8 RESOURCE MANUAL
« FOR IMPLEMENTING
THE NSPS CONTINUOUS
S MONITORING REGULATIONS
c Manual 3 - Procedures for Agency
« Evaluation of Continuous Monitor Data
8 and Excess Emission Reports
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fe U.S. ENVIRONMENTAL PROTECTION AGENCY
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OFFICE OF ENFORCEMENT
OFFICE OF GENERAL ENFORCEMENT
< WASHINGTON, D.C. 20460
-------
EPA-340/1-78-005C
April 1978
RESOURCE MANUAL FOR IMPLEMENTING
THE NSPS CONTINUOUS
MONITORING REGULATIONS
Manual 3 - Procedures for Agency
Evaluation of Continuous Monitor Data
and Excess Emission Reports
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
tu
Division of Stationary Enforcement
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Research Triangle Park, North Carolina 27711
April 1978
-------
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.
ii
-------
TABLE OF CONTENTS
Section Page
A INTRODUCTION 3-1
B REGULATIONS 3-1
C DATA CONVERSION TO UNITS OF STANDARDS 3-4
1. Gaseous Pollutants for Fossil Fuel Steam
Generators 3-4
2. Gaseous Emissions for Nitric Acid Facilities .... 3-9
3. Gaseous Emissions for Sulfuric Acid Plants 3-10
D EVALUATION OF QUARTERLY EXCESS EMISSION REPORTS .... 3-10
Attachment 1 3-27
Attachment 2 3-29
Attachment 3 3-33
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A. INTRODUCTION
Manual 3, Procedures for Agency Evaluation of Continuous Monitor Data
and Excess Emission Reports, of the "Resource Manual for Implementing the
NSPS Continuous Monitoring Regulations" presents the NSPS regulations for
data and reporting requirements for affected sources. The Manual also
discusses the use of various factors in converting data to the units of the
standards as they apply to three specific source categories, fossil fuel-
fired steam generators, nitric acid facilities and sulfuric acid plants.
One section of this Manual which agency personnel should find very beneficial
in Section D, Evaluation of Quarterly Excess Emission Reports. Hypothetical
and actual examples are used to illustrate what must be reported and how to
evaluate the contents of the reports.
Manual 3 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 2 Preliminary Continuous Monitoring System Certification
Activities (Installation, Notification and Performance
Evaluations)
Manual 4 Source Operating and Maintenance Procedures for Continuous
Monitoring Systems
B. REGULATIONS
The data and report requirements placed upon the source are detailed
in Part 60.7(b) and (c) of the New Source Performance Standards.
Records must be kept for 2 years for:
• ...any periods during which a continuous monitoring system or
monitoring device is inoperative...
t ...including continuous monitoring system, monitoring device and
performance testing measurements; all continuous monitoring
system performance evaluations...
3-1
-------
• ...all continuous monitoring system or monitoring system calibration
checks...
• ...adjustments and maintenance performed on these systems or
devices...
• ...and all other information required by this part recorded in
a permanent form suitable for inspection...
This portion of 60.7(d) appears to be all-inclusive. However, there
are several important limitations to keep in mind during evaluations or
other contacts with the source.
Although there is no specific requirement on the timeliness or avail-
ability of data, a source must have the data in a "form suitable for inspec-
tion." A source is only required to convert strip charts or other records
to the applicable averages (in the case of excess emissions, to units of the
standard). Therefore, data needs to be inspected and converted only in
conjunction with the filing of the quarterly report. A series of strip
chart records from various monitors would almost certainly be a "permanent
form suitable for inspection," although from these records alone (without
supporting data), the inspector probably could not tell whether the source
was operating within limits. On the other hand, a magnetic tape record
would generally not be considered a "form suitable for inspection."
Second, the regulations do not require the source to maintain a read-
out device that is visible to the operator or the operator to use the
monitoring system output directly to control the source. Neither realtime
nor explicit use of monitoring data is required of the source at any time.
However, since the monitoring system data will be used to determine whether
the source is properly operating and maintaining its control equipment, it
is to the source's advantage to make use of the realtime information available.
In addition, although realtime attention is not specifically required
of the source, the source must be able to identify the deviation, magnitude,
cause, and corrective action taken for all periods of excess emissions. In
order to comply with these requirements, the source must have a procedure for
keeping this information.
3-2
-------
The following data should be available to the inspector on short
notice:
t The daily zero and calibration check and adjustment log
• The monitor's maintenance log, containing the time and date of
any malfunctions, the nature of the repair, and the time and date
of return to service
• Source operating logs containing sufficient operating information
to identify startups, shutdowns and malfunctions that might explain
excess emissions, the nature and cause of these malfunctions, and
the corrective action or preventive measures taken
• A copy of the most recent report, along with the original data
records covering the reporting period
In summary a good set of records will contain the following:
t The raw data output.(i.e., strip chart) (although not required)
including:
- A record of stack S0«/N0 ppm or opacity versus time, normal and
b> /\
abnormal operation (unless the monitor is shut off)
— A record of calibrations
— A record of malfunctions in the monitoring system in the
form of instrument response
• Handwritten records, consisting of:
- Any notes on the charts
- Notebook-type records of troubleshooting, maintenance and
adjustments
• Any emission test reports and monitor performance test reports
All other information, reports, statistical calculations, averages,
etc., is derived from these records.
