TRACEABILITY PROTOCOL FOR ESTABLISHING TRUE CONCENTRATIONS OF

          GASES USED FOR CALIBRATION AND AUDITS OF

             CONTINUOUS SOURCE EMISSION MONITORS

                      (Protocol No.  1)
                        June 15, 1978
       ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
             OFFICE OF RESEARCH AND DEVELOPMENT
            U.S. ENVIRONMENTAL PROTECTION AGENCY
        RESEARCH TRIANGLE PARK, NORTH CAROLINA  27711

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                               Table  of Contents
                                                                     Page
1.0       TRACEABILITY  PROTOCOL FOR  ESTABLISHING TRUE  	    1
          CONCENTRATION OF  GASES  USED  FOR CALIBRATION  AND AUDITS
          OF CONTINUOUS SOURCE EMISSION MONITORS
1.1       OVERVIEW OF TRACEABILITY PROCEDURES  .....  	    1
1.2       ESTABLISHING  TRACEABILITY  OF COMMERCIAL CYLINDER   	    1
          GASES  TO NBS, SRfl CYLINDER GASES
          1.2.1      Procedure for Instrument Calibration   	    2
          1.2.1.1    Instrument Multipoint Calibration  	    2
          1.2.1.2    Instrument Span  Check for  Linear Response  ....    6
                    Instrument
          1.2.1.3    Instrument Span  Check for  Non-Linear   	    6
                    Response Instrument
          1.2.2      Procedure for Analysis  of  Cylinder Gas   	    7
                    for True Concentration
          1.2.3      Use of  Gas Manufacturer's  Primary  Standards  ...    8
          1.2.4      Verification  of  Cylinder Gas Stability	    8
          1.2.5      Reanalysis of Cylinder  Gases   	    9
          1.2.6      Minimum Cylinder Pressure  	    9
          1.2.7      Cylinder Label and Analysis Report  	    9
1.3       PERFORMANCE AUDIT PROGRAM  	   10
1.4       REFERENCES	10

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                                                                 Protocol  No.  1
                                                                 Revision  No.  0
                                                                 Date:   June  15,  1978
                                                                 Page 1  of 10
1.0       TRACEABILITY PROTOCOL FOR ESTABLISHING TRUE CONCENTRATION  OF GASES
          USED FOR CALIBRATION AND AUDITS OF CONTINUOUS SOURCE  EMISSION
          MONITORS
1.1       OVERVIEW OF TRACEABILITY PROCEDURES
          Performance standards promulgated^  's'5'  by the U.S.  Environmental
Protection Agency for stationary sources require the installation and operation
of continuous monitoring systems for specified pollutants.   Extractive con-
tinuous monitoring systems for gaseous pollutants must  be calibrated and
audited using gas standards that are accurate and stable.
          The traceability procedure described here is  intended to minimize
systematic and random errors during the analysis of calibration and audit
gas standards and to establish the true concentrations  by means of National
Bureau of Standards, Standard Reference Materials (NBS, SRM).  The procedure
provides for a direct comparison between the  calibration and audit gas standards
and an NBS, SRM or a gas manufacturer's primary standard (GMPS) which is refer-
enced to NBS, SRM.  All comparisons are made  using instruments calibrated with
applicable NBS, SRM.  Traceability must be performed by the gas standard manu-
facturer at the time of purchase.  Reanalysis as described in 1.2.5 may be
performed by the gas standard manufacturer or by the user.
          This procedure is applicable to any continuous, semi-continuous or
periodic analysis instrument which meets the  performance requirements in the
following sections.
1.2       ESTABLISHING TRACEABILITY OF COMMERCIAL CYLINDER GASES TO NBS, SRM
          CYLINDER GASES

