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CONTINUOUS EMISSIONS
MONITORING CONFERENCE
DALLAS, TEXAS:
FEBRUARY 15-17, 1977
CONFERENCE REPORT AND RESPONSES
TO KEY QUESTIONS AND ISSUES
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
OFFICE OF GENERAL ENFORCEMENT
WASHINGTON, D.C. 20460
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EPA-340/1-77-025
CONTINUOUS EMISSIONS
MONITORING CONFERENCE
DALLAS, TEXAS:
FEBRUARY 15-17, 1977
CONFERENCE REPORT AND RESPONSES
TO KEY QUESTIONS AND ISSUES
by
Entropy Environmentalists, Inc.
P.O. Box 12291
Research Triangle Park, N.C. 27709
Contract No. 68-01-4148
EPA Project Officer: Louis R. Paley
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
Office of General Enforcement
Washington, D.C. 20460
December 1977
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STATIONARY SOURCE ENFORCEMENT SERIES
The Stationary Source Enforcement series of reports is issued by the Office
of General Enforcement, Environmental Protection Agency, to assist the
Regional Offices in activities related to enforcement of implementation
plans, new source emission standards, and hazardous emission standards to
be developed under the Clean Air Act. Copies of Stationary Source Enforcement
reports are available - as supplies permit - from the U. S. Environmental
Protection Agency, Office of Administration, General Services Division,
MD-35, Research triangle Park, North Carolina 27711, or may be obtained, for
a nominal cost, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22151.
REVIEW NOTICE
This report has been reviewed by the Division of Stationary Source Enforcement
and approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the Environmental Protection
Agency, nor does mention of trade names or commercial products constitute
endorsement or recommendation for use.
11
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PREFACE
The Division of Stationary Source Enforcement (DSSE) in
conjunction with the Region VI office of the U.S. Environmental
Protection Agency (EPA) sponsored a conference in Dallas, Texas
during February 15-17, 1977, on continuous emission monitoring.
This report presents a detailed summary of the conference pro-
ceedings as well as consensus responses to some of the key
questions which arose during the course of the conference.
These consensus responses were jointly developed by DSSE and
the Emission Standards and Engineering Division (ESED) after
the conclusion of the conference.
Furthermore, these concensus reponses (which are detailed
in Section II of the report) serve to either place in proper
perspective, complete, correct, or modify concepts and issues
presented during the conference. All responses have been reviewed
and, as necessary, amended by appropriate'EPA personnel to re-
flect the latest, most thorough agency interpretation of the
various questions and issues. Section II is, therefore, intended
to provide States and EPA Regional Offices with interim, but
at the same time, the most current guidance to assist them in
expeditiously implementing their continuous monitoring programs.
The text of the conference proceedings (Section III) is
presented in a format summarizing the individual presentations
and has been prepared through the use of tape recordings and
notes made during the conference. Although an extensive effort
has been made to present the information as accurately as
possible, many of the statements have been augmented by the re-
collections and interpretations of the authors in an effort to
clarify or complete presentations when necessary. Therefore,
it should be understood that the presentation abstracts in Section
III do not necessarily reflect the exact statements of the
designated speakers.
111
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TABLE OF CONTENTS
I. Conference Summary 1
II. Responses to Key Questions and Issues Raised
During the Conference
A. Communication with Sources 4
B. Continuous Monitor Types, Costs, Maintenance 5
C. Continuous Monitoring Data-Uses and Handling 7
D. Location of Continuous Monitors 10
E. Testing, Observation of Tests, Calibration, 13
Certification
F. Enforcement, SIPs, NSPS 18
III. Proceedings: Summaries of Conference Presentations
A. Operation Principles of Continuous Monitors 21
B. Monitoring Regulations 22
C. Implementation of Regulations 22
D. Quality Assurance in Continuous Monitoring 23
E. Location and Selection of Monitors
1. Regulations 24
2. Agency Experience - Selection 25
3. Agency Experience - Location 26
4. Source Experience 26
F. Vendor Experience with Regulations
1. Lear-Siegler (Dave Lester) 27
2. Du Pont (Bill Fuller) 29
3. EDC (Harry Lord) 29
G. Monitor Performance Tests - Pretest Meetings 30
H. Performance Specification Test Procedure
1. Regulations 31
2. Source Experience 32
3. Conducting Performance Tests 33
I. Observation and Evaluation of Monitor
Performance Tests 33
J. Evaluation of Performance Test Data 34
K. Importance of Calibration and Follow-Up
Inspections 34
L. Transmissometer Performance and Inspection 35
M. Data Handling Regulations 36
N. General Comments on Continuous Monitoring Data 36
0. Evaluation and Use of Excess Emission Reports 37
P. Regulations Revisions 38
Q. Agency Strategies and Future Plans 38
IV. Conference Questionnaire Results 41
V. Appendices
A. Regional Office Contacts for NSPS § SIP Revisions 47
B. Reference Publications 51
C. Conference Attendees 60
IV
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SECTION I
CONFERENCE SUMMARY
A "Continuous Emission Monitoring Conference", sponsored
by the Division of Stationary Source Enforcement (DSSE) in con-
junction with the Region VI Office of the EPA, was held on
February 15-17, 1977 in Dallas, Texas, and was the second EPA-
wide forum of its type conducted during the past two years. The
conference was structured to assist state and regional personnel
in implementing their continuous monitoring programs, (primarily
emphasizing related NSPS requirements), through technical as well
as administrative oriented presentations, to identify and discuss
key unresolved continuous monitoring questions, and to present
future plans for a continuous monitoring program. Agency, source,
vendor and contractor personnel discussed various aspects of contin-
uous monitoring and their individual experiences with continuous
monitors. Throughout the conference much discussion was generated
which led to a variety of questions. Solutions to many questions
were offered, but a large number remained unanswered at the con-
clusion of the conference. Subsequent reviews and consideration
of these questions by ESED and DSSE have resulted in answers and
interim guidance to these and additional questions. Therefore,
it should be noted that the responses to key questions and issues
as found in Section II, as a whole, unofficially represent the
latest consensus viewpoint of these two EPA divisions (as of 6/77) .
The conference topics were primarily geared toward NSPS
regulations, with lesser emphasis being placed on the SIP revisions
and NESHAP regulations. The general format of the conference was
to discuss, from the different points of view, the steps which are
necessary for state agencies, Regional Offices, and sources to
ensure that continuous monitoring systems become and remain work-
able. With group discussion providing important input to most of
the presentations, topics which were presented included: the
types of equipment available and their operational principles,
quality assurance, regulation summaries, monitor selection and
installation, pretest meetings, monitor performance specification
tests, data handling and recording, inspection, use of continuous
emission monitoring data and future planning.
The operating principles of various types of continuous
monitors for measuring opacity and gaseous emissions were
discussed with special emphasis being placed on the advantages
and disadvantages of a particular type of device. A set of
notes describing the basic monitoring principles was distributed
to those persons attending the conference. This was followed by
a description of some of the larger monitor companies, pointing
out differences in marketing philosophy where some companies prefer
to sell only monitors while others sell entire systems. It was
noted that a variety of data handling devices are available, and
the level of sophistication chosen by a source owner or operator
usually depends on the resources and manpower available to him.
When choosing a data handling system, consideration must be
given to the normally higher manpower requirements for using
and maintaining less automated devices.
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Regulations controlling facilities specified in the Federal
Register were described, summarizing what has to be monitored
and the emissions limits. There was much discussion on the
reporting requirements imposed on the source owners. The method
in which sources retain data for the required two year period is
not well defined by the regulations and is often left to the
interpretation of the source owners. Large source to source
variation is found in reporting formats, location of data, ease
of retrieval, and the coordination of process and continuous
emission data. This causes problems for agency personnel
interested in recovering past information.
The Region VI method of determining where new sources
are located is rather informal. Obtaining copies of construction
permits is usually the best form of information. Very often,
sources reveal themselves by requesting information from the
agency. Interchange between agency and source then begins and
becomes straight forward.
The State of Texas, through the effort of the Texas Air
Control Board, has become a leader in implementing continuous
monitoring regulations. They feel that their regulations for
self-monitoring, referred to as Rule 9, work well and represent an
adequate response to EPA's State Implementation Plan revision
requirements for continuous emission monitors.
The question of location of monitoring systems spurred
much discussion. The regulations are rather well defined for
transmissometers but are less definitive in the case of gaseous
monitors. There are many sections of the regulations that are
left for interpretation by source and agency personnel. This
often leads to a monitor being installed incorrectly or not in
an optimum location. If this is the case-, the source either has
to move the monitor or prove that representative measurements
of emissions can be obtained from the present location.
It was pointed out that early involvement by informed
agency personnel can prevent the selection of continuous moni-
toring devices and installation sites not capable of meeting
federal or state requirements. Education for source and agency
personnel is also a necessity and is presently lacking. Both of
the above could help prevent costly mistakes and save both
industries and agencies time and monev.
Vendors of transmissometers and in-situ and extractive
gaseous monitors presented working descriptions of their par-
ticular types of monitors, in addition to much valuable field
information which they had acquired working with sources.
Brought to light were many problems that probably were not en-
visioned or considered in writing the regulations, as well as many
problems which have arisen as a result of the regulations. It
was apparent that vendors can be a valuable source of information
in developing manuals and workshops on continuous monitoring,
•a- d their input should be used.
The benefits of holding a meeting before an actual monitor
performance specification test were discussed from several view-
points. Many problems can be avoided if the meeting is held
well in advance of the actual testing.
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The presentation of source experience in carrying out a
monitor performance test was very informative and well received
by the audience. Procedural alternatives were discussed along
with problems that may arise during testing. Agency personnel
stated that it was their function to see that tests are run
properly, and if unacceptable procedures are observed, testing
should be repeated or, in very serious cases, be stopped com-
pletely. TACB also suggested that it is good policy to check
the analytical procedures of testers by giving them spiked or
standard unknown samples. Many useful points on observing
performance tests were made. Possible methods of handling excess
emission reports were discussed along with the intent of the
Federal Register on the subject of data handling. Furthermore,
several weak points in the regulations were pointed out.
Quality assurance programs have been started which assess
the performance of continuous monitors. Results of these pro-
grams showed that, in general, gaseous monitors are meeting the
accuracy specifications set forth in the regulations. The
studies have only been checks on particular continuous moni-
toring devices and have not included system checks. These
and other field inspection programs also showed that other
requirements such as those of the continuous process monitoring,
monitor system maintenance, and data recording areas, are very
often not being met by various sources.
Overall, the conference brought out many of the needs that
agency personnel have in implementing the NSPS and NESHAP
continuous monitoring regulations and in helping states develop
and use their SIP continuous monitoring requirements. There is
an immediate need to develop guidance for observers of continuous
monitoring tests, for monitoring data evalvations and inspections,
and for sources installing monitors. In many areas, the Federal
regulations need clarification. It is also necessary to have
open communications between regions, to remain consistent when
alternative procedures are developed and determinations made.
Guidance in these areas would be of great use. Additional
technical background is also needed for states to revise their
SIPs to incorporate continuous monitors.
Future plans for continuous monitoring programs were pre-
sented, and other programs, which would be invaluable for agency
people to carrying out their operations, were discussed. The
responses to a questionnaire on the scope of the conference
pointed out where efforts should be directed and relayed the
message that the conference was accepted very favorably by those
who were present.
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SECTION II
.ESPONSES TO KEY QUESTIONS AND ISSUES RAISED DURING THE CONFERENCE
During the course of the conference, many key questions
and issues arose which were fielded either by the speakers
or by other participants in the conference. In the
section below, those of significant importance have been
delineated along with the answers and discussions which
followed. An attempt has been made to place each
individual question under one of several topical headings.
For this reason, answers to some questions may rightfully
overlap into one or more additional categories and may even
appear to be out of context.
The following text has been reviewed by personnel from
the Division of Stationary Source Enforcement (DSSE) and
from the Emission Standards and Engineering Division (ESED).
The answers offered during the conference sessions by the
named individuals along with those responses which resulted
from the subsequent input (herein designated as "Supplemental
Consensus Viewpoint") of the DSSE and the ESED define, in
terms of the subject and within the limits of the questions,
the current thinking of these two offices. As such, consensus
viewpoints serve to either place in proper perspective,
complete, correct, or modify any substantive but unclear or
ambiguous responses made during the conference. It is cer-
tainly the intention that this" Section be used by States and
EPA Regional Office personnel to complement and assist in the
effectual and expeditious implementation of their continuous
monitoring programs.
A. Communication With Sources
1. HOW ARE SOURCES NOTIFIED OF CONTINUOUS MONITORING
SYSTEM (CM) REGULATIONS (AND CHANGES IN THE
REGULATIONS)?
R.J. Woods, E.I. DuPont (Source): The State's
construction permit outlines continuous monitoring
requirements for his plant.
R.E. James, TACB (State Agency): I feel that TACB
has been a little remiss in keeping in touch with
sources. We need to answer questions before they
become problems.
J. Cohen, EPA, NEIC: One problem is that the questions
often do not arise until after the fact.
L.R. Paley, EPA, DSSE: Officially, through the
Federal Register, in addition some agencies notify
their sources on an intermittant basis.
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2. CAN A SOURCE BE REQUIRED TO ATTEND A PRE-TEST MEETING?
L.R. Paley: Although most people (sources and agencies
alike) believe it is advantageous to do so, probably
not, if they do not want to cooperate.
3. CAN A NSPS SOURCE (WHICH IS REQUIRED TO OPERATE CM's)
START-UP WITHOUT HAVING ADEQUATE CONTINUOUS MONITORING
SYSTEMS?
L.R. Paley: Yes, because the source is not required
to adequately operate the CM until prior to his
conducting the performance test (60 days after
achieving maximum production, but no later than 180
days after initial start-up) and does not have to
demonstrate that the CM meets EPA's performance
specifications until (up to) 30 days after the
performance test.
B. Continuous Monitor Types, Costs, and Maintenance
1. IS CONTINUOUS MONITORING TECHNOLOGY SUFFICIENTLY
ADVANCED TO JUSTIFY THEIR REQUIREMENT? WHICH (IF ANY)
TECHNOLOGIES WORK WELL OVER THE LONG TERM?
L.R. Paley: Yes, our experience presently indicates
that those CM's which pass the performance evaluation
test will work well over the long term. These are
two of the objectives of the Quality Assurance Branch's
(QAB) surveys concerning quality control in continuous
monitoring. There is not enough data accumulated
yet to determine precisely how well monitors work,
but the surveys are to be continued in expanded form.
Supplemental Consensus Viewpoint: Yes, preliminary
findings of the QAB and other agency studies show
that it is sufficiently advanced to justify the
present requirements.
2. HOW DOES THE COST OF CONTINUOUS MONITORING EQUIPMENT
RELATE TO PLANT SIZE? WHAT ARE THE COSTS OF SAMPLE
CONDITIONING? OF DATA HANDLING?
F.C. Jaye, Acurex/Aerotherm (Contractor): Costs are
fairly independent of plant size. Opacity instruments
will run from $6,000 to $9,000 generally; other,
$5,000 to $7,000 per instrument. Some variation in
cost will arise in the interface between stack and
instrument, and in the sample conditioning equipment.
