United States      Office of Air Quality        EPA-340/1 -86-009a
 Environmental Protection  Planning and Standards      May 1986
 Agency        Washington, DC 20460

 Stationary Source Compliance Series
CEMS PILOT
PROJECT:
Evaluation of
Opacity CEMS
Reliability and
QA Procedures
Volume I

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                                  EPA-340/1-86-009a
    CEMS  PILOT PROJECT:
 Evaluation  of Opacity CEMS
Reliability and QA Procedures
                Volume I
                   Prepared by
                 James W. Peeler
              CEM/Engineering Division
             Entropy Environmentalists, Inc.
         Research Triangle Park, North Carolina 27709
             Under Contract No. 68-02-3962
            Work Assignments 2-52 and 3-101
                 With JACA Corp.
              Fort Washington, PA 19039
                   Prepared for

             EPA Project Officer: John Busik
      EPA Work Assignment Managers: Anthony Wayne
                           and Mary Cunningham
        U.S. ENVIRONMENTAL PROTECTION AGENCY
           Stationary Source Compliance Division
         Office of Air Quality Planning and Standards
               Washington, D.C. 20460
                                   n  ;,  ,,- .:••)!•> I Protection AS.OU-
                   May 1986                   i  " ' ' •>')

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                                   DISCLAIMER

    Although the research described in this report has been funded wholly or in
part by the United States Environmental Protection Agency through Contract
68-02-3962 to Entropy Environmentalists, Inc., it has not been subject to the
Agency's peer and administrative review, and therefore does not necessarily
reflect the views of the Agency, and no official endorsement should be
inferred.

    Mention of specific trade names or products within this report does not
constitute endorsement by either the U. S. EPA or by Entropy Environmen-
talists, Inc.

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                           TABLE OF CONTENTS


                                                                        Page No.

Executive Summary	     i

1.0  Introduction.	     1

2. 0  Conclusions	     6

3.0  City Utilities, James River Station, Units No.  4 and 5...........     9
     3.1  Source and Monitor Descriptions	     9
          3.1.1 Source Description	     9
          3.1.2 Monitor Description	     9
     3.2  Initial Audit	     9
     3.3  Quality Assurance Procedures	    17
          3.3.1  Daily QA Checks	    17
          3.3.2  Periodic QA Checks	    21
          3.3.3  Corrective Action	    24
     3.4  Source Self Audit	    25
     3.5  Final Performance Audit	    25
     3.6  CEMS Downtime	    30
     3.7  Conclusions	    32

4.0  Union Electric Company, Portage Des Sioux, Units No. 1  and 2	    35
     4.1  Source and Monitor Descriptions	    35
          4.1.1 Source Description	    35
          4.1.2 Monitor Description	    35
     4.2  Initial Audit	    39
     4.3  Quality Assurance Procedures	    46
          4.3.1  Daily QA Checks	    46
          4.3.2  Periodic QA Checks	    52
          4.3.3  Corrective Action	    56
     4.4  Source Self Audit	    57
     4.5  Final Performance Audit	    66
     4. 6  CEMS Downtime	    76
     4. 7  Conclusions	    78

5.0  Kansas City Power and Light Company, latan Station	    81
     5.1  Source and Monitor Descriptions	 •»	    81
          5.1.1 Source Description	    31
          b. 1. 2 Monitor Description	    81
     5.2  Initial Audit	    81
     5. 3  Quality Assurance Procedures	    86
          5.3.1  Daily QA Checks	    86
          5.3.2  Periodic QA Checks/Corrective Action	    90
     5.4  Source Self Audit/Off-Stack Zero Check	    92
     5. 5  Final Performance Audit	    92
     5. 6  CEMS Downtime	    9b
     5.7  Conclusions	    95

(continued)

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TABLE OF CONTENTS (continued)
                                                                          Page No.
    6.0  St. Joseph Light and Power Company,  Lake Road Station,
           Unit No. 5	    99
         b.1  Source and Monitor Descriptions	    99
              6.1.1 Source Description	    99
              6.1.2 Monitor Description	    99
         6.2  Initial Audit	    99
         6.3  Quality Assurance Procedures	   102
              6.3.1  Daily QA Checks	   103
              6.3.2  Periodic QA Checks/Corrective Action	   106
         6.4  Source Self Audit	   109
         6.5  Final Performance Audit	   109
         6.6  GEMS Downtime	   112
         6.7  Conclusions	   112

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                                 LIST OF TABLES


Table No.                                                                 Page No.

  1 -1.     Opacity GEMS Study Sources	        2

  3-1.     Summary of Performance Audit Results, City Utilities,
            James River Station, Unit No. 4, Dynatron Model 1100
            Opacity Monitoring System	       15

  3-2.     Summary of Performance Audit Results, City Utilities,
            James River Station, Unit No. 5, Dynatron Model 1100
            Opacity Monitoring System	       16

  3-3.     Periodic QA Check Results: City Utilities, James River
            Station, Boiler No. 4, Monitor No. 2	       22

  3-4.     Periodic QA Check Results: City Utilities, James River
            Station, Boiler No. 5, Monitor No. 1	       23

  3-5.     Summary of Performance Audit Results, City Utilities,
            James River Station, Unit No. 4, Source Self Audit,
            Dynatron Model 1100 Opacity Monitoring System	       26

  3-6.     Summary of Performance Audit Results, City Utilities,
            James River Station, Unit No. 5, Source Self Audit,
            Dynatron Model 1100 Opacity Monitoring System	       27

  3-7.     Summary of Final Performance Audit Results, City Utilities,
            James River Station, Unit No. 4, Dynatron Model 1100
            Opacity Monitoring System	       28

  3-8.     Summary of Final Performance Audit Results, City Utilities,
            James River Station, Unit No. 5, Dynatron Model 1100
            Opacity Monitoring System	       29

  4—1.     Summary of Initial Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 1, Monitor A
            Lear Siegler Opacity Monitoring System	       40

  4-2.     Summary of Initial Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 1, Monitor B
            Lear Siegler Opacity Monitoring System	        41

  4-3.     Summary of Initial Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 2, Monitor A
            Lear Siegler Opacity Monitoring System	       42


  4-4.     Summary of Initial Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 2, Monitor B
            Lear Siegler Opacity Monitoring System	       43

   (continued)

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LIST OF TABLES (continued)


Table No.                                                                Page No.


  4-5.     Dual Audit Experiment Data and Results:
            Union Electric Company	       44

  4-6.     Periodic QA Check Results: Union Electric Company,
            Sioux Station, Units No. 1 and 2	       53

  4-7.     Summary of Performance Audit Results, Union Electric
            Company, Sioux Station, Unit No. 1,  Monitor A,  Source
            Self Audit, Lear Siegler Opacity Monitoring System.......       58

  4-8.     Summary of Performance Audit Results, Union Electric
            Company, Sioux Station, Unit No. 1,  Monitor B,  Source
            Self Audit, Lear Siegler Opacity Monitoring System	       60

  4-9.     Summary of Performance Audit Results, Union Electric
            Company, Sioux Station, Unit No. 2,  Monitor A,  Source
            Self Audit, Lear Siegler Opacity Monitoring System.......       62

  4-10.    Summary of Performance Audit Results, Union Electric
            Company, Sioux Station, Unit No. 2,  Monitor B,  Source
            Self Audit, Lear Siegler Opacity Monitoring System.......       64

  4-11.    Summary of Final Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 2, Monitor A
            Lear Siegler Opacity Monitoring System	       68

  4-12.    Summary of Final Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 2, Monitor B
            Lear Siegler Opacity Monitoring System.	      70

  4-13.    Summary of Final Performance Audit Results, Union
            Electric Company, Sioux Station, Unit No. 1, Monitor A
            Lear Siegler Opacity Monitoring System	      72

  4-14.    Summary of Final Performance Audit Results, Union
            Electric Company, Sioux  Station, Unit No. 1, Monitor B
            Lear Siegler  Opacity Monitoring System	      74

  5-1.     Summary of Initial Performance  Audit Results, Kansas City
            Power and Light Company,  latan Station,  Unit No.  1,
            Lear Siegler  Opacity Monitoring System	      85

  5-2.      Summary  of Performance  Audit  Results, Kansas City  Power  and
            Light  Company,  latan Station,  Source Self Audit,
            Lear Siegler  Opacity Monitoring System	      93

   (continued)

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LIST OF TABLES (continued)


Table No.                                                                Page No.


  5-3.     Summary of Final Performance Audit Results, Kansas City
            Power and Light Company, latan Station, Unit No.  2,
            Lear Siegler Opacity Monitoring System	        94

  6-1.     Summary of Initial Performance Audit Results, St.  Joseph
            Light and Power Company, Lake Road Station, Unit No.  5,
            Contravez Goerz Model 400 Opacity Monitoring System	       101

  6-2.     Summary of Performance Audit Results, St. Joseph Light
            and Power Company, Lake Road Station, Unit No. 5,
            Source Self Audit, Contraves Goerz Model 400 Opacity
            Monitoring System	       110

  6-3.     Summary of Final Performance Audit Results, St. Joseph
            Light and Power Company, Lake Road Station, Unit No.  5,
            Contraves Goerz Model 400 Opacity Monitoring System	       111

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                                LIST OF FIGURES
Figure No.                                                               Page No.

  3-1.      City Utilities, James River Station,  Unit No.  4
             Opacity GEMS Project.	         10

  3-2.      City Utilities, James River Station,  Unit No.  4
             Opacity GEMS Project	         11

  3-3.      Unit No. 4 Opacity Monitoring Location	         12

  3-4.      Unit No. 5 Opacity Monitoring Location	        13

  3-5.      Example Opacity GEMS Daily Log:  City Utilities,
             James River Station	        18

  3-b.      GEMS Downtime: City Utilities, James River Station,
             Units No. 4 and 5	        31

  <*-1.      Union Electric Company, Portage Des Sioux Station,
             Unit No. 1: Opacity GEMS Project Study	        36

  4-2.      Union Electric Company, Portage Des Sioux Station,
             Unit No. 2: Opacity GEMS Project Study	        37

  4-3.      Schematic Diagram of Opacity GEMS	        38

  4-4.      Example Opacity GEMS Daily Log:  Union Electric Company
             Portage Des Sioux Station	        47

  4-5.      GEMS Downtime: Union Electric Company, Portage Des
             Sioux Station, Units No. 1 and 2	        77

  5—1.      Kansas City Power and Light Company, latan Station,
             Opacity GEMS Project	        82

  5-2.      Kansas City Power and Light Company, latan Station
             Monitoring Location	        83

  5-3.      Example Opacity GEMS Daily Log:  Kansas City Power
             and Light Company, latan Station	        87

  5-4.      GEMS Downtime: Kansas City Power and Light Company,
             latan Station	        96

  b-1.      St. Joseph Light and Power and Light Company,  Lake  Road
             Station, Unit No. 5: Opacity GEMS Project	       100
   (continued)

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LIST OF FIGURES (continued)

Figure No.                                                              Page tio.

  b-2.      Example Opacity GEMS Daily Log:  St.  Joseph Light
             and Power Company,  Lake Road Station	       104

  6-3.      GEMS Downtime:  St.  Josepn Light  and  Power Company,
             Lake Road Station,  Unit No.  5......	       113

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                               EXECUTIVE SUMMARY

    A field study was conducted at several sources as part of the GEMS Pilot
Project in Missouri in order to evaluate the reliability of opacity continuous
emission monitoring data and to facilitate the development and evaluation of
quality assurance (QA) procedures for opacity continuous emission monitoring
systems (CEMS's).  The field study included opacity CEMS's installed on six
coal-fired electric utility generating units located at four generating
stations, each owned by a different utility company.  The study sources were
selected to be representative of a wide range of monitoring applications and
conditions, and were equipped with contemporary opacity monitoring instrumen-
tation provided by the three ma]or opacity GEMS manufacturers.

    For each station included in the study, monitor- and source-specific
opacity GEMS QA procedures were developed.  Opacity GEMS performance and system
audits were conducted at each unit at the beginning of the one-year field
study.  Plant personnel implemented and revised the QA procedures and conducted
a performance audit during a 6- to 8-month period.  Performance audits were
also conducted at the end of the field study.

  This report details the results that were obtained from the project and
presents evaluations both of opacity GEMS reliability (i.e., accuracy,
precision, and availability) and of the effectiveness of the QA procedures that
were developed and used in this study.  In summary, appropriate and effective
QA procedures can be developed and implemented for a variety of opacity
monitoring equipment and applications without imposing an undue burden on the
monitor operators.  Such procedures are inherently source- and monitor-
specific.  Reliable opacity monitoring data are obtained when appropriate QA
procedures are implemented.  The use of such QA procedures results in opacity
monitoring data of sufficient accuracy, precision, and availability to be used
as a reliable indicator of process and control system problems that affect
particulate emissions.

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                               1.0  INTRODUCTION

    As part of the GEMS Pilot Project in Missouri, a field study was conducted
at a limited number of sources in order to evaluate the reliability of opacity
continuous emission monitoring data and in order to facilitate the development
and evaluation of quality assurance procedures for opacity continuous emission
monitoring systems (CEMS's).  The field study included opacity CEMS's installed
on six coal-fired electric utility generating units located at four generating
stations, each of which is owned by a different utility company.  The sources
included in this study were selected to be representative of a wide range of
monitoring applications and conditions, and were equipped with contemporary
opacity monitoring instrumentation provided by the three major OEMS manufac-
turers.  This report summarizes the results that were obtained from the project
and presents evaluations both of opacity GEMS reliability (i.e., accuracy,
precision, and availability) and of the effectiveness of the QA procedures that
were developed and used in this study.

