includes Aggregate Downtime for Pollutant and Diluent Monitors)
Causes of CEMS Downtime**
(a) Monitor Equipment Malfunctions
(b) Non-monitor CEMS Equipment Malfunctions
(e.g., computer, data recorder, etc.)
Monitored Operating
Tlj» (Hours)
Where s
Time
in
Quarter
(Houri)
Source CEMS Downtime
Down- __ During Source
time Operating Time
(Hours) (Hours)
Monitored
" Operating
Time
(Hours)
Assume all reported CEMS downtime occurs during periods of source operation unless explicitly stated.
** Emission *1? ^ "^^ categories appear in "Technical Guidance on the Review and Use of Excess
-------
-------
Appendix Bt
Appendix B
Page 75
GEMS GENERAL COMPLIANCE AUDIT DATA SHEET
40 C.F.R. part 60, Subpart D
(See Instruction Sheet)
Audit Results
Follow-up
Recommended
Performed By
(Yes/No)
(Name)
(Datej
2. Plant/Unit(s)
Address
Source Type
Size
3. CEMS Contact
(Name)
(Position]
(Telpnone No.J
4. Bnissions Requirements
Opacity
SO,
NO..
Emissions
Limitations
Are There Exceptions?
Description of
Control Svstera
5. CEHS Compliance Status
Opacity
S02
N0x
Type of
CSA/CEHS
Recuirement
Date
CEMS In-
stalled &
Operational
^
^
^
Date
of PST
Is Source
Filing
EERs?
To Whom?
^
/
/
Do EERs
Indicate
Emissions
Problems?
Do EERs
Indicate
CEMS
Problems?
Do EERs
Comply w/
Reporting
Requirements ?
Results
of Agency
Field
Audit
-------
6. Basic Monitor Information
Opacity
S02
CO,
0,
Monitor Make,
Model & Serial Number
7. Additional Baseline Information/Comments
Appendix B
Page 76
Recorder Type
and Model
Computer/
Software
Other
8. Follow-up Action Plan
-------
Appendix C;
Appendix B
Page 77
Company:
Unit:
Quarter:
Table 1
SUMMARY OF SOURCE DOWNTIME
START
Month/Day/Time
STOP
-Month/Day/Time
TOTAL SOURCE DOWNTIME:
hours
-------
Appendix C
Page 78
Table 2
SUMMARY OF GEMS DOWNTIME
Company:
Unit:
Quarter:
Incident
Number
*
START
Month/Day/Time
;
STOP
Month/Day/Time
Duration
(Hours)
Reason/Correc-
tive Action
"
Reason
Code
TOTAL GEMS DOWNTIME:
Reason Codes
hours
a = Monitor equipment malfunction
b - Non-monitor equipment malfunction
c - Calibration/QA
d s Other known causes
e s Unknown causes
-------
Appendix C
Page 79
Table 3
SUMMARY OF INCIDENTS OF EXCESS OPACITY
Company:
Unit:
Quarter:
Incident
Number
,
START
Month/Day/Time
STOP
Month/Day/Time
Duration
(Hours)
Reason/Correc-
tive Action
Reason
Code
TOTAL EXCESS EMISSIONS:
Reason Codes
a = Startup/shutdown
b = Sootblowing
c = Control Equipment Failures
d = Process Problems
e = Fuel Problems
f = Other Known Problems
g = Unknown Problems
hours
-------
Appendix C
Page 80
Table 4
SUMMARY OF INCIDENTS OF SO, EXCESS EMISSIONS
Company:
Unit:
Quarter:
Incident
Number
START
Month/Day/Time
- --
;
'
STOP
Month/Day/Time
Duration
(Hours)
Reason/Correc-
tive Action
-
Reason
Code
TOTAL EXCESS EMISSIONS:
Reason Codes
a » Startup/shutdown
b = Control Equipment Failures
c « Process Problems
d « Fuel Problems
e = Other Known Problems
f = Unknown Problems
hours
-------
Appendix D
Page 81
Appendix D;
OPACITY CEMS COMPONENTS
The monitoring equipment includes all of the apparatus necessary to measure the opacity of the
emissions at the monitor installation location(s) and to convert the measurements to the equivalent
opacity that would be observed at the stack exit. Almost all contemporary opacity monitors are
double-pass systems (i.e., the light beam traverses the effluent stream twice; the light source and
detector are both located on the same side of the stack). The major components of the opacity
measurement system are:
(1) transceiver .
