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RESOURCE MANUAL
FOR IMPLEMENTING
THE NSPS CONTINUOUS
MONITORING REGULATIONS
Manual 2 -
Preliminary Activities
for Continuous Monitoring System
Certification
00
I
o £ u s ENVIRONMENTAL PROTECTION AGENCY
m *" OFFICE OF ENFORCEMENT
OFFICE OF GENERAL ENFORCEMENT
WASHINGTON, D.C. 20460
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EPA-340/1-78-005b
RESOURCE MANUAL FOR IMPLEMENTING
THE NSPS CONTINUOUS
MONITORING REGULATIONS
Manual 2 - Preliminary Activities
for Continuous Monitoring System
Certification
by
F. Jaye, J. Steiner, and R. Larkin
Acurex Corporation/Aerotherm Division
485 Clyde Avenue
Mountain View, CA 94042
Contract No. 68-01-3158
EPA Project Officer: Louis Paley
Division of Stationary Source Enforcement
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Research Triangle Park, North Carolina 27711
April 1978
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STATIONARY SOURCE ENFORCEMENT SERIES
The Stationary Source Enforcement series of reports is issued by the Office
of General Enforcement, Environmental Protection Agency, to assist the
Regional Offices in activities related to enforcement of implementation
plans, new source emission standards, and hazardous emission standards to
be developed under the Clean Air Act. Copies of Stationary Source
Enforcement reports are available - as supplies permit - from the U.S.
Environmental Protection Agency, Office of Administration, Library
Services, MD-35, Research Triangle Park, North Carolina 27711, or may be
obtained, for a nominal cost, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
REVIEW NOTICE
This report has been reviewed by the Division of Stationary Source
Enforcement and approved for publication. Approval does not signify
that the contents necessarily reflect the views and policies of the
Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for
use.
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TABLE OF CONTENTS
Section Page
A INTRODUCTION 2-1
B PRELIMINARY CONTINUOUS MONITOR PERFORMANCE EVALUATION
ACTIVITIES 2-1
1. Regulations 2-1
2. Source Installation of Continuous Monitors 2-3
C NOTIFICATION OF CONTINUOUS MONITOR SYSTEM PERFORMANCE
EVALUATION TESTS 2-4
D AGENCY OBSERVATIONS OF CONTINUOUS MONITOR SYSTEM
PERFORMANCE EVALUATION TESTS 2-5
1. Regulations 2-5
2. Important Parameter During Performance Tests .... 2-6
a. Location of the Monitor 2-6
b. Monitor Design and Operation 2-6
c. Design and Operation of Data Handling Systems. . 2-7
d. Calibrating the Monitoring System 2-7
e. Manual Source Testing Observations 2-9
3. Monitoring System Malfunction 2-11
4. Calibration and Zero Techniques 2-11
5. F Factor Determination 2-12
6. NO/NOX Ratio 2-13
7- Sulfuric Acid Plant Conversion Factor 2-15
E CONTINUOUS MONITOR REPORT AND RECORD KEEPING
REQUIREMENTS 2-15
F CHECKLISTS FOR EVALUATING THE INSTALLATION AND SYSTEM
PERFORMANCE EVALUATION TESTS 2-16
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A. INTRODUCTION
Manual 2, Preliminary Activities for Continuous Monitoring System
Certification, of the "Resource Manual for Implementing the NSPS Continuous
Monitoring Regulations," discusses the NSPS regulations pertaining to monitor
installation, agency notification requirements and performance test evalua-
tions. The text and the referenced checklist are intended to supplement the
actual performance specifications. The agency observer should pay particular
attention to Section D.2 which contains a wealth of practical information
regarding procedures and problems encountered during continuous monitor
performance evaluations.
Manual 2 is one of a series that comprise the "Resource Manual". The
other manuals are:
Manual 1 Source Selection and Location of Continuous Monitoring
Systems
Manual 3 Procedures for Agency Evaluation of Continuous Monitor Data
and Excess Emission Reports
Manual 4 Source Operating and Maintenance Procedures for Continuous
Monitoring Systems
B. PRELIMINARY CONTINUOUS MONITOR PERFORMANCE EVALUATION ACTIVITIES
1. Regulations
The NSPS do not require that a source involve or inform an agency
concerning any advance planning or installation of a monitoring system.