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                                                                 Revision  No.  0
                                                                 Date:   June 15,  1978
                                                                 Page  2 of 10
1.2.1     Procedure for Instrument Calibration
          The following procedures for periodic  multipoint calibration  and
daily instrument span checks are prescribed to minimize systematic  error.
Separate procedures for instrument span checks are described  for  linear and
non-linear instruments.  For this purpose,  a linear instrument  is defined as
one which yields a calibration curve which  deviates by 2% of  full scale or
less from a straight line drawn from the point determined by  zero gas to the
highest calibration point.   To be considered linear,  the difference between
the concentrations indicated by the calibration  curve and the straight  line
must not exceed 2% of full  scale at any point on the curve.
1.2.1.1   Instrument Multipoint Calibration
          A multipoint calibration curve is prepared monthly  using  two  SRM
cylinder gases and zero gas.  The zero gas  must  not contain more  than 0.2%
of the full scale concentration of the component being analyzed.  In addition,
zero gas must be free of any impurity that  will  give a response on  the
analytical instrument.  A list of SRM cylinder gases recommended  for trace-
ability of commercial cylinder gases is shown in Table 1.1.   A  list of  new
stationary sources which are required to install continuous source  emission
monitors for gaseous pollutants and diluent gases (CL and CCL)  is shown in
Table 1.2.  This table also lists existing  stationary sources that  may  be
required to install continuous source emission monitors for gaseous pollutants
and diluent gases.
          The multipoint calibration is accomplished by diluting  the highest
SRM with zero gas using a calibration flow  system.  Obtain the  instrument
response for 6 points representing 0, 10, 30, 50, 75 and 100% of  the instru-
ment full scale.  Plot the data and construct the calibration curve. Obtain
the instrument response for the other lower SRM  without dilution.  Compare

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                                                 Revision  No. 0
                                                 Date:  June 15,  1978
                                                 Page 3 of 10
TABLE 1.1  NBS, SRM AVAILABLE FOR TRACEABILITY  OF
       CALIBRATION AND AUDIT GAS STANDARDS

                 Cylinder Gases
SRM
(1)
(1)
1661
1662
1663
1664
(2)
1684
1685
1686
1687
(3)
(3)
(3)
(3)
(4)
(4)
1609
Type
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Sulfur Dioxide in N2
Nitric Oxide in N2
Nitric Oxide in N2
Nitric Oxide in N2
Nitric Oxide in N2
Nitrogen Dioxide in Air
Nitrogen Dioxide in Air
Nitrogen Dioxide in Air
Nitrogen Dioxide in Air
Oxygen in N2
Oxygen in N2
Oxygen in N2
Size
liters at STP
870
870
870
870
870
870
870
870
870
870
870
870
870
870
870
870
870
870
Nominal
Concentrations
50 ppm
90 ppm
500 ppm
1000 ppm
1500 opm
2500 ppm
3500 ppm
100 ppm
250 ppm
500 ppm
1000 ppm
250 ppm
500 ppm
1000 ppm
2500 ppm
2%
10%
21%

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                        TABLE 1.1 (Continued)
                                                           Protocol  No.  1
                                                           Revision  No.  0
                                                           Date:   June 15,  1978
                                                           Page 4 of 10
SRM
2622
2626
1674
(4)
1675
Type
Carbon Dioxide in N2
Carbon Dioxide in N2
Carbon Dioxide in N2
Carbon Dioxide in N2
Carbon Dioxide in N2
Size
liters at STP
870
870
870
870
870
Nominal
Concentrations
2%
4%
7%
10%
14%
(1)   SRM currently  under development, planned issue date September, 1979.

(2)   SRM currently  under development, planned issue date April, 1979.

(3)   SRM currently  under development, planned issue date July, 1979.

(4)   SRM currently  under development, planned issue date April, 1979.

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                                                          Protocol No.  I
                                                          Revision No. 0
                                                          Date:  June 15, 1978
                                                          Page 5 of 10
              TABLE  1.2   CONTINUOUS SOURCE EMISSION MONITORS FOR
                      NEW AND  EXISTING STATIONARY SOURCES
 Pollu-
 tant
  Source
    EPA
Regulation
Monitors Mid-Range and Span
Gas Concentrations, ppm (3)
 SO,
Steam Generation       SPNSS (1)
Steam Generation       SIP (2)
Petro. Refinery        SPNSS
Sulfuric Acid Plant    SPNSS
Sulfuric Acid Plant    SIP
Primary Smelters:      SPNSS
Copper, Lead & Zinc
                  Oil-500,  900; Coal-750, 1350
                  Coal-500  to 2000 (4)
                  50, 90
                  500,  900
                  2000  to 3500 (4)
                  1600  to 1800
 NO
Steam Generation
              Steam Generation
  SPNSS
                       SIP
Gas & Oil - 250, 450
Coal - 500, 900
Coal - 400 to 1500 (4)
              Nitric Acid Plant      SPNSS
              Nitric Acid Plant      SIP
                                       250, 450
                                       200 to 1000 (4)
co
Steam Generation
Steam Generation
  SPNSS
  SPNSS
EPA Regulation 40 CFR 60
(SPNSS) does not require
a specific setting for
monitor full scale
    (1)  Standards of Performance for New Stationary Sources.
    (2)  State Implementation Plan?  (for existing stationary sources).
    (3)  Required setting for monitor full  scale (called span value)  is
         specified in SNPSS (40 CFR  60).   Span is 90% and mid-range is  50%
         of the monitor full  scale.
    (4)  This is the range of typical operation.  Mid-range and span  gas
         concentrations needed will  depend on state regulations.   However,
         the concentrations should be within the range shown.

