EPA-600/4-77-022
April 1977
Environmental Monitoring Series
        SURVEY  OF  CONTINUOUS SOURCE EMISSION
                               MONITORS:  Survey No.  1
                                              NOX  and S02
                                 Environmental Monitoring and Support Laboratory
                                        Office of Research and Development
                                        U.S. Environmental Protection Agency
                                  Research Triangle Park, North Carolina 27711

-------
                RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology.  Elimination  of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

      1.  Environmental Health Effects Research
      2.  Environmental Protection Technology
      3.  Ecological Research
      4.  Environmental Monitoring
      5.  Socioeconomic Environmental Studies
      6.  Scientific and Technical Assessment Reports (STAR)
      7.  Interagency  Energy-Environment Research and Development
      8.  "Special"  Reports
      9.  Miscellaneous Reports

This report has been assigned to the ENVIRONMENTAL MONITORING series.
This series describes research conducted to develop new or improved methods
and instrumentation for the identification and quantification of environmental
pollutants at the lowest conceivably significant concentrations. It also includes
studies to determine the ambient concentrations of pollutants in the environment
and/or the variance of  pollutants as a function  of time or meteorological factors.
 This document is available to the public through the National Technical Informa-
 tion Service, Springfield, Virginia 22161.

-------
                                       EPA-600/4-77-022
                                              April 1977
 SURVEY  OF CONTINUOUS SOURCE
EMISSION MONITORS:   Survey No.  1
               NOX and S02
                       by

            Michael C. Osborne and M. Rodney Midgett

                 Quality Assurance Branch
           Environmental Monitoring and Support Laboratory
            Research Triangle Park, North Carolina 27711
        ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
             OFFICE OF RESEARCH AND DEVELOPMENT
             U.S. ENVIRONMENTAL PROTECTION AGENCY
          RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711

-------
                                DISCLAIMER

     This report has been reviewed by the Environmental Monitoring and
Support Laboratory, U.S. Environmental Protection Agency, and approved for
publication.  Mention of trade names or commercial products does not con-
stitute endorsement or recommendation for use.
                                     ii

-------
                                 CONTENTS

Tables	   iv
Acknowledgment 	    v

     1.  Introduction   	    1
              History   	    1
              Purpose of This Survey  	    2
     2.  Survey Preparation   	    5
              Industries and  Pollutants   	    5
              The Survey Reference Materials  	    6
              Data Requirements  	    8
              Finding Monitors for the Survey   	   11
              Monitor Descriptions 	   11
      3.   Survey  Procedures  	   17
              Scope  of  Activities  ....    	   17
              Conducting  the  Field Measurements   	   19
      4.   Results	   21
              Monitor  Performance	   21
              Monitor  History  	   25
      5.   Discussion  of Results	   31
              Monitor  Performance   	   31
              Monitor  History  	   33
      6.   Conclusions and  Recommendations  	   34

References	   36
Technical Report Data and Abstract 	   37
                                     m

-------
                                   TABLES
Number                                                               Page
  1      SPNSS Continuous Monitoring Requirements 	   5
  2     Monitoring System History  	  10
  3     Continuous Emission Monitor Survey Results 	  22, 23,
                                                                      24
                                    iv

-------
                             ACKNOWLEDGMENTS
     The authors wish to acknowledge with appreciation the assistance
of Mr. Berne I. Bennett and his co-workers in the Quality Assurance
Branch for their assistance in analyzing the large number of gas cylinders
used in this survey.  Appreciation is also extended to each of the survey
participants who cooperated in every aspect of the survey.  Their names
cannot be mentioned here for the reasons stated in the report.

-------
                                  SECTION 1
                                INTRODUCTION
HISTORY
     On September 11, 1974, the U.S. Environmental Protection Agency publish-
ed in the Federal Register  the proposed Standards of Performance for New
Stationary Sources (SPNSS) and State Implementation Plans (SIP) requirements
for continuous emission monitoring.  On October 16, 1974, a separate continu-
                                          2
ous emission monitoring method, Method 12,  was proposed for primary copper,
zinc and lead smelters.  A slightly revised version of the proposed SPNSS and
SIP requirements for continuous emission monitoring was promulgated on Octo-
            3                     4
ber 6, 1975.   In January of 1976,  Method 12 was withdrawn, and smelters
were added to the list of industries required, under SPNSS, to adhere to the
monitoring specifications established on October 6, 1975.  Therefore, the
most significant regulatory document on continuous emission monitoring is the
                o
Federal Register  of October 6, 1975, which lists system performance specifi-
cations, operating procedures, data reduction, and reporting requirements.
     The new, or existing, sources that have been, or are being, required
to install, calibrate, maintain, and operate continuous gaseous emission
monitors are, initially, from five basic industries:
          -  Fossil Fuel-Fired Steam Generators
          -  Nitric Ac-id Plants
          -  Sulfuric Acid Plants
          -  Petroleum Refineries

-------
          -  Primary Copper, Zinc, and Lead Smelters
     At present, the only one of these industries in which monitors may be
used to determine compliance with the standards of performance is the smelter
industry.
     Although federal regulations requiring continuous emission monitors are
fairly new, the use of these monitors in the aforementioned industries goes
back several years.  Some of the monitors included in this survey were in-
stalled  6  or 7 years ago, while the majority went into operation since 1973.
     Very  few monitors that are on-line today have actually gone through a
                                                                     4
performance test  as  outlined in the October 6, 1975 Federal Register.   There
are two  basic reasons for this.  The first and primary reason is that most
monitors in plant operation today are on processes that are not classified as
new or modified sources  according to SPNSS specifications.  Instruments in-
staTi_d  prior to  October 6, 1975, are required to under go the Performance
Test only  at the  request of the administrator.  The second reason is that
much time, effort, and money is required to conduct one of these 168-hour per-
formance tests.   Reports from  the few performance tests which have been con-
ducted indicate that most source samplers do not clearly understand many of
                                                            4
the details outlined in  the October 6, 1975 Federal Register  for conducting
a performance test.  Therefore, few industries want to be the test case for a
consultant to learn  how  to conduct a performance test.  As more experience is
obtained in performance  testing and as more pressure is placed on the indus-
tries to conduct  the tests, a  significant number of these tests may be ex-
pected.
PURPOSE  OF THIS SURVEY
    In most cases, when  a survey  is conducted, insufficient data is the