However, communication can take place, and it is very likely that the sources
will look to the local, state, or regional offices for assistance and advice
in planning their continuous monitoring system installations. Experience has
shown that early agency coordination.and involvement with a source concerning
monitors enhanced the likelihood that valid and timely data will be acquired
by the source. Therefore, within the limits of the law and your manpower and
resources, we encourage you to provide as much helpful support as you can
give the source in the planning phase.
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It would be extremely helpful, and could probably, save time and
money, if the agency were to contact sources subject to NSPS at the earliest
possible date and review a preperformance checklist such as the following:
• Are you familiar with the October 6, 1975, Federal Register?
• Have you ordered the proper span gases?
• Are the gases 50 percent and 90 percent of required full range?
• Is monitor location proper?
• Is there a provision for injecting span gas at the probe?
• Is analysis of span gases scheduled?
t For transmissometers, have bench-top tests been done or scheduled
by the vendor (if yes, get certification)
• If the monitor is already installed are readings accurate? What
problems, if any, have occurred and how have they been remedied?
• Has a detailed schedule for the week of the test been worked out?
For the most part, the average source will know little about monitoring,
and will welcome your advice and guidance. Typically, a source will ask which
monitoring system the Agency would approve for installation. The Agency
should not recommend a particular system, but should be aware of similar
sources that have installed continuous monitoring systems and suggest that
the source contact some of them. Where possible, the source should be
encouraged to find examples of reliable systems and examples of good perfor-
mance test results.
Secondly, an Agency should indicate to the source the level of
evaluation it plans to conduct on the monitoring system, so that the proper
facilities will be provided in the initial installation of the system.
Finally, the Agency should review the location the source has chosen for
installing the monitoring system. This would prevent installation of the
system in a nonrepresentative location. A friendly attitude toward information
exchange will help later in the implementing of a good monitoring system.
Rapport with the source will probably also provide the greatest impetus
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to good monitoring practice. It may be helpful to suggest well written
reports, since they will be most effective in communicating needs.
2. Source Installation of Continuous Monitors
Installing monitoring systems is generally the joint responsibility
of both the source and the equipment vendor. The source will provide the
representative location, mounting brackets, flanges, sampling ports, plumbing,
power, etc., according to vendor specification or blueprints. The source
or the vendor will then connect the monitoring system to the prepared
facilities. It is important to note that a transmissometer should be tested
prior to installation at the source (see Performance Specification 1). Also,
some sources will need to verify the absence of stratification.
NOTE
Section 60.13 (c)(2) states that owners or operators of
monitoring systems installed before October 6, 1975 are not
required to conduct the performance testing discussed in
this section. These exempted systems must be upgraded or
replaced and the new systems performance tested before
September 11, 1979.
Prior to performance testing, the continuous monitoring system must
complete 168 hours of continuous operation (referred to as the "conditioning
period") as required by Paragraph (b) of 60.13:
(b) All continuous monitoring systems and monitoring devices shall
be installed and operational prior to conducting performance tests under
Section 60.8. Verification of operational status shall, as a minimum, consist
of the following:
(1) For continuous monitoring systems references in Paragraph (c)(l)
of this section, completion of the conditioning period specified
by applicable requirements in Appendix B.
(2) For continuous monitoring systems references in Paragraph (c)(2)
of this section, completion of 7 days of operation. The require-
ment for, and duration of the conditioning period was selected
because:
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— Many field evaluation programs have shown that several common
failures occur during the first few days of operation. These
problems include improper installation, plumbing mistakes,
electrical failure, insufficient sample conditioning, unsus-
pected conditions in the effluent stream, normal equipment
or component failures, poor assembly line quality control, etc.
- Operating the monitor for 1 week will give the source
personnel some familiarity with the routine maintenance and
functioning of the system.