    As the first step in the field study, information was compiled on the
various electric utility steam generating units in Missouri that are required
to implement opacity monitoring programs.  Basic information included data
regarding: the size/capacity of the installation, year on-line, primary and
alternative fuel, type of control equipment, and the applicable monitoring
regulations and standards (i.e., state regulations for existing sources versus
EPA NSPS regulations).  More detailed information was also obtained regarding
the status of opacity monitoring programs for the various generating units.
This information included: (1) the type of monitor installed, (2) monitor
installation location(s), (3) the type(s) of data handling system(s), (4)
performance specification test results, (5) previous opacity GEMS performance
audit results, (6) whether required quarterly excess emission reports were
being submitted, and (7) previous GEMS problems and/or excess emissions
problems.

    Based on the information that was compiled, opacity CEMS's on six
generating units at four different generating stations were selected for the
study.  Some of the important parameters of the four study sources are
summarized in Table 1-1.  All four of the study sources are pulverized
coal-fired electric utility boilers and are equipped with electrostatic
precipitators for the control of particulate emissions.  All six generating
units are subject to opacity monitoring requirements, and all submit quarterly
excess emission reports (EER's) to the Missouri Department of Natural Resources
(DNR).  In addition, the opacity CEMS's on each of the six generating units had
been installed at least 1 year prior to this study and had successfully comple-
ted the required initial performance specification test.

    The differences among the generating stations and units selected for this
study are perhaps more revealing than their similarities with respect to the
representativeness of the results obtained.  The capacities of the various
units ranged from 25 MW to 680 MW, thus including both the smallest sources
that are subject to opacity monitoring requirements and the second largest unit
currently operational in Missouri.  The various units were placed in service
between 1951 and 1980, and thus reflect changes that have occurred over a
30-year period with respect to power plant design and construction.  The study
included contemporary opacity monitoring instrumentation manufactured by

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    TABLE 1-1.  OPACITY CEMS STUDY SOURCES
(SIX ELECTRIC UTILITY STEAM GENERATING UNITS
        EQUIPPED WITH COLO SIDE ESPs)
COMPANY, STATION UNIT
Kansas City Power and Light Unit 01
latan Station
St. Joseph Light & Power Co. Unit 05
Lake Road Station
City Utilities, Springfield Unit 04
James River Station
City Utilities, Springfield Unit 05
James River Station
Union Electric Company Unit ti
Sioux Station
Union Electric Company Unit #2
Sioux Station
OPACITY
STANDARD
20%
(NSPS)
20%
(SIP)
40%
(SIP)
40%
(SIP)
20%
(SIP)
20%
(SIP)
MONITOR TYPE DATA RECORDER
LSI RM-41 STRIP CHART
CONTRAVES-GOERZ STRIP CHART
Model 400
DYNATRON Model 1100 STRIP CHART/
DATA LOGGER
DYNATRON Model 1100 STRIP CHART/
DATA LOGGER
TWO LSI RM41s COMPUTER DATA
LOGGER
(STRIP CHARTS)
TWO LSI RM41s COMPUTER DATA
LOGGER
MONITORING APPLICATION
Stack-mounted monitor at 300 ft
elevation.
Stack-mounted monitor.
Duct-mounted monitor on
pressurized boiler.
Stack-mounted monitor.
Dual, duct-mounted monitors
with parallel analog & digital
combiner system.
>
Dual, duct-mounted monitors
with parallel analog & digital
                                 (STRIP CHARTS)
combiner system.

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Lear Siegler, Inc. (LSI); Uynatron, Inc.; and Contraves Goerz Corporation.
The study addressed a variety of opacity GEMS applications typical of those
commonly encountered in the electric utility industry, such as: (1) a
stack-mounted monitor with very difficult access to the monitoring location
(i.e., 300-foot ladder);  (2) a stack-mounted monitor with very easy access; (3)
identical monitoring equipment on two units at the same station, with one
monitor installed in a horizontal, circular, metal duct on a pressurized boiler
and the other monitor installed in the masonry exhaust stack of a balanced
draft boiler; and (4) identical opacity GEMS's installed on two generating
units where each system is composed of two transmissoraeters (one on each of a
pair of twin ducts downstream of the ESP's) and both analog and digital systems
for determining the combined stack exit opacity for the single exhaust stack of
each generating unit.  Two of the stations and four of the units had opacity
GEMS's with data loggers or computerized data handling systems.  The other
units relied solely on the use of strip chart recorders.  In addition to the
above differences, which were apparent at the outset of the study, significant
differences among the various sources were observed as the study progressed
with respect to (1) the management and organizational structure of the
personnel involved with the opacity monitoring program, (2) the relationship
between station personnel and corporate representatives, and (3) the presence
and impact of union agreements that affected the operation and/or maintenance
of the opacity GEMS's.

    For each of the stations selected for the study, preliminary draft opacity
GEMS QA procedures were developed.  The development of these preliminary
procedures was based on  (1) the design of the monitoring system, (2) informa-
tion from the operator's manuals provided by the monitor manufacturers, and (3)
previous experience in testing and auditing similar monitors.  An initial audit
of each of the six opacity CEMS's was performed.  Each initial audit included a
systems audit (i.e., a qualitative evaluation of operation, maintenance, and
record keeping practices) and a performance audit (i.e., a quantitative
evaluation of GEMS accuracy and precision).  Based on information gained from
the initial audits and comments provided by personnel from the participating
sources, the preliminary QA procedures were revised.  These revisions primarily
addressed (1) source-specific factors that were unknown prior to the initial
auait, (2) inclusion of existing routine maintenance procedures in the draft
periodic QA procedures, and (3) modification of the QA procedures to make them
compatible with the management and organizational structure of each of the
participating sources.  For each source, the QA procedures included: (1)
relatively simple checks to be performed on a daily basis from the monitor
control unit location  (i.e., the boiler control room), (2) periodic QA checks
to be performed (usually on a monthly basis) both at the actual monitoring
location and at the control unit, and (3) generalized corrective action
procedures to be used when daily QA check and/or periodic QA check control
limits were exceeded or when repairs to the opacity GEMS were necessary.
 During this project, Thermo Electron, Inc. acquired the sole rights to sell
 the opacity monitor previously manufactured and sold by Contraves Goerz.  The
 monitor is now referred to as a TECO Model 400; however, throughout this
 report, the monitor is referenced as a Contraves Goerz Model 400 opacity GEMS.

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    After agreement with source representatives was obtained on all of the
detailed step-by-step QA procedures, station personnel implemented these
procedures for approximately 6 to 8 months.  The QA documentation was then
reviewed by the project team, and recommendations for revisions to the QA
procedures were made.  In most cases, suggestions were made to simplify the QA
procedures based on analysis of the data that had already been obtained.

    Personnel from each station were asked to conduct a performance audit of
the CEMS('s) included in the study using audit equipment supplied by the
project team and procedures similar to those used in the initial performance
audit of the opacity CEMS('s).  The purposes for requesting the source self
audits were: (1) to quantify further the accuracy and precision of the opacity
GEMS data and (2) to determine if source personnel could conduct such audits
with little or no training.  Each station conducted an audit of their opacity
CEMS('s) and provided copies of the audit results to the project team.

    The four study sources continued the implementation of the opacity GEMS QA
procedures to varying degrees for the duration of the approximate 1-year
study.  The field study was concluded at each station when the project team
completed the final performance audit of the CEMS('s) and interviewed station
personnel to obtain additional comments regarding the reliability of the
opacity monitoring equipment and the appropriateness/effectiveness of the QA
procedures.

    In addition to the QA documentation provided by each of the study sources
and the results of the performance audits that were conducted, data and
information on opacity GEMS performance were also obtained from the review of
EER's that were submitted to the Missouri DNR.  These data were used to
supplement and to compare with the QA documentation.  (An evaluation of monitor
performance based on data for all electric utility sources in Missouri
submitting quarterly reports to the DNR is contained in "An Analysis of Opacity
GEMS Downtime in Excess Emission Reports: Opacity GEM Pilot Project Report"
 (May 1986).

    It is emphasized that two of the major technical objectives of the  opacity
GEM Pilot Project field study were  to determine  (1) whether appropriate and
 effective opacity GEMS QA procedures could be  developed and implemented for a
 variety of opacity monitoring equipment and applications without imposing an
 undue burden on the monitor  operators, and  (2) whether reliable opacity moni-
 toring  data are obtained when such  QA procedures are used.  For this project,
 the quality of opacity GEMS  data was considered adequate when the data  were of
 sufficient  accuracy, precision, and availability to provide a reliable  indica-
 tion of process and  control  system  problems for both source representatives and
 control agency personnel.  Thus, this study did not  attempt to identify or to
 define  the  "ideal" or  "absolute minimum" QA plan.  Instead, the study attempted
 to develop, for a number of  monitor- and source-specific situations,  relatively
 simple, cost  effective QA procedures.  It  was  intended that the process of
 developing  these procedures  and the flexibility of the approach that  was used
 would provide examples  that  could  be easily adapted  for other  sources and
 situations.   An  example  of  this approach is provided by the QA control  limits
 used in this  study.   These limits  reflect  a rough  balance between what  is
 achievable  and what  is necessary  to ensure that  the  opacity monitoring  data are
 reasonably  reliable.   As  a specific example,  the  zero  and span check  control
 limits  varied slightly among the  four  study sources  (due to monitor-  and

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source-specific technical considerations as well as to the opinions of monitor
operators as to what tolerance was appropriate), and differed from the
currently applicable EPA requirements.  However, these differences in specific
QA control limits are not considered important, since the QA control limits can
be easily adjusted to whatever level is appropriate for any particular case.
Again, the specific QA control limits should be established at a level (1) that
ensures monitoring data will be of sufficient accuracy and precision to
facilitate the intended use of the data, and (2) that takes into account the
level of performance that can be achieved when the opacity GEMS is properly
operated and maintained.

    Section 2.0 of this report presents the overall findings and conclusions
that were obtained from the Missouri Opacity GEMS Pilot Project relative to
opacity GEMS reliability and to the evaluation of QA procedures.  Sections 3.0
through 6.0 present relevant background information, a detailed summary and
discussion of the data and results obtained, and the conclusions that were
developed for each of the study sources.  Appendices A through D include copies
of source-specific QA procedures, daily QA check summaries, and the data and
calculations resulting from the source self audits.  Appendix E includes a
report describing the calibration procedures and results for the neutral
density filters used in the performance audits of the opacity CEMS's during the
project.

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                                2.0  CONCLUSIONS
    This section presents the overall conclusions developed from the Missouri
Opacity CEMS Pilot Project with respect to opacity GEMS reliability (i.e.,
accuracy, precision, and availability) and to the effectiveness of opacity CEMS
quality assurance procedures.  These conclusions are supported by the
information included in Sections 3.0 through 6.0, which present the results
obtained at each of the four study sources.

    1.  Most properly operated and maintained opacity CEMS's can achieve high
        levels of monitor availability (i.e., greater than 95% of the hours per
        calendar quarter), regardless of whether a single monitor CEMS or a
        dual monitor/combiner system CEMS is used.

    2.  Monitor availability can be improved at sources using computerized data
        handling systems if properly calibrated chart recorders are used as
        back-up recording devices during computer system outages.

    3.  The accuracy and precision of opacity CEMS data relative to zero (or
        low range) and span checks can be maintained within +^2.5% opacity with
        very few calibration adjustments per year for CEMS's equipped with
        chart recorders, data loggers, or computerized data handling systems.

    4.  The accuracy of opacity CEMS data can be consistently maintained within
        +^3% opacity relative to audit filter values used in calibration error
        checks for opacity CEMS's equipped with chart recorders, data loggers,
        or computerized data handling systems.

    5.  On-stack, clear-path zero checks (i.e., zero alignment tests)  cannot be
        performed for most sources because of the presence of significant
        residual opacity during source outages.

    6.  Off-stack, clear-path zero checks can be performed;  however, some CEMS
        operators contend that such tests do not enhance the accuracy of the
        opacity monitoring data.   CEMS operators did not attempt the alter-
        nate zero alignment procedures that were recommended during this
        project, even though these procedures can be performed at the
        monitoring location.

    7.  Appropriate and effective opacity CEMS QA procedures are inherently
        monitor- and source-specific.  In addition, the designation of
        responsibilities for particular QA activities must be consistent with
        the management and organizational structure for the personnel at the
        power plant.

    8.  It has been demonstrated that opacity CEMS QA procedures can be
        developed and successfully implemented where only a few personnel are
        responsible for the opacity monitoring program, or where many personnel
        share responsibility for the opacity monitoring program.  The need for
        clearly written QA procedures and careful, complete documentation of QA
        check results increases in direct proportion to the number of people
        involved in the opacity monitoring program.

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 9.   Some monitor system fault indicators are useful in the identification
     of monitor operational problems.

10.   Daily QA checks of opacity CEMS's provide both timely identification of
     problems and adequate records from which changes in monitor performance
     and/or chronic monitoring problems can be identified.    Such checks may
     include (a)  checks of fault indicators, (b)  determination of whether
     the opacity CEMS (including the data recording system)  is operating
     within applicable zero and span check control limits,  and (c)  checks of
     other readily accessible  monitor-specific parameters.

11.   Adequate and effective checks for most opacity CEMS's can be completed
     from the monitor control unit (usually located in the boiler control
     room), and typically require less than 5 minutes per monitor per day to
     perform.

12.   Optimization of the parameters to be included in daily QA checks is
     facilitated by recording values for all parameters in question for some
     baseline period, and subsequently selecting  an appropriate frequency
     for performing the checks based on observed  monitor performance (i.e.,
     the stability of the recorded values over time).