-------
reason for the survey.  The survey of continuous source emission monitors is
no exception.  Although several different types of source emission monitors
had been evaluated by the EPA, prior to this survey, no continuing program of
emission monitor evaluation could be found within or outside the Agency.  The
concern within the Quality Assurance Branch (QAB) of the Environmental Moni-
toring and Support Laboratory (EMSL) was that the monitors that were meeting
initial design specifications were possibly failing to perform satisfactorily
after months of continuous in-plant usage.  Some question existed as to
whether continuous emission monitoring technology had progressed far enough
to develop a long-term maintainable system.  Complaints about monitor failure,
particularly from electric utility companies, tended to lend credibility to
these questions.  Were the industries expected to obtain valid monitoring
data from instrumentation that could not be expected to adequately perform
without excessive maintenance problems?
    Another area of concern was which monitors worked well over extended
periods and which did not.  The EPA policy on continuous source emission
monitoring has been, and still is, to provide basic performance requirements
for the continuous monitoring systems and leave it at that.   No specific
monitors will be recommended, nor will EPA recommend a particular method or
mechanism over any other.  Yet, the Quality Assurance Branch holds to the
position that long-term operation data on specific continuous monitors can,
and should, be made public knowledge.  This practice will  be followed without
officially recommending any product or method.  Also, the names of the speci-
fic industries where this information was obtained will not be mentioned.
Their participation in this survey was totally voluntary and these industries
should, in no way, be penalized for cooperating.

-------
     Additional and more extensive surveys will be required to obtain compre-
hensive answers to the questions:  (1)  Is emission monitoring technology
sufficiently advanced to provide a long-term maintainable monitoring system
for industry? and (2) How well do specific continuous emission monitors per-
form over an extended period of time?  Therefore, this report should only be
considered a preliminary investigation and should be coordinated with sub-
sequent survey reports to provide a more complete answer to these questions.

-------
                                 SECTION 2
                            SURVEY PREPARATION

INDUSTRIES AND POLLUTANTS
     The industries which were considered for in-plant continuous emission
monitor evaluation are the same as those listed in the introduction as having
to meet the October 6, 1975, monitoring specifications.   Table 1  lists these
industries and the pollutants which must be continuously monitored.
         TABLE 1.  SPNSS CONTINUOUS GASEOUS MONITORING REQUIREMENTS
               (Industry)                        (Pollutant)
         Fossil Fuel-Fired Steam Generators      S02, NO, 02  or C02
         Nitric Acid Plants                      N02
         Sulfuric Acid Plants                    S02
         Petroleum Refineries                    S02
         Smelters: Primary Copper, Zinc, Lead    S02
     After a review of the list of possible industries and pollutants which
could be included in the initial survey, it was concluded that a survey in-
volving all of these industries and all of these pollutants would be too
extensive for a first effort in this subject area.  There were too many un-
knowns with regard to possible survey tools, number of monitors available,
access to the plants and the monitors, and the cost of such a survey.  The
problem became one of.properly reducing the number of industries and pollut-
ants so that the maximum beneficial information could be obtained without
exceeding time and budgetary allotments or current technical  capabilities.
                                      5

-------
     In the process of making this decision about which industries and pollut-



ants were to be included, several significant considerations became apparent:



1) A satisfactory survey tool to evaluate the performance of opacity monitors



has not been adequately tested; 2) The number of available nitric acid plants



with continuous emission monitors is severely limited; 3) Op and COo emissions



are only indirectly related to other pollutant emissions in contrast to S02



and NO  emissions, which are primary pollutants; 4) More monitors could be
      A


readily located in power plants and sulfuric acid plants than in the other



listed industries; 5) A much lower range of SOp survey gases is required in



petroleum refineries than could be used in either power plants or sulfuric



acid plants; and 6) Smelters were of special interest since, in this industry,



the monitor is used to determine compliance with emission standards during



the performance test.



     With these considerations in mind, the decision was made to limit the



 initial  survey to  Fossil Fuel-Fired Steam Generators, Sulfuric Acid Plants,



 and Smelters.  The pollutants  to be surveyed were limited to sulfur dioxide



 (S09)  and nitrogen oxides  (NO  ).  The other industries and pollutants were to
    £                         X


 be added in future surveys  as  time and resources became available, enabling



 them to  be included.



THE SURVEY REFERENCE MATERIALS




     One additional limitation on the first survey was that only extractive



monitors were included.  Ten to twenty percent of the S09 and NO  monitors
                                                        £       /\


encountered when setting-up this survey were in-si'tu units.  The in-situ



units could not be checked with calibration gases like the extractive units,



and calibration cells were not readily available to test the in-situ units.

-------
Since the beginning of the survey, Lear Siegler, a manufacturer of in-situ

monitors, has developed a way of introducing calibration gases into the probe

and around the sensor so that calibration cells would not be necessary.

Future surveys of S07 and NO  monitors will  include both extractive and in-
                    Cf       3\

situ monitors, using gas cylinders when possible and calibration cells on all

other units.

      The October 6, 1975, Federal Register  clearly states that extractive

monitors must be checked by zero and span gases, i.e.,  gas cylinders.   There-

fore, the logical reference material for continuous extractive emission moni-

tors is cylinder gases.  Some may think that the best reference would  be EPA

Test Methods No. 6 and 7.  It is generally agreed that  these are reference

methods; however, it has been proven through collaborative testing that these

methods have within-laboratory standard deviations of about 4.0 and 6.6 per-

cent, respectively.   At the 95 percent confidence level, this variability

would, of course, be considerably greater.  On the other hand, gas cylinders

are readily certified by the gas vendors to  be accurate within 2 percent, and,

with NBS certified or traceable calibration  gases as back-up standards, the

concentrations may be further verified.  The practicality of using gas cylin-

ders instead of the reference methods was another major consideration. Cylin-

der gases were, therefore, used as the reference.