There will also be wide variations in data handling
costs depending on the complexity of the data handling
system desired.
Supplemental Consensus Viewpoint: The costs given
above are capital costs per pollutant. A more
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detailed discussion of costs is outlined in the
6 October 1975 preamble of the regulations.
Highlights are as follows:
"...For opacity monitoring alone, investment
costs including data reduction equipment
and performance tests are approximately
$20,000, and annual operating costs are
approximately $8,500. ...For power plants
(using) opacity, nitrogen oxides, sulfur
dioxide, and diluent monitoring systems,
the investment cost is approximately
$55,000, and the operating cost is
approximately $30,000 (annually)..."
These estimates are intended to reflect
installation costs, data reduction and
recording costs, and evaluation costs --
based on 1975 dollars.
3. WHAT ARE TYPICAL MAINTENANCE HISTORIES FOR CONTINUOUS
MONITORING SYSTEMS?
H.C. Lord, EDC (Vendor): We have found that to date
users are not motivated to maintain their own
systems. EDC feels that it should perform
maintenance on its monitors.
D.J. Lester, LSI (Vendor): Maintenance is up to
the customer. Most companies choose to have their
own personnel do the maintenance; there is a wide
variety among plants in the extent of this maintenance
W.F. Fuller, E.I. DuPont (Vendor): A preventive
maintenance program including probe inspection is
recommended about twice a year. Routine maintenance
by the customer is encouraged by equipment design
and instructional documentation.
4. WHAT ARE THE RELATIVE ADVANTAGES OF SINGLE-PATH
AND DOUBLE-PATH TRANSMISSOMETERS?
F.C. Jaye: As they are being built right now, the
double-path instruments tend to be less sensitive
to misalignment. If correctly installed, there
are no theoretical advantages to either. The
double path instruments do perform slightly better
at low opacities.
Supplemental Consensus Viewpoint: We presently
do not know of any single pass instrument that meets
the zero, span and calibration requirements set forth
in the regulations. Fiber optics may permit the
future use of single-path systems.
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5. ARE THERE ANY MONITOR SPECIFICATIONS FOR VINYL
CHLORIDE CONTINUOUS MONITORS? IS THERE SOME
EQUIVALENT, SUBSTITUTE METHOD?
There are presently no monitor specifications or
methods, and none will be available in the near
future. OR§D has long range plans to develop
this information.
Supplemental Consensus Viewpoint: There are no
monitor specifications or methods, and none are
being considered except as noted in Part 61 of the
21 October 1976 Federal Register.
6. WHAT IS THE USUAL RELATIONSHIP BETWEEN THE SELLER
AND THE INSTALLER OF MONITORING EQUIPMENT?
H.C. Lord: The seller is usually responsible for
obtaining the purchase order. At that point, an
installer usually takes over supervision of the
installation and certification of the CM.
7. DO ( OR WILL) MONITOR VENDORS SUPPLY LITERATURE TO
AGENCIES CONCERNING THEIR EQUIPMENT?
R.E. James: Very few do or will. Lear Siegler has
a well-done presentation for agency personnel.
C. Continuous Monitoring Data -- Uses and Handling
1. MUST SOURCES CONVERT ALL OF THEIR DATA TO THE UNITS OF
THE STANDARD (i.e., CORRELATING VARIOUS TYPES OF
DATA SUCH AS POLLUTANT, DILUENT AND FUEL INFORMATION)?
L.R. Paley: No, they are only required to reduce
their data to specified averages. Any excess
emissions must be converted and reported in the
units of the standards.
2. HOW MUCH MANPOWER IS REASONABLE FOR DATA REDUCTION
BY THE SOURCE?
L.G. Jones, EPA, ESED: At one time, use of continuous
monitoring data for modeling (SARDOS, etc.) was
considered, but it was decided that it was not
reasonable to require more extensive data than
necessary to determine excess emissions. Sources
are now required to keep raw data for two years,
so that it will be available if EPA wishes to pursue
more extensive analyses.
L.R. Paley: EPA is not really the best group to
answer this question. However, it is important to
understand that EPA did carefully consider the
ramifications upon manpower requirements (both
agency and non-agency) when it was developing the CM
regulations. Basically, these regulations were
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designed to provide the necessary information without
being overly burdensome. Furthermore, it is
important to note that the quantity of manpower
expended to reduce CM data is not only a function
of the regulations, but is also greatly affected by
such things as the degree to which the source
automates his CM as well as the level of competency
of his personnel.
3. MUST A SOURCE THAT REMAINS WELL IN COMPLIANCE
REDUCE ITS DATA (AT LEAST) EVERY QUARTER? (ASKED BY
A SOURCE HAVING VERY LOW EMISSIONS)?
All data must be recorded periodically, averaged
and stored, but only excess emissions must be
reduced to units of the applicable standard.
4. HOW IS THE TWO-MINUTE-PER-HOUR OPACITY EXEMPTION
HANDLED BY AUTOMATIC DATA PROCESSING SYSTEM?
IN THE QUARTERLY REPORTS?
Supplemental Consensus Viewpoint: EPA will soon
promulgate the following response to this question
(as part of its response to the court remand - Essex
Chemical vs. Ruckelshaus). An excess opacity emission
will be any 6-minute period which exceeds a 20%
(average), except for one 6-minute period per hour
which exceeds 27% (average) opacity. Therefore,
the data generated by an automatic data processing
system can be used directly to determine
the source's compliance status.
5. IS CONTINUOUS MONITORING DATA ALL THAT IS REQUIRED TO
BE SUBMITTED QUARTERLY OR IS SUPPLEMENTARY, EXPLANATORY
INFORMATION ALSO REQUIRED?
Supplemental Consensus Viewpoint: Reports must include
excess emissions, auxilliary process information,
monitor malfunction information, etc. See Part 60.7
of the Federal Regulations.
6. WHAT IF A SOURCE WISHES TO COMBINE (ARITHMETICALLY)
READINGS FROM MONITORS ON SEVERAL SIMILAR PROCESSES
USING A COMMON STACK?
L.G. Jones: Generally, we would want all the data
individually, in case one of the sources was out of
compliance. However, in the special case where each
of the processes is subject to the same emission
standard, monitors installed on the common stack (to
report the combined emissions) may be acceptable.
The question of how to combine data from separate
monitors is still under consideration.
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Supplemental Consensus Viewpoint: This is normally
a case for review by the Regional enforcement office,
and should be handled on a case by case basis.
7. DOES LITERATURE SUPPLIED BY VENDORS HELP WITH
MEETING THE DATA (SUB-SYSTEM) REQUIREMENTS?
H.C. Lord: We outline the data reporting requirements
for our customers. Other vendors probably do much
the same.
L.R. Paley: So far most vendors provide very little
guidance concerning the data sub-system.
8. WHAT MIGHT ACCOUNT FOR VARIATIONS BETWEEN TRANSMISSOMETER
READINGS AND METHOD 9 OPACITY OBSERVATIONS?
D.J. Lester: Diffusion of light, chemical reactions
or condensation of acid gases, poor monitor maintenance,
and the presence of water vapor are some of the
things which can lead to such variances.
L.R. Paley: The most well-known case of this variance
occurs at oil-fired combustion sources (due to the
acid droplet formation from the sulfur in the fuel).
9. HAVE ANY CORRELATIONS BEEN ESTABLISHED BETWEEN
TRANSMISSOMETER OR OPACITY READINGS AND MASS EMISSION
RATES?
L.R. Paley: Some curves have been generated (for
coal-fired power plants, cement plants, coke pushing
operations, catalytic crackers, asphalt concrete,
sewage sludge incinerators, secondary brass and lead,
kraft pulp recovery boilers and hog fuel boilers)
by ESRL/RTP and DSSE and non-agency groups. Particle
size has an effect on opacity, yet some of these
correlations look good. More data is needed.
10. WILL EPA REQUIRE THE REGIONS TO USE EXISTING CONTINUOUS
MONITORING DATA FOR ENFORCEMENT?
R. Biondi, EPA, DSSE: States may use continuous
monitoring data for direct enforcement. EPA,(except
for smelters) however, cannot (presently) directly
enforce NSPS or:NESHAP emission limits based on
continuous monitoring data.
L.R. Paley: There is some possibility that additional
regulations will require or permit this in the
future.
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11. WHY IS CONTINUOUS MONITOR DATA NOT DIRECTLY USEABLE
TO DETERMINE COMPLIANCE WITH A NSPS EMISSION
STANDARD?
L.Ci. Jones: The original, purpose of continuous
monitoring was to track the plant operations and
maintenance performance. Enforcement of the emission
standard is still based upon performance (source)
tests. The only exception thus far is with primary
smelters. Even in this case, the CM cannot be used
as a "continuous" means of determining compliance
(i.e., agency must pre-designate a specific period
as a "Performance Test" period).
L.R. Paley: As noted above, these may change in the
future.
D. Location of Continuous Monitors
1. ARE VENDORS ASKED TO HELP SOURCES MEET THE INSTALLATION
REGULATIONS? CAN THEY SUPPLY LITERATURE? HOW MUCH
ASSISTANCE IS PROVIDED?
H.C. Lord: EDC engineers will work with plant
engineers. Accessibility and obtaining representative
samples are the main criteria. We do not specify
locations, we just remind the source of what the
regulations require.
W.F. Fuller: Monitor location is mostly a matter of
common sense. Extractive monitors and the associated
probes are flexible with regard to ability to sample
at a representative point. A simple traverse can
help to resolve the question of representativeness.
D.J. Lester: LSI always suggests that the appropriate
agency be contacted before installation begins. We
hand out lots of underlined Federal Registers and put
the source in contact with agencies.
L.R. Paley: Essentially the vendors are presently
providing very little assistance on this subject.
The unfortunate thing is that many sources do not
realize (until it is too late) how important proper
location of its monitor probe(s) (pollutant and diluent)
is to achieve valid emission data.
2. CAN SOURCES BE MADE TO COMPLY WITH THE 8-DIAMETER?
CRITERION CONTAINED IN SPECIFICATION 2 (GAS CM LOCATION)?
L.R. Paley: No, however, as one can see (in 4.2 of
CM Specification 2) it is often to the source's
advantage to locate his monitor at least 8 diameters
downstream from any air inleakage to the effluent stream.
10
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Supplemental Consensus Viewpoint: The key criteria
for proper location of a CM is: (a) to obtain a
representative sample of the effluent gas stream,
(1) locating the probe (if needed) of the diluent
monitor in close proximity to the pollutant monitor's
probe, such that one ensures a common representation
of that stream, (2) locating the probe where gas
mixing has been completed; and (b) to locate the
probe where servicing and checking can be performed
fairly easily.
3. MUST EPA ACCEPT A MONITOR AND ITS DATA WHICH IS NOT
LOCATED IN THE STACK?
L.R. Paley: Yes, as long as the source demonstrates
that its measurements are (or have been corrected to)
consistently representative of the exhaust gas stream,
and are consistently within 20% of the results of a
yalid (including location) reference method test.
Achievement of these requirements will be facilitated
if the source follows the criteria delineated in the
previous response.
Supplemental Consensus Viewpoint: Although EPA must
accept such data, the source should be cautioned that
if he substantially separates the CM from the reference
method test location, he runs the risk of introducing
additional differences in the results between the
two monitoring locations. Regardless of this, he
still must demonstrate a consistant relationship
(±20%) between the two.
4. IS THERE A CONFLICT BETWEEN THE IDEAL COMPLIANCE
LOCATION FOR A MONITOR (BOTH POLLUTANT AND DILUENT)
AND THE IDEAL PROCESS MONITORING LOCATION?
L.R. Paley: Sometimes there can be a conflict,
particularly in the case of the diluent monitor
(0~ or C0~) at fossil fuel fired steam generators
(FFFSG). FFFSG operators generally prefer to locate
their 0? or CO- monitors just downstream of the
burner (i.e., upstream of the air preheater); however,
such a location generally will not meet the criteria
previously delineated.
Supplemental Consensus Viewpoint: For the agency's
purposes, the combination of pollutant and diluent
CM's should represent emissions being exhausted.
Therefore, both should account for any air in-leakage
and chemical and physical reactions which occur
prior to being exhausted.
11
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5. HOW SHOULD THE REGIONS HANDLE THE FACT THAT A MANUAL
SAMPLING LOCATION IS NOT SPECIFIED FOR VERIFYING
THE PERFORMANCE OF IN-SITU CM's?
Since the purpose of doing manual sampling is to
establish the relationship between the monitor and
the reference method, it is desireable (if possible) ,
but not required to take manual samples at the
location of the monitor.
Supplemental Consensus Viewpoint: (There are two
separate criteria.)
1.) In the case of the CM specification test,
the Reference Method test logically should represent
the same effluent stream as the CM. Moving the
Reference Method test point away from the CM inlet
increases the chance that the CM will not be greater
than or equal to 20% relative accuracy (but the source
can make the decision at his own risk).
2.) In the case of proper location, the CM must be
located such that it directly represents (or can
be corrected to represent) total emissions (Specifica-
tion 2, No. 4). Also, when the source conducts the
performance test, using Reference Methods, it must
be done in conformance with the requirements contained
in Part 60 and all relevant Reference Methods (i.e.,
Reference Method 1, etc.). Therefore, if the source
chooses to perform simultaneous performance test and
CM specification test, it is at his own risk.
6. WHERE SHOULD MANUAL SAMPLES BE TAKEN IF A MULTI-POINT
PROBE IS BEING USED? (STRATIFICATION IS ASSUMED)
The simplest approach is to take Reference Method
samples at some other location in the system where a
representative sample would be expected (i.e.,
no stratification). Otherwise, Reference Method
tests should be done while traversing the stack.
Supplemental Consensus Viewpoint: This case is not
adequately discussed in the regulations and probably
would require a Regional Office decision on a case-
by-case basis.
7. IF STRATIFICATION IS SUSPECTED, IS IT PREFERABLE FOR
THE SOURCE TO USE A MULTI-POINT PROBE OR A SINGLE-POINT
PROBE PLACED AT A REPRESENTATIVE LOCATION?
W.F. Fuller: This is not a common problem. Sometimes
samples from several points are mixed. Your best choice
is to move the probe to a better location.
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8. COULD TEMPERATURE, 02, OR OTHER EXHAUST GAS STREAM
GRADIENTS BE USED TO FIND A REPRESENTATIVE (OR ONE
CORRECTABLE TO BE REPRESENTATIVE) POINT AT WHICH TO
PLACE A SINGLE-POINT PROBE IN A STRATIFIED FLOW?
L.R. Paley: Sure, if it is well established that the
sample will be representative (or one correctable
to be representative). However, adequate documentation
of this would be difficult. Therefore, it is probably
not worth the effort. It is easier for the source
to move to a better location. (This question could
use more study.)
E. Testing, Observation of Tests, Calibration, Certification
1. WHEN SHOULD THE MONITOR PERFORMANCE SPECIFICATION
TESTS BE DONE IN RELATION TO THE SOURCE'S
PERFORMANCE TEST?
Q. Wong, S$A, Region VI, EPA: In Region VI, both
tests are usually shceduled at the same time. If
a problem arises, both tests are postponed.
Supplemental Consensus Viewpoint: Concurrent
tests are usually cost effective to the source.