Experience has shown that if a system successfully completes this preliminary
week of uninterrupted operation, it is likely to operate successfully!during
the performance test period and thereafter, if maintained correctly.
Several operational parameters should also be quantified during this
period. These may include frequency of required window cleaning, filter
blowback, and some indication of expected zero and span drift. When the
conditioning period is completed, the continuous monitoring system is ready
for the operational test period and performance testing.
C. NOTIFICATION OF CONTINUOUS MONITOR SYSTEM PERFORMANCE EVALUATION TESTS
Paragraph 60.13 (b) states:
(b) All continuous monitoring systems and monitoring devices shall
be installed and operational prior to conducting performance tests ...
Paragraph (a)(5) of Section 60.7 requires that the source provide
30-days notice to the Administrator of their intent to conduct performance
tests on each monitoring system:
(a)(5) A notification of the date upon which demonstration of the
continuous monitoring system performance commences in accordance with
Section 60.13(c). Notification shall be postmarked not less than 30 days
prior to such date.
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D. AGENCY OBSERVATIONS OF CONTINUOUS MONITOR SYSTEM PERFORMANCE EVALUATION
TESTS
1. Regulations
The "as-installed" performance test is the first required interaction
between the agency and the source regarding the continuous monitoring system.
The majority of the testing requirements are clearly spelled out in the
regulations and the testing portion of the performance specifications. The
specific sections are as follows:
• Performance Specification 1: Opacity Monitors
• Performance Specification 2: S09, NO Monitors
fc. A
• Performance Specification 3: 02, C02 Monitors
Paragraph (c) of Section 60.13 requires that the appropriate monitoring
system performance tests be conducted during any source performance tests or
within 30-days thereafter.
(c) During any performance tests required under Section 60.8 or within
30-days thereafter and at such other times as may be required by the Adminis-
trator under Section 114 of the Act, the owner or operator of any affected
facility shall conduct continuous monitoring system performance evaluations
and furnish the Administrator within 60-days thereof, two, or upon request,
more copies of a written report of the results of such tests. These continuous
monitoring system performance evaluations shall be conducted in accordance with
the following specifications and procedures:
(1) Continuous monitoring systems listed within this paragraph except
as provided in Paragraph (c)(2) of this section shall be evaluated
in accordance with the requirements and procedures contained in
the applicable performance specification of Appendix B as follows:
(i) Continuous monitoring systems for measuring opacity of
emissions shall comply with Performance Specification 1
(ii) Continuous monitoring systems for measuring nitrogen oxides
emissions shall comply with Performance Specification 2
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(iii) Continuous monitoring systems for measuring sulfur dioxide
emissions shall comply with Performance Specification 2.
(iv) Continuous monitoring systems for measuring the oxygen
content or carbon dioxide content of effluent gases shall
comply with Performance Specification 3.
Since the performance tests are detailed and involve simple worksheets
for calculations, we will not discuss the testing routine. The following
subsections are oriented toward several items that should be observed and
ultimately become part of the file on a source. One purpose of these
observations is to provide a background file for future evaluations. Another
purpose is to appraise the overall operation of the monitoring system and the
variability of the measurements to provide some information for assessing this
source's monitoring records. If the source varies suddenly, the monitoring
system may have difficulty following process changes in routine practice,
even though it may pass the performance tests.
2. Important Parameters During Performance Tests
There are several important parameters that observers should note
during the performance test of a continuous monitoring system.
a. Location of the Monitor
An observer should first note the location of the monitor in the duct
or stack. He must decide whether or not the selected location meets the
installation criteria of the applicable performance specification (see
Section 4 of each performance specification) and whether or not a represen-
tative measurement will be made.
b. Monitor Design and Operation
A detailed flow chart of the continuous monitoring installation should
be obtained from the source (or should be prepared by the observer) so that
the observer is completely familiar with the individual components and
operations of the system (sample acquisition, calibration, back purge, etc.).
To insure that sufficient information is collected on the monitoring system,
the agency should obtain a copy of the manufacutrer's operating manual for
the particular type of monitor.