      Four cylinders of S02 in nitrogen, having a concentration of 100, 250,

600, and 850 ppm,* were purchased.  These cylinders were then sent to  the
*EPA policy is to express all measurements in Agency documents in metric units.
When implementing this practice would result in undue cost or lack of clarity,
ERC/RTP is providing conversion factors for the particular nonmetric units used
in the document. For this report the factors are:  1  ppm SO  = 0.376 mg/m.
       Jn
1 ppm NO  = 0.802 mg/n

-------
National Bureau of Standards (NBS) for analysis at the beginning of the survey
and again at the end.  The cylinders were used to calibrate a continuous
source SC^ monitor, which was then used to measure S02 in 25 survey cylinders.
In this way, the survey cylinders were traceable to the cylinders analyzed by
the NBS.
      Four cylinders of nitric oxide (NO) in nitrogen were purchased directly
from the NBS.  These were Standard Reference Materials (SRMs) at the concen-
trations of 100, 250, 500, and 1000 ppm.  As in the above case, the SRMs were
used to calibrate an NO source monitor.  Seventy-five NO survey cylinders
were then analyzed on the source monitor, thereby once again establishing
traceability.
     All of the cylinders were guaranteed stable for a period of 12 months
from the date of shipment from the vendor's plant.  The cylinders were made
of troj»ted alutiinum, fully pressurized with 30 cubic feet of gas per cylin-
der and weighed less than 25 pounds per cylinder.
DATA REQUIREMENTS
     The  information obtained from each survey participant was in two
general categories:  1) measured cylinder concentration data and 2) monitor
history.  The concentration data were simply the monitor reading and equiv-
alent concentration in parts per million for each survey cylinder gas that
was introduced into the monitor.  At least three different pollutant concen-
trations were introduced into each monitor, yielding at least three differ-
ent data points for each monitor.
     The information classified as monitor history was considerably more
extensive.  Answering the question, "How well do continuous emission monitors
perform over an extended period of time?" required delving into the more

                                      8

-------
involved questions of "Why do monitors fail to perform?" and "What types of
problems do monitor users encounter?"  To obtain answers to these questions
a "Monitor System History" questionnaire (Table 2) was prepared.
     On the day of the field testing, the questionnaire was filled out by
the individuals in the plant who were most familiar with the monitoring
equipment.  Most of the questions were intended to show not only whether the
monitors performed satisfactorily, but also to pinpoint why the user was or
was not pleased with the operation of the monitor.

-------
              TABLE 2. MONITORING SYSTEM HISTORY

1.   Monitor description, including model number.
2.   Date that the monitor became operational at its present location.
3.   Dates and descriptions of modifications to the monitoring system.
4.   How satisfied are you with the services provided by the equipment supplier?
5.   How satisfied are you with the overall operation of the monitoring system?
6.   What is the normal maintenance schedule for this equipment?
7-   For each time that the monitoring system was inoperative during the past
    6 months, list the date, number of hours, and reasons:
Date               No. of Hrs.     Reason
8.  What special maintenance problems have you had during the past six months
    with:
    a)  the probe
    b)  the delivery system
    c)  the monitor
    d)  the recorder
9.  What was the span of the instrument on the day of the test?
10. What was the concentration range of the emissions on the day of the test?
                                    10

-------
FINDING MONITORS FOR THE SURVEY
     The perfect continuous emission monitor survey would seek out a sample
of X number of identical monitors from each of Y number of different monitor
designs.  Unfortunately, the survey covered in this report was hampered from
following the perfect experimental  design.   The major obstacle was locating
enough S09 or NO  extractive continuous emission monitors to conduct a survey.
         £      A
An initial list of nine utilities,  sulfuric acid plants,  and smelters with
some type or types of S09 or NO  monitors was submitted by the Emission
                        c.      x
Measurement Branch of the Office of Air Quality Planning  and Standards.   Each
of these nine plants was contacted, and the planned monitor survey was dis-
cussed.  Of the nine plants on the  original OAQPS-suggested list,  only two
finally participated in this first  survey.    Reasons for  nonparticipation in-
cluded:  1) The monitors are not operating at this time,  2) A compressed gas
cannot be readily introduced into the monitor, 3) The monitor has  been
returned to the manufacturer for repairs, 4) The monitors have been turned
off until data collected earlier may be evaluated, and 5) Plant employees
are not allowed to talk with EPA representatives at this  time.   Since two
plants were an insufficient number  of participants for the survey, suggest-
ions for additional  participants were sought through correspondence with
instrument suppliers, EPA Regional  Offices, State air pollution control
agencies, and through the industries themselves.  About 20 companies were
contacted to obtain the 8 different companies that were finally included in
the survey.  Fortunately, some of the companies that participated  had several
monitors among a number of plants.
MONITOR DESCRIPTIONS
     A total of 19 monitors were included in this initial survey.   This

                                     11

-------
included 6 NO or NOX monitors and 13 S02 monitors.  There were four different



types of NO or NO  monitors surveyed -- Dynascience, MSA, Envirometrics, and
                 /\


Thermo Electron.  S02 monitors were also of four different types -   DuPont,



Leeds and Northrop, Dynascience, and Thermo Electron.



     The only reasons that these monitors were selected over others were that



they met the requirement of being extractive NO  or S09 emission monitors and
                                               A      £


that they were in operation in the plants of the companies participating in



the survey.



     The following description of each monitor covered by the survey should



provide an insight into the differences that existed between the monitors



surveyed.  Literature from the monitor venders is the primary source of this



information. Some difficulty in comparing system performance specifications



may be encountered because each vender reported on different specifications.



DuPont nude! 400 Photometric Analyzer (SOo)



     This photometric monitor operates in the UV-visible range at a "measur-



ing" wavelength of 302 nm and a reference wavelength of 546 nm.  Changes in



S02 concentration cause the difference in absorption between 302 nm and 546



nm to vary.  The light signal is detected by the monitor and displayed as



changes in SOo concentration.  The manufacturer claims that high linearity



permits the use of widely different pollutant ranges with one analyzer.  Each



S02 monitor contains an optical filter that mimics the light absorption



characteristics of SOo and is used for daily calibration, once the filter is



calibrated against a known source.  DuPont offers the option of purchasing



just the basic Model 400 Analyzer - or a complete custom-engineered system



that includes the Model 400 and a sampling system.  Some system specifications



include:





                                     12

-------
          -  Precision: +_ 1% full  scale
          -  Accuracy:  + 2% full  scale
          -  Zero Drift:  1% full  scale in 24-hr for most applications
          -  Sample Temperature Range:   up to 1000°F (S38°C)
Leeds and Northrop 7864 Infrared Analyzer (SOp)
     Essentially, the unit is the combination of two simple infrared analyz-
ers.  One senses all of the infrared-absorbed gases  in the sample;  the other
senses all but the gas you want to measure, i.e.  S02-   The range  of the
particular instrument tested was 0 to 10,000 ppm.   Calibration  gases can  be
used; however, a three-way solenoid valve for selection of sample or cali-
brating gas must be specified as a separate option.   Similarly, sample con-
ditioning equipment must be either ordered separately, ordered  as a standard
sampling system, or otherwise provided by the user.   Some system  specifica-
tions include:
          -  Accuracy:  + 1% of span or 30 ppm (whichever is  greater)
          -  Reproducibility:  +_ 1.5% of span (24-hr)  or 30 ppm (whichever  is
             greater)
          -  Zero-drift:  +_ .7% of span (24-hr)  or 20 ppm (whichever is
             greater)
          -  Analyzer Temperature:  Maximum of 140°F (46°C),  thermostated
Dynascience -PSC-01, Self Contained Dual  Monitor and Sample Aquisition System
for NOX/S02
     The Dual Monitoring Model  utilizes the EPD Selectro Cells. These electro-
chemical transducers convert the gas concentrations  into electric current out-
puts for simultaneous readings of the two pollutants being measured.  Typical
concentration ranges of the instrument go up to 2000 ppm.  Calibration of the

                                     13

-------
system with compressed gases is standard with the option of automatic zero
and span calibration for unattended use.  A complete "turnkey" system capable
of continuously acquiring, conditioning, analyzing, and recording pollutant
concentrations car, be provided.  Some system specifications include:
          -  Sensitivity:  +_ 2% of full scale
          -  Repeatability:  +_ 2% minimum
          -  Zero Drift:  +_ 2% of full scale
          -  Operating Temperature Range:  40-43°C (Temperature controlled
             at 43°C)
Thermo Electron SO,, Pulsed Fluorescent Analyzer - Model 40
     In this analyzer, a gas sample is submitted to a source of pulsed ultra-
violet illumination through a monochomatic filter.  S02 molecules, energized
by the high-intensity pulsed-light source, emit an S02 specific illumination,
which, through a narrow band filter, impinges upon the sensitive surface of a
photomultiplier tube.  The emitted light is linearly proportional to the con-
centration of SOp molecules in the sample.
     Five standard sensitivity ranges are available, going up to 5000 ppm.
Calibration gases are used for calibration purposes, but care must be taken to
note the percentage of quenchable compounds in the compressed gas cylinder. A
separate sample conditioning and sample collection system is available from
the manufacturer.  Some system specifications include:
          -  Accuracy:  +_ 0.5%
          -  Reproducibility:  +0.5%
          -  Zero Drift:  + 1% (7 days)
          -  Operating Temperature Extremes:  0-40°C
                                     14

-------
Environmetrics Series N-76 Analyzer (NO )
                                       /\


     Each monitor utilizes FARISTOR cartridge sensors to monitor NOX over



various sensitivity ranges.  Inside the FARISTOR is a liquid-state device,



containing a chemically sensitive activating surface layer upon which pollut-



ant molecules are strongly absorbed by catalytic action.  This action results



in a change of oxidation state, producing a charged surface.  The magnitude



of the charge is determined by the rate at which the gas molecules reach the



activating surface, this rate in turn being directly proportional to the



pollutant concentration.  Typical operating ranges for the monitor extend



upward to 10,000 ppm.  The system calibrates against a gas of known concen-



tration in a nitrogen carrier gas.  Sampling and conditioning systems must be



obtained separately.  System specifications are said to meet or exceed exist-



ing EPA standards.  This statement was made in 1972, when there were no



existing EPA standards on continuous emission monitors.



Thermo Electron Series 10A NO-NO  Chemiluminescent Analyzer
                                A


     This chemiluminescent analyzer includes an NO-NO converter for the con-
                                                  y\


version of NO  to NO for subsequent measurement via the chemiluminescent
             A


process.  The instrument has eight different concentration ranges all the way



up to 10,000 ppm.  Regular calibration of the monitor requires the use of



calibration gas cylinders.  As with the TECO S02 analyzers, a separate sample



conditioning and sample collection system is available from the manufacturer.



Some system specifications include:



          -  Accuracy:  +_ 0.5%



          -  Reproducibility:  +0.5%



          -  Zero Stability:  +_ 1 ppm (24-tirs)



          -  Operating Temperature Extremes:  0-40°C




                                     15

-------
MSA Lira Infrared Analyzer - Model 202 (NO)
     This analyzer operates on the principal of nondispersive infrared (NDIR)
detection.  The NDIR analysis method is used on the hypothesis that most
nitrogen oxides (NO ) emitted from power plants are in the form of nitric
                   /\
oxide  (NO).  Typical analytical ranges are 0-2000 ppm NO.  Calibration
selector values for using calibration gases are built into the system.  The
complete sampling acquisition and conditioning system consists of a specially
designed 5-micron shielded filter probe assembly for installation in the stack
and a  heat-traced insulated Teflon or stainless steel sample line condition-
ing system.  Some system specifications include:
          -  Accuracy:  1.0%
          -  Repeatability:  1.0%
          -  Zero Drift:  1.0% (24-hr)
          -  Operating Temperatures:  0-48°C
                                      16

-------
                                 SECTION 3
                             SURVEY PROCEDURES
SCOPE OF ACTIVITIES
     In the complete picture of what is involved in conducting a survey of
continuous emission monitors, the actual field measurements make up only a
small part.  The following is the chronological order for this first survey
and should be looked upon as the cycle which each additional survey is likely
to follow.
     1.  Identified companies with monitors
         This step was described earlier, including the difficulties which
were encountered.
     2.  Initial contact with a knowledgable employee
         Few plant managers knew whether their monitors were extractive, the
make of the monitor, or the operating range of the monitor.   An individual
who worked directly with the instrument on a day-to-day basis was contacted.
     3.  Sent letters requesting the participation of the company in the
         survey
         Official permission to perform tests in a given industry almost
always required a written request.
     4.  Initial calibration of survey cylinders
         This step needed to be taken within a few weeks of the actual field
measurements to minimize chances of degradation taking place.
     5.  Receipt of confirmation of willingness to participate
         The survey was held up until this letter was received.
                                     17