EPA only requires that the CM performance specification
test be done within 30 days after the performance
test.
2. WHAT TIME INTERVAL REQUIREMENTS ARE THERE FOR PERFORMING
THE CONCURRENT REFERENCE METHOD TESTS DURING THE CM
PERFORMANCE SPECIFICATION TEST?
R.E. James: There is no requirement to spread
them out (although common sense would suggest it).
If the tester chooses to do them back-to-back and
there are no testing problems, an accuracy test for
one gas monitor can be done in nine hours. In
practice, manual testing will usually be carried
out over two or three days.
3. MUST MONITOR PERFORMANCE SPECIFICATION TEST EVER
BE REPEATED? WHEN?
L.R. Paley: Not if the monitor is in compliance.
Therefore, retesting would normally be done only
if we want to revalidate the monitor's accuracy.
(We still have to do some thinking on this subject.)
Supplemental Consensus Viewpoint: The Administrator
can require retesting of the CM's whenever he deems
it appropriate (i.e., questionable data, substantial
CM modifications or repairs, etc.).
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4. MUST THE MONITOR "CONDITIONING PERIOD" BE DONE
DURING CONDITIONS OF "NORMAL PLANT OPERATION"?
WHY NOT IN THE FACTORY?
It is to the mutual benefit of both source and
agency that the monitor should not be certified at
conditions greatly different from actual source
conditions. The primary purpose of this period is
to determine that the CM is properly operating prior
to initiating the (resource intensive) operational
period.
Supplemental Consensus Viewpoint: It was found that
a monitor's performance is very sensitive to the site
and the environment. Therefore, one could not
effectively accomplish the primary purpose of this period
in the laboratory.
5. HOW DOES PLANT DOWNTIME AFFECT THE CONDITIONING (NOT
THE OPERATIONAL) PERIOD?
L.G. Jones: The object of the first 168-hour test
period is to test the monitor (not the source) to
try to ensure that it is generally capable of operating
properly. If the source goes down, the regulations
do not require the source to re-start the 168-hour
period. One might just continue where things were left
off. The objective is to obtain 168 hours of operating
time on the monitor under plant conditions without
failure of the monitor.
6. WHAT CAN BE DONE TO THE MONITOR DURING THE
CONDITIONING PERIOD? THE OPERATIONAL TEST PERIOD?
L.G. Jones: The monitor should not be touched,
except for normal calibration and maintenance checks
as recommended by the manufacturer, during both the
conditioning and operational test periods.
7. WHAT IF A STATE AGENCY IS INCAPABLE OF PROPERLY
EVALUATING A CONTINUOUS MONITOR PERFORMANCE
SPECIFICATION TEST?
J. Cohen: DSSE has a training course on how to perform
such evaluations.
L.R. Paley: DSSE can also provide contractors
to perform such evaluations.
8. HOW SHOULD ONE GO ABOUT OBSERVING A PERFORMANCE
EVALUATION IF UNFAMILIAR WITH THE EQUIPMENT
AND/OR DUBIOUS ABOUT THE VALIDITY OF THE RESULTS?
L.R. Paley: Read and use the various DSSE manuals
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and guidelines on the subject; go out with an
experienced observer at first. These people
are available through DSSE.
Few sources will run the risk of being caught
defrauding the government, therefore, a good
technical evaluation should result in obtaining
sufficient agency confidence in the data of
the system.
R.E. James: Admit your ignorance and ask questions.
Try to obtain instrument manuals from vendors
prior to the observation.
F.C. Jaye: Monitors are not as "magic" as they
seem. The number of repetitions required for each
test makes consistent fudging almost impossible.
Most sources and vendors are interested in
complying properly.
R.J. Woods: Most sources use outside firms for
testing; these people will probably resist manipula-
tion by the source.
9. MUST THE MONITOR CALIBRATION BE OBSERVED DURING THE
CM PERFORMANCE SPECIFICATION TEST? WHY CAN'T
CALIBRATION BE DONE IN THE FACTORY?
L.R. Paley: No. It really depends upon the agency
resources, its confidence in the source, etc., as
to whether or not they are observed.
Supplemental Consensus Viewpoint: Extractive
monitor calibration is required to be done on-site.
The in-situ calibration can be done in the factory
where the gas cells are prepared.
10. IF THE RESULTS FROM A REFERENCE METHOD TEST ON A
CYLINDER OF CALIBRATION GAS YIELDS A DIFFERENT
VALUE FROM THE CYLINDER TAG VALUE (WITH OR WITHOUT
NBS TRACEABILITY), WHICH SHOULD BE USED WHEN
CALIBRATING AN INSTRUMENT?
R.J. Woods: We would go with the reference method
test value rather than the cylinder tag value.
This would give us a better correlation with the
performance (stack) test results.
L.R. Paley: I agree; theoretically the difference
should be small, but both gas vendors and testers
are still making too many errors. (EPA must give
this more thought.)
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Supplemental Consensus Viewpoint: At this time
EPA has not specified the necessary protocol which
gas vendors would have to follow before their tag
value could be correctly deemed "NBS traceable"
(as specified in the CM regulations). Therefore,
one should use the value obtained from the reference
method test, but only after one is sufficiently
convinced that those results were acquired through
the proper use of the method and that test was
done on the cylinder within two weeks prior to the
CM's performance specification test.
11. SHOULD THE 10% ZERO OFFSET BE REQUIRED IF EXTENSIVE
MODIFICATIONS (i.e., COMPUTER REPROGRAMMING) ARE
NECESSARY TO QUANTIFY NEGATIVE ZERO DRIFT DURING THE
PERFORMANCE SPECIFICATION TEST?
Maybe not. One solution is to permit the use of a
digital voltage readout instrument hooked into the
analyzer on the stack. Then the source could
establish a relationship between the voltmeter
readouts and the computer (recorder, etc.) printout.
12. CAN A GAS MONITOR BE ZEROED USING AMBIENT AIR?
Yes, either certified zero gas or ambient air is
acceptable. The source may elect to use ambient
air to save money.
13. HOW STRICT ARE THE REGULATIONS REGARDING DETERMINING •
THE SPAN FILTERS' DENSITIES?
L.R. Paley: As with any of the requirements, an
alternate procedure can be approved.
D.J. Lester: Most filters will not be exactly a
certain density, but will fall within a range of
approximately ±15%.
J.A. Jahnke, Northrop (Contractor): A filter-check
transmissometer can be built easily for calibrating
span filters.
14. WHEN CHECKING AN INSTALLED MONITOR AGAINST A PORTABLE
UNIT, WILL ZERO AND SPAN CALIBRATIONS OF THE PORTABLE
ONE BE SUFFICIENT TO ENSURE THAT IF THE TWO MONITORS
READ DIFFERENTLY, THE PERMANENT MONITOR IS THE
ONE GIVING FALSE READINGS?
H.C. Lord: Yes, this assumption should be OK if
both samples are representative. Some other causes
for this difference are wet vs. dry basis, stratifica-
tion, sensitivity to temperature, or other differences
which can affect readings on the portable.
L.R. Paley: If there is a significant difference,
16
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the inspector may choose to perform some simple,
fast troubleshooting, such as; (1) make sure both
CM's are evaluating the same gas stream;
(2) analyze a sample of the source's calibration gases
taken from the inlet to the in-stack monitor with the
portable monitor; (3) take a sample of stack gas
to the agency lab to evaluate on a carefully calibrated
analyzer, being sure that the gas is not changed
during transit by condensation, reaction, etc., and;
(4) verify that both monitoring systems are not measurably
affected by characteristics of the stack gas (such as
temperature, moisture, interfering components and
particulates).
15. CAN (OR SHOULD) A TESTER BE REQUIRED TO PERFORM LAB
ANALYSES FOR THE MANUAL TEST METHODS ON SITE?
HOW ABOUT SPLITTING THE SAMPLES?
L.R. Paley: Yes. The agency could request a
field analysis to demonstrate the tester's
technique, proficiency (on spiked samples) and
to be observed.
D. Stonefield, S$A, Region I, EPA: We (Region I)
often ask the contractor to hire a local lab so that
if we choose to, we can observe performance, lab
conditions, etc.
R.E. James: Having them analyze samples of known
concentration seems like a reasonable technique to
rapidly check the tester's capability.
P.C. Schwindt, S§A, Region VI, EPA: Cannot split
particulate and NO samples, and there is usually
not enough SO- reagent to split.
J. Cohen: A correct analysis of a spiked sample only
shows that the lab can do good work, not necessarily
that they always will.
Supplemental Consensus Viewpoint: The idea may be
appropriate, but the agency must recognize that field
conditions may introduce added errors and may be
non-representative of the tester's normal performance,
particularly if he normally does the analysis in the lab.
16. WHAT OPTIONS DOES AN AGENCY OBSERVER HAVE WHEN BAD
WORK IS WITNESSED?
If you see bad work: (1) tell the tester immediately,
(2) tell him you will reject his results, (3) suggest
that the tests be redone, (4) if he will not redo
them, tell source that it is his choice. Do not wait
until it is done and then reject the results.
17
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Most testers will cooperate. If the poor technique
continues, (yielding a basis for rejection), inform
the source, document specific problems thoroughly
and return to the office.
17. HOW LONG SHOULD A TEST OBSERVER REMAIN ON SITE?
WHAT IF THINGS ARE GOING SMOOTHLY? OR NOT GOING
AT ALL?
L.R. Paley: This is a matter of personal discretion
and must be decided on a case-by-case basis. Consider
the reputations of the tester, source and instrument
vendor when deciding. Primarily, one should observe,
evaluate and document a sufficient quantity of the
test to have adequate confidence in the results.
18. HOW SHOULD 02 AND C02 MONITORS BE EVALUATED?
(NO REFERENCE METHOD COMPARISONS ARE REQUIRED)
L.G. Jones: The use of calibration gases is believed
to be sufficient.
Supplemental Consensus Viewpoint: Follow the
procedures outlined in Appendix B, Performance Specifi-
cation No. 3.
19. WHEN SHOULD CERTIFIED CONTINUOUS MONITORS BE REINSPECTED?
Q. Wong: None have been reinspected in Region VI
since testing.
Supplemental Consensus Viewpoint: Reinspect them
whenever the agency has doubts about the validity
of results as part of a regular source inspection
plan or continuous monitor reevaluation plan.
20. WHAT SHOULD THE AGENCY DO WHEN IT FINDS A MONITOR
. INOPERATIVE?
R. Biondi: To prove a violation, the agency must
demonstrate that source negligence is responsible
for the monitor being inoperable. One option is
simply to require a new performance test of the
CM after seeing that it. is serviced.
Supplemental Consensus Viewpoint: Determine why it
is down. Require the source to operate it as soon
as possible. Also, it may be appropriate to verify
its proper operation for several months by requiring
monthly excess emission reports and by requiring
extra evaluations of their CM's.
F. Enforcement, SIP's, NSPS
1. DOES THE PROVISION FOR MONITORING SULFUR CONTENT
18
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IN FUEL CIRCUMVENT THE INTENTION OF THE CONTINUOUS
MONITORING REGULATIONS? WHAT FUEL MIXES QUALIFY
FOR A LOW-SULFUR EXCLUSION?
R. Biondi: Fuel monitoring regulations are still
being developed; sources must await finalization.
Fuel mixes should be handled on a case-by-case
basis.
Q. Wong: Mixed fuel sources must still be monitored
as required by NSPS.
2. WHY IS THE SO, MONITOR USED FOR COMPLIANCE IN THE CASE
OF SMELTERS? Z
For the smelting process, a long-term sample (6-8
hours) is needed to integrate the effects of process
fluctuations. Method 6 is not adaptable to such
long-term testing.
Supplemental Consensus Viewpoint: EPA acquired
sufficient experience and data to show that the
monitor reliably could provide valid results.
3. WHAT SHOULD AGENCIES DO WITH EXCESS EMISSION REPORTS?
T.A. Gibbs, AHM, Region IV, EPA: Do not look at
just the excess emission report; review all
reporting done by the plant. If a problem is
indicated, a follow-up evaluation or a retest
of the source and/or monitor would be advisable.
Supplemental Consensus Viewpoint: Compare them
with the previous quarter's information and the
baseline data obtained during the performance
specification test. Compare data with other
similar plants to determine adequacy of the continuous
monitoring system, and identify possible major or
recurring problems which source should resolve.
4. HAS HEADQUARTERS PROVIDED THE REGIONAL OFFICES WITH
GUIDELINES FOR REVIEWING SIP's? ARE GUIDELINES
PRESENTLY BEING USED BY THE REGIONS WHEN REVIEWING
CONTINUOUS MONITOR SIP REVISIONS?
R. Biondi: DSSE's Guideline S-26 incorporates a
model regulation revision for this purpose.
5. WILL THERE BE A NATIONAL PROMULGATION TO COVER
DEFICIENT SIP's? WHEN? OR WILL REGIONS HAVE TO
HANDLE SIP's ON A STATE-BY-STATE BASIS?
G. Rust, CPDD, EPA: A national promulgation is being
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developed (for a mid '78 promulgation) by EPA.
I.Z. Milner, AHM, Region III, EPA: Regions should
not be wasting their resources to cover something
that is going to happen anyway by means of a national
promulgation.
6. REGARDING REQUIREMENTS AND ENFORCEMENT OF SIP's,
WHOSE DECISIONS TAKE PRECEDENCE, THOSE OF THE STATE
OR THE REGIONAL OFFICE?
The states make the decisions, but they must submit
their decision-making procedures to the Regional Office
for approval.
7. WHAT IS THE PROCEDURE FOR ADDING NEW SOURCE TYPES
TO THE PRESENT FOUR FOR WHICH STATES MUST PROMULGATE
CM REVISIONS?
R. Biondi: The states have the latitude to add new
source categories as the need arises. The Appendix P
requirements were intended to be "minimum" requirements.
J. Key, TACB (State Agency): We (TACB) had the
opposite view ... that we have to wait for promulgation
in Appendix P before we could expand the list.
8. WHY ARE THERE NO EXCESS EMISSION REPORTING REQUIREMENTS
FOR OPACITY FROM STEAM- GENERATORS?
R. Biondi: These were "reserved" until we rehash
the opacity standards for steam boilers and
submit a brief to the court in response to the
litigation we have received (Essex Chemical vs.
Ruckleshaus).
NOTE: The December 5, 1977 Federal Register promulgation of EPA's
response to the remand removed this reporting
reservation. Therefore, NSPS steam generators
must submit excess emission reports including opacity.
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SECTION III
PROCEEDINGS: SUMMARIES OF CONFERENCE PRESENTATIONS
OPERATIONAL PRINCIPLES - Fred Jaye, Acurex/Aerotherm
Fred Jaye described the basic concepts of the three types
of continuous monitors in operation and the advantages and dis-
advantages of each.