3-3
-------
A source is required to file a quarterly report of excess emissions,
monitoring system maintenance, or a negative report covering these items
(see list of Quarterly Excess Emissions report requirements on page 4-16).
C. DATA CONVERSION TO UNITS OF STANDARDS
Conversion of monitoring data to the applicable units of the standard
is, for most sources, straightforward. However, for fossil fuel-fired steam
generators, nitric acid plants and sulfuric acid plants certain factors are
required in the data conversion.
1. Gaseous Pollutants for Fossil Fuel-Fired Steam Generators
Under Part 60.45, the operator of a fossil fuel burning steam generator
has the option to measure either oxygen or carbon dioxide to correct for the
effects of variable amounts of excess air in the effluent.
Because of recent NSPS revisions and approval of alternate monitoring
requirements (42FR5936 and 41FR44838, respectively), it is acceptable for
fossil fuel steam generators monitoring gaseous pollutants to:
• Measure C02 after a flue gas desulfurization device if used.
However, since reactions produce COp in limestone scrubbing, a
1-percent increase in the FC factor is required when this type of
FGD device is used.
t Measure the pollutant and diluent 02 on a consistent, wet or dry
basis
An instantaneous monitoring system gas concentration can be con-
verted to units of the standard in three steps. First, the output of the
monitoring system is converted from watts or milliamperes into concentration
(ppm, percent) using a prepared chart (Figure 3-1) or a calculation formula.
The concentration then is multiplied by a unit conversion factor and the
molecular weight to convert the ppm concentration to Ib/dry scf or to gm/dry
scm. The conversion factor is 2.59 x 10~5 x M for gm/dscm. The molecular
weight (M) are 64.07 for S02 and 46.01 for NOX (calculated as N02).
3-4
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5000
4000
3000
CO
en
2000
vS
1000
0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1.0
Figure 3-1. Typical continuous analyzer calibration chart.
-------
Three formulas are used for diluent correction: one based on 02 dry,
one based on CL wet, and one based on C02- If the source operator chooses
to monitor on a dry 02 basis, both the 02 and S02/NOX must be measured with
the monitoring system removing the moisture from the sample stream. The
emission calculation formula is
E - CF 20'9
20.9 - %Q2
(where C is the concentration of NO or S0? calculated in gm/dscm (Ib/dscf),
X L-
as shown above, and F is a factor which relates the volume of flue gas to the
heat input of fuel.) The F factor is computed according to the type of fuel
burned. The source has the option of using "standard" F factor values
(prescribed in the regulation) or computing their own factors based on actual
chemical and physical analysis of each lot of coal.
To compute F on actual coal analysis, the formula is:
(Metric) F = 227.(%H) + 95.7 (%C) + 35.4 (%S) + 8.6(%N) - 28.5(%0)
GCV
where the GCV is the gross calorific value in calories/gram.
(English) F = 106[3-64(%H) + 1.53(%C) + 0.57US) + 0.14(%N) - Q.46 (%0)]
GCF
where GCV is in Btu/lb.
If the source operator chooses to monitor on a wet basis, both the
02 and pollutant must be measured without removing water from the gas stream.
In this case, the emission calculation formula is
20.9
E " Cws Fw 2079~1
(where C is the pollutant concentration at stack conditions and F is a
factor representing a ratio of the volume of wet flue gases generated to the
caloric value of the fuel combusted.) Here too, the source may use EPA
calculated F factors or calculate a factor based on the actual fuel used.
W
3-6
-------
To compute F using the actual fuel, the formula is
W
(Metric) F = 347.4%H + 95.7%C + 35.4%S + 8,6%N - 28.5%0 + 13.4% H-P1
V ; w —.-
_ 106[5.56%H + 1.53%C + 0.57%S + 0.14%N - 0.46%0 + 0.21%
- _
w
W
If the source operator chooses to monitor carbon dioxide instead of
oxygen to determine excess air, the emission calculation formula becomes:
F- TF 10°
L ~ Ll"c %C02
C is defined as for the previous emission computation. Fp may be
obtained from standard EPA values for the appropriate fuel or computed based
on the actual chemical and physical analysis of each lot of coal:
(Metric units - dry basis only) FC =
(English units - dry basis only) FC = 321
Table 3-1 summarizes all F, FQ, and F.. factors determined by EPA to
c W
be representative of specific fuel types. Again, the source operator may
use these values or calculate factors for his particular fuel.
If the procedure based on C02 is used, the S02 (or NOX) and the C02
must be measured consistently (either wet or dry). In other words, both the
pollutant and the C02 may be measured by an extractive monitoring system
which removes the water vapor before both gases are measured (dry) or both
gases may be measured either in situ or extract! vely without removing the
water vapor (wet). The source may not measure one gas wet and the other dry.
The source should be asked which derivation of the F, F- or F value
is used for emission calculation. If the source calculates the factor from
chemical analysis, he should have written procedures for determining which
lot of coal is used at a given time, how the lots of coal are separated, and
how to use the lot analysis results to compute F, FC, or FW> It would be
useful to compare two or three coal analyses to determine the lot-to-lot
term may be omitted if %H + %02 includes the unavailable hydrogen
and oxygen in the form of water.
3-7
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TABLE 3-1. F, FC, and FW FACTORS FOR FOSSIL FUELS
Type of Fuel
Standard
F
(Measuring
dscf/
MBtu
Anthracite 10140
Bituminous 9820
Subbituminous 9320
Liquid 9220
Natural gas 8740
Propane 8740
Butane 8740
o2)
dscm/
Meal
1.