13.   Periodic QA procedures provide for (a) the identification of problems
     that may otherwise be overlooked, (b) verification of proper opera-
     tional status of parameters not included in  the routine zero/span
     checks or daily checks, and (c) a means by which the optimum frequency
     for various activities included in the periodic QA procedures can be
     determined.  Periodic QA procedures may include (a) zero and span
     checks for all data display devices, (b) checks of optical alignment,
     (c) checks for dust accumulation on, and cleaning of,  exposed optical
     surfaces, (d) checks of auxiliary monitoring parameters (e.g., refer-
     ence currents/voltages, etc.), and (e) performance of preventive
     maintenance procedures recommended by the manufacturer.

14.   It has been demonstrated that effective O.A procedures may involve the
     performance of periodic QA checks at frequencies ranging from once per
     month to once every four months.  The time required to perform such
     tests typically ranges from 2 to 8 hours per periodic QA check.  Both
     the frequency of performing such checks and the time required to
     complete them will vary depending on monitor- and source-specific
     factors.

 15.   Properly conducted performance audits provide a valid means of
     assessing monitor performance; however, they do not provide a check of
     the accuracy of the zero adjustment status.

 16.  In order to provide a representative indication of actual monitor
     performance, audit procedures published previously (i.e. , "Performance
     Audit Procedures for Opacity Monitors," EPA-340/1-83-010) should be
     modified to account for source-specific factors (see "Opacity CEMS
     Audit Procedures Guidelines: Opacity CEMS Pilot Project Draft Report,"
     March  1985).

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   17.  Modified performance audit procedures must be used for dual
        CEMS/combiner applications in order to obtain a representative
        indication of monitor performance (see "Opacity GEMS Audit Procedures
        Guidelines: Opacity GEMS Pilot Project Draft Report," March 1985).

   18.  Most electric utility generating stations have personnel capable of
        conducting opacity GEMS performance audits with little or no formal
        training, provided that they receive clearly written audit procedures
        with examples of completed data sheets and calculations.

   19.  Most electric utility generating stations with opacity CEMS's that  have
        been installed for at least 1 year have personnel who thoroughly
        understand how the monitor works and who are capable of performing
        virtually all necessary repairs and/or adjustments to maintain the
        opacity GEMS within the applicable control limits.

    In summary, appropriate and effective QA procedures can be developed and
implemented for a variety of opacity monitoring equipment and applications
without imposing an undue burden on the monitor operators.  Such procedures are
inherently source- and monitor-specific.  Reliable opacity monitoring data  are
obtained when appropriate QA procedures are implemented.   The use of such QA
procedures results in opacity monitoring data of sufficient accuracy, pre-
cision, and availability to be used as a reliable indicator of process and
control system problems that affect particulate emissions.

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          3.0  CITY UTILITIES, JAMES RIVER STATION,  UNITS NO.  4 AND 5


    This section provides relevant background information and a summary and
discussion of results obtained from both (1 ) the implementation of quality
assurance procedures and (2) the performance audits of the installed opacity
CEMS's at City Utilites' James River Station, Units No. 4 and 5.  An overview
of the field study conducted for these two units is provided in Figures 3-1 and
3-2.


3.1  SOURCE AND MONITOR DESCRIPTIONS

3.1.1  Source Description

    Three coal-fired electric utility steam generating units are currently
operational at the City Utilities James River Station.  All three units operate
independently, and each unit is equipped with an electrostatic precipitator
(ESP) and an exhaust stack.  Units No. 3, 4, and 5 are rated at 44, 60, and
105 MW capacity, respectively.  The coal used to fuel all three units is mined
in Kansas and Oklahoma and typically ranges from 2% to 3% sulfur.  All three
units are subject to a Missouri opacity limit of 40%.  As shown in Figures 3-1
and 3-2, Units No. 4 and 5 operated intermittently during the field study.


3.1.2  Monitor Description

    Units No. 3, 4, and 5 are each equipped with a separate Dynatron Model 1100
opacity monitoring system; however, only the performance of the Units No. 4 and
5 monitors were evaluated during this project.  Units No. 4 and 5 represent
different opacity monitoring applications, even though identical instrumen-
tation is used for the two units.  Unit No. 4 is a pressurized boiler, and the
opacity monitor is located in a metal, horizontal, circular duct between the
ESP and the stack (see Figure 3-3).  Unit No. 5 is a balanced draft boiler; the
opacity monitor is installed in the masonry exhaust stack (see Figure 3-4).

    Each of the Dynatron Model 1100 opacity monitors utilized at the James
River Station consists of a single transmissometer (transceiver and reflector)
and a monitor control unit.  Plastic weather covers with tight fitting seals
and internally mounted purge air systems are provided at each of the
transceiver and reflector installation locations.  Both transceivers are
equipped with optical alignment sights.  A single, 3-pen strip chart recorder
and a time-shared data logger are used to record data for all three monitors.
All three monitor control units, the strip chart recorder, and the data logger
are mounted together in the boiler control room.  Six-minute average effluent
opacity levels are displayed by the strip chart recorder; the data logger
provides a printed record of calibration data and effluent opacity values
greater than 40% opacity.
 3.2   INITIAL AUDIT

    Initial audits  of the opacity CEMS's installed at the James River Station
 Units No.  4 and 5 were performed on April 12, 1983.  The audits included  (1) a
 visual  evaluation of the monitor installation location, (2) a systems audit

-------
  BOILER DOVN-
MONITOR DOVN-
    PERIODIC
    QA CHECKS
     DAILY QA .
      CHECKS
       AUDITS-
 4/12
INITIAL
AUDIT
                          I
II     I
  I
                                                                                     X  X
                                       5/17
                                       SELF
                                       AUDIT
 6/6
FINAL
AUDIT
                        I       I       I       I       I        I      I       I       I       I       I       I       I
                  APR.   MAY  JUNE   .JULY    AUG.  SEPT.  OCT.   MOV.    DEC.   JAW,  FEB.  MAR.   APR.    MAY    JUNE
                                              U983)
                                                        MONTHS
                                 (I 984)
                                cjURE 3-1  CITY UTILITIES , JAMES RIVER UNIT NO. 4  OPACITY CEMS PRO.JECT

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  BOILFR DOVN-
MONITOR DOVN-
   PERIODIC
   QA CHECKS
     DAILY QA
      CHECKS
       AUDITS-^
Dl
HIM
                                      5/1 7
                                      SELF
                                      AUDIT
              6/6
             FINAL
             AUDIT
                      I       i      i       i      i       \      i       i      i       i      r      i       (       i
                 APR,   MAY  JUNE   JULY   AUG.  SEPT.   OCT.  NOV.    DEC.   JAN   FEB.  MAR.   APR.   MAY    JUNE
                                          C1983J
     MONTHS
  (1994)
                             FIGURE 3~2.  CITY UTILITIES, -JAMES RI'v'ER UNIT NO. 5  OPACITY CET-1S PROJECT

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o
--J
CXI
               t


               .-*.

               ^






              I
                                                     TRANSCEIVER
                                                       REFLECTOR
                                                                                        ESP
                             FIGURE 3-3. UNIT NO. 4 OPACITY MONITORING LOCATION

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                                                                       13
             \4— 8'4"
t
                   37777?^
                 12-8"
J
                                                           350'
T
                                                   I
  FIGURE 3-4. UNIT NO. 5 OPACITY MONITORING LOCATION

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                                                                                14
(i.e., a qualitative evaluation of monitor operation, maintenance,  and record
keeping practices), and (3) a performance audit of each opacity GEMS (i.e.,  a
quantitative evaluation of monitor accuracy and precision).   Detailed
discussions of the findings and results of the initial audits are included in
the April 1983 audit report for this station.

    The results of the initial performance audits of the Units No.  4 and 5
opacity CEMS's are summarized in Tables 3-1 and 3-2, respectively.   The
following conclusions were derived from the initial audits of the James River
opacity monitoring systems.

Monitor Installation Location

    1. The Unit No. 5 monitoring system is installed in accordance with
       Performance Specification 1, Appendix B, 40 CFR 60,  and the measurement
       location provides opacity measurements that are representative of the
       entire effluent stream.

    2. The Unit No. 4 monitoring system is installed in accordance with
       Performance Specification 1, Appendix B, 40 CFR 60,  and is installed at
       the best available monitoring location, since no access nor ports are
       available in the Unit No. 4 masonry stack.  It is believed that the
       measurement location provides opacity measurements that are represen-
       tative of the entire effluent stream.

    3. The Units No. 4 and 5 opacity monitoring systems are not currently
       subject to any known adverse environmental conditions.

    4. The excellent access to the installed transmissometers on Units No. 4 and
       5 facilitates performance of necessary monitor maintenance activities.


Monitor Operation, Maintenance, and Record Keeping

    1. The Units No. 4 and 5 opacity monitoring instrumentation operates
       reliably.  High levels of monitor availability are achieved; adjustments
       of zero and/or span values are rarely, if ever, required.

    2. Problems with the inconsistent operation of the data logger timer are due
       to short term fluctuations  (i.e., spikes and glitches) in the power
       supply voltage.

    3. Successful solutions for several previously encountered monitor
       operational problems have been devised by source personnel  (e.g.,
       fabrication of prototype Teflon/stainless steel transition pieces to
       eliminate corrosion problems, fabrication of a rubber shroud to prevent
       rain water runoff from being aspirated into the purge air system, etc.).

    4. Monitor alignment problems  during boiler outages due to thermal contrac-
       tions of the metal duct at  the monitoring location will continue to
       necessitate additional maintenance activities for the Unit No. 4 monitor.

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                                                                                15
               TABLE 3-1.  SUMMARY OF PERFORMANCE AUDIT RESULTS

                CITY UTILITIES, JAMES RIVER STATION, UNIT NO. 4
                 DYNATRON MODEL 1100 OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Lamp
Window
Air Flow
Audit
Result

Off
Off
Off
Acceptable
Result

Off
Off
Off
  Stack Exit Correlation Error

  Panel Meter Correction Factor

  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
0% (Assumed)

   1.00

0.5% Opacity
0.5% Opacity



   Yes
   +_ 2%

0.98 to 1.02

_+ 2% Opacity
_+ 2% Opacity



   Yes
Transceiver Window
Reflector Window
Total
CALIBRATION ERROR ANALYSIS




Low Range (32.1% Opacity)
Mid Range (72.8% Opacity)
High Range (88.1% Opacity)
1% Opacity
0% Opacity
1% Opacity


Mean
Error
( Opacity )
-0. 1%*
-4.4%
-0.7%





Calibration
Error
(Opacity)
0.6%*
4.9%
1.3%
< 2% Opacity
£2% Opacity
< 4% Opacity

Acceptable
Calibration
Error
(Opacity)
1 3%
<_ 3%
_< 3%
* Results calcuated from first four measurements, since effluent opacity
  fluctuations affected the last filter measurement result.

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                                                                                16
               TABLE 3-2.   SUMMARY OF PERFORMANCE AUDIT RESULTS

                CITY UTILITIES,  JAMES RIVER STATION,  UNIT NO.  5
                 DYNATRON  MODEL 1100  OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Lamp
Window
Air Flow
Audit
Result

Off
Off
Off
Acceptable
Result

Off
Off
Off
  Stack Exit Correlation Error

  Panel Meter Correction Factor

  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
 0%  (Assumed)

    1.00

-1.0% Opacity
-0.5% Opacity



    Yes
  0% Opacity
 -1% Opacity
 -1% Opacity
   +_ 2%

0.98 to 1.02

jf 2% Opacity
+2% Opacity
   Yes
  2% Opacity
  2% Opacity
  4% Opacity
CALIBRATION ERROR ANALYSIS
  Low Range  (19.2% Opacity)

  Mid Range  (48.5% Opacity)

  High Range (65.8% Opacity)

Mean
Error
(Opacity)
0.2%
-1.9%
0.2%

Calibration
Error
(Opacity)
2.0%
2.7%
0.5%
Acceptable
Calibration
Error
(Opacity )
_< 3%
< 3%
< 3%

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                                                                                17

Monitor Performance

    1.  The Unit No. 5 opacity montoring system was found to exhibit acceptable
        performance for all criteria evaluated during the performance audit.

    2.  The Unit No. 4 opacity monitoring system was found to exhibit accept-
        able performance for all criteria evaluated during the performance
        audit except for the mid range calibration error.  Taking into
        consideration both the magnitude of the error for the mid range filter
        and the opacity level at which the mid range test was performed, it is
        expected that the observed problem will not affect the identification
        of periods of excesss emissions.


3.3  QUALITY ASSURANCE PROCEDURES

    Draft quality assurance procedures were developed for the James River Units
No. 4 and 5 opacity GEMS's.  The QA procedures consisted of daily checks,
periodic QA procedures, and criteria and general procedures for use in
performing corrective action for the opacity CEMS's.  During the initial audits
of the opacity CEMS's, additional information was obtained which allowed for
revision of the draft QA procedures.  (A copy of the QA procedures utilized
during the study is included in Appendix A of this report.)  Implementation of
the QA procedures began on June 28, 1983.  Based on a review of the QA data
obtained during the first 9 months of the field study, recommendations for
revisions to the QA procedures were developed.  The following section provides
a brief description of the QA procedures, a summary of the QA data, and a
discussion of the results of implementing the QA program.


3.3.1  Daily QA Checks

    The daily check procedures involve only simple checks of monitor operation
that can be performed at the monitor control unit.  The purpose of these checks
is to determine whether the opacity CEMS is apparently operating properly or if
corrective action is necessary.  For the Dynatron opacity CEMS's at the James
River Station, these procedures involved: (1) a check of whether fault lamps
were illuminated, (2) zero and span checks for both the strip chart recorder
and the data logger, and (3) a check of the data logger timer.  The time re-
quired to perform the QA checks, as well as both the boiler and monitor
downtime during the previous 24-hour period, were also noted on the daily log.
An example daily log is shown in Figure 3-5.  As was agreed at the beginning of
the study, the daily logs were not filled out on Saturdays and Sundays because
of the reduced number of personnel at the station during weekend shifts.