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c. Design and Operation of Data Handling Systems
The observers should also have an operating manual for any data
handling devices, particularly if complicated automatic data loggers are used.
This will help him determine if the source is obtaining sufficient data and
if the quarterly report format is correct. The inspector should check the
operation and setpoints of any alarm systems. During the performance testing,
the source's procedures for data reduction and completing quarterly reports
should be reviewed. In addition, a log should be available for operating
parameters, adjustments, maintenance, etc., to be used for preparing the
testing report.
«
d. Calibrating the Monitoring System
The ultimate accuracy of a monitoring system depends heavily on the
standards and techniques used for the calibration of the instrument. Three
calibration techniques are commonly used for gaseous emission monitors. The
first is used for extractive monitoring systems. Bottled supplies of
calibration gases with known compositions are used to calibrate the entire
monitoring system. The gas calibration is introduced near the inlet of the
sample probe so that any dilution or absorption of the gas by the plumbing
and conditioning systems prior to the gas analyzer can be detected. Section
60.13 Paragraph (d)(l) states that the manufacturer of zero and span gases
should certify that their products are traceable to the National Bureau of
Standards reference gases (if available). Note that the observer should
verify that the proper calibration gases are being used. In addition, the
source should then analyze the calibration gases in triplicate using the
applicable reference methods. The observers should obtain samples of the
calibration gases for analysis by agency personnel, or have the source use
calibration gases that have been certified by the agency.
EPA's Environmental Monitoring and Support Lab is currently working
with a calibration gas manufacturer and the National Bureau of Standards to
develop traceability procedures and requirements for these calibration gases.
2-7
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Nonextractive or in situ monitoring systems are typically calibrated
in place by inserting certified gas cells or test cells, which are functionally
equivalent to known gas concentrations, into the optical path (see Section
60.13, Paragraph (d)(2)). This test cell insertion should cause a known
upscale indication on the data output device. The observer can request a
copy of the procedure used to certify the concentration of gas in the sealed
cell. He may also request that the cell be sent to the agency for certifica-
tion. Finally, the observer may provide the source with a test cell that
has been certified by the Agency. Implementation of this procedure will
depend on the resources, facilities, and technical expertise of the Agency
personnel. Since the calibration must be done at least once each 24-hour
period, the procedure should be made simple and fast. If possible, the pro-
cedure should be built into the equipment, so that it is automatic. A lab
and field evaluation of an in situ S0? monitor (EPA Report 650/2-75-053a)
reported that the optical alignment of the instrument was affected by the
chassis latch bolt tension. If the daily calibration procedure requires
removing the chassis covers to manually insert a cell, the effect of these
manipulations on alignment should be considered. This type of problem should
be noted in the data file to alert the next observer to check on this inform-
ally during subsequent inspections. As we will point out several times in
this section, the observations you make and the notes you take during
performance testing will be the primary source of information for the next
observer.
Section 60.13, Paragraph (d)(3) explains the calibration requirements
for opacity monitors. An opacity monitor is usually calibrated using certified
neutral density filters. These filters look like a greyish piece of exposed
film and absorb light at a wide wavelength band that is equivalent to a
fixed opacity. They may be inserted into the monitoring system either by
hand or automatically. The observer should obtain a copy of the filter
certification procedure or request the source to send the filters, prior to
use, to the Agency for an independent check using a well-collimated, photopic
transmissometer of known linearity. The observer may also provide the
source with an Agency-certified set of filters. The inspector should verify
that the filters are large enough to attenuate the entire light beam of the
2-8
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transmissometer. Again, any pertinent observations regarding the time
required and difficulty associated with using these filters should be record-
ed by the inspector.