1.
1.
1.
0.
0.
0.
139
103
103
036
982
982
982
Fc
(Measuring
dscf/
MBtu
1980
1810
1810
1430
1040
1200
1260
Values
co2)
dscf/
Meal
0.
0.
0.
0.
0.
0.
0.
222
203
203
161
117
135
142
FW
(Measuring C
v/scf/
MBtu
10580
10680
10680
10360
10650
10240
10430
2 Wet)
wscm/
Meal
1
1
1
1
1
1
1
.188
.200
.200
.164
.196
.150
.172
3-8
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variability, and then to calculate the effect that these variations have
on the F, Fp, and F factors and the emission calculation.
In most sources, the actual NOV emission is a combination of nitric
A
oxide (NO) and nitrogen dioxide (N02). In a power plant, for example, the
emission may be 95-percent NO and 5-percent N02< NO and N02 are best measured
by different means. Consequently, EPA states in the preamble to the October
6, 1975 amendment to the New Source Performance Standards that the source
may determine the ratio of N02 to NO in the flue gases and then use a factor
to adjust the continuous monitoring system emission data. The data can be
adjusted if the factor is applied consistently to all data generated by the
monitoring system thereafter.
Steam generators that emit NO levels that are 30-percent or more
A
below the standard during performance testing are not required to monitor
N°x
2. Gaseous Emissions for Nitric Acid Facilities
Unlike steam generators, nitric acid facilities have no standard F
factors for translating concentrations into emission units. Part 60 (60.73)
requires the emissions to be calculated for 3-hour averages made up of 1-hour
averages calculated according to 60.13 (h).
During the performance testing of the monitoring system, or any
subsequent source performance testing, the monitoring system should be
operated concurrently with the reference method. After each set of data is
validated and computed on a time comparable basis, the reference method
readings are divided by the monitoring system readings to produce a ratio of
volumetric ppm concentrations and the corresponding emission rate in kg/ton
of nitric acid produced.
In a nitric acid plant without a decolorizer or "abater," the emission
can be 90 to 95 percent N02 with the remainder NO. With a decolorizer or
"abater," the ratio can vary from 90-percent N02 to 90 percent NO. Therefore
since nitric acid plants are unable to meet the 10-percent N02 limitation,
they are exempt from using the NOY factor to adjust the continuous monitoring
* A
system emission data.
3-9
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3. Gaseous Emissions for Sulfuric Acid Plants
The conversion factor for sulfuric acid plants is computed by deter-
mining the sulfur dioxide input to the converter once each 8-hour shift.
The operator should record the volume percentage of S02 emitted, as indicated
by the monitoring system. The conversion factor is given by:
PP - u 1.000 - O.OlSr
Ll" K r - s
where CF = measured conversion factor (kg/metric ton per ppm, Ib/short ton
per ppm)
k = 0.0653 for metric units (kg/metric ton/ppm) or 0.1306 for English
units (Ib/short ton/ppm)
r = volume percentage of S02 input to the converter (appropriate
corrections for air injection plants) as measured with the Reich
test or other suitable method
s = volume (as measured with the CM) percentage of S0? in the exhaust
gas during the determination of r
This factor is used to compute the emission averages:
E = CF x ppm S02 (in-stack as indicated by monitoring system)
Again, consistent inspection of the records will show whether the data are
valid. By comparing the records of CF, r, and s for several days or weeks,
any major deviations from approximate average values should be accounted for.
Since most plants are built to operate most efficiently over small ranges of
conditions, deviations of 10 to 20 percent or more should be matched by
varying input feedstocks or products or some other substantive change in
physical plant operation. Large changes in any of the measured values with-
out corresponding changes in by-process parameter may indicate sloppy testing,
a poor attitude, or faulty equipment. All of these possibilities should be
investigated and the problem corrected as soon as possible.
D. EVALUATION OF QUARTERLY EXCESS EMISSION REPORTS
Quarterly Excess Emissions Reports are not an end in themselves. To
be useful, the information they contain must be accurately interpreted. This
3-10
-------
section lists the information required in a quarterly report, describes the
summary reports from which this information is derived, and discusses how to
review a quarterly report. To aid the observer in evaluating reports, a
short checklist of direct questions is included. The answers to these
questions will help to identify malfunctions in monitoring or control equip-
ment or inaccuracies in reports. To illustrate the use of the checklist,
three examples of typical reports are reviewed. Omissions — both accidental
and purposeful — are pointed out, and specific corrective actions are
suggested.
What Must be Reported
Any facility owner or operator required by the New Source Performance
Standards to install, operate, and maintain a continuous emissions monitoring
system is required to file a Quarterly Excess Emissions Report within 30
days of each calendar quarter. The report must contain the following
information:
• The magnitude of excess emissions (as defined in applicable
subparts)
t Conversion factors used in calculations
• The date and time of commencement and duration of each excess
emission
• Identification of excess emissions that occur during periods of
startups, shutdowns, and malfunctions of the affected facility
• The nature and course of any malfunction (if known)
• The corrective action taken or preventative measures adopted
t Dates and times that the continuous monitoring system was
inoperative (except for zero and span checks)
• Repairs and adjustments (including zero and span) made to the
monitoring system
• A report (if applicable) that no excess emissions have occurred,
and that the monitoring system has been 100-percent operative
and has not been repaired or adjusted
3-11
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Often, the data required to report this information are recorded
manually by an operator at the source. However, many sources use automated
data systems to record the output of their continuous monitors. Table 3-2
shows a typed hourly report generated by one of these systems. This part-
icular facility is a coal fired power plant monitoring opacity, sulfur
dioxide, nitric oxide, and oxygen. The report indicates the 6-minute
opacity measurements and show three periods when the monitor was apparently
out of service (the three periods indicated as "ND" -- no data). The average
indicated readings are corrected for zero and span offsets. This particular
source has facilities to determine stack gas velocity and, thus, flowrate.