    Summaries of all of the daily QA check results from June 28, 1983 until
June 6, 1984 for both Units No. 4 and 5 are included in Appendix A of this
report.  These summaries contain all of the information recorded on the daily
logs in a condensed format.  With very few exceptions, the daily log sheets
were completed each day, including those periods during which the boiler was
not operating.  (Extended boiler outages occurred for both Units No. 4 and 5
during the study.)  The same individual performed almost all of the daily
checks of both monitoring systems during the 1-year study.  Only two other
individuals performed daily checks of either of the opacity CEMS's during the
study.

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                                                                                  18
        CITY UTILITIES

  I.   GENERAL INFORMATION

      Name:
Opacity Monitoring System

        DAILY LOG

   JAMES RIVER STATION
UNIT:
     Date:
                                                   Time Start:
                                                   Time Complete:
      Hours Boiler Down:

 II.   FAULT LAMPS
                  Hours Monitor Down:
FAULT LAMPS ON?
Lamp
Window
Air Flow
NO



YES



III.  ZERO/SPAN CHECK DATA

      Chart Recorder, Zero Value:
      Data Logger, Zero Value:  	
                          Span Value:
                          Span Value:

1 Data Logger
Timer
Correct

Incorrect


Does Zero Value exceed acceptable limits of H
Does Span Value exceed acceptable limits of H
- 2% opacity?
- 2% opacity?
NO


YES


      IF YES ANSWERS ARE INDICATED FOR ANY OF THE ABOVE QUESTIONS, CORRECTIVE
      ACTION SHOULD BE INITIATED AS SOON AS POSSIBLE.

 IV.  COMMENTS:
 FIGURE 3-5.  EXAMPLE OPACITY CEMS DAILY LOG:  CITY UTILITIES,  JAMES RIVER STATION

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                                                                                19
    Fault Lamp Indicators

    Each of the Dynatron Model 1100 opacity monitoring systems are equipped
with three fault lamps which, when illuminated, indicate an operational problem
with the monitor.  These fault lamps are:

   (1) LAMP     - Indicates when lamp reference voltage is outside of
                  acceptable range.

   (2) WINDOW   - Indicates when dust accumulation on the transceiver optics
                  exceeds acceptable range.

   (3) AIR FLOW - Indicates problem with air purge system.

   The daily check results indicate that no fault lamps were illuminated at any
time during the 1-year study for the Unit No. 4 opacity CEMS.

   The daily check results for the Unit No. 5 opacity CEMS indicate that no
fault lamps were illuminated at any time during the 1-year study except for one
instance when the "LAMP" fault was activated.  This fault condition was first
observed during the periodic QA check performed on 8/4/83, and subsequently
appeared on the daily log records for 8/5 and 8/8/83 while corrective action was
being performed.  Corrective action was completed on 8/9/83; the fault condition
was resolved at that time and did not reappear during the remainder of the study.

   Although the "WINDOW" fault was never illuminated for either the Unit No. 4 or
No. 5 monitors, several instances were observed when the apparent effluent
opacity was significantly reduced as a result of cleaning of the transceiver
window.  Notes on the daily check logs indicate that cleaning of the trans-
missometer windows on July 28, 1983 reduced the apparent effluent opacity by 11%
opacity and 8% opacity for Units No. 4 and 5, respectively.  (The daily logs also
indicate that the Unit No. 5 windows were cleaned on December 2, but no estimate
of the effect of this action on the effluent opacity measurements is provided.)
For Unit No. 4, the data recorded during the periodic QA checks indicate that the
apparent effluent opacity was reduced by 13% (9/15/83), 5% (1/9/84), 5% (2/1/84),
and 8% opacity (3/30/84) as a result of cleaning of the transceiver window.  For
Unit No. 5, the periodic QA check data show reductions in the apparent effluent
opacity of 5%  (9/15/83), 3% (2/1/84), and 3% opacity (3/30/84) as a result of
cleaning of the transceiver window.  Although the method used to estimate the
impact of window cleaning during the QA checks is inexact, the results that were
obtained suggest that the "WINDOW" fault detector does not necessarily provide an
effective indication of when the windows need to be cleaned.  This problem may
result from either (1) an inherent problem in the design of the "WINDOW" fault
system, or (2) an improper setting of the "WINDOW" fault sensitivity adjustment.


   "Zero" Checks
   For Dynatron opacity monitors, a check of each of the monitoring systems'
responses in the low opacity range (e.g., 8-10% opacity) is performed once per
day in place of a zero opacity check.  The monitors' responses to this check, as
indicated, by both the data logger printout and the strip chart, were recorded on
the daily log.  According to the draft QA procedures, adjustment of the monitor
was to be performed when the monitor response exceeded +_ 2.0% opacity relative to
the correct value for the low range check.

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                                                                                20
    For the Unit No. 4 opacity CEMS, the correct value for the "zero" check is
9% opacity.  During the 1-year study, there were no exceedances of the +^2%
opacity "zero drift" limit indicated by the responses recorded from either the
chart recorder or data logger.  The +_ 2% opacity zero drift limit was equalled
but not exceeded on three occasions as indicated by the chart recorder
responses, and on only one occasion as indicated by the data logger.  In the
vast majority of the checks, the low range check responses indicated by the
chart recorder and the data logger agreed within +_ 1% opacity.

    For the Unit No. 5 opacity CEMS, the correct value for the "zero" check is
10% opacity.  During the 1-year study, there were no exceedances of the +^2%
opacity "zero" drift limit indicated by the responses recorded from either the
chart recorder or the data logger except on 2/9/84, when the chart recorder
indicated a "0" value for the low range check, and on 2/10/84, when the data
logger recorded the same value for both the "low" range and span check
responses.  In both of these cases, the alternate recording device indicated
that the low range response was within +_ 2% opacity.

    There were 17 occasions when the +_ 2%  "zero" drift limit was equalled but
not exceeded by either or both the chart recorder and data logger responses.
All but one of these occurrences were during the same 50-day period  (7/10/83 to
8/18/83).  In general, the low range check responses indicated by the chart
recorder and the data logger agreed within ^ 1% opacity most of the time, and
within +_ 2% opacity nearly all of the time.

    The same data logger is used for both Units No. 4 and 5.  The daily QA
checks indicate many instances when the data logger failed to record the low
range check response.  In most of these cases, the calibration checks were
initiated manually by the operator.  The temporary malfunction of the data
logger/timer circuits are attributed to supply voltage transients (i.e., peaks
and glitches) at the James River Station.
     Span Checks

     Span checks of the Units No.  4  and 5  opacity monitors  were performed  at
 least once daily during the study using the internal  calibration  devices
 contained in the Model 1100 transceivers.   The opacity CEMS's span  check
 responses indicated by both the chart recorder and the data logger  were
 recorded on the daily log.   According to  the draft QA procedures, corrective
 action was to be initiated when the monitor responses exceeded +^2% opacity
 relative to the correct value (i.e.,  61%  and 50% opacity for Units  No.  4  and  5,
 respectively).

     For the Unit No. 4 opacity CEMS,  there were no exceedances of the +_ 2%
 opacity span limit during the 1-year study indicated by either the  chart
 recorder responses or the data logger responses.   In fact, all of the chart
 recorder responses and all except eight  of the data logger values were within
 +1% opacity of the correct span value.   The eight data logger responses that
 Exceeded +_ 1% opacity were all 63%  opacity (i.e.,  2% opacity), indicating a
 slight positive bias in the data logger  calibration relative to  the Unit No.  4
 chart recorder calibration.

     For the Unit No. 5 opacity CEMS, there were no exceedances of the +_ 2%
 opacity span drift limit during the 1-year study  indicated by the data logger
 responses.  In fact, all of the data logger responses were within +_ 1% opacity.

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                                                                                21
One exceedance of the span drift limit was observed in the chart recorder
response on 2/9/84, when a value of 37% opacity was recorded for the span
check.  The daily log acknowledged that the chart recorder response differed
from the data logger response; however, the problem was apparently resolved
before the span check was conducted the following day.  Other than the above
problem, all except four of the chart recorder span check responses were within
+^1% opacity.  The four chart recorder responses that exceeded +_ 1% opacity
were all 48% opacity (i.e., - 2% opacity), indicating a slight negative bias  in
the chart recorder calibration relative to the data logger calibration.

    Time Required for Daily Checks

    The time required to perform the daily checks of the James River Station
opacity monitoring systems is recorded on the daily log sheets.  During the
1-year field study, three different individuals performed all of the daily
checks of the Units No. 4 and 5 monitoring systems.  Exclusive of the first
week of the project, the time required to perform the daily check procedures
was almost always 2 minutes per day per monitor.  For a relatively small number
of cases, 3 to 6 minutes were necessary to complete the daily checks.
3.3.2  Periodic QA Checks

    The periodic QA procedures provide  for  checks  of monitoring  system
components  and operational  status  that  are  unfeasible,  impractical,  or
unnecessary on a daily basis.  The periodic QA  checks were  intended  to be
performed in conjunction with the  opacity CEMS  routine  maintenance program that
is  performed monthly  at the James  River Station.   The periodic QA check
procedures  included:  (1) "zero"/span  checks of  the panel  meter,  chart  recorder,
and data logger, (2)  a check of  the lamp reference voltage,  (3)  a check of
optical alignment of  the transmissometer components, and  (4)  a determination of
the apparent dust accumulation on  the transmissometer windows.

    A  total of eight  periodic QA checks for each monitor  were performed on an
approximate monthly basis.   All  of the  periodic QA checks were performed by the
same person; this individual did not  perform  any of  the daily checks of the
opacity CEMS's.  Summaries  of the  periodic  QA check  results for  Units  No.  4 and
5  are  shown in Tables 3-3 and 3-4, respectively.   The periodic QA results
support the following findings:

    o   The time required to perform  the periodic  checks  ranged  from 15 to 45
        minutes per monitor. A  significant amount of additional time was
        needed to complete  corrective action  for a problem  identified during
        the first periodic  QA check of  the  Unit No.  5 opacity CEMS.

    o   The low range and span  check  responses  provided by  the panel meter,
        chart recorder, and data logger during  the periodic QA checks  were all
        within +_ 2% opacity of  the correct  values  for both  monitors.  The
        differences among the responses of  the  three recording devices were
        consistently  less than  2%  opacity  for all  of the  low range  and span
        checks  for  both monitors.  No "zero"  or span adjustments were made for
        either  the  Unit No. 4 or No.  5  opacity  CEMS's  during the 1-year field
        study.

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                                                                     TABLE 3-3
                                                             PERIODIC QA CHECK RESULTS
                                                        CITV UTILITIES. JAMES RIVER STATION
                                                             BOILER *4, MONITOR *2
DATE
8/4/83
9/15/83(1)
10/7/83
12/12/83(2)
1/9/84(3)
2/1 /84
3/30/84
4/9/84
TIMEREQ.
(MIN.)
45
--
20
15
30
20
45
45
LOW RANGE ERROR
(95 OPACITY)
METER
0*
0%
095
OSS
095
096
096
095
CHART
095
095
09?
+ 195
09?
+ 195
+0.595
+0.595
LODGER
-195
-195
-195
-195
095
095
-195
-195
HIGH RANGE ERROR
(96 OPACITY)
METER
095
09?
09?
095
09?
+195
+195
+19?
CHART
09?
09?
09?
+ 195
+0.59?
+ 195
+ 195
+0.595
LOGGER
+ 19?
09?
+195
+ 19?
+ 19?
+29?
+ 19?
+ 19?
LAMP
VOLTAGE
(VOLTS)
6.43
__
6.63
6.73
6.75
6.70
6.65
6.67
ALIGNMENT
Q.K.
O.K.
OK.
O.K.
OK.
OK.
OK.
OK.
APPARENT DUST ACCUMULATION
(9? OPACITY)
REFLECTOR
095
19?
19?
09?
49?
49?
69?
09?
TRANSCEIVER
19?
1395
19?
09?
59?
59?
89?
29?
TOTAL
195
1495
295
095
995
995
1495
295
6-MIN. AVG.
395
1495
295
095
1195
1295
1595
295
NOTES:
      (1) "Clear" lamp burnt out.
      (2) Unit off-line.
      (3) Replaced recorder pen and lamp in "early warning" indicator.
                                                                                                                                              K)
                                                                                                                                              K)

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                                                                      TABLE 3-4
                                                              PERIODIC QA CHECK RESULTS
                                                         CITV UTILITES, JAMES RIVER STATION
                                                              BOILER «5, MONITOR »1
DATE
8/4/83(1)
9/15/83
10/7/83
12/12/83
1/9/84(2)
2/1/84(3)
3/30/84(4)
4/9/84(5)
TIMEREQ.
(MIN.)
45
--
20
15
30
185
45
45
LOW RANGE ERROR
(96 OPACITY)
METER
-195
+195
0??
OS?
0%
095
095
095
CHART
-1.595
095
095
095
095
095
095
095
LOGGER
-195
+195
+195
095
+155
+195
095
09?
HIGH RANGE ERROR
(95 OPACITY)
METER
-195
095
OS5
096
095
096
096
095
CHART
-195
-195
-0.595
-0.595
-195
-195
-0.595
095
LOGGER
095
096
096
096
+ 196
+ 196-
096
096
LAMP
VOLTAGE
(VOLTS)
4.34
—
6.35
6.31
6.36
6.31
6.28
6.26
ALIGNMENT
O.K.
Q.K.
O.K.
O.K.
Q.K.
O.K.
O.K.
OK.
APPARENT DUST ACCUMULATION
(56 OPACITY)
REFLECTOR
095
295
195
095
195
495
595
095
TRANSCEIVER
095
595
096
095
195
396
395
095
TOTAL
096
796
196
096
296
796
896
096
6-MIN. AVG.
0.595
895
295
-395
095
1295
895
095
NOTES:
      (1) Lamp light on; could not adjust lamp voltage above 4.36 volts.  (Corrective action performed 8/5 - 9/83; readjust lamp pover supply and performed
          system set-up procedure - 36 monhours total.)
      (2) Replaced clear lamp in panel indicator.
      (3) Unit *5 off-iine. Repaired alignment scope and rezeroed monitor.
      (4) Unit *5 off-line.
      (5) Unit *5 off-line.