I. Transmissometers
A. Double-ended: light source sends a beam of light across
stack; reflector sends beam back. Photoelectric cell
then compares intensity as it returns
Advantages:
1. less sensitive to mislignment in stack
2. easier to compare two light beams with same
photoelectric cell
B. Single ended: light source sends a light beam across
stack to a photoelectric cell - no return
II. Extractive Monitors
A. Electrochemical: gas diffuses through membrane into
electrolyte; voltage is read
1. Advantages
a.inexpensive, portable,
b.can be made to respond to different gases
Z. Disadvantages
a.requires a very stable temperature
b.requires a very good gas conditioning system
B. Chemiluminescent: Also Flourescent (UV excitation)
Chemical reaction (e.g., NO + 03) excites gas molecules;
light is measured
1. Advantages
a. very high sensitivity
b. good selectivity
2. Disadvantage
a. very few compounds give the chemical reaction
III. In-Situ Monitors
A. Non-dispersive Infrared (NDIR). Principle: IR absorption
by selected molecules
1. Advantages
a. large number of organic and inorganic compounds are
infrared absorbent
b. can be more specific
c. simple operation
2. Disadvantages
a. only filtering comes from absorption characteristics
b. water vapor interferes with infrared absorbency
and may also damage components
c. only one component can be monitored
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B. Non-dispersive ultra-violet analyzers: Principle:
UV absorption by selected molecule
1. Advantages
a. water vapor has no absorption bands
b. uses conventional optics
2. Disadvantages
a. limited in number of measurable pollutants
b. poor selectivity
MONITORING REGULATIONS - Fred Jaye, Acurex/Aerotherm
Monitor performance specification tests are required within
180 days of initial facility startup or within sixty days after
maximum production rate is reached, if that will move up the
testing date. A test report must be submitted within 60 days
after completion of the test as outlined in 60.13.
Under part 60.7 of the New Source Performance Standards,
the following records must be kept for two years:
-any periods in which the monitoring system is inoperative
-any monitoring device or system testing evaluations
-any performance test measurement
-all calibration checks
-any adjustments or maintenance performed on the systems
These records must be kept for inspection, although a particular
form is not specified.
The following data must be included in quarterly reports
submitted to Regional EPA offices:
-data worksheets
-reference method comparison test worksheets
-maintenance records from the monitoring system
-any F-factor or conversion factors from data and how they
were derived
-production rates for the facility during the time period
that the monitor was being tested
IMPLEMENTATION OF REGULATIONS - Gary Bernath, Region VI; Howard
Houston and Bob James, TACB
In identifying which sources are covered by NSPS regulations,
there are four ways that the agency can find new sources or
expansions of the old sources:
-monthly reports submitted
-those sources receiving permits from states
-the "grapevine"
-sources that actually comply with regulations and notify
the agency
After recognizing these sources, a form letter is sent to
the sources to acquire information about their emissions, etc.,
in order to determine whether or not they come under NSPS regu-
lations. If it is officially determined to be NSPS, the source is
22
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informed of various requirements including that the compliance
test must be run within 180 days of facility startup. The
test report is then submitted within 60 days and analyzed, and
the source is notified of the results. If the test fails, con-
sultation between the source and agency determines problems and
changes to be made by the source to meet standards. If the
test passes, the source is, of course, notified and congratulated,
and reminded of submission of quarterly reports. These reports
are compared to the original sample test and to previous reports
for changes in results, operating conditions, etc.
Texas has not received authorization from the agency to
enforce SIP's and NESHAP regulations; only existing sources that
were not constructed under NSPS are being considered for monitoring
requirements. Because of the legal problems in making changes in
SIP rules, TACB attorneys reviewed the SIP's and decided that
Rule 9 was adequate as it stood for enforcing continuous moni-
toring regulations. Under Rule 9, TACB can reasonably require the
measurement and monitoring of emissions of any source and the
maintaining of records on the measurement and monitoring of
emissions. The burden is on the source owner to buy, install,
and maintain a continuous monitoring system.
QUALITY ASSURANCE IN CONTINUOUS MONITORING - Mike Osborne,
Quality Assurance Branch, Environmental Monitoring Support
Laboratory
The Quality Assurance Branch of EMSL has undertaken an
ongoing survey of continuous monitor field performance. The
purpose is to gather data for evaluating how well continuous
monitoring systems work over the long term. There is a need
to know if monitoring technology is sufficiently advanced to jus-
tify their requirement
The initial survey included boilers, sulfuric acid plants,
and smelters. Extractive NOX and S02 monitors were evaluated.
National Bureau of Standards certified S02 and NO cylinders were
used to calibrate EMSL gas monitors, which in turn were used to
calibrate the cylinders to be used in the field. EMSL continued
to evaluate the stability of the mixtures in these cylinders.
Nineteen monitors, 13 S02 and 6 NOX , were surveyed.
Some conclusions:
1) Continuous monitor devices can perform well.
2) Some types of monitors consistently perform better than
others.
3) The process being monitored has no effect on monitor
performance.
4) Probes, delivery systems, and monitors all contributed
to regular maintenance problems.
5) The two most prominent maintenance problems were clogging
of probes and sample lines, and condensation in sample
lines.
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It should be noted that sample transport systems were not
evaluated, due to the inability to introduce calibration gases
directly into probes. Sample conditioning systems were, however,
generally included, as were data handling systems. A severe
problem with maintenance record keeping was also brought out
by the survey.
As far as traceability of the calibration gases is con-
cerned, it was Mike Osborne's personal opinion that the cylinder
tag value will be well within the tolerances of Methods 6 and 7,
and thus should be acceptable. If traceability standards are
promulgated, QAB plans to audit gas vendors to ensure quality
control.
Future surveys of this type will attempt to include:
1) More different types of monitors (C02,02,opacity)
2) Evaluation of in-situ as well as extractive monitors
3) Nitric acid plants, petroleum refineries, more smelters
4) Use of calibration gases at 50% and 90% of full-scale
concentration levels.
5) Introduction of calibration gases at probe inlets where
possible
LOCATION AND SELECTION OF MONITORS- Karl Karst, Entropy Environ-
mentalists, Inc.
Facilities that are required to purchase and install
monitors are listed in various subparts of the Standards of Per-
formance: Part 60 for new sources, Part 61 for hazardous air
pollutants, or in Appendix P of Part 51 of the Federal Register.
Each facility is really an individual case which will have spe-
cific problems. Because this is the case, interpretations of
the laws are continually necessary and this demands that involved
agency personnel have a working knowledge of the regulations.
Specific details for monitor locations are detailed in
Performance Specifications 1,2, and 3 in Appendix B of Part 60.
Some highlights for opacity and gaseous monitors are:
OPACITY
MONITOR
LOCATION
'Position must be representative of total emissions
'Recommended viewing across entire stack or duct
'Downstream of all control equipment
'As far as practical from bends or obstructions
'If downstream of bend, place in plane of bend
'Location to be accessible
'If two or more sources covered under the same standard
exhaust emissions to the atmosphere using a common
stack or duct, the source can locate one monitor
after each facility or in the common stack or duct
'If the facilities are covered under different standards,
each is to have its own monitor
'Optimum location can be compromised to avoid inter-
ferences such as water droplets
'Locate away from areas of high vibration or areas sub-
ject to large degrees of thermal expansion or
contraction
24
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GASEOUS 'Location must be representative or obtained data
MONITOR 'Must be able to be corrected to be representative
LOCATION 'Gases can be assumed to be non-stratified if location
is eight equivalent diameters downstream of air
in-leakage
'If sample area is stratified, data from monitor must
be corrected to be representative (use of F-factor
possible)
' If in stratified region and monitors (diluent and
pollutant) are not of same type (extractive or in-
situ), the extractive monitor has to use a multi-
point probe
'Multiple facilities exhausting into the stack - same
rules as for transmissometers
'Downstream of S02 scrubbers
'Diluent gas can be measured upstream or downstream
of a scrubber if the source can demonstrate no
air in-leakage. Important to keep basis straight
'Both the pollutant and diluent gases have to be
measured either before or after an air preheater
in the case of a fossil-fuel-fired steam generator.
The eight diameter criteria doesn't apply before
and monitors must be in-situ or extractive with
multipoint probes.
Overall, it was brought out that the regulations are complex
and subject to interpretations in many areas. A suggestion was
made that for each type of monitor on a particular category of
source, a list of (1) what is required, (2) what is not allowed,
and (3) what is negotiable should be compiled.
For selection of monitors three steps are followed:
(1) check the applicable subpart to determine what has to
be monitored, what spans are necessary, what conversion
approach is applicable, and what performance specifi-
cations have to be met.
(2) check the Performance Specifications which state what
the monitor must be capable of doing.
(3) check the location of the monitor in the facility.
This could dictate or recommend in-situ or extractive monitors
with single or multi-point probe.
The regulations do not specify particular brands of moni-
tors or what monitoring principles should be used. They do state
which facilities have to monitor and what specifications the
monitors have to meet.
SELECTION OF MONITORS - Bob James, TACB
1. Responsibility is that of the source owner. He is spending
the money.
2. Agency cannot endorse any particular brand names of equipment
So be careful about criticisms and/or recommendations.
3. Monitors are not certified, except as operated at a specific
facility. Each monitoring system is performance tested as
installed.
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4. Assistance
(a) Become familiar with vendor representatives in your area.
What companies have reps? This is important for suggest-
ing monitor servicing later to sources.
(b) Provide references to evaluation studies.
(c) Remind people that all systems are to varying degrees,
user sensitive.
(d) Give names of users if possible.
5. Self-education - Learn about different types of monitors and
limitations and advantages of applications.
6. Explain that it is difficult for the vendor to supply a demo.
The instrument alone does not do the job. Entire system
required.
LOCATION OF MONITORS, AGENCY EXPERIENCE, Rino Wong, Region VI
Three of the four sources evaluated by Region 6 had their
monitoring equipment located between the boiler and preheater,
a less than ideal location. The agency asked the source to
either demonstrate non-stratification by means of a sample tra-
verse, or move the monitor closer to the manual sampling port
areas on the stack. All three of the sources elected to move
their monitors.
The problem here is the agency is rarely involved with the
monitoring systems until after their installation, and while
the best location from the perspective of comparability of data
to manual tests for the continuous monitors would seem to be in
the manual sampling port area, most sources are reluctant to
install the continuous monitors on the stack due to problems
with maintenance and accessibility.
SELECTION AND LOCATION OF MONITORS-SOURCE EXPERIENCE
Roy Woods, Du Pont
On a particular stack, Du Pont has installed a trans-
missometer and extractive S(p2 and NOX analyzers. An Q£ analy-
zer, for control purposes, is located in ductwork other than
the final stack. The transmissometer was installed at a location
3.2 diameters up from the stack from the breeching (bend) and
2 diameters down from the stack exit. Manual sampling ports and
platform are also located at this level.
Problems arose concerning the location of each monitor.
These have been rectified, at some expense, as follows:
The transmissometer was not located in the plane of the
upstream bend. Rotation of the instrument about the axis
of the stack also involved rotating the sampling platform
and access ladder, an operation which cost approximately
$20,000 and two weeks.
26
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The probe for the extractive S02 and NOX instruments had to
be moved up the stack, to the level of the manual sampling
ports. This requirement is not specified precisely in the
Federal Register; specification that the extractive probe
be at the location of the sampling ports would be beneficial.
The 62 analyzer, installed to monitor excess air, is not
in the proper location for obtaining reliable data for use
in subsequent F-factor calculations. A second analyzer
placed on the stack is needed, and is less expensive than
moving the existing monitor.
Installation problems are not the only cause for expense.
Du Pont has found that calibration and maintenance of monitoring
instruments can be expensive. Examples:
NBS certified calibration gases cost $50-100 per cylinder
(approx. 150 cu. ft.).
Buying and calibration of span gases cost $2000-2500 per
set of four cylinders.
Valves and tubing for semi-automatic calibration were expensive,
Calibration checks on the S02 and NOX monitors require one
man-hour per day. Cost: about $5000/year
The problems encountered at this particular source regarding
monitor installation highlight the need for good communications
between sources and agencies. Contact should be made before
instruments are installed - better still, before plant con-
struction.. Written guidelines, perhaps in checklist form, would
also help prevent situations such as were encountered by Du Pont.
In the case of this particular installation, the construction
permit from the state of Texas outlines continuous monitoring
requirements. Better follow-up contact, apparently, is needed
to continue answering questions before they can become problems.
REGULATION EXPERIENCE BY EQUIPMENT VENDORS TRANSMISSOMETER SYSTEMS
Dave Lester, LSI
Transmissometer systems have been developed to meet a wide
variety of design requirements. Some of these requirements have
been imposed by the opacity monitoring regulations, either
directly or indirectly. Many others are outgrowths of the nature
of the sources where the monitors will be installed, of the
nature of the particulate to be measured, or of the nature of
the transmissometers themselves. These factors are summarized
below, along with some other problems to be aware of when dealing
with transmissometers.
Design Requirements
1. Some older transmissometers utilized light sources with a
high infrared content. Water vapor absorbs IR, and sub-
micron particulates do not scatter the long IR wavelengths.
Newer monitors use filters to remove much of the IR from the
source beam.
27
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2. The light beam should be uniformly bright over the entire
angle of proejction. The angle of projection of the light
source and the angle of view of the reflector (or receiver)
should both be about 5°. An angle of projection greater than
5° will result in false high readings due to excessive
scattering of the projected beam.
3. The built-in retro-reflector used for automatic zero
calibration checks must be outside all of the optics of
the system (except the reflector on the opposite side of
the stack). Internal placement of the reflector will not
reveal problems such as dirty windows.
4. When calibrating, some instruments are not bi-polar (they
register negative inputs as zero); some have their zero set
at a slightly negative point, so that a signal of 2-3% is
required before a positive reading is registered. Be aware
of these possibilities.
5. A 95% response time of less than 10 seconds is required.
Most transmissometer systems are well within this (1-2 sec.).
Fast response results in excessive spiking, making strip
charts difficult to read and average; a slow response (2-3
minutes) would dampen the graph, making it easier to read.
6. The January 31, 1977 Federal Register does not allow lot
testing of transmissometer systems at the factory. Lot
testing for response time and other parameters not affected
by installation would be more reasonable and economical than
testing every instrument.
Potential Problems After Installation
1. When using neutral-density filters for calibration checks,
remember:
a. Traceability of filters to NBS standards is informal,
if possible at all.
b. Filter must be placed perpendicular to the light beam,
so that the path length through the filter medium is
not lengthened, except:
c. For double-path systems, the filter will reflect some
some light back into the receiver, so align it 3° to 4°
off-axis to eliminate this source of bias.
d. Filters must be clean; no fingerprints, dust, etc.
2. Regulations call for zeroing transmissometers on a clean
stack once a year. Some problems with this:
a. Some stacks are never clear, especially if several sources
feed a common stack.
b. Drafts can keep dust airborne in a "clean" stack after
shutdown; maintenance work (i.e., welding) can also stir
up dust.
c. Rain coming down a clear stack will register on the
instrument.
-------
3. In-situ testing of the instrument is still important, for
several reasons:
a. The path length of the light beam (stack diameter) may
not be what the designer was told and the instrument
calibrated for.
b. The instrument can get out of alignment due to wind,
heat expansion in a metal duct, or other factors. A-
lignment drift is a common source of positive error.
REGULATION EXPERIENCE BY EQUIPMENT VENDORS-EXTRACTIVE SYSTEMS
Bill Fuller - Du Pont
Certification and performance of extractive gas monitoring
systems are proceeding without any major problems. Some problem
areas that have been observed are the interpretation of some of
the regulations, improper calibration of instruments by other
than the vendor, improper analysis of calibration gases, and cal-
culation errors during certification.