The time stability of these filters is quite good if they are not
grossly mishandled, scratched, or exposed to chemicals when evaluating
calibration, span, zero, and general monitor performance. Be sure to
consider the entire system, including data handling equipment over the same
averaging time period required by the standard (i.e., a 6-minute average for
opacity).
e. Manual Source Testing Observations
The gaseous pollutant continuous monitoring system must be checked
against the applicable reference method. The observer should inspect the
manual sampling train to insure that it meets the specifications of the
reference method (heated probe, proper number of impingers, proper absorption
solutions, etc.). Secondly, the observer should verify that components, such
as the dry gas meter in the S02 train, have been properly calibrated. Thirdly,
the sampling train should be checked for leaks before the test. For extrac-
tive monitoring systems, the probe tip of the manual sampling train should
be adjacent to the monitoring system's probe tip. Multipoint extractive
systems will require manual traverses to points adjacent to each probe inlet
using the reference method. Since in situ monitoring systems give an inte-
grated rating of the concentration across the duct or stack, the manual train
also must traverse the duct or stack in the same direction to obtain an
integrated concentration. Care must be taken not to insert the probe of the
manual train into the light beam. At the conclusion of the reference test,
the observer may request that a portion of the collected sample be sent to
the agency for independent analysis. The sample and averaging periods for
the reference tests and continuous .monitors should be identical. It is
important to note that if the bases for the continuous monitoring system
and the reference method are not the same, then a moisture correction factor
must be applied to either the monitoring system data or the reference method
data. The moisture correction factor must be determined by conducting
moisture tests concurrent with the reference method testing period. Finally,
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certain sources (fossil fuel-fired steam generators, sulfuric acid plants,
nitric acid plants) require additional measurements during the reference
method tests to convert the continuous monitoring data to units of the stan-
dard. The observer should become familiar with these meathods (e.g., the
Reich test) as well as the reference methods. Generally speaking, the most
important point to watch for is that the manual reference tests and the
analyzer tests are done over identical time periods with the two probe tips
near each other.
During performance testing, the meaning of relative accuracy and
calibration error can be confused. The observer should be aware of the
difference and check the source's technique for computing these values. The
calibration error of extractive monitors is computed by comparing measure-
ments of calibration gas concentrations to the actual calibration gas
concentrations. With nonextractive monitors (in situ), the measurement is
determined by comparing the calibration measurements to the actual concen-
tration values of calibration gas cells. NSPS Performance Specification 2
requires the source to:
Report the calibration error (the sum of the absolute value of the
mean difference and the 95-percent confidence interval) as a percent-
age of each respective calibration gas concentration. In equation
form:
Calibration error = Mean [Differencel + 95% C.I. ,QO
Average Calibration Gas Concentration
The relative error compares the analyzer's measurement of the source's
stack gas concentrations to the concentrations measured by the applicable
EAR Reference Method (either Method 6 or 7). NSPS Performance Specification 2
requires the source to report relative accuracy:
... as-the sum of the absolute value of the mean difference and the
95-percent confidence interval of the difference expressed as a per-
centage of the mean reference method value. In equation form:
Accuracv = Mean of the |difference! + 95% C.I. ,nn
m^urdcy reference method value x IUU
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3. Monitoring System Malfunctions
The conditioning period occurs before the performance test so that any
installation or design errors can be identified and fixed. Several weeks of
operation before the performance test will minimize failures. The ability of
source personnel to recognize, diagnose, and fix these failures gives some
indication of their attitude and proficiency with regard to continuous
monitoring. This is a very important observation that the observer should
record in the source file.
The failures that would probably occur during these tests are
associated with plugging particulate filters on extractive probes (inadequate
purge cycle), window cleaning for opacity or in situ monitors (poor purge
blowers or installation), excessive zero drift due to voltage fluctuations
or temperature variations, calibration drift because of the chemical or
physical degradation of the sensor element, and monitor misalignment due to
vibration or poor installation.
To the Agency, the most important aspect of a failure during perform-
ance testing is how it is identified and fixed. If the vendor representative
is the only person who knows that the system has failed, then (at least
initially) the monitoring system may not be attended to effectively when
the representative leaves. If it is a subtle failure and the operating
personnel identify it or are interested in the diagnosis and correction,
the system will probably live a long and successful life, experience
very little downtime, and produce meaningful data.