By using the flowrate, the oxygen content, and the "F" factor for coal, the
data system calculates the heat input rate as 1275.8 million Btu/hr. The
S02 emission rate is calculated at 2.7 Ib/MBtu, which exceeds the standard
and is flagged with asterisks. The data percentage indicates the percentage
of operating time during which the monitoring system collected data. This
"emissions summary report," while answering some of the reporting require-
ments, must be accompanied by text which answers other questions, such as,
what corrective action was taken for the excess emissions?
Table 3-3 shows a daily summary of emissions compiled from hourly
reports like that in Table 3-2. Notice that only excess emissions and their
duration are shown. For example, between noon and 3 p.m., two 6-minute
opacity averages exceeded the limit and the average opacity during those two
periods was 23.4 percent. During the same period, the SCL emissions were
also high (1.65 Ib/MMBtu) and the NO emissions were 0.84 l./MBtu. At the
bottom of the report, excess emissions for the day are averaged and the
emissions limit for the source is recorded. In this case, the source has
exceeded its limit.
Table 3-4 shows a weekly summary report. The data represents an
adequate reporting of the magnitude and duration of excess emissions as
required by the regulations. However, such automatic summaries are not the
complete picture in themselves. The source must also report malfunctions
and adjustments made to the continuous monitoring system.
3-12
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TABLE 3-2. EMISSIONS SUMMARY REPORT
Hourly Report
06/19/77
Opacity, %
6 min Avgs.
Hourly Avg.
Indicated
Zero Cal
Span Cal
Corrected
Ib/MBtu
Ib/hr
Data %
Q SCFM 10E8
481.40
Heat-MBtu/hr
1275.8
16.699
2.1972
OPAC
17J38*
49.975
2.7959
—
—
70.
V-IND
38.741
2.1972 2.1972
2.1972 ND*
so2
767.35
56.396
1289.7
788.20
2.7189
3.4697
100.
V-AVG DIA-FT
45.157 20.
Time:
2.1972
ND*
NO
539.13
78.369*
1116.
510.82
0.8216*
1.0542
100.
Plant #4
0900-1000
2.1972
ND*
°2
9.5175
0.7275
8.9208
10.551
—
—
100.
3-13
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TABLE 3-3. EMISSIONS SUMMARY REPORT
Daily Report
06/16/77
Period
0000-0300
0301-0600
0601-0900
0901-1200
1201-1500
1501-1800
1801-2100
2101-2400
Summary
Limits
Data, %
Opacity
6-Min. Int Av. Mag
(Number) (%)
0
0
0
1 21.6
2 24.4
5 25.6
1 22.7
0
9 24.3
0 20.0
95.
so2
8-Hr. Int
(Number)
1
0
0
1
1
1
0
0
4
0
Av. Mag
(Ib/MBtu)
1.24
—
--
1.32
1.65
1.63
—
--
1.46
1.20
95.
Plant #4
NO
8-Hr. Int
(Number)
0
0
0
1
1
1
0
0
3
0
Av. Mag
(Ib/MBtu)
« .
—
—
0.92
0.84
0.75
—
—
0.84
0.70
95.
3-14
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TABLE 3-4. EMISSIONS SUMMARY REPORT
Weekly Report
06/16/77 - 06/22/77
Opacity
Period
06/15
06/16
06/17
06/18
06/19
06/20
06/20
Summary
6-Min. Int
(Number)
6
9
5
2
0
0
1
23
Av. Mag
(%)
22.4
24.3
22.9
24.6
--
—
22.8
23.5
so2
8-Hr. Int
(Number)
2
4
3
1
1
0
1
12
Av. Mag
(Ib/MBtu)
1.36
1.46
1.33
1.35
1.33
—
1.28
1.38
Plant #4
NO
3-H4. Int
(Number)
3
2
1
2
1
1
0
10
Av. Mag
(Ib/MBtu)
0.74
0.84
0.78
0.84
0.76
0.79
—
0.79
3-15
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Table 3-5 shows a typical calibration check log as it might be printed
by the data system. At this facility, normal zero and span checks are run
each day on the second shift. More frequent checks of zero are made auto-
matically by the monitor system. As was seen in the hourly report (Figure 3-1),
on 6/19/77, at 9:45, the opacity monitor apparently had a malfunction that was
noted by the data system, which typed out "ND" (no data) for the last three
opacity averages for the 9 to 10 p.m. period. The maintenance man performed
a zero check at 9:46, found a malfunction, and fixed it. The instrument was
recalibrated and zeroed at about 10:15 a.m. The record of this in the
maintenance log might read as follows:
09:45 a.m. Fuse blown on window blower on opacity monitor. Oiled
motors, replaced fuse, cleaned window, and checked zero and span
calibration. Return to service 10:20 a.m.