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                                                                                24
    0   All lamp voltage checks performed during the periodic QA checks produced
        results within the acceptable range except for the 8/4/83 check on Unit
        No. 5, when the "LAMP" fault was activated.   (This problem was resolved
        during corrective action following the periodic QA check.)

    o   For both the Units No. 4 and 5 opacity GEMS's, the optical alignment was
        reported to be acceptable for each of the periodic QA checks.   However,
        repairs to the Unit No. 5 alignment scope were required on one occasion.

    o   Significant particulate accumulation on the optical surfaces of both
        monitors sometimes occurs, as indicated by the reduction in apparent
        effluent opacity when the transceiver and reflector windows were cleaned
        during the QA checks.  (Two methods were used to quantify the apparent
        dust accumulation.  The first method involves comparison of instanta-
        neous opacity readings obtained before and after cleaning each of the
        optical surfaces.  The total dust accumulation is simply the sum of the
        apparent dust accumulation on the transceiver and reflector windows.
        The second method determines the total dust accumulation for the monitor
        by comparing the minimum 6-minute average opacity values during the
        1-hour period preceding and following the periodic QA check.)

        The two methods of quantifying dust accumulation on the optical sur-
        faces provided consistent results in most cases.  The maximum dif-
        ference between the results provided by the two methods was 3% opacity
        for the Unit No. 4 monitor and 5% opacity for the Unit No.  5 monitor.

        The apparent reduction in opacity corresponding to window cleaning
        exceeded 4% opacity in four of eight checks for the Unit No. 4 GEMS and
        in three of eight checks for the Unit No. 5 GEMS.


3.3.3  Corrective Action

    Because a limited number of people are involved in the operation and
maintenance of the opacity CEMS's at the James River Station, the need for
documentation of corrective action is diminished.  Thus, documentation of most
minor corrective actions is usually included as notes in the daily logs or
periodic QA checks.  Such activities include: (1) unscheduled cleaning of
transmissometer windows, (2) resetting of the timer or data logger, and (3)
resolving chart recorder problems.  At the James River Station, most of these
problems are resolved so expeditiously that they are scarcely mentioned in the
QA records at all.

    The only corrective action log that was completed during the 1-year study
corresponded to the lamp reference voltage problem identified during the 8/4/83
periodic QA check of the Unit No. 5 opacity GEMS.  The corrective action was
necessary to adjust the observed  lamp voltage (4.36 volts) to be within the
acceptable range specified by the manufacturer (6.5 +_ 1.0 volts).  As stated in
the corrective action log, the entire GEMS set-up procedure was performed after
the lamp reference voltage was adjusted.  The corrective action log shows that
the repair/adjustment procedures were initiated at 0800 on 8/5/83, were
completed  at  1100 on 8/8/83, and  required 36 manhours to complete.  This one
instance appears to be the only major problem that was encountered for either
the Unit No.  4 or No. 5 opacity GEMS during the  1-year project.

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                                                                                25
3.4  SOURCE SELF AUDIT

    Personnel at the James River Station conducted performance audits of the
Units No. 4 and 5 opacity GEMS's on May 17, 1984 using audit devices supplied by
the project team.  Source personnel had previously observed and/or partici-
pated in the initial audit, had access to the detailed report for the initial
audit, and were furnished a copy of "Performance Audit Procedures for Opacity
Monitors" (EPA-340/1-83-010).  Using this information, the James River Station
personnel conducted the performance audit generally in accordance with the
prescribed procedures and completed the necessary data sheets (see Appendix A).
The results that were calculated from the data provided by the source self audit
are summarized in Tables 3-5 and 3-6 for the Units No. 4 and 5 CEMS's,
respectively.

    The results of the source self audit show that the Unit No. 4 opacity GEMS
met all of the audit criteria except for the optical surface dust accumulation
check.  The apparent dust accumulation on the transceiver window slightly
exceeded the recommended 2% opacity limit, and the total dust accumulation level
exceeded the recommended 4% opacity limit by 1% opacity.

    For Unit No. 5, the results of the source self audit show that the GEMS met
all of the audit criteria.

    It should be noted that for the audits of both the Unit No. 4 and No. 5
CEMS's, only one measurement for each filter was obtained during the
calibration error test, instead of the five measurements normally obtained.
Therefore, it is not possible to determine the confidence interval or the
calibration error results (i.e., sum of the mean difference and confidence
interval) for either monitor.  If the five measurement repetitions had been
performed, the CEMS's may not have met the calibration error limit at all three
test levels, since the contributions of the confidence intervals could have
resulted in excessive calibration error results.  The single measurements of
each filter indicate an increasing negative bias with increasing opacity for
the Unit No. 4 GEMS and somewhat random measurement errors for the Unit No. 5
GEMS.
 3.5  FINAL PERFORMANCE AUDIT

    A  final performance audit  of  the James River Station Units No. 4  and 5
 opacity CEMS's was  conducted on June 6,  1984.  This audit marked the  end of the
 1-year field  study  at the James River Station.  Detailed discussions  of the
 findings  and  results of the final audit  are  included  in the June 1984 audit
 report for this  station.

    The results  of  the final performance audits of the Units No. 4 and 5
 opacity CEMS's are  summarized  in  Tables  3-7  and 3-8,  respectively.  The
 following conclusions were derived from  the  results of the final performance
 audits of the James River opacity monitoring systems:

    (1)   The  Unit No. 5 opacity monitoring system was found to exhibit
          acceptable performance for all  criteria evaluated during the audit
          except  for dust accumulation on optical surfaces.

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                                                                                 26
               TABLE 3-5.  SUMMARY OF PERFORMANCE AUDIT RESULTS
                CITY UTILITIES, JAMES RIVER STATION, UNIT NO. 4
                 DYNATRON MODEL 1100 OPACITY MONITORING SYSTEM
                             - SOURCE SELF AUDIT -
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Lamp
        Window
        Air Flow

  Stack Exit Correlation Error

  Panel Meter Correction Factor

  Internal Low Range Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
    Audit
    Result
    Off
    Off
    Off

Not Determined

    1.00

-1.0% Opacity
 1.0% Opacity



    Yes
  3% Opacity
  2% Opacity
  5% Opacity
Acceptable
  Result
   Off
   Off
   Off

   +_ 2%

0.98 to 1.02

+_ 2% Opacity
_+ 2% Opacity




   Yes
_£ 2% Opacity
^2% Opacity
_<_ 4% Opacity
CALIBRATION ERROR ANALYSIS
Mean Confidence
Error Interval

Low Range (16.0% Opacity)
Mid Range (41.5% Opacity)
High Range (55.8% Opacity)
(Opacity)
1.0%
-2.5%
-2.8%
(Opacity)
ND
ND
ND
Calibration
Error
(Opacity)
ND
ND
ND
Acceptable
Calibration
Error
(Opacity)
1 3%
< 3%
< 3%
 Only one measurement of each filter was reported; therefore, the confidence
 interval and calibration error  results cannot be determined.  The opacity  level
 of the  low, mid, and high range checks is the value that  results from  the
 superposition of the filter value  (corrected to the stack exit pathlength) and
 the effluent opacity indicated  by  the monitor.

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                                                                                27
               TABLE 3-6.  SUMMARY OF PERFORMANCE AUDIT RESULTS
                CITY UTILITIES, JAMES RIVER STATION, UNIT NO. 5
                 DYNATRON MODEL 1100 OPACITY MONITORING SYSTEM
                             - SOURCE SELF AUDIT -
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Lamp
        Window
        Air Flow

  Stack Exit Correlation Error

  Panel Meter Correction Factor

  Internal Low Range Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
      Audit
      Result
      Off
      Off
      Off

  Not Determined

      1.00

   0.0% Opacity
  -1.0% Opacity



      Yes
Negligible Opacity
Negligible Opacity
Negligible Opacity
Acceptable
  Result
   Off
   Off
   Off

   + 2%

0.98 to 1.02

+^2% Opacity
+_ 2% Opacity



   Yes
£ 2% Opacity
£2% Opacity
£4% Opacity
CALIBRATION ERROR ANALYSIS
Mean
Error
(Opacity)
2.6%
Confidence
Interval
(Opacity)
ND
Calibration
Error
(Opacity)
ND
Acceptable
Calibration
Error
(Opacity)
< 3%
Low Range (10.6% Opacity)
Mid Range (24.9% Opacity)
High Range (34.4% Opacity)
2.6%
-0.8%
-0.2%
ND
ND
ND
ND
ND
ND
1 3%
<_ 3%
£ 3%
 Only one measurement of each  filter was reported; therefore, the  confidence
 interval and  calibration  error  results cannot be determined.  The opacity  level
 of the  low, mid, and high range checks is the value that  results  from  the
 superposition of the filter value  (corrected to the stack exit pathlength) and
 the effluent  opacity indicated  by  the monitor.

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                                                                                28
            TABLE 3-7.   SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                CITY UTILITIES, JAMES RIVER STATION, UNIT NO.  4
                 DYNATRON MODEL 1100 OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Lamp
Wi ndow
Air Flow
Audit
Result

Off
Off
Off
Acceptable
Result

Off
Off
Off
  Stack Exit Correlation Error

  Panel Meter Correction Factor
Exceeds Limits (see text)

         0.984
  Internal Low Range Error (chart)
  Internal Low Range  Error (data logger)
  Internal Span Error (chart)
  Internal Span Error (data logger)

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
       0.5% Opacity
       Not Determined
       0.5% Opacity
       1.0% Opacity
    Sightly off-center
       but OK
   +_ 2%

0.98 to 1.02

_+ 2% Opacity
+_ 2% Opacity
+_ 2% Opacity
+2% Opacity
    Yes
CALIBRATION ERROR ANALYSIS
Low Range
Mid Range
High Range
(15.5% Opacity)
(40.6% Opacity)
(54.9% Opacity)
Mean
Error
(Opacity)
-1.3%
-3.0%
-4.3%
Confidence
Interval
(Opacity)
0.5%
0.2%
0. 1%
Calibration
Error
(Opacity)
1.8%
3.2%
4.4%
Acceptable
Calibration
Error
(Opacity)
< 3%
1 3%
< 3%

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                                                                                29
            TABLE 3-8.   SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                CITY UTILITIES, JAMES RIVER STATION, UNIT NO. 5
                 DYNATRON MODEL 1100 OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Lamp
Window
Air Flow
Audit
Result

Off
Off
Off
Acceptable
Result

Off
Off
Off
  Stack Exit Correlation Error

  Panel Meter Correction Factor

  Internal Low Range Error (chart)
  Internal Low Range  Error (data logger)
  Internal Span Error (chart)
  Internal Span Error (data logger)

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
 0%  (Assumed)

    1.01

-0.5% Opacity
 0. 0% Opacity
-1.0% Opacity
 0.0% Opacity
    Yes
 4.0% Opacity
 3.0% Opacity
 7.0% Opacity
   +_ 2%

0.98 to 1.02

+_ 2% Opacity
_+ 2% Opacity
+_ 2% Opacity
+_ 2% Opacity
   Yes
£ 2% Opacity
_<_ 2% Opacity
_< 4% Opacity
CALIBRATION ERROR ANALYSIS
Low Range
Mid Range
High Range
Mean
Error
(Opacity)
(9.6% Opacity) 0.4%
(24.2% Opacity) -0.6%
(33.9% Opacity) -1.7%
Acceptable
Confidence Calibration Calibration
Interval Error Error
(Opacity) (Opacity) (Opacity)
0.3% 0.7% _< 3%
1.0% 1.6% _< 3%
0.6% 2.3% _< 3%

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                                                                               30
    (2)  The Unit No. 4 opacity monitoring system was found to exhibit
        acceptable performance for all criteria evaluated during the audit
        except  for  (a) stack exit correlation error, (b) dust accumulation on
        optical surfaces, and  (c) mid and hxgh range calibration error.

    (3)  Although the stack  exit  correlation error could not be determined
        directly, the audit results indicate a high probability that the
        internal pathlength correction factor for the Unit No. 4 monitor was
        incorrect at the time the audit was performed.

    (4)  The condensed moisture observed on the Unit No. 4 transceiver window
        during  the  audit substantiates statements by plant personnel that this
        problem occurs during unit outages.

    (5)  The dust and/or moisture deposited on the optical windows of the Unit
        No. 4 and No. 5 opacity  monitors will bias all opacity measurements
        high.   However, the amount of dust accumulation on the optical
        surfaces observed during the audit may not be representative of normal
        conditions, because (a)  both Units No. 4 and 5 had been off-line for
        several days preceding the audit and were off-line during the  audit,
        and  (b) the problem identified in  (4) above is reported to occur only
        during  source outages.

    (6)  Residual  effluent opacity is present at both the Units No. 4 and 5
        monitoring locations when the units are not operating.