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                                                                 Revision  No.  0
                                                                 Date:   June  15,  1978
                                                                 Page 6  of 10
the apparent concentrations from the calibration curve  to the true  concen-
tration of the lower SRM.   If the difference between the apparent concentra-
tion and the true concentration of the lower SRM exceeds 3%  of the  true
concentration, repeat the multipoint calibration procedure.   Test the cali-
bration curve for linearity as defined in 1.2.1  and proceed  to either 1.2.1.2
or 1.2.1.3.
1.2.1.2   Instrument Span Check for Linear Response Instrument
          At the start of each day that cylinder gases  are to be  analyzed,
check instrument response to the highest SRM (or GMPS)  in the range to be
used and to zero gas.  Adjust response to the value obtained in the most
recent multipoint calibration and proceed to 1.2.2.  Cylinder gases analyzed
with a linear instrument must not have a concentration  greater than 15%  above
the highest available SRM concentration.
1.2.1.3   Instrument Span Check for Non-Linear Response Instrument
          At the start of each day that cylinder gases  are to be  analyzed,
check instrument response to two SRM (or GMPS) in the range  of calibration
gases to be analyzed and to zero gas as follows.  First, set the  instrument
zero with zero gas and then adjust the instrument response to the highest SRM
(or GMPS) to the value obtained in the most recent multipoint calibration.
Next, obtain the response to the lower SRM (or GMPS).  If the response to the
lower SRM (or GMPS) varies by greater than 3% from the  response obtained in
the most recent multipoint calibration, a full multipoint calibration must  be
performed as in 1.2.1.1, otherwise, proceed to 1.2.2.  Calibration  gases
analyzed with a non-linear instrument must not have a concentration greater
than the highest available SRM concentration.

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                                                                 * I U UUUU I  1 «U .  >
                                                                 Revision  No.  0
                                                                 Date:  June  15,  1978
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1.2.2     Procedure for Analysis of Cylinder Gas  for True Concentration
          The following procedure is designed to  establish the  true  concentra-
tion of a cylinder gas.  The analyses involve the direct comparison  of the
cylinder gas to the SRM (or GMPS) in order to compensate for variations  in
instrument response between the time of daily span check and the time of
analysis.  Significant variations in response often result from changes  in
room temperature, line voltage, etc.  Analyses are performed in triplicate
to expose erroneous data points and excessive random variations in  instru-
ments response.  After the gas cylinder has been  filled, a minimum  of 4  day
holding time must be observed before the following protocol analysis is
initiated.  (Note:  when steel cylinders are used for SOp, a minimum 15  day
holding time must be observed before the following protocol analysis is
initiated.)
          (a)  Analyze each cylinder gas directly against the nearest SRM
(or GMPS) by alternate analyses of the SRM and calibration gas  in triplicate
(3 pairs).  Adjust the instrument span if necessary prior to the analysis,
but do not adjust the instrument during the triplicate analyses. The
response to zero gas shall be obtained with sufficient frequency that the
change in successive zero responses does not exceed 1% of full  scale.
          (b)  For each of the six analyses, determine the apparent concen-
tration of the SRM (or GMPS) or cylinder gas from the calibration curve.
          (c)  For each pair of analyses, one SRM (or GMPS) and one cylinder
gas, calculate the true concentration of the cylinder gas by:
-r    o      ,- ^ i  n     «      i. ^      c ,* i  o     True Cone, of SRM  (or GMPS)
True Cone, of Cyl. Gas = Apparent Cone, of Cyl.  Gas x Apparent Cone, of  SRM (or GMPS)
          (d)  Determine the mean of the three values for true concentration
of the cylinder gas.