A note in the emissions report should call attention to this entry in the
maintenance log.
The weekly summary shown in Table 3-4 indicates that the facility was
at over the opacity limits frequently between 6/15 and 6/18, but was clean
during the next 2 days. The source's operating log should show a series of
notations that would explain these emissions. The problem might, for
instance, be a malfunction of one bank of the electrostatic precipitators.
If this is the case, a notation describing the failure, replacement of parts,
and corrective action taken should be found in the operating log. For
example:
"6/15, 4:30 p.m. Segment 3 of ESP shorted out, metering resistor
burned out, replacement ordered from G.E. Should arrive in 2 to 3
days. Operators — try to reduce load if possible -- watch opacity
and soot blowing."
"06/18, 12:15 p.m. Replaced ESP resistors. Working correctly now.
Opacity 12 to 13 percent."
3-16
-------
TABLE 3-5. CALIBRATION SUMMARY REPORT
* * t
Weekly Report
06/16/75 -
Calibration
06/22/75
Value
Sensor Readings
Date
06/16/77
06/17/77
06/18/77
06/19/77
06/19/77
06/20/77
06/21/77
06/22/77
Time
19:46
18:10
20:17
10:21
19:45
20:46
18:31
19:20
Opacity
49.97
S02
1289
PI
NO
1116
ant #4
02
8.92
Before Adjustment to Correct Value
pet
49.7
48.1
49.0
49.9
49.1
49.8
49.3
50.1
ppm
1312
1301
1296
1292
1286
1274
1281
1293
ppm
1120
1115
1119
1123
1116
1107
1121
1113
pet
8.95
8.91
8.99
8.92
8.87
8.92
8.95
8.98
Zero Summary Report
Weekly Report
06/16/77 -
06/22/77
Sensor Readings Before
Date
06/16/77
06/17/77
06/18/77
06/19/77
06/19/77
06/20/77
06/21/77
06/22/77
Time
19:40
18:01
20:07
9:46
19:35
20:40
18:20
19:09"
Opacity
pet
3.1
1.2
0.6
17.2*
1.6
1.0
0.9
1.3
Adjustment
so2
ppm
-10.2
5.6
4.3
9.2
4.2
14.1
-6.8
-2.7
PI
to Zero
NO
ppm
-1.2
4.7
-3.1
5.2
10.4
-0.8
-2.4
1.9
ant #4
°2
pet
0.1
-0.05
0.11
0.03
0.04
-0.02
0.09
0.06
3-17
-------
How to Evaluate a Report
Quarterly excess emissions data should be reported in a tabular
manner:
Start Stop
Date Time Time Emission Magnitude Remarks
The remarks column should contain any notes referring to calibration checks,
zero checks or the causes of excess emissions. The remaining information
may be recorded only once or twice during the reporting period, but should
be well documented by explanatory text. The actual format and style of such
reports may vary, but all the required information must be present and under-
standable.
Attachments 1, 2, and 3 to this section represent three typical -- but
quite different -- emissions reports. Report number 1 is essentially a
negative report, since no excess emissions were found. Report number 2
properly records a few emissions and malfunctions. Report number 3 records
emissions and malfunctions but is incomplete and does not meet the intent of
the regulations.
The checklist shown in Table 3-6 can be used to aid evaluation of
reports like those in the attachments. Below, the questions on the check-
list are explained and then applied to the three sample reports.
Explanation of Checklist
1. Was the report filed?
Every owner or operator required to monitor emissions must file a
written report for each calendar quarter even if no excess emissions occurred
during that quarter and the monitoring system was operating correctly. In
other words, a report must be filed whether it is positive or negative.
2. Was the report filed within 30 days?
All quarterly reports must be postmarked by the 30th day following
the end of each calendar quarter.
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TABLE 3-6. EMISSION REPORT CHECKLIST
Yes No
1. Was the report filed?
2. Was the report ftled within 30 days?
3. Did it report any excess emissions?
a. Was the time reported?
b. Was the duration or completion time reported?
c. Was the'magnitude reported?
4. How were excess emissions calculated?
a. Was a conversion factor used?
b. Does it match the standards?
5. What percent of operating time did excess
emissions represent?
a. Less than 1%?
b. 1 to 5%?
c. 5 to 10%?
d. 10% +?
6. Did source indicate any malfunctions?
a. Normal process equipment?
b. Control equipment?
c. Percent of operating time for control
equipment?
1) 1 to 5%?
2) 5 to 10%?
3) 10% +?
7. Did source specify causes of malfunctions?
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TABLE 3-6, Concluded
Yes No
8. Did sources specify corrective action?
9. Are malfunctions more frequent than last
quarter/year?
10. Is magnitude of emissions greater than last
quarter/year?
11. Did the source specify any downtime for the
monitoring system?
a. 1 to 5%
b. 5 to 10%
c. 10 to 20%
d. 25%
12. Did the source indicate a cause(s) and repair(s)
for such downtime?
13. Did the same problem recur during the
monitoring period?
14. If no excess emissions occurred, did the source
make a negative report?
15. If no monitoring system outages occurred, did
the source make a negative report?
16. Is there a pattern to reported excess emissions?
a. A specific time of day?
b. A specific day of the week?
c. At longer intervals weekly, monthly?
3-20
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3. Did it report any excess emissions?