    (7)  The  failure of  the  Unit  No. 4 monitor to achieve acceptable
        performance for  the calibration  error test is believed to be due
        primarily  to  a  shift or  change in  the monitor's internal pathlength
        correction factor.
3.6  GEMS DOWNTIME

    Figure 3-6 illustrates the total GEMS downtime for the James River Station,
Units No. 4 and 5, as reported in excess emission reports from the first
quarter of 1982 through the second quarter of 1984.   The data for 1982 were
obtained from summaries prepared by the Missouri DNR; the data for 1983 and
1984 were obtained from a detailed review of quarterly reports submitted by
City Utilities to the Missouri DNR.  (See " An Analysis of Opacity GEMS
Downtime in Excess Emission Reports: Opacity GEM Pilot Project" (May 1986)  for
additional discussions and comparative results for other sources.)

    As can be seen from Figure 3-6, GEMS downtime for both Units No. 4 and 5
decreased from a value of approximately 4% (85 hours), for the first quarter
that data were reported, to a minimum level, which was consistently below 0.6%
(14 hours), for all subsequent reporting periods.  Thus, both of the opacity
GEMS's at the James River Station achieved very high levels of monitor
availability  (i.e., greater than 99% during the field study).  Almost all of
the GEM  downtime that has occurred at the James River Station is attributable
to  (1) cleaning of transmissometer windows, (2) changing chart recorder paper,
(3) resetting of tne data logger/timer, and (4) preventive maintenance/monthly
monitor  checks.

-------
              10.0 T
    CEttS
DOWNTIME PER   , A
  QUARTER     ' °
     (X)
                                                              2        3

                                                                 1983
                                                YEAR AND QUARTER
                                    ":> JAMES RIVER-UNIT *5 '*- JAMES RIVER-UNIT *4
1         2
   1984
                                    FIGURE 3-6. CEMS DOWNTIME - JAMES RIVER UNITS NO. 4 AND 5

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                                                                                32
    During the 1-year field study, there was some reduction in the reported
frequency of window cleaning that slightly increased GEMS availability. However,
offsetting these small gains, a small increase in GEM downtime was associated
with the time required to perform the periodic QA checks (which include window
cleaning).  Overall, there is no indication that the time required to perform QA
procedures detracted from the opacity CEMS's availability.


3.7  CONCLUSIONS

    The evaluation of the results obtained from the performance audits ana from
the implementation of quality assurance procedures shows that reliable opacity
monitoring data are provided by the two Dynatron Model 1100 opacity CEMS's
installed at City Utilities' James River Station, Units No. 4 and 5.  Specific
conclusions regarding monitor performance and the effectiveness of the QA
procedures used during the study are provided below.

    1 • The Dynatron opacity CEMS's installed on Units No. 4 and 5 both achieved
       exceptionally high levels of availability during the study (i.e.,
       greater than 99% for each calendar quarter).

       (These availability results are expressed relative to the total number
       of hours in each quarter, since the opacity CEMS's are operated even
       during boiler outages.)

    2. The Dynatron opacity CEMS's are capable of providing precise and
       accurate effluent opacity measurements.

       o  For both the Unit iVo. 4 and 5 opacity CEMS's, all of the daily "zero"
          (i.e., low range) checks were within +_ 2% opacity and all of the span
          checks were within +^1% opacity of the correct values during the
          1-year study.  No zero or span adjustments were made for either
          monitor during the study.

       o  The accuracy of the Unit No. 5 opacity GEMS was consistently within
          +_ 3% opacity as indicated by calibration error checks for three
          performance audits conducted during the study.  Although a minor
          calibration shift was observed for the Unit No. 4 opacity GEMS,
          monitor accuracy was found to be within +_ 5% opacity as inciicated by
          calibration error checks for three performance audits.
       A high bias in opacity measurements sometimes occurs because of the
       accumulation of excessive amounts of dust and/or moisture on the exposed
       optical surfaces of the opacity CEMS's.  However, actions taken by
       station personnel prevent this problem from significantly affecting the
       identification of periods of excess emissions.

       (The results of several of the periodic QA checks and performance audits
       indicated exceedances of the 4% opacity dust accumulation limit for both
       monitors.  This problem often occurs during boiler outages.  However,
       since the optical surfaces are usually cleaned when the boiler operators
       observe higher than expected opacity values, this problem does not
       result in the reporting of periods of apparent excess emissions that are
       actually due to particulate accumulation on the optical surfaces.)

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                                                                            33
4. The WINDOW fault lamp at the monitor control unit does not provide an
   accurate indication of when excessive dust accumulation on the opacity
   surfaces of the transmissometer occurs for either the Unit No. 4 or
   No. 5 opacity GEMS.

   (Although several occasions were documented when the transceiver dust
   accumulation exceeded 4% opacity, the WINDOW fault indicators were never
   activated for either monitor.  Thus, for both monitors either (1) the
   WINDOW fault sensitivity level is incorrectly adjusted or (2) the WINDOW
   fault system simply does not work properly.  The WINDOW fault system
   only detects dust on the transceiver optics.  Since different levels of
   dust accumulation are sometimes observed for the transceiver and
   reflector windows at the James River Station, the window fault system
   cannot provide a reliable indication of the total dust accumulation.
   Station personnel are aware of the above limitations; therefore, they
   clean the optical surfaces when higher than expected opacity values are
   observed.)
5. Completion of a daily QA check log is not necessary in order to maintain
   opacity CEMS's within control limits at the James River Station.

   (The daily QA checks typically required 2 minutes per day per monitor to
   perform during the 1-year study.  Performance of the daily "zero" and
   span checks is required by the applicable regulations; checks of the
   other parameters included in the daily QA check procedures are
   recommended.  However, the completion of daily QA check logs should be
   eliminated to reduce the record keeping burden, since (a) the same
   person, who is thoroughly familiar with the operation of the opacity
   CEMS, performs almost all of the daily checks, and (b) the parameters
   included  in the daily QA checks proved to be very stable over the
   study.  Maintenance of a control chart similar to the daily QA check
   summaries in Appendix A may be useful in tracking monitor performance
   over time.)
6. Periodic QA  checks and performance audits are effective for the identi-
   fication of  monitor operational problems that may otherwise be overlooked.

   (Both the periodic QA checks and the performance audit results docu-
   mented occurrences of excessive dust accumulation on the optical
   surfaces of  the opacity CEMS's.  The two methods for quantifying dust
   accumulation that were included in the periodic QA checks provided
   consistent results in most cases.  The periodic QA checks also revealed
   the  need for (1) repairs to the Unit No. 5 monitor alignment  scope and
   (2)  corrective action to resolve a problem with the Unit No.  5 monitor
   lamp reference voltage.  In addition, the performance audit results
   identified a slight shift in the Unit No. 4 monitor calibration.)

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                                                                            34
7.  James River Station personnel have demonstrated the necessary expertise
   and capability to operate and maintain the ins-tailed opacity GEMS' s
   properly.

   (Prior to the 1-year study, station personnel had developed successful
   solutions for several unique monitor problems (including:  design and
   fabrication of prototype transition pieces to eliminate corrosion
   problems, improvements in the monitor optical alignment sight, and
   elimination of water runoff problems during severe rainstorms).  During
   the study, station personnel completed the QA checks and necessary
   repairs and adjustments properly and expeditiously.  They also
   successfully conducted performance audits of the opacity GEMS's.  As
   evidenced by interviews conducted before and after tne study period and
   by the results obtained at the James River Station, source personnel
   both understand how the GEMS works and take pride in achieving
   successful monitor performance.)

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                                                                                35
       4.0  UNION ELECTRIC COMPANY, PORTAGE DBS SIOUX, UNITS NO. 1 AND 2
    This section provides relevant background information and a summary and
discussion of results obtained from both (1) the implementation of quality
assurance procedures and (2) the performance audits of the installed opacity
CEMS's at Union Electric Company's Portage Des Sioux Station, Units No. 1
and 2.  An overview of the field study conducted for these two units is
provided in Figures 4-1 and 4-2.
4.1  SOURCE AND MONITOR DESCRIPTIONS

4.1.1  Source Description

    The Union Electric Company, Portage Des Sioux Station is composed of two
coal-fired electric utility steam generating units, each rated at approx-
imately 489 MW.  Units No. 1 and 2 are completely independent; each is equipped
with twin electrostatic precipitators (ESP's) for control of particulate
emissions and a separate exhaust stack.  For each unit, the boiler effluent is
divided evenly, routed through twin ESP's and twin I.D. fans, and subsequently
recombined in the exhaust stack.  Both Units No. 1 and 2 are subject to a
Missouri opacity limit of 20% opacity.

4.1.2  Monitor Description

    The Lear Siegler, Inc. (LSI) opacity monitoring systems utilized for Units
No. 1 and 2 at the Portage Des Sioux Station are identical.  Each monitoring
system consists of two RM41 transmissometers (one transmissometer installed in
each of the two breeching ducts serving each unit), a Model 21-622 Emissions
Monitor Combiner (which also serves as the control unit for both transmis-
someters), and a dual pen strip chart recorder.  In addition, a dedicated
digital computer/data logger (LSI DP-30) is used to record and report data
obtained from both the Units No. 1 and 2 monitoring systems.  A schematic
diagram of the Sioux Station opacity CEMS's is shown in Figure 4-3.  The
monitor combiner units, the strip chart recorders, and the computer-output
printer are located in the boiler control room.  Normally, both instantaneous
and 6-minute average effluent opacity measurements (corrected to stack exit
conditions) are displayed on the strip chart recorders for each generating
unit.  On command, the computer/data logger prints instantaneous effluent
opacity values at 1-minute intervals for either the Unit No. 1 or No. 2
monitoring systems.  An hourly emissions summaries (containing 6-minute average
opacity values), a daily summary, and a weekly report are generated by the
computer/data logger system.

    The Sioux opacity CEMS's are inherently more complex than most opacity
monitoring systems, since the outputs of two duct-mounted transmissometers are
combined and corrected for pathlength changes to provide a single result
equivalent to the opacity of the effluent at the stack exit.  At the Sioux
Station, the process of determining the equivalent stack exit opacity is
performed separately by both the combiner and the digital computer.  The same
input signals from the two transmissometers are provided to both the combiner
and the computer.  (The two data processing devices are arranged in series with
respect to the "reference" and "measurement" current loops for each of the
monitors.)  The combiner determines the equivalent stack-exit opacity using

-------
   BOILER
   DOVN
  MONITOR
    DOVN
CORRECTIVE
  ACTION
PERIODIC OA
  CHECKS
  DAILY OA
   CHECKS
   AUDITS  -
3/23-30
 INITIAL
 AUDIT
                      I       I     I
I     I   I       II
  I
•III
                                                 C  C
              	1	1	j	1	1	1	1	j	1	1      I      I	1	1	1
              MAR.  APR.  MAY   JUNE  JULY  AUG.  SEPT. OCT.  NOV.   DEC  ,JAN.   f EB  MAR.  APR.   MAY  ,JUHE
                                                               MONTHS
                    FIGURE 4-1
                                         ; COMPANY, PORT AGE DEG -MOUX STATION, UNIT NO 1 :  .IPACIT'-. cut-is PROJECT STUD'V

-------
   BOILER
   DOVH
 MONITOR
    DOVH
CORRECTIVE
  ACTION
PERIODIC: QA
 CHECKS
  DAILY QA
   CHECKS
   AUDITS  -
                /28-30
                INITIAL
                                                        II            III   ••••   1     I
                                                                ii
                  mi
                                                                                 c:
                                                              X
X
X

                                                                                                     -.     -.-

                                                                                                    \ '••. \ ''-•."•-. X '••.'•-•. ••-.. '... VWX'v vlKS.
                MAR.  APR,  MAY   JIJNlf  •JULV  M)&-  SEPT.   OCT.   «OV   DfC-  JAN,   FER   MAR   APR.    MAY  JUNE
                                           (.1983)
                                                                      MONTHS
                       F,GL'F't4-2  UNION ELECTRIC COr-!<-• ANY, PORTAO'; f>E"=; -lO'.i'-; ;:lAT'frj MWrNfJ  .   OF'AC-ITN Cfcri9PROJECTSTi.tr.',

-------
                                                              38
                                   DUCT  A  MONITOR
MEASUREMENT SIGNAL


REFERENCE SIGNAL




0 tp

n J-,
• •• LpJ



U







U
^
[
1
sjEL.
                                    DUCT B  MONITOR
  MEASUREMENT SIGNAL
    REFERENCE SIGNAL
                          O
TJ
TJ
           EMISSION MONITOR COMBINER
                  1
                   <3D.
               1 OO» -vL/—HIOU
                     -LOW
                  	 •viiocrrfH
               OaMP-^^-HIOH
               IWPUT-
                                              STACK EXIT OPACITY

                DP-30

              COMPUTER
Figure  4-3.  Schematic diagram of opacity CEMS

-------
                                                                                39
analog electronic circuitry, and provides an analog output signal that serves
as the input signal for the strip chart.  Independently, the computer converts
the analog "reference" and "measurement" current signals to digital values, and
then calculates the equivalent stack-exit opacity.  In addition, the output
signal from the combiner is routed to the computer, converted to a digital
signal, and then compared to the stack-exit opacity calculated by the
computer.  The comparison of the digital and analog stack-exit opacity values
provides a check on the degree of agreement between the two data processing
methods, and is used to flag operating problems in the computer printout.