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                                                                 Revision No. 0
                                                                 Date:  June  15,  1978
                                                                 Page 8 of  10
          (e)  If any one value differs  from the  mean  by  greater  than  1.5%,
discard the data, reset the instrument span  if  necessary,  and  repeat steps  (a)
through (d).
1.2.3     Use of Gas Manufacturer's  Primary  Standards
          Gas manufacturer's primary standards  (GMPS)  are gas  mixtures  pre-
pared in pressurized containers and  analyzed against SRM  cylinder gases.
Their purpose is to conserve SRM where large quantities of gas cylinders  are
analyzed.   GMPS may be substituted for SRM for  instrument span check in 1.2.1.2
and 1.2.1.3, and cylinder gas analysis in 1.2.2 if the following  conditions
are met.  In no case may GMPS be substituted for  SRM for  the required  instrument
multipoint calibrations in 1.2.1.1.
          (a)  GMPS must have been analyzed  against SRM cylinder  gases  as
described in 1.2.1 and 1.2.2 within  30 days  of  their use  for cylinder  gas
analysis.   It is preferred that GMPS be  analyzed  on the days that instrument
multipoint calibrations are performed.
          (b)  GMPS must not have changed in concentration by  more than 1%  per
month (average) for the three-month  period prior  to their use  for cylinder
gas analysis.
1.2.4     Verification of Cylinder Gas Stability
          The stability of reactive  gases (including cylinder  gas of sulfur
dioxide, nitric oxide, and nitrogen  dioxide) must be verified  before use.
The stability of each cylinder gas  is verified  by performing a second  set of
triplicate analyses (using procedure in  1.2.2)  a  minimum  of 7  days after the
first set of triplicate analyses. The mean  of  the second triplicate analyses
must not differ from the mean of the first triplicate  analysis by more than 1.5%.

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                                                                 Protocol  No.  I
                                                                 Revision  No.  0
                                                                 Date:   June 15,  1978
                                                                 Page 9 of 10
1.2.5     Reanalysis of Cylinder Gases
          Reanalysis of reactive gases  by the  gas  manufacturer or user must be
performed every 6 months from the last  analysis  date  by the procedure in 1.2.2.
Cylinder gases used for audits may need to be  analyzed  more frequently than
every 6 months.  Reanalysis of diluent  gases  (Op and  CC^)  by the gas  manu-
facturer or user must be performed every 12 months from the last analysis date
by the procedure in 1.2.2
1.2.6     Minimum Cylinder Pressure
          No cylinder gas should be used below a cylinder  pressure of 200 pounds
per square inch as shown by the cylinder gas  regulator.
1.2.7     Cylinder Label and Analysis Report
          Each gas cylinder shipped by  a gas manufacturer  to a user must contain
the following minimum traceability information on  a gummed label affixed to
the cylinder wall and/or a tag attached to the cylinder valve:
          (a)  Cylinder number
          (b)  Mean concentration of cylinder  gas, ppm  or  mol  %
               (on last analysis date)
          (c)  Balance gas used
          (d)  Last analysis date
          (e)  Expiration date (six months after the  last  analysis date for
               reactive gases and 12 months for  diluent gases)
          In addition, a written analysis report should be prepared which
certifies the cylinder gas has been analyzed  according  to  this protocol.  The
analysis report should contain the following  information:
          (a)  Cylinder number
          (b)  Mean concentration of cylinder gas, ppm  or  mol  % (on last
               analysis date)
          (c)  Replicate analysis data

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                                                                 Protocol  No.  1
                                                                 Revision  No.  0
                                                                 Date:  June  15,  1978
                                                                 Page  10 of 10
          (d)   Balance  gas  used
          (e)   NBS,  SRM numbers  used  as  primary  standards
          (f)   Analytical  principle used
          (g)   Last  analysis  date
          The  user should maintain a  file  of  all  analysis  reports  for
three years.

1.3       PERFORMANCE AUDIT PROGRAM
          With the initiation and use of this  traceability protocol, the  U.S.
Environmental  Protection Agency  will  initiate  a  national performance audit
program of cylinder  gas prepared by this protocol.   Cylinder  gas prepared
following the  protocol  will be obtained  directly or  indirectly  by  the  U.S.
Environmental  Protection Agency  and analyzed  in  their  laboratory for accuracy
compared to the gas  manufacturer's reported concentration.

1.4       REFERENCES
          1.    Requirements for  Submittal  of  Implementation Plans  and  Standards
               for New  Stationary Sources  - Emission Monitoring. Federal
               Register 40, Number 194,  October  6, 1975, pages  46240-46270.
          2.    Part  60  - Standards of Performance for  New  Stationary Sources -
               Emission Monitoring Requirements  and  Revisions to Performance
               Testing  Methods,  Federal  Register 40, Number 246, December 22, 1975,
               pages 59204  and 59205.
          3.    Part  60  - Standards of Performance for  New  Stationary Sources -
               Primary  Copper, Zinc and  Lead  Smelters, Federal  Register 40,
               Number 10,  January 15, 1976, pages 2332-2341.

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