The certification process requires 2-5 days on-site and
an elapsed time of about 45 days total to collect and report
data. Errors are often made in summing an absolute mean value
and a 95% confidence interval for a series of tests. Check also
that reference mean value and the calibration gas mixture value.
Also watch for "swamping" of the data by a large confidence in-
terval when using only a few data points (3 or 4).
Reputable equipment should certify the first time. Steps
which may be taken to ensure a sound certification test include:
1. Adequate planning before the sampling begins, so that the
procedures are very clear to all personnel involved.
2. Good communications between vendor and tester.
3. Acquisition and review of equipment manuals by operator and
observer before the date of the test. Operator, observer, and
tester should be aware of what is going to be involved.
4. Insuring that the tester will analyze his samples properly.
Check titrations for S02 concentration performed on site,
under observation, if at all possible, to avoid potential
surprises.
5. Assure that the calibration gas value is well established.
A cylinder should be good for more than six months of au-
tomatic, daily calibrations. Changing the cylinder every
six months will guard against "old" gases changing in con-
centration.
REGULATION EXPERIENCE BY EQUIPMENT VENDORS
IN-SITU SYSTEMS(Harry Lord - EDC)
In-situ systesm utilize absorption spectroscopy. A beam
of light is sent across the gas stream, and specific wave-
lengths are absorbed by certain gases. Receptors are then de-
signed to look for attenuation in the specific wavelengths of
interest. Opacity, S02, NO, CO, and C02 can be measured in this
way. Some characteristics of in-situ monitors follow:
29
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1) very fast response
2) concentrations are averaged out across the stack-
stratification is not a problem
3) readings are on a wet basis
4) results can be recorded in ppm
5) temperature adjustments are made in real-time
Calibration of in-situ gas monitoring instruments is similar
to calibration of transmissometers. For the zero calibration,
what is known as a "zero jig" is used, where a separate light
source shines directly into the analyzer, by-passing the gas
stream. For span checks, a sealed cell containing a known con-
centration of the gas of interest is placed in the zero jig beam,
so that the beam travels through the same number of absorptive
gas molecules as would be encountered in a traverse of the stack.
Another type of span calibration has been developed, and
involves the incremental addition of known concentrations to the
incoming signal. In this way, the light beam is still traversing
and monitoring the gases in the stack. Verification that the span
is acceptable is merely an exercise in curve-fitting.
Most of the problems associated with in-situ systems involve
aspects other than the monitor itself. Among the problems that
have surfaced to date:
1) The requirement for offsetting the zero point on the
monitor interferes with the curve-fitting described
above. This problem can be avoided by performing the
zero offset on the recorder, rather than on the monitor.
2) Cutoff of power to the monitor, even if it has been
provided with a discrete power supply.
3) Difference in readings at the instrument and on the re-
corder. Calibration of the recorder is important.
4) Use of too many pens (4 or 5) on the same strip chart.
Try to have charts limited to 2 pans each, with all
traces clearly labeled,
MONITOR PERFORMANCE TESTS - PRETEST MEETINGS
Bob James, TACB: Roy Woods, Du Pont; Lou Paley, DSSE (stand in for
tester representative)
Pre-testing consultation between the testing, agency, and
source personnel was emphasized before performing tests on the
monitors, if not in the form of a meeting, then by telephone or
letter. The time and money saved by the pre-test communication
are the main reasons for holding such a meeting.
Meetings should cover the following points:
1) decide what to do about location and stratification
problems
2) clarify regulations
3) devise a test schedule to be followed. If facility per-
formance test and monitor performance test are to be done
in the same week, careful planning is extremely important.
Without working out a schedule, task completion in one
week is doubtful.
30
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4) review prerequisites to performance and compliance testing.
Roy Woods mentioned five benefits of the meetings in the
source's experiences:
1) By meeting with the agency and tester face to face, all
parties had the same information prior to testing; ques-
tions were answered which prevented later problems.
2) The agency provided planning assitance to the source
(suggested running the compliance and performance tests
concurrently).
3) It was decided that a S02 probe be moved to a better
position.
4) It was found the Lear Siegler monitor had to be certified.
This was done in time to proceed with testing.
5) Most problems were resolved before the testing began;
therefore, no delay or rescheduling was required.
In the case of Du Pont, final scheduling was done on a daily
progress/daily plan ahead basis. Again, pre-test planning made
this much easier. Proficiency of tester was a critical factor.
He was able to do NOX sampling while S02 samples were in progress,
for example.
Lou Paley listed what should be accomplished at the meeting
from the tester's viewpoint.
1) All" questions should be asked and answered concerning
all aspects of the testing.
2) The scope of the work should be outlined for the tester.
3) Physical dimensions, equipment requirements, etc.,
should be determined. :,
4) Each party should denote a leader or speaker to answer
questions arising in the field during the actual testing.
PERFORMANCE SPECIFICATION TEST PROCEDURE
Karl Karst, Entropy Environmentalists, Inc.
The performance specification test procedures is set up to
look at all the components of a continuous monitoring system:
sampling, interface, sample conditioning, sample transport, analy-
zers, and data handling. When considering the monitor test, four
questions must be answered:
1) Who has to run the performance test?
2) When does the test have to be run?
3) What has to be done during testing?
4) What do the results have to be?
WHO If the source is of sufficient size in an affected
source category, the monitor testing must be run.
Affected facilities are outlined in the Federal Register.
If a monitor was purchased before Spetember 11, 1974
and installed before October 6, 1975, the source is ex-
empted from running the monitor performance test until
September 11, 1979.
31
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WHEN
WHAT
(TESTING)
WHAT
(RESULTS)
If a monitor was purchased after September 11, 1974
or installed after October 6, 1975, the testing must
be run as covered under "WHEN" below.
The monitor specification test can be run during the
performance test for compliance (within 180 days of
initial starting or within 60 days after reaching
maximum produciton rate) or up to thirty days after
the compliance test.
The test report must be submitted within sixty days
after the test is completed.
Specific tests are different for opacity, pollutant
and diluent monitors.
All monitors have a 168 hour operational test period
where only 24 hour adjustments can be made (unless
specified otherwise by the vendor).
All monitors are tested for zero and calibrate drift
at two and/or twenty-four hours and response time.
Monitors must meet performance specifications as
outlined in Appendix B, part 60.
Only
and NOX monitors have to be checked against
manual methods and must be accurate to ± 20%.
Suggestions were made that it is just as important to de-
termine accuracy of the diluent type monitors and process mon-
itors in order to obtain accurate measurements of emissions.
PERFORMANCE SPECIFICATION TESTS - SOURCE EXPERIENCE
Roy Woods, Du Pont
A major concern that Du Pont encountered in working with
the emission monitors was the effects of plant downtime on the
conditioning and operational test periods. Since the object
is to see how well the monitor works, rather than the source,
the concensus was that the conditioning or testing period need
not be restarted, but that the hour count be resumed at the
point of plant shutdown. In other words, the monitor must oper-
ate on a "dirty" stack for 168 hours without breakdown before
testing can begin. Other pertinent questions and comments were:
1) Can the monitor be calibrated during either the conditioning
period or the operational test period?
2) Why span S02 and NOX monitors at 50% and 901 of the
specified range, especially if, for example, a NOx monitor
or a gas fired boiler will usually read about 301 of
full range?
3) For 02 analyzers, their logarithmic nature prevents spanning
accurately at 50% and 90%. Again, since 02 will usually
read about 2-3% (for boilers), why not span nearer to
operating range?
32
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4) Suggest locating extractive probes near manual
sampling ports to simplify performance testing.
CONDUCTING PERFORMANCE TESTS- Roy Woods, Du Pont; Lou Paley, DSSE
(stand in for tester)
Roy Woods told of the source's experience in conducting
performance tests. The biggest problem in conducting the
tests was the weather conditions. NO samples were taken
using both natural gas and #2 fuel oil. This resulted in two
levels of NOX values to use in accuracy determination. It was
decided that all the tests be taken on the same fuel. It was
also recommended that enough fuel be on hand to complete all of
the testing.
Lou Paley had two questions from the tester's viewpoint:
1) when using a multi-point gas monitor probe, it is assumed
that there is some stratification in the duct, so where should
the tests be taken, and 2) how should the tests be spaced time-
wise? Both questions did not receive definite answers.
OBSERVATION AND EVALUATION OF MONITOR PERFORMANCE TESTS -
Rino Wong, EPA Region VI
This presentation was concerned primarily with specific
experiences and problems encountered by Region VI in the
enforcement of continuous monitoring regulations. There are 18
sources in Region VI that are required to comply with the monitoring
regulations; ten of these had their monitors before the cutoff
dates, and are waiting until the 1979 deadline to act.
Two of the remaining eight sources burn pyrolysis fuel oil
(p.f.o.), and a third burns a p.f.o. mixture. Since p.f.o. has
been defined as a non-fossil fuel, these sources are not covered
as of the present. Requiring sources to test while burning #2
fuel oil, which is similar to p.f.o., was tried but dropped be-
cause sources question the motive behind being asked to test
while burning a fuel they do not plan to use normally.
One source, which used a computer data handling system,
preferred not to reprogram their system to meet the 10% zero
offset requirement. A voltmeter was attached to the instrument
itself (terminals are usually provided) and voltage readings
correlated to the computer output. It was also suggested that
the zero offset be done on the strip chart recorder rather than
on the monitor, if possible.
Regulations require that 27 NOX samples be taken in groups
of three. Each group of three samples must be taken within a
three minute period and no more than one set is to be run in
any one hour.
Typically, these NOX tests are spread over three days, at
nine per day, and the S02 and zero span tests are interspersed
among these. Though all the testing could be done in one day, a
three or four-day testing schedule is preferable. Scheduling
procedures, in general, are not yet well defined.
33
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OBSERVATION AND EVALUATION OF PERFORMANCE TESTS
Bob James, TACB
One important function of the observer is to insure proper
reference method testing. If the testing is not being done
correctly, stop it, make corrections (start over if necessary),
and review proper procedure with the tester. Reference method
tests must be done as accurately as possible since these are
the standards by which the monitoring systems are judged.
Numerous points of analytical technique, including timeliness of
procedures, can be invoked to ensure accuracy. Two examples:
1) Do not let NOX sample bombs sit for more than 24 hours be-
fore recovery. Recovery as soon as possible after 16 hours is
desireable. 2) Titrations for the SC>2 samples should be done
in the field (Bill Fuller's experience). The observer should be
thoroughly familiar with Appendix B performance test procedures,
and also understand how the instrument works. Instruction manuals
and cooperation from the vendors, source personnel, and operators
can only improve the situation. The observer should witness
at least one zero-span check and one response time test.
EVALUATION OF PERFORMANCE TEST DATA - Phil Schwindt, Region VI
Phil Schwindt discussed the procedures followed by Region VI in
evaluating performance tests. Region VI requires all raw data
sheets be included in the report so that calculations can be
verified. Such action may seem time-consuming, but all calcu-
lations are checked. This check has on occasion changed a
source's compliance status. All calculation sheets for parti-
culate and gaseous tests and calculations of F-factor are included
in the report, along with the trip report submitted by the observer.
All data is evaluated and the evaluation report and suggestions
are sent to the enforcement division. If a source is not in
compliance, the agency will usually require a retest of the source
performance before going out for an actual field inspection.
The format for the performance test report is basically the same
as that of the compliance tests, since the tests are often con-
current.
IMPORTANCE OF CALIBRATION AND FOLLOW-UP INSPECTIONS
Bob James, TACB
In order to validate data obtained under 40CFR60 and
40CRF51.19e, a program of quality control over data submitted from
industrial monitors will need to be established. Without on-site
inspections and calibration checks, reported data will be of
questionsable reliability. During a one year survey of continuous
mo liters, eighty percent of all plant monitors inspected by
the Texas Air Control Board were found to be either non-operational,
incorrectly calibrated, or improperly operated (these were pre-
NSPS) . Inspections must be held since there is no guarantee
that the calibrations and maintenance will be kept up.
-------
The major problems for the plant sources right now are not
so much in performing calibrations, but in interpretation and
clarification of regulations. The problem is checking cali-
brations. TACB would like to have all SC>2 and NOX monitoring
data based on a common standard. However, it is not within
present resources to transport a primary standard method or cy-
linder throughout the state and check each and every monitor.
A viable alternative is to set up a spot check program.
Bob gave a slide presentation on the use of TACB's analy-
zer as an inspection tool. The TACB monitoring system is a mobile
unit utilizing a very simple sample conditioning system. If the
inspector calibrates both systems on one span gas (company Or
TACB), then the two independent measurements of pollutant con-
centration should be the same after correcting for moisture.
If not, a problem wiht the company monitor is indicated. Some-
times there is no other means of obtaining such an indication.
Bob emphasized the cost and portability advantage of such
an instrument compared to a typical installation system for ex-
tensive use in inspection work.
TRANSMISSOMETER PERFORMANCE AND INSPECTION
John Key, TACB
There is no set procedure for inspecting transmissometers.
However, several points were covered in John's discussion.
Read plume on the way into the plant so as to get a general
idea of what your results should be.
At the monitor readout location, watch a zero and calibra-
tion check if possible.
Check charts for any variations in process and compare with
monitor readings. .
Determine character of output: optical density vs. opacity,
single or double pass, pathlength displayed (instrument
or stack exit), full scale range.
Review log book for calibrations, maintenance.
Check other monitors for verification of load shifts.
Look for correlations between monitor readings.
Check fuel flow and other changing operating conditions.
Read and use monitor operating manual - beforehand if
possible - to better understand ambiguities in readouts.
Inspect the monitor itself. Record serial number and span
calibration filter value for future information , should
communication with the vendor be necessary.
Evaluate suitability of installation location: plane of
bends, diameters upstream § downstream. Record duct or
stack dimensions @ installation and @ exit; also exact
instrument pathlegnth.
Check purge systems, filter for clogging, pinched hoses, etc.
Make sure the access covers are in place to avoid problems
later.
Verify alignment if provisions have been made to do so.
Compare on-stack readout (if any) with control room output.
Check that the transmissometer is mounted above the plane of
the sampling ports to prevent sampling probes from inter-
fering with opacity readings.
35
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DATA HANDLING REGULATIONS - Larry Jones, ESED
Larry Jones discussed data handling regulations concerning
the recording and verification of monitoring data. Originally,
the purpose of the continuous monitoring systems had been to
use the data as a maintenance check to assure the continued com-
pliance of the plant source. The data however, cannot be used
to determine compliance; a source test must be performed. There-
fore, the monitor is not being used for enforcement of Federal
standards with the exception of smelter standards. Because of
indecision concerning use of data received at this juncture, no
specific format has been laid out for the reporting of the data.
It is felt this format will come when it is decided how the in-
formation will be used. The development of a programming system
whereby all of the data will be compiled for the purpose of com-
paring plant performance nationally has been proposed. For the
present, however, only specifications as to how data is to be re-
ported and what data must be reported have been made. Excess e-
missions, startup or shutdowns of the facility, malfunctions of
control equipment and malfunctions in the monitoring systems must
be reported every quarter. A negative declaration must also be
reported.