Contains the light source, detector, optical analyzer, and some
electronic processing equipment. Also incorporates means for
generating simulated zero condition and upscale (span) condition to
facilitate daily zero and span checks. May also include alignment
sight for checking optical alignment of transceiver and reflector
components.
(2) reflector
(3) signal cable
(4) control unit
(S) combiner system
(Sometimes referred to as a retrorefleeter, although this is a trade
name.) Usually contains only a corner cube reflector. Has no
moving parts and no electronic components.
Multi-conductor signal cable which transmits output signal from
transceiver to control unit.
Converts electronic signal from transceiver (usually proportional to
double-pass transmittance) to units of opacity corrected for path
length variations between the measurement location and the stack
exit. Also includes fault lamps, provisions forinitiating zero and
span checks, and panel meter readout of opacity and other measure-
ment parameters. The control unit contains multiple electronic
signal processing circuits (often referred to as "PC's" ~ printed
currents-, "cards," or "boards"), a power supply, and various
switches and controls.
Used only when multiple transmissometers are installed in multiple
ducts. The combiner determines the equivalent stack exit opacity
from the inputs provided by the multiple transmissometers. For some
opacity measurement systems, the combiner is used in conjunction
with individual control units. The combiner contains electronic
signal processing circuits and other electronic hardware similar to
that contained in the control unit.
The opacity "monitoring equipment" also includes those components of the measurement system that
protect the optical components of the transmissometer from the effluent stream. The equipment which
provides on-line protection of the analyzer consists primarily of a purge air system (i.e., power
supply, blowers, air filters, and connecting hoses). The equipment which provides temporiry~protec-
tion for the analyzer in the event of failure of the purge air system usually consists of pneumati-
cally or electronically activated shutter devices.
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-------
Appendix E
Page 82
Appendix E:
DISCUSSION OF SOURCE REASONS FOR OPACITY CEMS DOWNTIME
The following are explanations of typical source descriptions of problems associated with
different components of the CEMS:
Monitor Equipment Malfunctions
What they said
What they meant
(1) Transmissometer malfunction
(2) Transceiver malfunction
(3) Transceiver board damaged
(4) Shutter failure
Repaired shutter
(5) Blower failure
Blower shutdown
Blower problems
Blower replacement
(6) Filter alarm switch
malfunction
Repair filter alarm switch
(7) Monitor misalignment
Alignment shift
(8) Investigation of alarm
problem
Troubleshooting for alarm
problem
Replaced defective alarm card
Undefined malfunction of measurement system generally
resulting in no data or obviously invalid data (e.g.,
offscale above 100%, offscale below 0%, data exhibiting
repeating oscillating pattern clearly not due to process or
control system problems, etc.).
Same as (1) except problem was isolated to transceiver.
Failure of electronic circuit board in transceiver, most
often attributable to aging of electronic components, light-
ening strikes, or power supply fluctuations.
Steel shutters on transceiver or reflector side of
stack blocking light beam. Shutters are reported to fail
when they activated at an inappropriate time (i.e., when the
purge air system is working properly).
Blower in purge air system for either the transceiver or
reflector either failed completely or failed to
maintain sufficient air flow through the air filters.
Usually results in activation of fault light, indicating
need for maintenance, and activation of shutters (where so
equipped), thus eliminating all further effluent opacity
measurements until problem is resolved.
Indicates faulty pressure activated switch in air purge
system which is used to determine if there is sufficient
air flow through system to protect transmissometer
component. Failure of this switch usually results in
activation of shutters, thus eliminating all further opacity
measurements until the problem is resolved.
Indicates that the optical alignment between the
transceiver and reflector has deteriorated, thus resulting
in opacity measurements which are biased high (or are 100% if
alignment is sufficiently disturbed). This problem occurs
most frequently during startup and shut-down due to thermal
contraction or expansion of the duct or stack in which the
transmissometer is installed.
All of these statements indicate problems with one of the
fault lamp indicators or opacity alarm systems. When
the fault and alarm indicators are operating properly, the
activation of these systems usually indicates that some
component of the monitoring system is operating outside the
manufacturer's limits or source selected control limits, and
thus, that the data quality may be affected. The corrective
actions necessary to resolve the problem indicated by the
fault lamp or alarm system are basically the sasae? and
usually require that the monitor be remover
during the troubleshooting/repair aetiviti©s.