If the source has reported excess emissions did they also report the
time, duration, and magnitude date of the excess emissions? Reports of no
excess emission should be scrutinized carefully, considering past records,
compliance tests, and the type of control system used.
4. How were excess emissions calculated?
For opacity, the monitor system will read directly. For power plants,
the type of fuel and monitoring system will determine which F factor is used.
Did the source specify sufficient information to determine which factor to
use?
5. What percentage of operating time did the excess time represent?
A source that records 2 hours of excess emissions over an 8-hour
period of operation may require more serious enforcement action than a source
that records 2 hours of excess emissions over a 24-hour period of operation.
6. Did the source indicate any malfunctions?
Any source that achieves the emission standard during normal operation
may occasionally record excess emissions due to common maintenance problems.
However, the majority of excess emissions should be attributable not to
normal operations but to some specific malfunction.
7. Did the source specify the cause of the malfunctions?
8. Did the source specify the corrective action?
These two items question the effectiveness of the entire emissions
monitoring program. In order to have an effective pollution control program,
a source must be aware of excess emissions, must find out why they occur, and
must try to prevent them from occurring again. However, many sources may
not have the technical staff or expertise to accomplish these goals. When
that is the case, assistance from EPA personnel may be required. On the
other side is the source that does not or will not investigate malfunctions
beyond just returning the equipment to service by replacing parts. A good
3-21
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chief engineer or plant maintenance supervisor is interested in knowing why
a part fails repeatedly, because it costs him money each time he must repair
the unit. There is a significant difference in taking corrective action to
repair the malfunction and taking corrective action to investigate and solve
the problem. Obviously, to achieve maximum pollution control, we need the
problem-solving type of corrective action along with repair of malfunction.
The key things to look for in the source's report is the subjective
feeling as to which of the above two categories the source belongs. If there
are any similar sources in your area, compare the performance of each as
regards type of control equipment, emissions, and malfunctions.
9. Are the malfunctions more frequent than last report?
10. Are the emissions greater than last report?
The evaluation of these two questions will give the first warnings of
neglect of control equipment or a gradual decline in its performance. A
gradual decline may indicate that more frequent maintenance is required,
more highly skilled maintenance is needed, more extensive maintenance is
required, or that the emission characteristics of the process may be changing
and a different control technology should be applied. For example, an oil
fired boiler converting to coal or a coal/oil mixture may produce greater
emissions than it did when it fired oil alone.
11. Did the source specify any downtime for the monitoring system?
12. Did the source indicate the causes and repairs associated with the
downtime?
Complex electromechanical monitoring systems are subject to breakdown
maintenance. Downtime and repairs will vary considerably with the type of
source and type of monitoring equipment. A source with particulate emissions,
such as a coal fired power plant or a smelter, should expect to need to replace
sample or air blower filters on their monitoring systems every few months.
It would be unusual for these plants, or plants processing sulfuric acid,
iron, or steel not to report some type of maintenance over a two-quarter period.
3-22
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On the other hand, a nitric acid plant using a chemiluminescent or UV
monitor could easily record a 180-day performance period if installed and
operated correctly.
Extremes should be suspect, A source that consistently shows no
maintenance, quarter after quarter, should be questioned. A source that
consistently reports 15 to 20-percent or more downtime should also be
questioned.
Perhaps the most important thing for the evaluator to determine is
whether the source is taking its malfunction problems seriously. Whatever
the reason for downtime, is the the source making efficient and timely efforts
to remedy the situation?
13. Did the same problem occur again during the monitoring period?
Frequently occurring problems are not malfunctions, but normal oper^ :
ations which need improvements. If a problem keeps recurring, a prudent
source operator will try to identify and correct the root cause rather than
treat the symptoms of the problem. For example, instead of merely replacing
source lamps in the monitor as they burn out, the prudent operator will check
the wattage on the lamps and the function of the current regulator.
14. If no excess emissions occurred, did the source make a negative report?
15. If no monitoring system outages or maintenance occurred, did the source
make a negative report?
The requirement for negative reports causes more inaccuracies than
any other requirement. If nothing has happened in a particular category it
is easy to forget to file a report. A quarterly report must be filed whether
or not there were excess emissions. If the source operator has forgotten or
is late in filing, some form of communication with the source is in order,
as a reminder of his obligations.
3-23
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16. Is there a pattern to reported excess emissions?
This question is asked to help gain insight into the normal operations
of the source. If excess emissions periods correlate with peak load or out-
put, the control equipment may be undersized for the application or some
aspect of the emission may make the control device less effective under peak
conditions. This type of information may be important if the source operates
under changing conditions. For example, power plants normally operated with-
out excess emissions, at 50 to 60-percent load, may produce excess emissions
if required to operate temporarily at 90-percent of load. This kind of
background information may be of significant value to the evaluator.
The primary reason for requiring a source to monitor emissions is to
make the source aware of excess emissions in time to correct them. Another
reason for requiring monitoring is to determine whether sources that have
been in compliance continue to operate and maintain their equipment properly,
so as to remain in compliance. To achieve these goals, only the magnitude
and frequency of excess emissions are needed to judge if the emission control
equipment is being maintained or is degrading in performance.
A properly maintained facility should show only a few randomly occuring
excess emissions and the number and duration should not change significantly
(50 to 100-percent increase) from quarter to quarter or month to month.