It is minimally required that all opacity data be reduced to
six minute averages to be consistent with Method 9 so there will
be a direct comparison between opacity data from the continuous
monitoring system and from field observations. All averages
start on the hour and ten are compiled in one hour. One hour
averages are used for gaseous pollutants because analog integrators
for integrating data were reasonably available for integrations
up to one hour, after which they tend to get more expensive.
Any available data given by the monitor during the hour should
be included in the report, whether there was a malfunction or not.
It is also required that the data output be reduced to units of
applicable standards for excess emissions only.
GENERAL COMMENTS ON CONTINUOUS MONITORING DATA - Lou Paley
Any data is of questionable value if all potential sources
of error are not accounted for in some fashion, including estimates
A continuous monitoring system consists of elements other
than the monitor itself. Sample conditioning devices, sample
extraction devices, data handling devices, and the human element
in data transfer processes can introduce errors. Strip charts
are often difficult to read, maintenance records are frequently
incomplete, and old data difficult to access. Factors such as
these must be taken into consideration when continuous monitoring
data is interpreted or analyzed.
Some of these difficulties are outgrowths of specific short-
co.^ings in the regulations. Items needing clarification are:
guidelines for record keeping, data averaging
specifications for components in the system in addition
to those for the monitor itself
acquainting sources with F-factor, other data handling
methods
36
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limiting and specifically identifying the number of pens
on the same strip chart
keeping records of zero and span calibrations
means of verifying calculations
guidelines for determining whether data "looks" good or bad
provisions guaranteeing accessibility of past records
more coordination among regional offices
standardization of reporting formats
In the final analysis, too little data has been generated and
analyzed, and too little experience accumulated to smooth out all
the wrinkles at this point in time. As more questions arise and
are answered, a lot of this will fall into place. We should be
a lot better off in a year or so than we are right now.
EVALUATION AND USE OF EXCESS EMISSIONS REPORTS - Gibbs
The fact that continuous monitoring regulations are not
generally used for enforcement points up a very basic problem
with monitoring, namely, that we don't really know where we are
going with the regulations. The EPA must decide either to
enforce the continuous monitoring regulations, or let the whole
matter drop and say to the source, "Sorry, we didn't really mean
it".
Many sources are still unclear as to what excess emission
reports are to be used for. As a result, the reports are sub-
mitted in a variety of formats. Some are sent out immediately
following an excess emission, and some are incorporated into
the quarterly reports. Some of the excursions are a result of
process upsets, and some result from problems with the monitors.
Guidelines, manuals, and training of agency personnel are needed
to help both sources and agencies understand the regulations and,
thus, how to resolve these types of problems.
Some additional points:
Continuous monitoring regulations and data should be useful
to sources as well as agencies.
Some equipment arrangements are unique. If a new source
doesn't fit the regulations, have them submit an alternate
plan for agency approval.
Don't look at excess emission reports only. Review all
reporting done by the source to get the total picture.
Don't visit source only when problems arise or violations
occur. Come around just to check up, once every 6 months
or so, to resolve little problems.
Copies of inspection manuals, etc., should be made available
to sources. There should be nothing secret about inspection
procedures.
Keep instrument vendors, source testers available for
answers as the need arises.
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REGULATIONS REVISIONS - Larry Jones, ESED
No further revisions are going to be made on Method 9
at this time. However, plans are being made to make the LIDAR
system available, and minor changes will be made to allow the
EPA to approve the system. Wet F-factors have been approved.
AGENCY STRATEGIES AND FUTURE PLANS - Lou Paley, DSSE
Lou Paley concluded the conference with the future plans
concerning the continuous monitors. See Figure I. At the
moment, he feels that all of the regions need to work together in
compiling data and information on all the continuous monitoring
systems and to find answers to arising questions. It will be
necessary to better understand the regulations and to clarify
their meaning. Further, we need to improve various types of
training of personnel so they can answer the questions concerning
regulations, evaluate incoming data, do inspections, etc.
Manuals need to be developed and used. Sources need to be edu-
cated and assisted in the use of these monitors. A good data
base needs to be developed to use for setting operating standards,
making comparisons, etc. The regions themselves need to start
implementing the NSPS nad NESHAP continuous monitoring regulations.
Also, start acting on the State Implementation Plan monitoring
provisions. Regions should provide assistance to the states
on the SIP's in lining up sources for possible collaborative
testing.
The agency's future plans are basically to identify the
need for continuous monitors and their use, and to develop a
plan for the use of available data. Direct enforcement through
the use of continuous monitors will be sought. An overall con-
tinuous monitoring program was presented graphically. See Figure
-------
Draft 2/8/77
FIGURE 1. PHASE 1. CONTINUOUS MONITORING ACTIVITIES
CURRENT STATUS OF CONTINUOUS
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I
-------
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Y
/ /
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SECTION IV
QUESTIONNAIRE RESULTS-(PRESENT PROBLEMS fr FUTURE PLANS)
At the conclusion of the conference, a questionnaire was
completed by the majority of the people attending the two and
one-half day meeting. The response was excellent and showed
that the conference was of value to all present.
Most people answered the questions with definite emphasis
on their own responsibilities. Many felt that a separate
conference specifically developed for persons with their own
job responsibility would be very beneficial. When this was the
case, most people listed the subjects they thought should
receive special interest.
The salient points discussed under five questions are
listed below. The remarks are broken down as being received
from four groups of people: a) Surveillance and Analysis, b)
Air Enforcement, c) Air and Hazardous Materials and d) Miscel-
laneous.
1. WHAT PROBLEMS HAVE YOU ENCOUNTERED IN IMPLEMENTING THE
FEDERAL REGULATIONS?
S§A •Identifying and notifying sources subject to the
regulations.
•Lack of experience, equipment, and manpower. Need
to train state employees to observe and evaluate
performance tests.
•Lack of continuous monitoring background.
•Regulations need clarification.
•Need input to facility at early stage for monitor
locating; owners, testing companies, and design
engineering companies are not aware of provisions
of the monitoring regulations.
ENFORCEMENT "Uncertainty in knowning what to do with excess
emission reports.
•Difficulty in obtaining compliance from small
plants and plants having boilers which use fuel
that require monitors on an auxiliary basis
(where combustion of primary fuel does not require
a monitor).
A § HM -States have not submitted SIP revisions; the Region
has not promulgated for the state.
•Lack of priority of resources for SIP continuous
emission monitoring.
MISC. 'Ambiguities in regulations (Example: when to use
reference method analysis of span gases or NBS
-------
traceable assay).
•Non-specific language in regulations dealing
with monitor installation specifications.
2. IN WHAT AREAS DO YOU FEEL EDUCATION/MANUALS/ASSISTANCE IS
NECESSARY IN ORDER FOR THE CONTINUOUS MONITORING PROGRAM
TO BE SUCCESSFUL?
S§A •Education on continuous monitoring regulations
for agency, source and contractors.
Inspection manuals and courses (including
laboratory sessions).
•Background documents.
•Better communication between regions.
•Manuals for source operators.
•Better methods of data handling-have daily
values available for inspectors to review on
site.
•Additional guidelines are needed for monitor
location based on experience and allowable
alternative procedures.
•Contractors should be developed to assist Regions
in conducting inspections of monitors.
ENFORCEMENT •Desperately need first inspection manual.
•Detailed discussion of what are excess emissions
vs. malfunctions. Discussion of when to take
action and what action to take after receipt of
excess emission reports.
HM
MISC.
•Need to generate data to demonstrate the observer-
opacity meter correlation for each source category,
or adapt meter as reference method.
•There should be no rush toward SIP revision until
the states are competent to assume the program.
Efforts should be in helping states.
•Formal guidelines to use for inspection reports.
•Booklets of standardized data reporting forms
for sources to use for reporting results of
monitor performance tests.
•Need for opacity vs. visible emission correlation.
•Develop test procedures for installation of opacity
monitors and gaseous monitors.
•Field calibration check methods to be used for
inspection of opacity monitors.
•Access to EPA published information.
•Education and manuals on principles of instru-
mentation and monitoring systems.
42
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3. WHAT TYPE OF ASSISTANCE SHOULD BE PROVIDED BY THE FEDERAL
EPA IN ORDER FOR YOUR TO MORE EFFECTIVELY PERFORM YOUR
JOB?
S§A • Set priorities in order for program managers to
put all activities in proper perspective, and
if necessary, shift resources accordingly.
•Technical workshops-discussions of regulations,
delegation, etc.
•More background documents and manuals.
•Need a central clearing office for approved
regulation alterations, experience, questions,
and general clarification to be used by agency
and source personnel to establish consistent
decisions.
•Assistance in training state and regional employees.
•Directories to determine who to contact for
specific information on monitors, interpretation
of regulations - to establish effective means of
communications.
ENFORCEMENT
HM
MISC.
•Monitoring will never have a high enforcement
priority as long as monitor violations are not
enforceable.
•Resolution of S02 monitor/fuel sampling issue
for boilers.
•Need to emphasize the importance and time re-
quired to accomplish this program to District
Directors and Regional Administrators. Other-
wise it will be difficult to find time to work
in this area.
• Bibliography of available continuous monitoring
related documents.
•Change the regulations to allow clear use of
continuous monitors for enforcement.
•Assistance in running workshops for the states
for delegation of regulations, as well as gen-
eral requirements of the states under delegation,
•Financially and administratively supporting
desired state-sponsored conferences with major
sources affected by the 10/6/75 Federal Register,
•improve availability of technical publications.
•Quick reponse to requests for opinions and in-
tent of the law in interpreting the Federal
Register.
•Start a program of standardization for applying
the regulations throughout the country. Cover
usual and unusual cases on an individual basis.
-------
4. WHAT ASSISTANCE IS NECESSARY FOR STATES TO IMPLEMENT SIP's?
S§A • Lists of contacts for technical information.
• Convince the states that SIP revisions are
necessary.
•Convince states that this program will be worth
the effort.
•Workshops.
ENFORCEMENT 'Technical assistance, manuals, training, workshops,
etc.
A § HM «The state needs to gain expertise in continuous
monitoring. Much will come from experience, but
suggest getting contractor assistance from vendors
to get program going.
•Assistance in drafting enforceable regulations.
•Technical assistance for workshops on calibration
and inspection procedures.
•Eventual funding for additional enforcement in-
spectors.
MISC. «Push state directors; working level personnel are
ready.
5. WHAT KIND OF SUBJECT MATTER WOULD BE OF BENEFIT TO YOU AT
FUTURE CONFERENCES OR WORKSHOPS?
S§A »More information on equipment and principles of
operations from vendors or other speakers.
•Written documentation on what to do to remain
consistent between regions in problem areas
where sources can not strictly follow the
Federal Register.
•More discussion of the vendor's field experience.
•Need to exchange experiences of various agency
personnel.
•A workshop with more source representatives who
have had experience and can comment on their
problems.
•A workshop on monitors.
•Presentations on changes in the regulations or a
need for changes.
•Need legal input on various questions.
•A vinyl chloride continuous monitoring workshop
should be developed to assist regions in conducting
inspections.
ENFORCEMENT "Detailed discussion of what are excess emissions
vs. malfunctions; discussion of what to do with
reports.
•Experience of practical applications of monitoring
programs.
44
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•Enforcement examples.
•Demonstrations of continuous monitor uses by and
for enforcement.
A § HM •Information on how to develop continuous monitoring
regulations for state SIP's.
•Discussion of approvability of existing state
regulations.
Based on the results of this questionnaire, it appears that
there is a future need for several types of conferences or work-
shops. First, meetings could be held for persons generally in-
volved with SIP, NSPS, or NESHAP regulations for continuous
monitors. And secondly, they could be slanted towards interests
of the observers, inspectors, sources, or those generally
involved.
The response of the persons attending the conference in
Dallas showed that there is much work that needs to be done and
many questions that need to be answered. As was pointed out
during the meeting, programs to fulfill some of the needs
listed on the questionnaire are in the planning stages or are
presently being pursued. Others have to be given serious con-
sideration. The conference response provided excellent input
from persons working directly with continuous monitoring acti-
vities and established a good basis from which to develop pro-
grams for implementing continuous monitoring regulations.
45
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APPENDICES
46
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APPENDIX A
MAIN FIELD CONTINUOUS MONITORING CONTACTS (NSPS £ SIP)
REGION
I. David Stonefield
Chief, Air Section
Surveillance and Analysis Division
Region 1, EPA
60 Westview Street
Lexington, Massachusetts 02173
Phone: 617/861-'6700 (commercial only)
II. Dennis Santella
Facilities Technology Division
Region II, EPA
20 Federal Plaza, Room 802
New York, New York 10007
Phone: 212/264-9628 (FTS 264-9628)
III. Robert Kramer
Surveillance and Analysis Division
Region III, EPA
6th and Walnut Street
Philadelphia, Pa. 19106
Phone: 215/597-9843 (FTS 597-9843)
IV. Doyle T. Brittain
Chief, Air Surveillance Branch
Surveillance and Analysis Division
Region IV, EPA
College Station Road
Athens, Georgia 30605
Phone: 404/546-3197 (FTS 250-5197)
Jim Wilburn(data validation § use)
Chief, Air Enforcement Branch
Enforcement Division
Region IV, EPA
345 Courtland Street, NE
Atlanta, Georgia 30308
Phone: 404/526-5291 (FTS 285-5291)
V. Ed ZyTstra
Surveillance and Analysis Division
Region V, EPA
230 S. Dearborn
Chicago, Illinois 60604
Phone: 312/353-2303 (FTS 353-2303)
A 7
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VI. Phil Schwindl
Surveillance and Analysis Division
Region VI, EPA
First International Building
1201 Elm Street
Dallas, Texas 75270
Phone: 214/749-3971 (FTS 749-3971)
VII. John J. Giar
Surveillance and Analysis Division
Region VII, EPA
25 Funston Road
Kansas City, Kansas 66115
Phone: 816/374-4461 (FTS 758-4461)
VIII. John R. Floyd
Surveillance and Analysis Division
Region VIII, EPA
1860 Lincoln Street
Denver, Colorado 80295
Phone: 303/837-4261 (FTS 327-4261)
IX. Ken M. Kitchingman
Surveillance and Analysis Division
Region IX, EPA
100 California Street
San Francisco, California 94111
Phone: 415/556-8752 (FTS 556-8752)
X. George C. Hofer
Chief, Air Surveillance
Surveillance and Analysis Division
Region X, EPA
1200 6th Avenue M/S 333
Seattle, Washington, 98101
OTHER CONTINUOUS MONITORING CONTACTS
Jules Cohen
National Enforcement Investigations Center
Building 53, Box 25227
Denver Federal Center
Denver, Colorado 80225
Phone: 303/234-4656
Bob James and John Key
Texas Air Control Board
8520 Shoal Creek Boulevard
Austin, Texas 78758
Phone: 512/451-5711
Louis R. Paley (EN-341)
Division of Stationary Source Enforcement
401 M Street, SW
Washington, D. C. 20460
Phone: 202/755-8137 (FTS 755-8137)
48
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Larry Jones (MD-13)
Hmission Standards and Engineering Division
HPA/OAQPS
Research Triangle Park, N.C. 27711
Phone: 919/541-5421 (FTS 629-5421)
REGULATION (NON-FIELD) CONTACTS
I. Linda M. Murphy
Air and Hazardous Materials Division
Region I, EPA
JEK Federal Building
Boston, Massachusetts 02203
Phone: 617/223-4448 (FTS 223-4448)
II. Dennis Santella
Facilities Technology Division
Region II, EPA
26 Federal Plaza, Room 802
New York, New York 10007
Phone: 212/264-9628 (FTS 264-9628)
III. Isreal A. Milner
Air and Hazardous Materials Division
Region III, EPA
v;. Curtis Building 10th Floor
6th and Walnut Streets
Philadelphia, Pa. 19106
Phone: 215/597-8174 (FTS 597-8174)
IV. Tommie A. Gibbs
Chief, Air Engineering Branch
Air § Hazardous Materials Division
Region IV, EPA
345 Courtland Street, NE
Atlanta, Georgia 30308
Phone: 404/285-4552 (FTS 257-4552)
V. Sue Karacki
Air § Hazardous Materials Division
Region V, EPA
230 S. Dearborn
Chicago, Illinois 60604
Phone: 312/353-2205 (FTS 353-2205)
VI. Oscar Cabra
Chief, Technical Support Branch
Air and Hazardous Materials Division
Region VI, EPA
First International Building
1201 Elm Street
Dallas, Texas 75270
49
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VII.