-------
     6.  Second conversation with plant contact
         At this point, information was obtained concerning the span of the
instrument, an agreeable testing date, and a confirmed mailing address for
the gas cylinders.
     7.  Shipped cylinders
         Available means of shipping compressed gas cylinders was limited.
While S02 cylinders could be sent through the U.S. Mail, NO cylinders were
limited to only a few commercial trucking companies.  Even then, delays were
common because the cylinders could not be placed on trucks hauling clothing.
     8.  Mailed final notification of visit
         To be certain that no misunderstandings existed between the surveyor
and the industry, the plant manager or supervisor received a final confirma-
tion of the date of the proposed visit and the extent of the planned testing.
The letter was received approximately a week before the actual field testing,
to ensure that it was not forgotten.
     9.  Determined if cylinders had arrived
         The surveyor did not go into the field until he was certain that all
necessary equipment was on site.
    10.  Conducted the field measurements
         This step will be expanded upon later.
    11.  Returned cylinders and re-analyzed concentrations
         If the cylinders' concentrations are re-analyzed quickly, there is
little opportunity for the cylinders to degrade.
    12.  Supplied participating industries with tentative results
         The courtesy of letting the industries know, without delay, how they
performed has created a willingness on their part to participate in the next

                                      18

-------
survey.  It was often possible to provide the industries with this information
during the actual field testing.  The concentrations did not change signifi-
cantly between pre- and post-test laboratory evaluations.
     13.  Combined The results of the independent surveys and published the
          data
          Information was compiled about both instrument accuracy, based on
field measurements, and instrument maintenance problems, based on the monitor
history questionnaire.
Conducting the Field Measurements
      Each company has its own security procedures and it is, therefore,
difficult to generalize about them.  In most cases, however, it was found
that the best approach was to proceed to the front gate and ask to see our
principal contact.  In some small plants this was the plant manager, or the
local plant supervisor, but in most cases our contact was the instrument man
or a plant engineer.
      After a discussion of the planned testing,  the next task was to locate
the shipped gas cylinders.  After the gas cylinders were taken to the monitor
location and the proper regulators attached, a determination was then made as
to where in the sampling line to introduce the gas.  Ideally, the gas should
be introduced immediately after the sampling probe so that the majority of
the sampling and conditioning system would also be evaluated.  It was
observed in this survey, however, that most installations were not prepared
for introducing the gas immediately after the probe, so a less suitable site,
such as just prior to the monitor, was usually selected.  A wide range of
stainless steel fittings and flexible tubing was  available to ensure a leak-
free connection to the sampling line.
                                     19

-------
     At least three different concentrations of reference gas were introduced
at each monitor, and the instrument reading was recorded in each case.   No
attempt was made to calibrate or zero the instrument before introducing the
gas.  Care had to be taken with some monitors to prevent over-pressurizing
the sample lines.  After obtaining the readings from the monitor for the
various gases, the concentration of the stack gases being recorded on the
strip chart or other recorder was noted.  After the gas line was disconnected
and the cylinders were re-sealed for return shipment, the appropriate plant
personnel were asked to complete the monitor history forms.  Usually, there
was limited information available to document items on the survey form.  As
a result, most interviews lasted only a few minutes.
      The last task was the shipment, or arranging the shipment, of the
cylinders back to the laboratory for re-analysis.  Leaving this task to the
plant personnel  would have significantly delayed the completion of the
project.
                                      20

-------
                                  SECTION 4
                                   RESULTS

MONITOR PERFORMANCE
     Table 3 shows the survey results from introducing three or more survey
gases into each continuous emission monitor.  Names of participating compan-
ies have been omitted for reasons stated previously.  In order to be able to
identify individual sources when evaluating the data, however, a number and
letter have been designated for each participating company.   The letters used
are £, A, and S^ corresponding to power plants, sulfuric acid plants, and
smelters, respectively.  The number in front of the letter designates which
power plant, etc.   In some cases, more than one of the same type of monitor
were evaluated at a given site.  When this happened, the monitors were also
numbered.
     A comparison of actual vs. measured concentration is included as the
basic evaluation criteria.  This value is called the percent accuracy; i.e.,
           % accuracy = concentration measured - actual  concentration
                                     actual  concentration               x 100,
where the "actual  concentration" is defined as the value established by the
Quality Assurance Branch.
     The average percent accuracy that is included in the results is the
absolute average,  giving no consideration to the sign of the individual
values.  One exception to the procedure is the results from the survey of the
TECO NO  monitor.   The reason for this exception is explained in the section
       A
on "Discussion of Results."
                                     21

-------
TABLE 3.


Pollutant Plant Monitor Cylinder
NO IP Dynascience FF 3152
FF 3264
FF 3275

NO 2P MSA FF 1121
FF 1138
FF 1106

NO 3P Envirometrics FF 1226
x FF 1192
FF 1108

NOV 3P TECO (No. 1) FF 1226
x FF 1192
FF 1232

NO 3P TECO (No. 2) FF 1226
x FF 1192
FF 1232

NO 3P TECO (No. 3) FF 1226
x FF 1192
FF 1232

SO, 3P DuPont FF 1073
* FF 1176
FF 1065

Concen.
measured @
plant ppm
520
1120
1640

240
400
420

215
350
370

235
390
425

245
388
392

235
390
400

140
385
630

Actual
concen
ppm
471
975
1459

236
404
406

246
395
406

246
395
407

246
395
407

246
395
407

150
367
782


V
h
Accuracy
+9.9
+14.9
+15.7
AVE: 13.5
+0.8
-1.0
+1.9
AVE: 1.2
-12.6
-11.4
+8.9
AVE: 11.0
-4.5
-1.3
+4.4
AVE: 3.4
-0.4
-1.8
-3.7
AVE: 2.0
-4.5
-1.3
-1.7
AVE: 2.5
-6.7
+4.9
-19.4
AVE: 10.3
                        22

-------
            TABLE 3.


Pollutant Plant Monitor Cylinder
S09 1A Leeds and FF 3234
Northrop FF 3259
FF 3248

S09 1A DuPont FF 3234
c FF 3259
FF 3248

SO- IS DuPont FF 1487
* (No. 1) FF 1385
FF 1458

S0? IS DuPont FF 1487
(No. 2) FF 1385
FF 1458

S07 IP Dynascience FF 1184
* FF 1086
FF 1494

S02 2A TECO F 312*
F 126*

i
FF 1166
FF 1258
FF 1175

Concen.
measured @
plant ppm
2150
4450
6150

2600
5300
7750

6,400
10,900
15,800

4,950
9,700
14,600

130
330
727

108
340


193
408
427

Actual
concen
ppm
2440
5180
7750

2440
5180
7750

5,560
10,800
16,300

5.650
10,800
16,300

151
364
805

147
453


158
362
378


%
Accuracy
-11.9
-14.1
-20.6
AVE: 15.5
+6.6
+2.3
0
AVE: 3.0
+13.3
+0.9
-3.1
AVE: 5.8
-14.4
-10.2
-10.4
AVE: 11,0
-13.9
-9.3
-9.6
AVE: 10.9
-26.5
-24.9
AVE. 25.7