4. Calibration and Zero Techniques
An important observation during performance testing involves the
complexity of the zero and calibration procedures. In most sources, the care
and maintenance of the monitoring system will ultimately fall upon one or
more of the plant maintenance technicians. If the source is large enough,
these technicians may be electricians or mechanics. At other sources,
however, skilled personnel may not be available. If the calibration or zero
sequence is more complex than turning a valve or two, actuating a switch, or
turning a knob until a zero or span reading matches a preset value, it
probably cannot be routinely accomplished at a plant that does not have
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skilled personnel available. It should be noted whether adjustments,
including zero and calibration, are made by source personnel or by the vendor
representative. The vendor representative can probably make the adjustments
quickly and efficiently — thus increasing the probability that the equipment
will meet specifications. However, the reliability of the routine monitoring
data will depend on whether the source personnel can do it on a daily basis.
The most critical item is whether the procedure is well defined and simple
enough for a person with normal plant maintenance skills to accomplish
routinely. It is important that the person who follows the maintenance
directions can perform the calibration correctly.
Each source is likely to have a senior engineer responsible for
communicating emission information to the Agency. The more this individual
knows and cares about the monitoring system, the more reliable the data is
likely to be. This individual's involvement with the monitoring system
should be noted by the observer. Finally, any potential problems, "tricks",
etc., that are part of the procedure should be noted for information and
checkup on future evaluations.
5. F Factor Determination
The F factor was developed by EPA to eliminate the need for measuring
effluent volumetric flowrate and heat input rate at fossil fuel-fired steam
generators. Simply stated, the F factor is the ratio of the volume of dry
flue gases generated to the calorific value of the fuel combusted. Section
60.45, Paragraph (f)(4) describes the ASTM methods and formulas used to
determine the F factor for a specific fuel. EPA has calculated F factors
for various fossil fuels and found that they vary by no more than +3 percent
within a given fuel category and, hence, can be considered a constant.
Section 60.45, Paragraph (f)(6) lists F factors for various types of fossil
fuels. The source has the option to calculate an F factor or use the F
factor calculated by EPA. Section 60.46, Paragraph (f)(3)(i) and (ii)
describes how the Op sample should be taken.
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The F factor is the ratio of the volume of carbon dioxide generated
c
to the calorific value of the fuel combusted. The F factor can be used in
t*
place of the F factor if a source feels it is more convenient to measure
C02 rather than 02- The advantage of this method is that the emission
ratio may be determined from wet basis concentration measurements without
recalculation of the F factor.
c
It sho-uld be noted that, without exception, when a C02 monitor is
installed after a limestone scrubber, the F factor should be increased by
L*
1 percent. The correction factor counteracts the negative bias in pollutant
emission (E) caused by C02 production in a limestone scrubber. The percent
correction corresponds to the "extreme case" of C0? production.
As with the F factor, the EPA has determined that for a given fuel
category the FC factor varies by no more than ±5.9 percent and hence can be
considered a constant. Of course, the source has the choice of using either
the EPA published FC factor or a factor derived from their particular fuel.
The regulations do not specify the number of times the F factor or
F factor should be determined. The frequency may be specified at a later
\+
date during the proposed studies on fuel sulfur analysis. ' In the absence
of further information, the factors should be determined at least once a day
during the performance testing period.
It is important to note that when a source fires combinations of
fossil fuels, the consumption of each fuel should be measured during each
testing period. Measurement methods must be confirmed by a material balance
over the steam generation system. The F or F factor must be approved by the
\f
administrator when fossil and nonfossil fuels are fired.
6. NO/NO.. Ratio
A
Most gaseous emissions that are monitored are single compounds, such
as S02, CO, C02, and 02> so the monitoring euqipment can be straightforward.
The NO monitoring requirements differ, on a source-by-source basis, according
X
to the varying ratios of NO to N02 in each source class. Nitrogen is a
multivalent compound and may form several oxides. Of the oxides, nitrogen
dioxide (N02) and nitric oxide (NO) are considered to be harmful air pollutants
2-13
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and are controlled under NSPS. Section 60,45(c) requires fossil fuel steam
generators to monitor the NO (NO + NO,,) emissions, which are mostly nitric
At
oxide (NO), with N02 being from 1 to 5 percent of the total. For these
sources, NO is the specified calibration and test gas. The preamble to the
regulations in the October 6, 1975 Federal register states that sources
might monitor only NO and apply a correction factor to all later data to
adjust for the small N02 content. Comments made to the administrator pointed
out that NO-only systems were less expensive than N0/N02 monitoring systems.