-------
Appendix E
Page 83
Hhat they said
What they meant
(9) Replace opacity card
Opacity PC board failure
(10) Optical density card failure
Replace OD P.C. board
(ID Zero cal stack
Zero cal failure
(12) Stuck in span
button stuck
(13) Span shift
(14) Defective micro switch
Switch contacts failed
(15) Not integrating properly
(16) Combiner stuck
Combiner malfunction
(17) D/A alarm
Indicates failure of specific electronic circuits within the
control unit. The opacity board converts the transmittance
signal to opacity and makes correction to stack exit
diameter.
Indicates failure of specific electronic circuits within
control unit. The optical density (OD) board converts
transmittance signal to units of optical density for further
signal processing. Of particular importance when multiple
monitors are installed on a single unit.
Indicates monitor remaining in zero check mode, thus
preventing effluent opacity measurements. Monitoring system
continuously displays zero value. Problem may be due to
malfunction in either transceiver or control unit
electronics.
Same as (11) except internal span check filter is in Cal
optical path. Monitoring system continuously displays span
check value.
Monitor displays incorrect value for span check. Reason for
drift is unknown. Span drift cannot be eliminated by normal
adjustment procedure. All subsequent effluent monitoring
data will be biased in same direction as span drift.
Switches in transceiver or control unit fail to operate
properly, usually resulting in problems described in (11) or
(12) above.
Monitor fails to generate 6-minute average opacity values
due to electronic malfunction in sample and hold circuitry.
Malfunction of combiner unit having similar impact to
malfunction of control unit in single monitor installations
(see items (8) through (14) above).
For computerized systems, "D" D/A flag usually refers to
digital and A/D error "A" refers to analog. The
example notations reflect (1) problems in the conversion
from the monitor to digital signals in the computer, or
(2) unacceptable differences in the stack exit opacity as
calculated independently by the analog control unit or
combiner and the computer data/acquisition system.
Non-monitor equipment malfunction:
Strip Chart Recorder Problems
(1) Recorder not functioning
Replace chart recorder
(2) Chart drive off
Chart drive running slow
(3) Chart paper off track
Chart paper jammed
(4) Chart not inking
Chart not recording
Several possible failures are (1) chart drive functioning,
but a constant value is recorded regardless of opacity
monitor output; (2) chart drive not functioning, but
instrument responds to changes in opacity monitor output;
and (3) chart recorder dead.
Obvious problems with the recorder time axis.
Obvious problems with chart paper.
Obvious problems with chart marking mechanisms.
-------
Appendix E
Page 84
What they said
Computer Data Acquisition System Problems
What they meant
(1) Insufficient data flag on DAS
(2) Reload program for alarm
problem
(3) Reinitialized system
(4) Incorrect entry time update
(5) Worked on incorrect alarm
printout
(6) Computer down -- replaced I/O
board after trying to
reprogram
(7) Program error reset time
(8) Computer stopped replaced
I/O board
(9) Malfunction data loager
(10) Reinitialized for time"
(11) DAS computer failed and
repaired
(12) Incorrect D/A alarm printout
(13) DP30 software check
(14) Ran diagnostic tape
(15) Reloaded program for D/A
alarm problem
(16) Lost info from terminal
(17) Lost information in computer
(18) Computer did not make cal-
culation ?
(19) Printer failure
Items (1) through (19) represent impenetrable computer
which is not meant to be understood. Usually indicative
of computer software, and/or operator malfunction and/or
basic incompatability.
Calibration, QA, and routine and preventive maintenance:
(1) Optics cleaned
Lens cleaned
Cleaned transceiver windows
Cleaned reflector
Cleaned zero reflector
(2) Cleaned purge air systems
Changed filters
Replaced air filters
(3) Cleaning monitor
General maintenance
Preventive maintenance
Cleaning ports
Cleaning site pipe
(4) Printer maintenance
Changed chart paper
Recorder maintenance
Cleaned control unit/combiner
Replace fault lamp bulbs
(5) Reinitiate computer system
Run diagnostic tape
Repair D/A alarm
Routine maintenance of
terminal
Software enhancements
(6) Partial calibration
Recalibrated control unit
Recalibrated combiner
On-stack audit checks
Opacity system audit
Adjust zero/span responses
Cleaned transmissometer optical surfaces exposed to
effluent.
Service air purge system.
Normal maintenance of transmissometer to improve monitor
reliability.
Normal maintenance of control room components and data
recording devices.
Normal maintenance of computer system.
Component calibration procedure.
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