    In theory, the determination of the equivalent stack-exit opacity where
multiple duct-mounted transmissometers are used requires determination of both
effluent opacity and volumetric flow rate at each monitoring location.  At the
Sioux Station, the effluent volumetric flow rates are assumed to be identical
at the two monitoring locations on each generating unit.
4.2  INITIAL AUDIT

    Initial audits of the opacity CEMS's installed at  the  Sioux Station Units
No. 1 and 2 were performed on  March 28-30,  1983.  The  audits  included  (1) a
visual evaluation of the monitor installation  location,  (2) a systems  audit
(i.e., a qualitative evaluation of monitor  operation,  maintenance, and record
keeping practices), and  (3)  a  performance audit of each  opacity GEMS  (i.e., a
quantitative evaluation of monitor accuracy and precision).   In addition, a
dual audit experiment was performed for the Unit No. 2 opacity GEMS.   Detailed
discussions of  the findings  and results of  the initial audits are  included in
the March 1983  audit report  for this  station.

    The results of the initial performance  audits of the Unit No.  1 A- and
B-side monitors are summarized in Tables 4-1 and 4-2,  and  the results  for the
Unit No. 2 A- and B- side monitors are summarized in Tables 4-3 and 4-4, re-
spectively.  The results of  the dual  audit  experiment  are  shown in Table 4-5.
The following conclusions were derived from the initial  audits of  the  Sioux
Station opacity monitoring systems.


Monitor Installation Location

    1.  The Sioux Station opacity monitoring systems are installed in  the best
        available locations  for monitoring  the performance of the  individual
        ESP's.  It  is believed that the monitoring  locations  provide  opacity
        measurements that are  representative of the  entire effluent  stream  at
        each measurement  location.

    2.  The Sioux Station opacity monitoring systems are not  subject  to  any
        known adverse environmental conditions.

    3.  The excellent access to  all of the  installed transmissometers on Units
        No.  1 and 2 facilitates performance of necessary monitor  maintenance
        activities.

-------
                                                                                40
           TABLE 4-1.   SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
                             UNIT NO.  1,  MONITOR A
               UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Control Panel Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)
  Zero Compensation:
    Before Cleaning
    After Cleaning

  Optical Surface Dust Accumulation:
    Transceiver Window
    Reflector Window
    Total

CALIBRATION ERROR ANALYSIS
     1.03
     1.05

    -4\ 5%
 0.0% Opacity
-0.1% Opacity
    Yes

  .003 OD
  .002 OD
 1.5% Opacity
 0.5% Opacity
 2.0% Opacity
0.98 to 1.02
0.98 to 1.02

   +_ 10%
+^2% Opacity
+_ 2% Opacity
   Yes

+_. 018 OD
+.018 OD
^2% Opacity
<_ 2% Opacity
<_ 4% Opacity
      Low Range (15.2% Opacity)
         Panel Meter
         Strip Chart
         Computer

      Mid Range (34.9% Opacity)
         Panel Meter
         Strip Chart
         Computer

      High  Range  (62.4% Opacity)
         Panel Meter
         Strip Chart
         Computer
Mean
Error
(Opacity)
-0.55%
-0.21%
-0.63%
-1.96%
-0.06%
-1.21%
-2.25%
-0.15%
-1.35%
95% CI
(Opacity)
0.14%
0.68%
0.11%
0.81%
1.43%
0.09%
1.11%
2.04%
0.00.%
Calibration
Error
(Opacity)
0.7%
0.9%
0.7%
2.8%
1.5%
1.3%
3.4%*
2.2%
1.4%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
_< 3%
< 3%
< 3%
< 3%
< 3%
< 3%
< 3%
   *See  text

-------
                                                                                41
            TABLE 4-2.   SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
                             UNIT NO.  1,  MONITOR B
               UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
                     LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Control Panel Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)
  Zero Compensation:
    Before Cleaning
    After Cleaning

  Optical Surface Dust Accumulation:
    Transceiver Window
    Reflector Window
    Total

CALIBRATION ERROR ANALYSIS
      1.02
      1.07

      2.5%
  3.5% Opacity*
  0.4% Opacity
     Yes

   .004 OD
   .002 OD
    No Data
    No Data
    No Data
              0.98 to 1.02
              0.98 to 1.02

                 _+ 10%
              _+ 2% Opacity
              j+ 2% Opacity
                 Yes
              _      OD
              +.018 OD
              ^2% Opacity
              ^2% Opacity
              £ 4% Opacity
                                       Mean
                                       Error
                                     (Opacity)
          95% CI
         (Opacity)
         Calibration
            Error
          (Opacity)
      Low Range (15.2% Opacity)
         Strip Chart
         Computer

      Mid Range (34.9% Opacity)
         Strip Chart
         Computer

      High Range (62.4% Opacity)
         Strip Chart
         Computer
             Acceptable
            Calibration
               Error
             (Opacity)
 4.01%
 0.01%
 2.14%
-0.95%
 0.55%
-1.30%
0.34%
0. 18%
           0.00%
           0.82%
0.28%
0.42%
4.4%
0.2%
            2.1%
            1.8%
0.8%
1.7%
                                     1 3%
                                     < 3%
              1 3%
              < 3%
                                       3%
                                       3%
  *Result obtained from panel meter; strip chart value not recorded.

-------
                                                                               42
           TABLE  4-3.  SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
                            UNIT NO. 2, MONITOR A
              UNION  ELECTRIC COMPANY, PORTAGE DBS SIOUX STATION
                   LEAR  SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Control Panel Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)
  Zero Compensation:
    Before Cleaning
    After Cleaning

  Optical Surface Dust Accumulation:
    Transceiver Window
    Reflector Window
    Total

CALIBRATION ERROR ANALYSIS
     1.01
     1.02

    -1.5%
 0.0% Opacity
 0.2% Opacity
    Yes

  -.001 OD
    .002 OD
 0.0% Opacity
 0.0% Opacity
 0.0% Opacity
             0.98 to 1.02
             0.98 to 1.02

                +_ 10%
             _+ 2% Opacity
             jf 2% Opacity
                Yes

             +..018 OD
             +.018 OD
                2% Opacity
                2% Opacity
                4% Opacity
      Low Range  (15.3% Opacity)
         Panel Meter
         Strip Chart
         Computer

      Mid Range  (35.1% Opacity)
         Panel Meter
         Strip Chart
         Computer

      High  Range (62.7%  Opacity)
         Panel  Meter
         Strip  Chart
         Computer
                                       Mean
                                       Error
                                     (Opacity)
          95% CI
         (Opacity)
         Calibration
            Error
          (Opacity)
             Acceptable
            Calibration
               Error
             (Opacity)
-0.08%
 0.04%
-0.48%
-1.11%
-0.65%
-0.87%
   64%
   34%
-1.16%
0.41%
0.31%
0.27%
0.15%
0.07%
0.38%
0.77%
0.29%
0.28%
0.5%
0.4%
0.8%
1.3%
0.7%
1.3%
3.4%
1.6%
1.4%
£ 3%
<_ 3%
< 3%
  3%
  3%
< 3%
  3%
  3%
  3%

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                                                                                43
           TABLE 4-4.   SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
                             UNIT NO.  2,  MONITOR B
               UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Control Panel Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)
  Zero Compensation:
    Before Cleaning
    After Cleaning

  Optical Surface Dust Accumulation:
    Transceiver Window
    Reflector Window
    Total

CALIBRATION ERROR ANALYSIS
      1.02
      1.03

     -0.5%
  0.0% Opacity
  0.5% Opacity
    Yes

    .008 OD
  1.0% Opacity
  0.0% Opacity
  1.0% Opacity
              0.98 to 1.02
              0.98 to 1.02

                 +_ 10%
              +^ 2% Opacity
              +_ 2% Opacity
                 Yes

              _+. 018 OD
              +.018 OD
              £ 2% Opacity
              <_ 2% Opacity
              £ 4% Opacity
                                       Mean
                                       Error
                                     (Opacity)
          95% CI
         (Opacity)
         Calibration
            Error
          (Opacity)
      Low Range (15.3% Opacity)
         Panel Meter
         Strip Chart
         Computer

      Mid Range (35.1% Opacity)
         Panel Meter
         Strip Chart
         Computer

      High Range (62.7% Opacity)
         Panel Meter
         Strip Chart
         Computer
             Acceptable
            Calibration
               Error
             (Opacity)
-0.42%
 0.30%
-0.96%
-1.35%
-0.83%
-1.59%
-2.68%
-1.00%
-1.90%
0.65%
0.20%
0.23%
0. 19%
0.27%
0. 14%
0.00%
0.20%
0.06%
1. 1%
0.5%
1.2%
1.5%
1.1%
1.7%
2.7%
1.2%
2.0%
<_ 3%
_< 3%
< 3%
  3%
  3%
  3%
  3%
  3%
  3%

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                           TABLE 4-5.   DUAL AUDIT  EXPERIMENT DATA AND RESULTS
TEST NO.
//
1 (LO)
2 (MO)
3 (HO)
4 (HL)
5 (HM)
6 (HH)
7 (MH)
8 (LH)
9 (OH)
10 (OM)
11 (OL)
12 (LL)
13 (ML)
14 (MM)
15 (LM)
16 (00)
EQUIVALENT FILTER VALUE
A-SIDE*
OPACITY OD
"/.
9.5 .043
18.5 .089
56.0 .356
56.0 .356
56.0 .356
56.0 .356
18.5 .089
9.5 .043
0 0
0 0
0 0
9.5 .043
18.5 .089
18.5 .089
9.5 .043
0 0
B-SIDE*
OPACITY OD
%
0 0
0 0
0 0
8.0 .036
19.5 .094
39.0 .215
39.0 .0215
39.0 .215
39.0 .215
19.5 .094
8.0 .036
8.0 .036
8.0 .036
19.5 .094
19.5 .094
0 0
EXIT**
OPACITY
%
9.4
18.5
55.8
59.3
64.4
73.0
50.2
44.7
39.0
19.4
7.9
16.6
24.9
34.3
27.0
0
MEASUREMENTS
A-SIDE
OD A
.02 -.023
.065 -.024
.322 -.034
.322 -.034
.322 -.034
.322 -.034
.065 -.024
.02 -.023
0 0
0 0
0 0
.02 -.023
.07 -.019
.07 -.019
.02 .023
0 0
B-SIDE
OD A
0 0
0 0
0 0
.02 -.016
.08 -.014
.195. -.02
.195 -.02
.195 -.02
.195 -.02
.08 -.014
.02 -.016
.02 -.016
.02 -.016
.08 -.014
.08 -.014
0 0
' AVC.-.0026 " -.017
EXIT OPACITY (%)
METER
Z A
6.8 -2.6
16.1 -2.4
51.8 -4.0
55.5 -3.8
.60.5 -3.9
69.5 -3.5
46.5 -3.7
41.0 -3.7
36.0 -3.0
17.9 -1.5
6.9 -1.0
14.5 -2.1
23.2 -1.7
31.2 -3.1
24.7 -2.3
-o ?
-2.82
RECORDER
% A
7.2 -2.2
16.5 -2.0
53.0 -2.8
56.5 -2.8
60.9 -3.5
70.5 -2.5
47.8 -2.4
42.0 -2.7
37.0 -2.0
18.0 -1.4
7.0 -0.9
14.7 -1.9
23.2 -1.7
32.0 -2.3
25.0 -2.0
-0 ?
-2,21
COMPUTER
% A
7.2 -2.2
16.5 -2.0
53.4 -2.4
57.1 -2.2
62.1 -2.3
71.8 -1.2
47.9 -2.3
42.3 -2.4
37.6 -1.4
18.4 -1.0
7.5 -0.4
14.4 -2.2
23.0 -1.9
32.2 -2.1
24.60 -2.4
0 0
-1.89
**
Values are actual single pass filter values

Equivalent opacity at stack exit
A = Measurement - equivalent  filter value

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                                                                                45
Monitor Operation, Maintenance, and Record Keeping

    1.  The Sioux Station opacity monitoring systems were reported to have
        operated relatively reliably.  High levels of monitor availability are
        normally achieved.

    2.  Solutions for most previously encountered monitor problems have been
        devised by source personnel.  The individual who is responsible for
        review of monitoring data and identification of operational problems is
        thoroughly knowledgeable and familiar with the opacity monitoring
        instrumentation.

    3.  A detailed routine maintenance program has been developed and is
        implemented on a monthly basis.  The routine maintenance program, in
        conjunction with an extensive spare parts inventory, contribute
        significantly to the reliability of monitoring data obtained at the
        Sioux Station.
Monitor Performance

    1.  The Sioux Station opacity monitoring systems were found to exhibit
        acceptable performance for almost all of the monitor component and
        maintenance analyses criteria evaluated during the initial performance
        audit.  Only very minor problems associated with the accuracy of panel
        meter readings were observed.   (The panel meter is rarely, if ever,
        used by the monitor operators at the Sioux Station.)

    2.  Calibration error test results  for the Units No. 1 and 2 opacity CEMS's
        and the dual audit experiment for the Unit No. 2 GEMS all show that the
        computer provides the most accurate data, the strip chart recorder is
        slightly less accurate, and the panel meter is the least accurate of
        the three data display devices.

    3.  All 33 calibration error test results for the four individual opacity
        monitors and the various data display devices were <_ 4.4% opacity.

    4.  Based upon the computer data, all four individual opacity monitors meet
        the applicable calibration error specification (<_ 3% opacity).

    b.  Based upon the strip chart responses, only the Unit No. 1 B-side
        opacity monitor failed to meet  the calibration error specification.
        This monitor failed to meet the calibration error specification only
        for the low range test.

    6.  The calibration error tests of  the individual Unit No. 2 monitors and
        the Unit No. 2 dual audit experiment provided functionally equivalent
        results.