+22.2
+12.7
+13.0
AVE. 16.0
TABLE 3 (continued)
                                    23

-------
             TABLE 3.
Pollutant Plant Monitor
SO- 4P DuPont
* (No. 1)
S09 4P DuPont
* (No. 2)
S09 4P DuPont
* (No. 3)
S0? 4P DuPont
* (No. 4)
SO, 4P DuPont
* (No. 5)
S02 3A DuPont
Cylinder
FF 1079
FF 1186
FF 1269
FF 3234
FF 1079
FF 1186
FF 1269
FF 3234
FF 1079
FF 1186
FF 1269
FF 3234
FF 1079
FF 1186
FF 1269
FF 3234
FF 1079
FF 1186
FF 1269
FF 3234
FF 1258
FF 1175
F 126*
F 314*
F 162*
Concen.
measured @
plant ppm
792
816
808
2252
720
736
756
2188
756
764
792
2284
732
752
772
2192
844
848
860
2332
355
400
485
645
770
Actual
concen
ppm
759
778
804
2440
759
778
804
2440
759
778
804
2440
759
778
804
2440
759
778
804
2440
362
378
453
615
760
%
Accuracy
+4.3
+4.9
+0.5
-7.7
AVE: 4.3
-5.1
-5.4
-6.0
-10.3
AVE: 6.7
-0.4
-1.8
-1.5
-6.4
AVE: 2.5
-3.6
-3.3
-4.0
-10.2
AVE: 5.3
+11.2
+9.0
+7.0
-4.4
AVE: 7.9
-1.9
+5.8
+7.1
+4.8
+1.3
AVE: 4.2
*denotes air is the carrier gas instead of nitrogen.

TABLE 3 (continued)
                                     24

-------
MONITOR HISTORY
      In trying to establish the overall reliability of the monitors surveyed,
investigators used the series of questions in Table 2 to develop a record of
the history of the monitoring system.  Some of the participating industries
had not maintained enough records on their monitoring equipment to answer all
of the questions.  Therefore, information which would have been helpful  in
evaluating some of the monitors was not available.  Specifically,  background
information on the Envirometrics (N02) monitor could not be obtained from the
company that owned the monitor.
      The following is a question-by-question summary of the information
obtained by use of the monitoring-system history questionnaire:
      1.  Monitor description including model number.  The answers to this
question are in the earlier sub-section on "Monitor Descriptions".
      2.  Date that the monitor became operational at its present  location.
A summary of the years in which the monitors became operational is listed be-
low:
   Year           1970       1971       1972       1973       1974       1975
No. of Monitors      130833
      3.  Dates and descriptions of modifications to the monitoring  system.
The dates when modifications were made to the monitoring systems were not
available at most plants that were visited.   Several  significant modifications
were made, however, and are listed below:
      Monitor                 Modifications
4P-DuPont No. 1-5 (S0«)       1.  Added a new design particulate filter.
                              2.  Shortened  probe.
                              3.  Increased  sample line from 1/4 inch to 5/8
                                  inch
                                     25

-------
     Monitor                Modifications
                            4.  Added a fuse to prevent shorting out in 220-
                                volt heat traced line.
                            5.  Made probe of 316 stainless instead of 304.
4P-DuPont No. 1-3 (802)     1.  Added switch to purge system during downtime.
IS-DuPont No. 1 & 2 (S02)   1.  Added temperature gauge at the monitor.
                            2.  Devised a filtering system to keep out
                                moisture and particulates.
2P-MSA (NO)                 1.  Replaced sample lines.
IP-Dynasciences (NOX & S02) 1.  Changed from a "glued-together" sample
                                conditioner to a "screwed-together" unit.
                                                                 a
                            2.  Replaced a Teflon piece in the diaphragm pump
                                with a rubber one.
                            3.  Changed blow back valves from a 10-minute
                                cycle to a 20-minute cycle.
                            4.  Replaced Teflon seats with nylon seats and an
                                0-ring.
2A-TECO (S02)               1.  Began making their own particulate filters.
3P-TECO (NO  )               1.  Have added heat tracing to the sampling line.
           J\
and DuPont (1) (S02)
     4.  How satisfied are you with the services provided by the equipment
supplier?  There were no complaints registered with regard to any of the equip-
ment suppliers.
     5.  How satisfied are you with the overall operation of the monitoring
system?  Most operators were pleased with the monitoring system as a whole.
However, three companies (2A-TECO, 2P-MSA, and 4P-DuPont (1-5) indicated that

                                      26

-------
there had been.unreasonably poor performance of the pumps,  sampling lines,  and
probes.
     6.   What is the normal maintenance schedule for this equipment? Responses
to this  question are listed below:
     Monitor                    Maintenance Schedule
IP-Dynascience (NOX and S02)    1.   Calibrate once per week with  calibration
                                    gases.
                                2.   Check flow and battery  daily.
                                3.   Clean SCU scrubbers once every  two weeks
                                    to  one month.
                                4.   Rebuild pumps  and compressors twice  a
                                    year.
                                5.   Valve maintenance 3-4 times per year.
                                1.   Daily calibration with  calibration gases.
                                1.   Cleaning of capillary tubes and change
                                    oil  in  the vacuum pump  once every 3 months.
                                1.   No maintenance schedule available yet.
                                1.   Check out system once per week.
                                2.   Calibration check once  per month or  soon-
                                    er with optical  filters (DuPont).
                                3.   Clean lenses once per month.
                                1.   Calibrate each morning  with optical
                                    filter.
                                2.   Particulate filter change once  per week.
                                1.   Daily zero and calibration check with
                                    calibration gases.   If  error exists, then
                                    maintain.
2P-MSA (NO)
3P-TECOO-3) NO
               A

3P-DuPont (S02)
lA-Leeds and Northrop and
DuPont (S02)
IS-DuPont (2)(S02)
2A-TECO (S02)
                                     27

-------
     Monitor                     Maintenance Schedule



3A-DuPont (S02)                  1.  Check it 3 times a day with optical



                                     filter.



4P-DuPont (1-5)(S02)             1.  Observed daily.



                                 2.  Weekly check with optical filter.



                                 3.  Complete calibration monthly with cali-



                                     bration gases.