Such systems would still be subject to the ±20-percent relative accuracy
requirement of Performance Specification 2. However, the data reported
could be multiplied by a correction factor determined by the performance
tests (e.g., 1.03 x NO = NOY) to yield the emission values. This discussion
A
is found in 40FR46253 and is not found anywhere in the regulations or the
Performance Specifications.
EPA's field experience with most steam generation has shown that the
N0/N02 ratios stay relatively constant during periods of steady operation
with a particular fuel. The coal burners tend to produce higher absolute
levels of NO, with the N02 remaining at about 3 percent of the total. Gas
fired units generally produce lower total levels, with as high as 8-percent
N02 being measured occasionally. This ratio of NO to N02 can be affected
by various parameters, such as excess air and plant load. However, even at
extremes, the ratio does not change more than 50-percent within a given
facility. (A plant with a nominal 3-percent N02 content may vary from 1.5
to 4.5 percent of the total NO .)
A
The situation is reversed for nitric acid facilities. In an uncon-
trolled source the major emission is N02 (representing unabsorbed acid).
Newer plants use hydrogen or ammonia to reduce the actual NO emission level.
A
Depending on control system operation and stability, the resultant emissions
can range from mostly NO to mostly N02 with traces of ammonia. Since the
major emission is N02 Section 60.73 requires that the calibration gas used
for the monitoring system be nitrogen dioxide (N0?).
The correction factor shall be calculated by dividing the reference
method test data averages by the monitoring data averages to obtain a ratio
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expressed in units of the applicable standard. This ratio, or correction
factor, shall be recalculated when any source performance testing is done.
7. Sulfuric Acid Plant Conversion Factor
Section 60.84, Paragraph (b) defines the conversion factor to be used
to convert the continuous monitoring system data to the units of the appli-
cable standard. To calculate this conversion factor, the inlet S02 concen-
tration to the converter must be determined using methods such as the Reich
test at least three times per day. For plants that use air injection to
cool the gases between passes through different stages of the converter,
appropriate corrections must be made, subject to the Administrator's approval.
The Reich test is a simple wet chemical test similar to the Orsat
test for C02, 02» and CO. A known volume of gas from the inlet to the
converter is withdrawn into a burette. The S02 in the gas is then passed
through 0.1 N iodine solution, which absorbs the SOp. The volume of S02
absorbed is measured and the concentration of S02 is calculated. To insure
that the tests are being performed correctly, the observer should become
familiar with the methods used to measure the inlet S02 concentration.
E. CONTINUOUS MONITOR REPORT AND RECORD KEEPING REQUIREMENTS
Paragraph (c) of Section 60.13 requires that the owner or operator of
a source shall provide the Administrator with two (or more if requested)
copies of a written report covering the monitoring system performance
evaluations within 60 days of completing the tests. The requirements for
this report are not specified, but the report should include the following
information to show compliance with the performance specifications:
t Data worksheets, as shown in the performance applications
(including sample calculations)
• Worksheets from the reference method tests conducted for comparison
(including sample calculations)
• Any required notations or records, such as records of maintenance,
adjustments, failures, etc., of the monitoring system during the
test period
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• The factor used to convert the measured emissions to the units
of the applicable standard (including sample calculations)
• Plant production rate during the testing period
• A narrative of the entire testing period (including equipment
and procedures used), which should give a reader a good under-
standing of the entire test as it actually occurred
t Certification or calibration records of span and calibration
gases, test equipment, etc.
All this data should become part of the monitoring file for each
source, and should be available for the observer to review before his next
visit to that source.
More specific details on the monitor reporting requirements are given
in Section 9 of Performance Specification 1 and Section 7 of Performance
Specifications 2 and 3.
