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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.
                     12

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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
                     14

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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.)
                       15

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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
                     19

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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.
                       20

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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
                              21

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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.
                         23

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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.

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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?

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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.

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     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

-------
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

-------
     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.

-------
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
                                   EMISSION MONITORING  PROGRAM
                                 (NSPS, NESHAP,SIP -  REGULATIONS)
O4
•-O
  DEVELOPMENT
     OF A
   RESOURCE
     FILE
IDENTIFY AFFECTED
SOURCES § DETERMINE
STATUS OF COMPLIANCE
1
NSPS ,
NESHAP | blp
i




COMPILE
EXISTING
CASE
HISTORIES


\
EVALUATE
ENFORCEABILITY
OF NSPS AND
NESHAP C.M.
REGULATIONS
ASSESS PROGRESS
AND ADEQUACY OF
   C.M. SIP
  REVISIONS
                                                                                        f
                                                 I	

-------
   ACTION ITEMS FOR EXISTING
REGUIATIONS (SIP,  NSPS, NESHAP)
FIGURE  2,                POTENTIAL ACTION  ITEMS FOR
                       DIRECT  ENFORCEMENT  USING C.M.'s
                                                A)  ADEQUACY OF EXISTING REGULATIONS?
                                                B)  DEVELOPMENT OF VIABLE ALTERNATIVE CONCEPTS?
                                                C)  JUSTIFICATION - EFFECTIVENESS?
                                                D)  DEVELOP PROGRAM TO  IMPLEMENT NEW REGULATIONS,
<\LL I
<\DEQl
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^

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TEMS '
ATE? N
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t
GOAL - 1
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MENTATION
OF EXISTING
REGULATIONS


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A
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I START
1 NOW












1. Background Documents Developed for
Regulations

2. EPA Regulations (Written/Understood/
Enforceable)

3. State Re
Enforcea

gulations (Written/Understood/
ble)

4. Emission
Used
Monitoring Devices Available/

5. Process 1
Monitors Available/Used

6. Data Hani
Availabl<
Jling and Recording Devices
s/Used

7. Validate
Performar
3n of Monitor Installation,
ice and Data

8. Data Utilized by Sources and Agency
\
**
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\ \\ i / / / /
ULTIMATE GOAI - e. .
START IF
D IS VALID
r*l
	 ;|!
•J;
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— |M

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REDUCE EMISSIONS v
                                                                                                 NO
                                                                                          rALL
                                                                                         •,  ADEQUATE? '
                                                                                                TYES
                                                                                          jFULL IMPLE- i

                                                                                          'MENTATION  |
                                                                                          i OF  NEW
                                                                                          .REGULATIONS
                                                                                              ~ 1 --- '
                                                                                                I
    Y
                                                  /   /

-------
                         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

-------
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

-------
             •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

-------
APPENDICES
    46

-------
                         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

-------
  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

-------
              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

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               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

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               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

-------
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

-------
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

-------
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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