VIII
IX.
X.
Wayne Durst
Chief, Air Support Branch
Air $ Hazardous Materials Division
Region VII, EPA
1735 Baltimore Avenue
Kansas City, Missouri 64108
Phone: (FTS 758-3791)
Robert De Spain
Chief, Air Branch
Air and Hazardous Materials Division
Region VIII, EPA
1860 Lincoln Street
Denver, Colorado 80295
Phone: 303/837-3711 (FTS 327-3711)
Allyn Davis
Air § Hazardous Materials Division
Region IX, EPA
100 California Street
San Francisco, California 94111
Phone: 415/556-7882 (FTS 556-7882)
Clark Gaulding
Chief, Air Programs Branch
Air § Hazardous Materials Division
Region X, EPA
1200 6th Avenue
Seattle, Washington, 98101
OTHER CONTACTS:
NSPS $ NESHAP
Determinations
SIP Revisions
Rich Biondi (EN-341)
Enforcement and Technical Determinations
Division of Stationary Source Enforcement
401 M Street SW
Washington, D.C. 20460
Phone: 202/755-2564 (FTS 755-2564)
Gary Rust
[SIP Revisions)
CPDD MDL5
Research Triangle Park, N.C. 27711
Phone: 919/629-5365 (FTS 629-5365)
50
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APPENDIX B
REFERENCE PUBLICATIONS
The following is a list of publications that deal with
monitoring systems and related subjects. We refer you to
these articles and documents hoping they will contain answers
to some of your questions. The "PB" number following each
document is the number used for ordering the document from
the National Technical Information Services (NTIS). A small
fee is charged for the documents.
51
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APPENDIX B
REFERENCE PUBLICATIONS
Stationary Source Measurements Research Branch
Extra.v.ural Reports
Contractor
A. D. Little
A, D. Little
A. D. Little
Aeronutronic-Ford
Corporation
Aerotherm
Arnold Research
Organization
Avco Corporation
Barringer Research
Eendix Corporation
Eendix Corporation
Bendix Ccrpoation
Dalmo Victor
Dalmo Victor
Dalmo Victor
52
Title
Manual Methods for Sampling and Analysis
of Particulate Emissions from Incinerators
Development of Methods for Sampling and
Analysis of Particulate and Gaseous
Fluorides from Stationary Sources
Development of a High Purity Filter for
Analysis by Advanced Sensitive Analyti-
cal Techniques
Infrared Absorption by Sulfuric Acid
Vapor
Fabrication and Installation of the
Stationary Source Simulator
Interferometric Instrumentation
for Particle Size Analysis
Feasibility Study of Remote Monitoring
of Gas Pollutant Emissions by Raman
Spectroscopy
Test Program/Optical Measurement of
SO and N02
Long Path Spectroscopy Instrumentation
for In-situ Monitoring of Gaseous
Pollution/Urban Atmospheres
Off-Line Analysis Programs for Long
Path Spectrometer
Development of Instrumentation for
Measurement of Stationary Source '
Aldehyde, Organic Acid, and Amine
Emissions
Study of Infrared Techniques for
Monitoring Stack Gases
Long Path Ozone Measurements by
IR Technique
Passive IR S02 Sensor
EPA Numbers
EPA 650/2-73-023
PB 238476/AS
EPA R2-72-126
PB 213-313
EPA 650/2-73-032
PB 230-886/AS
EPAr600/2-76-191
PB 257088/AS
EPA-650/2-75-015
PB 247231
EPA-650/2-73-034
PB 240584
APTD-0658
PB 198-204
APTD-1486
PB 193-485
APTD-0889
PB 205-256
EPA 650/2-73-010
PB 212-625
EPA-650/2-73-010
PB 230-884/AS
PB 187-391
PB 187-392
PB 187-390
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Title
Contractor
EPA Numbers
Collection Efficiency Study of the
Proposed Method 13 Sampling Train
Evaluation of Correlation Spectrometer
as an Area Monitor
In-Stack Transm-issometer Techniques for
Measuring Opaciti.es of Particulate
Emissions
Evaluation and Modification of Fluoride
Sampling and Analytical Methods
(26 AAP-23)
Evaluation of Measurement Methods and
Instrumentation for Odorous Compounds
in Stationary Sources
Magnitude of S02> NO, C02 and 0«
Stratification Tn Power Plant Dacts
Collection Efficiencies of Stack Sampling
Systems for Vanadium Emissions in Flue Gases
Particulate Sampling Strategies for" Large
Power Plants Including Non-uniform Flow
Development of an Instrumental Monitoring
Method for Measurement of Asbestos Concen-
tration in or Near Sources
Development of Infrared Scanning Spectroscopy
for Remote Monitoring of Emission Spectra of
Hot Gas Pollution
Field Measurements of Gas Pollutantin
Ambient Air and from Stationary Sources
by Remote Infrared Techniques
Compact Sampling System for Collection of
Particulates form Stationary Sources
Field Study on Application of Laser Coin-
cidence, Absorption Measurement
Performance Evaluation of Mobile Lidar
System
Entropy Environmen-
tal-, Inc.
Environmental Mea-
surements Inc.
Environmental Res.
Corporation
Environmental Science
and Engineering, Inc.
Esso Research and
Engineering Company
EXXON
EXXON
Fluidyne
The Franklin
Institute
General Dynamics
General Dynamics
General Electric
Corporation
General Electric
Corporation
General Electric
Corporation
EPA-600/2-75-052
EPA-600/2-75-077
PB 249113
EPA R2-72-099
PB 212-741
EPA 650/2-73-007
PB 230-954/AS
APTD-1180 (Vol. 1
PB 212-812
EPA R2-73-180
(Vol. II)
PB 223-654
EPA-600/2-75-053
EPA-600/2-76-096
PB 256399/AS
EPA-600/2-76-170
PB 257090/AS
EPA 650/2-73-016
PB 226-471/AS
EPA R2-72-052
PB 221-073
EPA 650/2-73-026
PB 230-885/AS
LTA GGO/2-74-029
PB 240398/AS
APTD-0981
PB 210-671
APTD-0968
PB 210-672
53
-------
Title
Contractor
EPA Numbers
Development of Range Squared and Cff-
Gating Modifications for a Lidar System
Sampling Interface for Quantitative Trans-
port of Aerosols
Sampling Interface for the Quantitative
Transport of Aerosols—Field Prototype
Design, Development and Fabrication of
a Beta Gauge and Filter
Development of Sampling Produce for
Polycylic Organic Matter and
Polychlorinated Biphenyls
Development of In-Situ Prototype Diode
Laser System to Monitor SO, Across-the-
Stack <•
Optical Method for Measuring the Mass
Concentration of Particulate Emissions
Evaluation and Development of Nitrogen
Oxide Monitors for Combustion Sources
Instrumentation or Methods for Measuring
Specific Particulate Substances Including
Beryllium and Cadmium in Stationary
Source Emissions (Phase I)
Conversion of Monsanto Model 3409
Chemiluminescent Ambient Air NO
and S02 from Stationary Sources
Construction and Field Testing of
Commercial Prototype Disc DiTuter
(26 AAP-27)
Remote Sensing of Pollutants
Transmisscmeter Evaluation
and Application to Particulate Opacity
Infrared Gas Filter Correlation
Instrument for In-Situ Measurement of
Gaseous Pollutants
General Electric
Corporation
Illinois Institute
of Technology
Research Institute
Illinois Institute
of Technology
Research Institute
Industrial Nucleonics
Corporation
Langston Labs, Inc.
Mass. Institute of
Technology, Lincoln
Laboratory
Meteorolgy Research
Inc.
Monsanto Research
Corporation
Monsanto Research
Corporation
Monsanto Research
Corporation
Monsanto Research
National Oceanic and
Atmospheric Administra-
tion
Owens-Illinois
Philco-Ford
Corporation
EPA 650/2-73-040
PB 228-715
EPA-650/2-74-016
PB 240423/AS
EPA 600/2-76-157
APTU-1150
PB 209-954
EPA-650/2-75-007
PB 243362/AS
EPA R2-73-218
PB 223-628/AS
EPA-600/2-76-062
APTD-0847
PB 204-877
PB 209-109
EPA R2-73-252
PB 232-088/AS
EPA 650/2-73-027
PB 231-084/AS
EPA-650/2-74-055
EPA-650/2-74-113
PB 240168/AS
EPA-650/2-75-008
PB 243402
EPA-650/2-74-094
PB 239467/AS
54
-------
Title
Contractor
EPA Numbers
In-Stack Transmisspmeter Measurement
of Parti-culate Opacity and Mass Con-
centration
Experimental Investigation of the
Infrared Emission by S0?
Infrared Sensor for the Remote Monitoring
of S02
Study of Low Backscatter by Particulates
in Stack Emissions
Development of a CW Lidar for the Remote
Measurement of Smoke-Piurae Opacity
Feasibility Study of In-Situ Source
Monitoring of Particulate Composition
by Raman or.Fluorescence Scatter
Development and Fabrication of a
Prototype Mass Emission Data System
Continuous Particulate Monitors for
Fossil-Fuel Combustion Sources
^
Development of a Subsidiary Emission .
Measurement Monitoring System *•
Adaptation and Evaluation of Odor •
Measurement Techniques to Various
Odor Sources (26 AAP-72)
Design and Construct a Protable
Laser Interference Type Velocimeter
for. Stack Velocity Measurements
Evaluation of Sulfur Dioxide Monitors
Combustion Sources
Feasibility Study of the Use of
Resonance Scattering for the Remote
Detection of Pollution in Stationary
Source Emissions
Filtration Characteristics of Glass
Fiber Media at Elevated Temperatures
Investigation of Extractive Sampling
Interface- Parameters
Philco-Ford
Corporation
Phil co-Ford
Corporation
Science Applica-
tions Inc.
Stanford'Research
Institute
Stanford Research
Institute
Stanford Research
Institute
Systems Technology
Association, Inc.
Thermo-Systems,
Inc.
Thunder Scientific
Corporation
TRC - The Research
Corporation of New
England '
TRW Inc.
TRW Inc.
United Aircraft
Corporation .
University of
Florida
Wai den Research
EPA-650/2-74-120
PR 239864/AS
APTD-0760
PB 203523
EPA-650/2-75-041
PB 243478 •
EPA R2-72-089
PB 212-530
EPA 650/2-73-037
PB 231-992/AS
EPA R2-73-219
PB 225-042/1AS
EPA 650/2-73-009
PB 232-013/AS
EPA 650/2-73-022
PB 231r919/AS
EPA 650/2-73-008
PB 232-442/AS
EPA-650/2-74-008-
a
PB 228-186/AS
EPA R2-72-132
PB 213-263
EPA R2-73-163
PB 220-202
EPA 650/2-72-106
EPA-600/2-76-192
PB 257132/AS
EPA-650/2-74-089
PB 242515/AS
55
-------
Title
Evaluation and Modification of Manual
S0? and-SCL Sampling Techniques
Evaluation of Monitoring Methods and
Instrumentation for Hydrocarbons in
Stationary Sources Emissions
Evaluation of Instrumentation for
Monitoring Total Mercury Emissions
from Stationary Sources
Contractor
Maiden Research
Division of Abcor,
Inc.
Wai den Research
Division of Abcor,.
Inc.
Wai den Research
Division of Abcor,
Inc.
EPA Numbers
EPA R2-72-105
ft! 215-807
EPA R2-72-106
PB 226-657/5WP
EPA R2-73-252
PB 232088/AS
56
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ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL SCIENCES RESEARCH LABORATORY
STATIONARY SOURCE MEASUREMENTS RESEARCH BRANCH
Staff Publications
August 1973 to November 1976
Barnes, H. M., Herget, W. F., and Rollins, R., "Remote Sensing of SOz 1n Power
Plant Plumes Using Ultraviolet Absorption and Infrared Emission", Analytical
Methods Applied to Air Pollution Measurements, Ann Arbor Science Publishers,
Inc., August 1974.
Barnes, H. M., and Jepsen, A. F., "The Accuracy of Remote Sensing Techniques
1n Emission Measurement and Vertical Plume Mapping", Proceedings Air Pol-
lution Measurement Accuracy As It Relates to Regulation Compliance Specialty
Conference» APCA, copyright 1976.
Barnes, H. M., and Homolya, J. B., "Data Requirements for Nox Emissions Moni-
toring from Fossil-Fuel Fired Steam Generators", J. Environ. Sci. Health-
Environ. Sci. Eng.. All (2), 107-119 (1976).
Barnes, H. M., and Caldwell, M. C., "Rapid Method for Determining NOX Emissions
1n Flue Gases". EPA 600/2-76-094, September 1976.
Barnes, H. M., Fortune, C. R., and Homolya, J. B., "An Evaluation of Measure-
ment Methodology for the Characterization of Gaseous Sulfur Emissions from
Combustion Sources", In press, Proceedings of the Fourth National Conference
on Energy and the Environment, Cincinnati, Ohio, October 4-7, 1976.
Bennett, R. L., J. Wagman, and K. T. Knapp, "The Application of a Mulitchan-
nel Fixed and Sequential Spectrometer System to the Analysis of Air Pollution
Particulate Samples from Source Emissions and Ambient Air", Advances In X-ray
Analysis, 19, Kendall/Hunt Publishing Co., Dubuque, Iowa, 393-402 (1976).
Bennett, R. L., and Knapp, K. T., "Chemical Characterization of Particulate
Emissions from Oil-fired Power Plants", In press, Proceedings of the Fourth
National Conference on Energy and The Environment, Cincinnati, Ohio, October
4-7, 1976.
Cheney, J. L., and Homolya, J. B., "A Systematic Approach for the Evaluation
of Triethanolamine as a Possible Sulfur Dioxide Sorption Detector Coating",
Analytical Letters. 8 (3), 175-193 (1975).
Cheney, J. L., and Homolya, J. B., "The Development of A Sulfur Dioxide
Continuous Monitor Incorporating a Piezo-Electric Sorption Detector", The
Science of the Total Environment, 5_, 69-77 (1976).