For example, a source using a baghouse might show bag replacement
early in the quarter and then start to show an increasing frequency of excess
emissions late in the quarter, as bags degrade and start to fail. If this
trend were noticed over one, two, or more quarters, it would be in the
Agency's interest to contact the source, bring these findings to his attention,
and require that corrective action be taken.
Examples
Using the reports checklist, let us review the hypothetical quarterly
reports presented in the attachments. Attachment 1 is a good example of a
negative report. The report was filed on April 16, 1977 -- within the 30-day
limit. The source stated that no excess emissions occurred. The basis of
determining the limit (x Ib N02 per ton of acid) was also stated. The report
3-24
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states the extent of operations, Jan. 1, 1977 to Mar. 19, 1977, and reports
no malfunctions in the identified control device. The report also indicates
that the NO monitor operated normally. Only preventive maintenance and
A
daily calibrations needed to be performed. The periods of outage other than
for daily maintenance are clearly identified. Although the report appears
to be complete, the inspector might require an explanation of the phrase
"periodic maintenance." Is the maintenance being done on a regular schedule?
Are further outages effectively being prevented?
The second excess emission report (Attachment 2) clearly states the
date of the report, the period covered, the methods of converting the monitor
readings to emissions and the conversion factor, F, for the bituminous coal
burned. The report also states that both S02 and 02 are measured dry. In
addition, the report states that Table I contains the excess emission data
and Table II contains the explanation of those emissions. However, apparently
by clerical mistake, Table II is omitted. In spite of that omission, the
inspector can gain the information he needs by examining the discussion of
source operations.
The source also indicated a recurring PH control problem in the wet
scrubber and described the investigation, identification of the cause, and
the corrective action taken. The most important part of this report is not
that emissions occurred, but that the causes of the excesses were identified
and that positive action was taken not only to correct them in the short
term, but to prevent occurrance in the long run.
In Table III, we see two short periods of outage due to equipment
problems in the continuous monitoring system. The first problem, an IR
source burnout, is a normal occurrence to be expected at periods of 1 to
2 years. If the source's other reports indicate replacement considerably
more often, then some fundamental investigation is in order. The second
outage is not unusual in wet scrubber installations, since the scrubber acts
as a SOp and particulate control device. A scrubber restart with liquid
droplet spray and wet sticky particulate will frequently clog the sample
filters of monitor systems.
3-25
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Although two downtime periods are indicated on the report, the reader
is left to assume that the monitoring equipment was operating at all other
times. No periodic or preventative maintenance is indicated.
The report is about 90 percent complete. But, because a series of
6- to 30-minute opacity excursions are not explained (perhaps this is in the
missing Table II), the report is probably worth a low-key telephone call to
the source asking for Table II and suggesting that a little more backup
information be supplied. If the next report does not improve in these areas,
a stronger phone call or letter might be in order.
The report in Attachment 3 represents a case where the source is
obviously negligent and warrants much attention. To begin with, the report
is late. In addition, the list of excess operating emissions is interesting
in several respects. First, no explanation is given as to the source or
cause of the emissions. Second, the emissions times are given in 15- or
30-minute intervals. Third, the emissions always seem to be exactly 30-percent.
It appears that the source is giving minimal attention to emission monitoring.
It is entirely possbile that dirty windows are not the real problem, but that
the opacity monitor is malfunctioning continuously and is not able to register
above 30-percent opacity. The source also does not appear to be taking any
corrective action to repair its S02 monitor or to correct the problems in its
opacity monitor. This source rates a strong letter requesting specific infor-
mation and action, and probably an evaluation to follow up.
3-26
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ATTACHMENT 1
Excess Emissions Report
January 1, 1977 -March 31, 1977
Nitric Acid Plant
April 16, 1977
3-27
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1. Excess Emissions
During the period January 1, 1977 thru March 31, 1977, the plant was
operated a total of 1824 hours with a total acid production of 22,800 tons
of nitric acid. During this period our chemiluinescent NO monitor showed
A
no periods of emissions in excess of the limit.
2. Source Operations
The facility was in operation on January 1, 1977 and operated for a
continuous period of 76 days prior to shutdown on March 17, 1977.
There were no malfunctions in our Puraseive-N NO absorption system.
A
3. Monitoring System Operation
Our chemiluminescent NO monitor performed reliably during the entire
A
time period. Periodic maintenance was performed monthly as shown below.
The overall on-time monitoring time was 1796 hours or 98 percent of 1824
hours. Normal calibration checks took an average of 20 minutes/day and the
two monthly periodic maintenance periods were 2 hours each.
This maintenance was performed on January 18, 1977 from 0947 to 1115
and February 21, 1976 from 1435 to 1602. Other than daily zero and span
checks, no other monitor system adjustment or repair was required.
3-29
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ATTACHMENT 2
Excess Emissions Report
April 1, 1977 - June 30, 1977
XYZ Power & Light Co.
River Bend No. 2
July 19, 1977
3-31
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1. Excess Emissions
Excess emissions for the period April 1, 1977 to June 1977 are
indicated by the attached printouts (Table 1} from our automatic data logger.
The opacity readings are logged directly in percent opacity. The S02
emissions are calculated from ppm SO^j percent oxygen, and the F factor for
bituminous coal of 9820 dscf/MBtu. Both our SCL and CL analysis are made
on a "dry" basis.