F. CHECKLISTS FOR EVALUATING THE INSTALLATION AND SYSTEM PERFORMANCE
EVALUATION TESTS
This section contains a checklist to be used as an aid to the Agency
observer when evaluating a source's continuous monitor certification program.
Each question in the checklist has been referenced to the appropriate part
of the Manual text.
Subsection
a. Installation References Yes No NA Notes
• See Section II, monitor -
location checklist
• Was the system installed B.2
prior to October 6, 1975?
If so, the source is ex-
empted from this section
until upgraded or replaced
before September 11, 1979.
2-16
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Subsection
b. Notification References Yes No NA Notes
• Is the performance testing C.
scheduled at least 30 days
after the notification?
• Has the 168-hour condition- C.
ing period been success-
fully completed?
• What problems were noted C.
during the preliminary
period and how were they
fixed?
c. Performance Testing
• Were the required EPA D.2.e
reference method tests
carried out according to
good sampling practice
and procedure?
• Were the zero and span D.4
adjustments made on the
monitoring system in
accordance with the
manufacturer's or source's
written procedures?
• Did the source or the D.2.d
system vendor make the
required adjustments?
• Were the calibration D.Z.d
i '*'•'
materials current and
properly documented or
certified?
2-17
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Subsection
References Yes No NA Notes
Were the calibration D,2.d
materials analyzed,
certified, or traceable
to NBS?
Were tests made to deter- D,2.a
mine whether the monitor
location is correct
stratification, etc.?
Is a functional system
diagram available for
both the monitor and data
handling subsystem?
Is the monitor in a stack D.2.a
or duct?
How difficult is the D.4
zero or calibration
procedure?
Can the source personnel D.4
conduct these procedures?
Were there any alignment D.3
or adjustment problems
during the testing?
Were malfunctions iden- D.3
tified quickly and fixed?
How does the source D.5
determine its "F" factor?
Does the source (if D.6
necessary) monitor total
NOX or use a N0/N02 ratio
in converting data? How
is this ratio determined?
2-18
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Subsection
References Yes No NA Notes
How were the nitric acid D,7
and sulfurtc acid plant
conversion factors
computed?
Are all operating para- D,8
meters, adjustments,
source operations, main-
tenance, etc. recorded
in a log to be used to
prepare the testing
report?
Is the procedure for data D.8
reduction and quarterly
reports established?
If automated, is software D.8
documentation included?
Can the report format be D.8
interpreted easily?
Who reviews and is respon- D.8
sible for submitting the
report?
Does the source know when D.8
and where to send the
report?
2-19
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT N
PORT NO.
40/1-78-005 b
2.
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Resource Manual for Implementing the NSPS Continuous
Monitoring Regulations. Manual 2 - Preliminary
Activities for Continuous Monitoring System
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
F. Jaye, J. Steiner, R. Larkin
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Acurex Corporation/Aerotherm Division
485 Clyde Avenue
Mountain View, CA 94042
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-3158
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
EPA Office of Enforcement
Division of Stationary Source Enforcement
Washington, D.C. 20460
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Manual 2 - Preliminary Activities for Continuous Monitoring Systems Certification -
is one of a series of four manuals that comprise the "Resource Manual for Im-
plementing the NSPS Continuous Monitoring Regulations." The other manuals are:
Manual I - Source Selection and Location of Continuous Monitoring Systems
Manual 3 - Procedures for Agency Evaluation of Continuous Monitor Data and
Excess Emission Reports
Manual 4 - Source Operating and Maintenance Procedures for Continuous
Monitoring Systems
Manual 2 discusses the NSPS regulations pertaining to monitor installations, agency
notification requirements and performance test evaluations. The text and re-
ferenced checklists are intended to supplement the actual performance specifications.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Stationary Source
Continuous Emission Monitoring
New Source Performance Standards
Continuous Emission
Monitoring
13 B
14 D
13. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (This Report)'
Unclassified
20. SECURITY CLASS (Thispage)
Unclassified
21. NO. OF PAGES
19
22. PRICE
EPA Form 2220-1 (9-73)
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