Cheney, J. L., Norwood, T., and Homolya, J. B., "The Detection of Sulfur
Dioxide Utilizing a Piezo-Electric Crystal Coated with Ethylenedinitrilo-
tetraethanol", Analytical Letters. 9. (4), 361-377, (1976).
Cheney, J. L., Fortune, C. R. Homolya, J. B., and Barnes, H. M., "The Ap-
plication of An Acid Dewpoint Meter for the Measurement of Sulfuric Acid/
Sulfur Trioxide Emissions", In press, Proceeding of the Fourth National
Conference on Energy and The Environment, Cincinnati, Ohio, October 4-7, 1976.
57
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Cheney, J. L., Norwood, T., and Homolya, J. B., "The Detection of Source
Levels of Sulfur Dioxide Using a Piezo-Electric Detector and Permeation
Membrane", Analytical Letters, i (6), 557-578 (1976).
Conner, W. D., "Measurement of the Opacity and Mass Concentration of Parti-
culate Emissions by Transmissometry", EPA-650/2-74-128, November 1974.
Conner, W. D., "A New Comparison Between In-Stack and Plume Opacity Measure-
ments at Oil-fired Power Plants", In press, Proceedings of the Fourth Na-
tional Conference on Energy and The Environment, Cincinnati, Ohio, October
4-7, 1976.
Herget, W. F., "The Application of Electro-optical Techniques to the Sensing
of Stationary Source Pollutants", Proceedings of the Second Joint Conference
on Sensing of Environmental Pollutants, Washington, DC, December 1973.
Herget, W. F., McClenny, W. A., and Stevens, R. K., "A Comparative Review
of Open Path Spectroscopic Absorption Methods for Ambient Air Pollutants",
Anal. Methods Applied to Air Poll. Meas., Ann Arbor, Ann Arbor Science
Pub!., Inc., 1974.
Homolya, J. B., "Development of Performance Specifications for Continuous
Monitors of Stationary Source Emissions", EPA Research Document RD 688,
Proceedings of the Second Conference on Environmental Quality Sensors, Las
Vegas, Nevada, October 1973.
Homolya, J. B., "Data Output Requirements for Monitoring S02 Emissions from
a Stationary Source", Proceedings, Instrument Society of America, #73-116,
October, 1973.
Homolya, J. B., "Measurement Techniques for Monitoring S02 Emissions from
Stationary Sources", Science of The Total Environment, 2_ (3), (1973).
Homolya, J. B., and Griffin, R. J., "Dilution Service for Coupling Monitors
to Source Emissions", Analytical Letters, 7_ (4), 299-312 (1974).
Homolya, J. B., "Coupling Continuous Gas Monitors to Emission Sources",
Chemtech, July, 426-433 (1974).
Homolya, J. B., "Current Technology for Continuous Monitoring of Gaseous
Emissions", JAPCA. 25. (8), 809-814, August 1975.
Homolya, J. B., "Continuous Monitoring Systems for Gaseous Emissions",
EPRI Workshop, Proceedings, Special Report #41, p. 17, October 1975.
Homolya, J. B., Barnes, H. M., and Fortune, C. R., "A Characterization of
the Gaseous Sulfur Emissions from Coal and Coal-fired Boilers", In press,
proceedings of the Fourth National Conference on Energy and The Environment,
Cincinnati, Ohio, October 4-7, 1976.
Homolya, J. B., "The Developmental Meeds for Continuous Source Monitoring
Systems of Gaseous Emssions", In press, Proceedings of the Fourth National
Conference on Energy and The Environment, Cincinnati, Ohio, October 4-7,
1976.
58
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Knapp, K. T., "Flow Problems 1n Source Sampling", In press, Proceedings
of the Emissions Sampling for Source Evaluation, Engineering Foundation
Conference, Hueston Woods State Park, Oxford, Ohio, September 1976.
Knapp, K. T., and Bennett, R. L., "Sulfur Analysis of Air Pollution Samples
Containing Sulfuric Acid with a Vacuum X-ray Fluorescence Spectrometer", Ad-
vances in X-ray Analysis, 19, Kendall/Hunt Publishing Co., Dubuque, Iowa,
427-434, (1976).
Knapp, K. T., "New Techniques for Continuous Measurement of Mass Emissions",
Proceedings of the Workshop on Sampling, Analysis, and Monitoring of Stack
Emissions, EPRI SR-41, April 1976.
Knapp, T. T., Conner, W. D., and Bennett, R. L., "Physical Characterization
of Particulate Emissions from Oil-fired Power Plants", In press, Proceedings
of the Fourth National Conference on Energy and The Environment, Cincinnati,
Ohio, October 4-7, 1976.
Knapp, K. T., "The Number of Sampling Points Needed for Representative
Source Sampling", In press, Proceedings of the Fourth National Conference
on Energy and The Environment, Cincinnati, Ohio, October 4-7, 1976.
'Nader, J. S., "Developments in Sampling and Analysis Instrumentation for
Stationary Sources", J.A.P.C.A., 23., 589-591 (1973).
Nader, J. S., and Duffee, R. A., "Defining and Measuring Objectionable Odors",
Preprint, Proceedings of the Second International Pollution Engineering Con-
ference, Philadelphia, Pennsylvania, October 22, 1973.
Nader, J. S., "Status of Source Measurement Techniques in the United States",
Proceedings of the INternational Synposium on Environmental Measurements,
Geneva, Switzerland, October 1973.
Nader, J. S., Jaye, F., and Conner, W. D., "Performance Specifications for
Stationary—Source Monitoring Systems for Gases and Visible Emissions",
EPA 560/2-74-013, January 1974.
Nader, J. S., "Current Technology in the Continuous Monitoring of
Emissions of Particulate Matter", JAPCProceedings of a Specialty Con-
ference on Continuous Monitoring of Stationary Air Pollution Sources,
St. Louis, Mo., March 20-21, 1975, Air Pollution Control Association,
Pittsburgh, Pa., 1975, and JAPCA 25_ (8), 814-421, August 1975.
Nader, J. S., "Particulate Mass Monitoring Techniques Applied to Emission
Sources", Preprint No. 75-60-2, 68th Annual Meeting of the Air Pollution
Control Association, Boston, Mass., June 15-20, 1975.
Nader, J. S., "Measurement Technology Applied to Source Emissions: Present
Needs and Developments", In Press, Proceedings of the Twelth International
Symposium on Atmospheric Pollution, Paris, France, May 5-7, 1976.
Wagtnan, J., Bennett, R. L., and Knapp, K. T., "X-r.ay Fluorescence Multi-
spectrometer for Rapid Elemental Analysis of Particulate Pollutants",
EPA 600/2-76-033, (1976).
59
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APPENDIX C
CONTINUOUS EMISSIONS MONITORING CONFERENCE
DALLAS, TEXAS
FEBRUARY 15-17, 1977
OFFICIAL ROSTER
Joe Arello
Sanitary Engineer
Surveillance & Analysis
25 Funston
Kansas City, Kansas 66115
FTS 758-4461
James P. Barta, Jr.
Engineering Assistant III
Source Evaluation Section
Texas Air Control Board
8520 Shoal Creek Blvd.
Austin, Texas 78758
512-451-5711, Ext. 398
Gary A. Bernath
Engineer
Enforcement Division, Region VI
1201 Elm Street
Dallas, Texas
(214) 749-7675
Rich Biondi
Chemical Engineer
Division of Stationary
Source Enforcement
401 M Street, S.W.
Washinaton, D.C. 20460
(202) 755-2564
Martin E. Brittain
Chemical Engineer
Air Compliance Branch
Enforcement Division
EPA, Region VI
1201 Elm Street
Dallas, Texas
(214) 749-7675
George A. Brooks
EPA, Region VI
S ." A Division
1201 Elm Street
Dallas, Texas 75270
214-749-7126
Jules B. Cohen
Technical Coordinator
NEIC
Bldg. 53, Denver Federal Center
Denver, Colorado 80225
303-234-4656
Peter J. Culver
Air Enforcement Coordinator
Enforcement Division, Region VII
1735 Baltimore
Kansas City, Missouri 64108
FTS 758-2576
James E. Cunningham
Chemist
Source Evaluation
Texas Air Control Board
8520 Shoal Creek Blvd.
Austin, Texas 78758
512-451-5711, Ext. 277
Lee Daniels
Chief, Air Surveillance Section
Surveillance & Analysis Division
EPA, Region VIII
1860 Lincoln Street
Denver, Colorado
FTS 327-4261
John R. Floyd
Environmental Engineer-
Air Surveillance Section
Surveillance & Analysis Division
EPA, Region VIII
1860 Lincoln 'Street
Denver, Colorado 80295
FTS 327-4261
Commercial: 303-837-4261
John J. Giar
Environmental Protection Technologist
Surveillance & Analysis Division
25 Funston Rd.
Kansas City, Kansas 66115
FTS 758-4461
60
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Tommie A. Gibbs
Chief, Ai r Engi neeri ng Branch
Air and Hazardous Materials Division
Region IV
345 Courtland St., N.E.
Atlanta, Georgia
FTS 285-4552
George C. Hofer
Chief, Air Surveillance and
Investigation Section
Surveillance & Analysis Division
Region X
1200 6th Ave. M/S 333
Seattle, Washington 98101
FTS 399-1106
Howard E. Houston
Compliance Division
Texas Air Control Board
8520 Shoal Creek Blvd.
Austin, Texas 78758
(512) 451-5711, Ext. 265
James A. Jahnke
Manager - Engineering and
Enforcement Section
EPA Air Pollution Training Institute
Northrop Services, Inc.
Environmental Research Center MD 20
Research Triangle Park, N.C.
919-549-8411, Ext. 2766
Robert E. James
Chief, Continuous Monitoring and
Special Projects Group
Source Evaluation Section
Texas Air Control Board
8520 Shoal Creek Blvd.
Austin, Texas 78758
512-451-5711
Fredric C. Jaye, Staff Engineer
Acurex Corporation
485 Clyde Avenue
Mountain View, California 94042
415-964-3200
ranc
Sue Karacki
Assistant tothe Br
Air Program Branch, A
230 S. Dearborn
Chicago,. Illinois 60604
312-353-2205
Karl Karst
Entropy Environmentalists, Inc.
RTP, Box 12291
Durham, N.C. 27709
919-781-3550
Robert Kramer
Environmentalist
Surveillance & Analysis Division
Region III
6th and Walnut Streets
Philadelphia, Pa. 19106
215-597-9843
Willie Kelley
Sanitary Engineer
EPA, Surveillance & Analysis Division
Region VI
First International Bldg.
1201 Elm Street
Dallas, Texas
FTS 749-7126
John W. Key
Engineer, Source Evaluation Section
Texas Air Control Board
8520 Shoal Creek Blvd.
Austin, Texas 78758
512-451-5711, Ext. 245
Kent M. Kitchingman
Environmental Engineer
Surveillance & Analysis Division
Region IX
100 California Street
San Francisco, California 94111
415-556-8752
Leland Marshall
Chief, Penna., Del., W. Va. Section
Air Compliance Branch
Enforcement Division
Region III
6th and Walnut Streets
Philadelphia, Pa. 19106
FTS 597-4779
- u
egion V
61
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Israel Z. Milner, Mgr.
Plans Management Group
Air & Hazardous Materials Division
Air Programs Branch
EPA, Region III
Curtis Bldg., 10th Floor
6th and Walnut Streets
Philadelphia, Pa. 19106
(215) 597-8174
Linda M. Murphy
Environmental Engineer
Region I
Air and Hazardous Materials Division
J.F.K. Federal Building
Boston, Massachusetts 02203
617-223-4448
Timothy Osag
Chemical Engineer
NEIC
Building 53
Federal Center
Lakewood, Colorado
234-2336
Louis R. Paley (EN-341)
Environmental Engineer
DSSE @ D.C.
401 M Street, S.W.
Washington, D.C. 20460
(202) 755-8137
Gary Rust
Environmental Specialist
CPDD MD 15
Research Triangle Park, N.C.
629-5365
Dennis Santella
Environmental Engineer
Region II - Air Facilities Branch
EPA
26 Federal Plaza - Rm 802
New York, New York 10007
212-264-9628
Phil Schwindt
Environmental Engineer
Surveillance & Analysis Division
EPA, Region VI
First International Building
1201 Elm Street
Dallas, Texas 75270
FTS 749-7126
David H. Stonefield
Chief, Air Section
Surveillance & Analysis Division
Region I, EPA
60 Westview Street
Lexington, Mass. 02173
Bruce Varner
Environmental Engineer
Air Enforcement Branch, Region V
230 S. Dearborn
Chicago, Illinois 60604
312-353-2086
R. J. Vong
EPA, Region IX AHMD APB
100 California St.
San Francisco, California 94111
Jim Wilburn
Chief, Air Enforcement Branch
Region IV
345 Court!and Street, N.E.
Atlanta, Georgia 30308
Quirino Wong
Environmental Engineer
Surveillance & Analysis Division
EPA, Region VI
1201 Elm Street
Dallas, Texas 75270
FTS 749-7126
Roy 0. Woods
Senior Chemist
E. I. DuPont De Nemours & Co.
Sabine River Works
P. 0. Box 1089
Orange, Texas 77630
(713) 883-8411, Ext. 612
Inc.
62
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Ed Zylstra
Air Surveillance Branch, Region V
230 S. Dearborn
Chicago, Illinois 60604
312-353-2303
William F. Fuller
DuPont Instruments
E.I. DuPont de Nemours, Co. (Inc.)
Concord Plaza, Quillen Bldg.
Wilmington, Delaware 19898
Larry G. Jones
EPA/OAQPS
Emission Standards & Eng. Division
Research Triangle Park, N.C. 27711
919-688-8146, Ext. 421
FTS 629-5421
Dave Lester
Lear Siegler, Inc.
Environmental Technology Division
3480 Greenbriar Parkway
Atlanta, Georgia 30331
Harry C. Lord
Environmental Data Corp.
608 Fig Avenue
Monrovia, California 91016
213-358-4551
63
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
340/1-77-025
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Continuous Emissions Monitoring Conference
Dallas, Texas: February 15-17, 1977
Conference Report § Response to Key Questions
5. REPORT DATE
December 20, 1977
6. PERFORMING ORGANIZATION CODE
Issues
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Entropy Environmentalists, Inc.
PO Box 12291
Research Triangle Park, NC 27709
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-4148 Task No. 502
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Enforcement
Office of General Enforcement
Washington, DC 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Division of Stationary Source Enforcement, in conjunction with the Region VI
Dffice of the Environmental Protection Agency (EPA) sponsored a conference workshop in
Dallas, Texas on February 15-17, 1977, on Stationary Source Continous Emissions
onitoring. This report includes a detailed summary of the Conference proceedings as
ll as consensus reponses by various EPA Divisions relating to many of the key
questions and issues which arose during the course of the conference.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Federal Continuous Monitoring Regulations
New Source Performance Standards
Enforcement
Continuous Emissions
Monitoring - Conferences
tew Source Performance
Standards Enforcement
Enforcement
13B
14D
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
22. PRICE
EPA Form 2220-1 (9-73)
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