Emissions are calculated by the formula
F - r v F v 20.9
L(lb/MBtu) " L X h x 20.9 - Q2%
2. Source Operations
Table I, which contains the emissions data, also contains reference
notes concerning startup, shutdowns and malfunctions. Table II contains
detailed comments about excess emissions. The facility was down from April
7 to April 12 to replace superheater tubes and from June 1 thru June 30 for
the annual repair and maintenance.
During the period from 1245 to 2310 on April 12, 1977, #6 fuel oil
was burned during plant startup before switching to the normal pulverized
coal. The excess opacity emissions were caused by excessive carbon deposi-
tion on cold boiler surfaces during startup and subsequent soot blowing
activities. This problem would be alleviated if natural gas were available
for startup but no supply is available.
There were three major process upsets in our limestone wet scrubber.
On 4/3/77 loss of ph control in the scrubber liquor caused low scrubber
efficiency. A recurrence on 4/5/77 caused us to suspect the pH sensor and
controller. The temperature compensation circuit in the sensor was faulty
and has been replaced. Since the unit had performed reliably for 2 years,
we concluded that this was a random failure and have taken no major action
other than replacement.
The 5/16 opacity and S02 upsets were caused by a liquid flow stoppage
in the scrubber. A new employee opened a bypass valve by mistake. The
valves have been retagged to prevent this error.
3-33
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TABLE I. EXCESS EMISSIONS
Date
04/02/77
04/03/77
04/05/77
04/07/77
04/12/77
04/17/77
04/17/77
04/17/77
05/16/77
05/16/77
05/18/77
Time
1410
0806
1921
0912
1245
2110
2240
2310
0311
0311
1739
Duration
15 min
6.5 hr
3 hr
30 min
10.5 hr
12 min
6 min
6 min
48 min
3 min
6 min
Emission
opacity
so2
so2
opacity
opacity
opacity
opacity
opacity
opacity
so2
opacity
Magnitude
22,5%
1.8 Ib/MBtu
1.6 Ib/MBtu
36%
25%
31%
30%
26%
29%
1.8 Ib/MBtu
22%
Remarks
3-34
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3. Monitoring System Operation
Table III Indicates the operattonal/nonoperational periods for our
monttoring system.
TABLE III
Date
Time
Problem/Corrective Action
April 21, 1977
4:15 pm to 5:45 pm
IR source lamp on C02 monitor
burned out. Replaced from stock,
checked voltage. System back on
line at 5:45 pm, recalibrated
May 16, 1977
4:00 am to 10:15 am
Night shift operator noticed
peculiar behavior of monitor after
scrubber restart. First shift
maintenance replaced clogged
fitter which was wet and sticky.
Unit recalibrated and appears okay.
3-35
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ATTACHMENT 3
Quarterly Report
April 1977 -June 1977
August 14, 1977
PDQ Smelting Company
3-37
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1.
Excess Emissions
The excess
Date
April 2
3
5
6
10
11
27
28
29
30
May 1
2
3
5
6
7
8
16
17
18
19
20
June 7
8
9
23
24
25
26
Monitoring
emissions report foi
Time
2:30 -
9:30 -
12:30 -
4:00 -
8:30 -
10:00 -
1:00 -
1:30 -
1:30 -
3:00 -
11:30 -
12:00 -
2:00 -
3:00
9:00 -
8:00 -
12:00 -
4:00 -
3:00 -
1:30 -
8:30 -
1:00 -
7:00 -
2:00 -
12:30 -
2:00 -
3:00 -
10:00 -
12:00 -
System
4:15
10:30
2:30
4:30
9:00
11:00
2:00
2:00
2:00
3:30
3:00
2:00
3:00
6:00
12:00
9:00
1:00
6:00
3:30
2:30
10:00
1:30
9:30
2:30
1:00
2:30
4:30
10:30
4:30
Emission
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
opacity
Magnitude
25%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
30%
2.
The SOg monitoring system was inoperative from April 1977 until June
1977 because we could not get replacement light sources from our local
supplier.
The opacity monitor was inoperative from April 11 to 27, May 8 to 16,
May 20 to June 7, and June 26 to June 30 because windows got dirty too
rapidly. The vendor made a poor installation.
3-39
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TECHNICAL REPORT DATA
(Please read Inductions on the reverse before completing)
1. REPORT NO.
340/1-78-005 C
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Resource Manual for Implementing the NSPS Continuous
Monitoring Regulations. Manual 3 - Procedures for
Agency Evaluation of Continuous Monitor Data and
5. REPORT DATE
April 1, 1978
6. PERFORMING ORGANIZATION CODE
Reports
F. Jaye, J. Steiner, R. Larkin
8. PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORG MMIZATION 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 3 - Procedures for Agency Evaluation of Continuous Monitor Data and Excess
Emission Reports - is one of a series of four manuals that comprise the "Resource
Manual for Implementing the NSPS Continuous Monitoring Regulations." The other
manuals are:
Manual 1 - Source Selection and Location of Continuous Monitoring Systems
Manual 2 - Preliminary Activities for Continuous Monitoring System Certification
(Installation, Notification and Performance Evaluations)
Manual 4 - Source Operating and Maintenance Procedures for Continuous Monitoring
Systems
Manual 3 presents the NSPS regulations for data and reporting requirements for
affected sources. The manual also discusses the use of various factors in con-
verting data to units of standards. Examples are given to illustrate what must
be reported and how to evaluate the contents of these reports.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
cos AT I 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
21. NO. OF PAGES
39
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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