     7.  For each time that the monitoring system was inoperative during the



past 6 months, list the date, number of hours, and the reason.  This was the



most difficult question on which to obtain answers.  The purpose of this



question was to determine the availability of the instrument, exclusive of



plant shut-downs or other times when the instrument was not needed.  A rough



estimate of the amount of time each monitor was non-functional during the 6-



month period prior to the survey follows:



     Monitor                     Approximate Time Non-Functional Over 6 Mos.



IP-Dynasciences (SCL & NO )      -  less than 3 weeks
                   Cm.     A


2P-MSA  (NO)                      -  10 days



3P-DuPont  (S0?) & TECO (1)(NOJ  -  6 weeks
             £               t\


3P-TECO (2&3)(NO  )               -  functioned continuously
                y\


4P-DuPont  (1-5)(S02)             -  2-4 weeks each



lA-DuPont  & Leeds & Northrop (S02) - less than 1 day each



2A-TECO (S02)                    -  1 week



3A-DuPont  (S02)                  -  less than 1 day



IS-DuPont  (1)(S02)               -  2 days



   -DuPont  (2)(S02)               -  1 day
                                      28

-------
     8.  What special maintenance problems have you had during the past 6-
months with the probe, the delivery system, the monitor, or the recorder?
Plants reporting problems with clogged probes include:
     - 2P - MSA (NO)
     - 4P - DuPont (1-5)(S02)
     - 1A - DuPont (S02)
     - 2A - TECO (S02)
     - 3A - DuPont (S02)
     - IS - DuPont (1 & 2)(S02)
Problems with the delivery system were of three types: clogging, condensation,
and leaks.  Those plants reporting problems with clogging were:
     - 4P DuPont (1-5)(S02)
     - 2A TECO (S02)
Condensation problems were reported by:
     - 2P MSA (NO)
     - 3P DuPont (S02)
     - 3P TECO (NOJ
                  X
     - IS DuPont (1 & 2)(S02)
The problem of leakage was reported by:
     - IP Dynasciences (NO  & S09)
                          /\     £
Problems that were reported with the monitor, itself,  included:
4P DuPont (1-5)(S02)  -  1) cracked housing on solenoid
                         2) dirty optics
                         3) defective diaphragm on vacuum breakers
IS DuPont (1 & 2)(S02) - 1) fluorides etch lenses
1A Leeds and Northrop (S02) 1) cracked lenses
                            2) electronic problem with power supply
                                     29

-------
2A TECO (S02)            1) dirty optics
3A DuPont (S02)          1) dirty optics
     Recorders were often not a part of the purchased monitor package and
were also generally not a problem.
9. and 10.  What were the span of the instrument and the concentration range
of the emissions on the day of the test?  The purpose of these questions was
to place the survey gases in perspective with the operating range of the
instrument, the concentration at which it was calibrated, and the normal
operating level of the instrument.  The results of the questions are as
fol1ows:
Monitor
IP  Dynascience  (NO  )
                  A
IP  Dynascience  (S02)
2P  MSA (NO)
3P  TECO  (1-3)  (NOJ
                  ^
3P  DuPont (S02)
4P  DuPont (1-5)  (S02)
1A  DuPont &  Leeds and
  Northrop (S02)
2A  TECO  (S02)
3A  DuPont (S02)
IS  DuPont (1&2)  (S02)
Calibration
Check ppm
not known
not known
888
900
not known
3233
5000
300
2300
9800
Full scale
ppm
600
1500
1000
1000
600
4000
10000
500
5000
20000
Concen. range
ppm
200-400
300-600
80
200-400
0
1200-2600
1500-2000
20-30
1700
4500-9000
                                       30

-------
                                   SECTION 5
                             DISCUSSION OF RESULTS

MONITOR PERFORMANCE
      Before a discussion of how the monitors performed as a whole, it is
necessary to clarify the results of the survey of the TECO (S02) monitor at
plant 2A.  As was noted in the section on "Monitor Descriptions", the TECO
($02) monitor is a pulsed fluorescence instrument which is sensitive to
quenchable compounds in the survey gas.  We were aware of this problem when
the survey was conducted and, therefore, used both cylinders of S02 in nitro-
gen and SOp in normal dry air (20% 02).  The results of the survey show that
the monitor consistently read the S02 in air cylinder concentrations low and
the S02 in nitrogen cylinder concentrations high.  An analysis of the sulfuric
acid plant stack gas indicated that there was 8.3 percent oxygen present.
Assuming that the amount of quenching was directly proportional  to the oxygen
concentration of the stack gas, an estimate of the average percent accuracy
based on the survey results would indicate that the TECO monitor was reading
low by only 1.7 percent.  This calculation is obviously questionable since
additional testing would be required to measure how much oxygen quenching
really occurred.  The approximation obtained by ratioing the oxygen present
gives, however, a much better representation of how well the monitor was
functioning than either the test performed with S02 in nitrogen or the test
performed with S02 in air.  Further evaluation of this type of monitor, using
more representative survey gases, is anticipated during our next performance

                                     31

-------
survey.
      Another point which should be considered before any gross generaliza-
tions about the findings of the survey are made, relates to the concentration
level of the survey gases.  In some of the installations, the monitor range
encountered at the site was much higher than anticipated.  Therefore, the
concentration levels that were introduced were occasionally on the lower end
of the monitor concentration read-out range.  Since few monitors are cali-
brated specifically for the low end of the scale, some of the monitors in the
survey may seem to perform worse than they would if we had always used survey
gases which were at least mid-range.  Closer attention will be paid to this
point in future surveys.
      In general, the monitoring systems surveyed performed better than had
been expected on the basis of earlier reports from industrial monitor users.
Nine of the 19 monitors surveyed had an average percent accuracy of less than
5 percent.  This is exceptionally good, considering the age of most of the
monitors and the limited regular maintenance which they had been given.  Only
six of the 19 monitors failed to come within 10 percent of the actual concen-
trations, and the worst one of these was out by only 15.5 percent.  Therefore,
there were no really poor monitor performances; only some that might be
classified marginal.  Without making reference to any specific monitor, the
data clearly show that certain monitoring systems were out-performing others.
Insufficient data are available to determine if the larger percent accuracy
was caused by failure within the instrument or by problems with the cylinder
gases used to calibrate the instrument.  No specially good or bad performance
was observed in any one of the three industrial categories.  It should be
noted, though, that at least one monitoring system worked exceptionally well
                                     32

-------
in each of the three industrial categories.
MONITOR HISTORY
     Each individual monitoring system that was evaluated in the survey was
found to have had one or more maintenance problems.  The significant finding
was that the probe, the delivery system, and the monitor were all  consistent-
ly contributing to these maintenance problems.  The most prominent problem
experienced by the majority of operators was clogging of either the probe or
the sample lines.  The second greatest problem was related to the first, in
that condensation in the sample line often is the cause of, or at least con-
tributes to, the clogging.
      Several problems were listed for some installations.  This fact may,
however, be more closely related to the disposition of the operator who
provided this information than to the quality of the monitor.
      In general, most participants were at least satisfied with the overall
operation of their monitor, and, as far as could be determined, no one was
displeased with the services of the equipment supplier.
      Several monitoring systems experienced a significant amount of downtime
during the 6 months prior to the survey.  This fact was partially due to the
low priority attached to keeping the monitoring system going, compared to
other types of instrumentation in the plant.  Since downtime was usually an
estimate, it may have been over-exaggerated.  Until plants start keeping a
record of this information, it will be impossible to obtain good monitor
availability data.
                                      33

-------
                                  SECTION 6
                       CONCLUSIONS AND RECOMMENDATIONS

      Most of the survey participants were pleased to learn that information
on the reliability and accuracy of continuous emission monitors was being
gathered for public distribution.  Such information can only enhance quality
control in this area of instrumentation.
      The initial survey produced few surprises.  Several general conclusions
from the survey were, however, possible.
      1)  Continuous emission monitors can perform exceptionally well, and
some did in this study.
      2)  Some types of continuous emission monitors consistently perform
better than others.
      3)  The industrial category in which the monitor is placed has no effect
on how well or how poorly the monitor performs.
      4)  The probe, the delivery system, and the monitor all contributed to
regular maintenance problems.
      5)  The two most prominent maintenance problems encountered were
clogging of the probe and sample lines and condensation.
      Recommendations for future surveys included:
      1)  Expand the survey to include:
          a.  more different types of monitors
          b.  in-situ monitors
          c.  monitors in nitric acid plants, petroleum refineries, and other
                                      34

-------
              types of smelters
          d.  662, ^2* anc' opacity monitors
          e.  monitors that have passed the 168-hour performance test
      2)  Repeat the survey on the same 19 monitors at regular intervals.
      3)  Use survey gases that are at the 50 percent and 90 percent of the
full-scale concentration levels that are suggested in the October 6, 1975,
                4
Federal  Register  for calibration purposes.
      4)  Conduct evaluations of the pulsed fluorescence instrument at  oxygen
and C02 levels that are equal to those in the stack gas.
      5)  Introduce the survey gas at the probe exit whenever possible.
                                     35

-------
                                  REFERENCES
1.  U.S. Environmental Protection Agency.  Standards of Performance for New
    Stationary Sources.  Federal Register, 39:32852-32860, September 11, 1974.

2.  U.S. Environmental Protection Agency.  Standards of Performance for New
    Stationary Sources.  Federal Register, 39:37040-37049, October 16, 1974.

3.  U.S. Environmental Protection Agency.  Standards of Performance for New
    Stationary Sources.  Federal Register, 40:46250-46270, October 6, 1975.

4.  U.S. Environmental Protection Agency.  Standards of Performance for New
    Stationary Sources.  Federal Register, 41:2332-2341, January 15, 1976.

5.  Hamil, H. F., and D. Camann.  Collaborative Study of EPA Methods 5, 6,
    and 7 in Fossil Fuel-Fired Steam Generators:  Final Report.  U.S. Environ-
    mental Protection Agency Technical Report No. EPA-650/4-74-013.  May 1974.
    (Available from National Technical Information Service, 5285 Port Royal
    Road, Springfield, Virginia 22161.)
                                     36

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
1. REPORT NO.

  EPA-600/4-77-022
                             2.
                                                           3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE'

 SURVEY OF CONTINUOUS  SOURCE EMISSION MONITORS:  SURVEY
 NO. 1 - NOY AND  S09.
           /\        £.
             5. REPORT DATE
              April  1977  issuing date
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
 Michael C. Osborne  and M.  Rodney Midgett
9. PERFORMING ORGANIZATION NAME AND ADDRESS
 Quality Assurance  Branch
 Environmental Monitoring and Support Laboratory
 U.S. Environmental  Protection Agency
 Research Triangle  Park,  N.C. 27711
                                                           10. PROGRAM ELEMENT NO.
               1HD621
             11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
 Environmental Monitoring and Support Laboratory-RTP,  NC
 Office of Research  and Development
 U.S. Environmental  Protection Aqency
 Research Triangle Park. NC  27711	
             13. TYPE OF REPORT AND PERIOD COVERED

               Final	
             14. SPONSORING AGENCY CODE
                EPA/600/08
15. SUPPLEMENTARY NOTES
16. ABSTRACT
      The Quality  Assurance Branch (QAB) of the  Environmental Monitoring and Support
 Laboratory has  undertaken the task of evaluating  the accuracy and reliability  of
 continuous monitors  which have been on-line  for six months or longer.  Only extractive
 monitors installed in power plants, sulfuric acid plants, and smelters were included
 in the first  survey.  The program was designed  so that additional industries and  types
 of monitors could be included in later surveys.

      The plan for the initial survey involved sending NBS-traceable gas cylinders of
 varying concentrations of SO, or NO to the participating industries.  The gases from
 the cylinders were introduced into the monitoring systems and the resulting data  made
 available to  both the QAB and the industry.

      Results  from this survey of eight different  companies, ten different plant sites,
 and nineteen  different monitors revealed that less than half of the monitors failed to
 achieve a performance accuracy of + 10 percent.   The instruments which failed  most
 often were the ones  that have seenHess wide-spread use.  In general, the S02  monitors
 and the NO  monitors performed equally well.  However, more information was available
 on S0_ monitors since they outnumbered NO  monitors in this survey almost two  to  one.
      £                                    3\
17.
                               KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                             b. IDENTIFIERS/OPEN ENDED TERMS
                          c.  COSATI Field/Group
 Monitors
 Sampling
 Sulfur dioxide
 Nitrogen  oxide
 Air pollution
 Chimneys  or Emission
 Continuous emission
    monitors
  13B
18. DISTRIBUTION STATEMENT
  Release  to  Public
19. SECURITY CLASS (ThisReport)
 Unclassified
21. NO. OF PAGES
       42
                                              20. SECURITY CLASS (Thispage)
                                               Unclassified
                                                                        22. PRICE
EPA Form 2220-1 (9-73)
                                           37

-------