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                                                                                46
4.3  QUALITY ASSURANCE PROCEDURES

    Draft quality assurance procedures were developed for the Sioux Station
Unit No. 1 and 2 opacity GEMS's.  The QA procedures consisted of daily checks,
periodic QA procedures, and criteria and general procedures for use in
performing corrective action for the opacity GEMS's.  During the initial audits
of the opacity CEMS's, additional information was obtained which allowed for
revision of the draft QA procedures.  Suggestions for improvement and simplifi-
cation of the QA procedures were provided by Union Electric personnel.
Implementation of the QA procedures began on June 12, 1983.  Union Electric
Company personnel provided additional revisions to the corrective action
procedures on February 29, 1984.  Based on a review of the QA data obtained
during the first 6 months of the field study, additional recommendations for
revisions to the QA procedures were developed by the pilot project team.  (A
copy of the QA procedures developed during the study is included in Appendix B
of this report.)  The following sections provide a brief description of the QA
procedures, a summary of the QA data, and a discussion of the results of
implementing the QA program.
4.3.1  Daily QA Checks

    The daily check procedures involve only simple checks of monitor operation
that can be performed at the monitor control unit.  The purpose of these checks
is to determine whether the opacity CEMS is apparently operating properly or if
corrective action is necessary.  For the LSI opacity CEMS's at the Sioux
Station, these procedures involved: (1) a check of whether fault lamps were
illuminated, (2) a check of the zero compensation values for both the A- and
B-side monitors, (3) zero and span checks of the opacity CEMS's for both the
strip chart recorder and the computer system responses, and (4) a check of the
computer system output for flags and/or error messages.  The time required to
perform the QA checks, as well as the boiler downtime during the preceding
24-hour period, were also noted on the daily log.  An example daily log is
shown in Figure 4-4.

    Summaries of all of the daily QA check results from June 12, 1983 until
June 20, 1984 for both Units No. 1 and 2 are included in Appendix B of this
report.  These summaries contain all of the information recorded on the daily
logs in a condensed format.  With very few exceptions, the daily log sheets
were completed each day, including those periods during which the boiler was
not operating.
     Fault Lamp Indicators

     Each of the RM41  combiners  are  equipped  with  five  fault  lamps which, when
 illuminated, warn of  monitor malfunctions.   These fault  lamps  and brief
 explanations of their functions are:

     (1)  REF        -  Indicates  when the reference current  level  is  outside  of
                      the acceptable range.

     (2)  WINDOW     -  Indicates  when the zero compensation, and thus,  the dust
                      accumulation on the transceiver optics  exceeds acceptable
                      range.

-------
                                                                                    47
        UNION ELECTRIC

    I. GENERAL INFORMATION
                               Opacity Monitoring System

                                       DAILY  LOG

                                     SIOUX  STATION
                               Date:
                                                83
                                                             UNIT: 1
                             Time Start:
                                                                         7
   III.  DP-30 HOURLY REPORT  DATA

     Zero Calibration:    O '
                                       _Span Calibration:    *?O >  / 3

Does
Does
zero
span
valu«
value
exceed
exceed
acceptable
acceptable
limits
litnts
ol
(6/
+ 2
.52
.5*
to
opacity?
72.5% opacity)?

NO/
/
^
YES


      Reason Code/Flags  (Circle those present on hourly  report)

         •ft            *           D            M   .         R
         [is  the  "H"  or "R" Flag present?
                                                 NO
                                                   .YES
Error Messages Present on Hourly Report?
1 . A/D REFERENCE FAULT
2. DIGITAL/ ANALOG DIFFERENTIAL ALARM
3. A/D TIME OUT
NO
S
i/
vS'
YES

^

         IF YES ANSWERS ARE INDICATED FOR ANY OF  THE ABOVE QUESTIONS, A JOB
         REQUISITION SHOULD BE  INITIATED
     IV. COMMENTS: J.R. No.
                                 was initiated
5P-192
         TIME COMPLETED:

       l)[M-t .It illf, l.Ili'illCf
       File A-13-26(d)
                               >  id
F. 4-4.  KXAMPT.K OPACITY GEMS DATLY LOG:
       1'ORTACK DKS SIOUX
                                                                UNION KI.KCTK I r CO.,

-------
                                                                                48
    (3) OVER RANGE


    (4) SHUTTER
Indicates that the measurement value exceeds the selected
optical density range.

Indicates that the protective shutter has been inserted
into the light path to protect the monitor from the
effluent.
    (5) FILTER     - Indicates a problem with the purge air system.
    During the 1-year study, the daily log sheets indicate that fault indica-
tors were activated on the following occasions:

Unit No. 1
    (1)  6/15-17/83   - SHUTTER fault indicator activated

    (2)  6/18-21/83   - SHUTTER and REF (reference)  fault indicators
                        activated
    (3)  6/23/83

    (4)  12/30/83-
          1/10/84
 - REF (reference) fault indicator activated

 - SHUTTER fault indicator activated (unit off-line)
Unit No. 2
    (1)  9/16/83

    (2)  10/6/83

    (3)  12/7/83

    (4)  1/10/84

    (5)  2/22/84

    (6)  3/4-5/84

    (7)  3/17/84

    (8)  4/30/84

    (9)  5/16/84
 - OVER RANGE fault indicator activated

 - WINDOW fault indicator activated

 - WINDOW fault indicator activated

 - SHUTTER and WINDOW fault indicators activated

 - WINDOW fault indicator activated

 - All fault indicators activated  (bus outage)

 - WINDOW fault indicator activated

 - WINDOW fault indicator activated

 - WINDOW fault indicator activated
    On  most  occasions, a Job Requisition  (i.e., corrective action) was initiated
the same  day or  the  day after  the problem was observed, with the exception of
those problems that  were resolved simply  by performing a manual zero/span check
of the  GEMS's.   In many cases,  the monitors were restored to proper operation
prior to  the time the  daily check was performed the following day.  All of the
problems  that occurred were considered  relatively minor, and are not indicative
of chronic or continuing reliability problems with the opacity monitors.

-------
                                                                                49
    For Unit No. 1, three of the four problems that occurred took place during
the first two weeks of the implementation of the draft QA procedures.  The
cause of the SHUTTER fault that occurred from 12/30/83 until 1/10/84 was a
failure of the instrument air line that is used in place of a purge air blower
for this monitor.  This problem continued for a number of days; however, the
generating unit was off-line during this period for a major outage.

    For Unit No. 2, the OVER RANGE problem on 9/16/83 was attributed to a
temporary interruption of power to the monitor.  Power was again interrupted on
3/4-5/84, resulting in the activation of all of the fault lamps.  The six
WINDOW faults observed for Unit No. 2 occurred at intervals of 3 to 8 weeks
and, in each case, were resolved expeditiously.


    Zero Checks

    A check of each of the opacity monitoring systems' responses at the zero
opacity level is performed at least once per day using the RM41 zero mirror to
simulate clear path conditions.  The monitors' responses to this check, as
indicated by the DP-30 computer printout and by the strip chart, were recorded
on the daily log.  According to the QA procedures, adjustment of the monitor
was to be performed when the monitor response indicated by the DP-30 printout
exceeded 4-^ 2.5% opacity during the zero check.

    During the 1-year study, the following exceedances of the +_ 2.5% opacity
zero check control limit occurred for the Unit No. 1 GEMS:

    (1)  6/22/83 - Zero check values: strip chart = 4%; DP-30 = 2.64%

    (2)  11/5/83 - Zero check values: strip chart = 4%; DP-30 = 1.03%

    (3)  6/10/84 - Zero check values: strip chart = 3%; DP-30 = 0.76%


    The Unit No. 1 zero check control limit exceedance indicated by the chart
recorder on 11/5/83 was not supported by the value indicated by the DP-30 print-
out.  Notations on the daily log sheets for the three following days indicated
that errors were made by the same operator in determining the chart recorder
zero responses.  Therefore, it appears that the apparent zero check exceedance
indicated by the strip chart may have been due to a chart reading error.

    For the Unit No. 2 opacity GEMS, no exceedances of the +_ 2.5% opacity zero
drift limit were indicated by either the DP-30 or the chart recorder data during
the 1-year study except for (1) the zero values recorded during the bus outage
(3/4-5/84) and (2) obvious recording errors.

    An extremely small number of exceedances of the zero control limit for the
Sioux Station opacity monitoring systems were observed.  For both the Unit
No. 1 and 2 monitoring systems, the tabulated strip chart data exhibit greater
variations than do the DP-30 data; part of this variability may be due to
imprecision in reading the chart record.  For both Units, the zero check
responses indicated by the DP-30 typically varied by approximately 0.1% opacity,
and rarely varied more than 0.5% opacity from day to day.

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                                                                                50
    Zero Compensation

    The LSI RM41 opacity monitors are equipped with a zero compensation
feature that automatically adjusts the measured opacity value to compensate
for dust accumulation on the exposed optical surfaces of the transceiver
unit.  Cleaning of the optical surfaces is recommended when the level of zero
compensation exceeds +_ 0.018 optical density (i.e., +_ 4% opacity);  however,
this activity is not required as part of the QA procedures.

    Zero compensation values were recorded on the daily log sheets for both
the A- and B-side transmissometers of the Unit No. 1 and 2 monitoring
systems.  A review of the zero compensation data indicates the following
results:
    (1)  Clearly incorrect zero compensation values were occasionally recorded
         for the A- and B-side monitors by various operators.  (This problem
         may be the result of difficulty in reading the zero compensation
         scale or unfamiliarity with this measurement on the part of some
         monitor operators.)

    (2)  The apparent variation in the zero compensation values on a
         day-to-day basis is significant; however, a part of this apparent
         variation may be due to inconsistent notations regarding whether the
         particular values were positive or negative.

    (3)  For the Unit No. 1 opacity CEMS, the reported zero compensation
         values exceeded the suggested +_ 0.018 optical density control limit
         on 9 days for the A-side monitor and on 5 days for the B-side
         monitor.  Two consecutive exceedances occurred for the A-side
         monitor; however, in all other cases, the zero compensation values
         were within the suggested control limits for the following day, even
         though no corrective action was undertaken.

    (4)  For the Unit No. 2 opacity CEMS, the reported zero compensation
         values exceeded the suggested +_ 0.018 optical density control limit
         on 9 days for the A-side monitor and on  10  days  for the B-side
         monitor.  All of the reported B-side monitor zero compensation values
         were within the suggested + 0.018 optical density limit.
     Span Checks

     An upscale check of the Unit No.  1  and 2  opacity CEMS's  responses  is
 performed at least once daily using an  internal  span filter  in  conjunction
 with the zero mirror of the RM41.   The  monitoring system responses  to  the span
 check, as indicated both by the DP-30 printout and the strip charts, were
 recorded on the daily log.   According to the  draft QA procedures, corrective
 action was to be initiated when either  of the monitor responses indicated by
 the DP-30 was more than +_ 2.5% opacity  relative  to the correct  value of the
 span filter.

     The following results are indicated by the review of the tabulated span
 check data for Units No. 1 and 2, respectively.

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                                                                                51
Unit No. 1
    (1)  All of the span check responses indicated by the DP-30 were within
         the span control limits except for two consecutive days (10/18-19/83)
         when extremely small exceedances of the control limit (i.e., 0.04%
         and 0.03% opacity) occurred.

    (2)  The DP-30 span check values were generally very consistent, typically
         reflecting day-to-day variations of considerably less than 0.5% opacity.

    (3)  For the span check responses indicated by the chart recorder, 125
         exceedances of the span control limit were observed; all of these
         exceedances reflected an apparent low bias in the recorded values.  It
         is emphasized that no requirement for adjustment of the chart recorder
         calibration was included in the QA plan, since emissions data from the
         recorder are not used in preparing excess emissions reports.
         Furthermore, there is no indication that the chart recorder was
         adjusted at any time during the 1-year study.  Of the 125 exceedances,
         90 indicated a low bias of 3% opacity or less, and a total of 106 of
         the 125 exceedances (i.e., 85%) indicated a low bias of less than 4%
         opacity.

Unit No. 2

    (1)  All of the span check responses indicated by the DP-30 were within the
         +_ 2.5% span drift control limit except for: (1) the two values
         recorded on 3/4-5/84, when power was interrupted, and (2) the value
         recorded on 3/12/84, when the upper limit was exceeded by 0.23%
         opacity.

    (2)  The span check values indicated by DP-30 are extremely consistent,
         typically reflecting day-to-day variations of considerably less than
         0.5% opacity.

    (3)  For the span check responses indicated by the strip chart recorder, 20
         exceedances of the +_ 2.5% opacity span control limit were observed.
         Sixteen of these exceedances reflected a low bias in the values
         recorded by the strip chart;, only four exceedances represented a
         positive bias.  Again, criteria for adjustment of the chart recorder
         calibration were not included in the QA procedures for this monitor.

    Based on the span check data, it is apparent that: (1) the accuracy of the
monitoring data recorded by the DP-30 is consistently within +^ 2.5% opacity
relative to the span check value, (2) the strip chart recorder data exhibited
both  greater variability than the DP-30 data and a low bias relative to the
span  check values, and  (3) the frequency and number of exceedances of the span
control limits as indicated by the strip chart recorder are greater than would
occur if adjustments to the recorder calibration were performed when exceed-
ances are initially identified.

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                                                                                52
    Time Required for Daily Checks

    The time required to perform the daily checks of the Sioux Station opacity
monitoring systems can be determined from the daily log sheets.  During the
1-year study, 14 different individuals performed the daily checks on various
occasions.

    The time necessary to perform the daily checks typically ranged from 2 to
10 minutes, and averaged approximately 5 minutes.  As individual monitor
operators became more familiar with the daily check procedures, a small
reduction in the amount of time needed is usually apparent.  However, the
average time required to perform the daily checks remained relatively constant
over the duration of the project on a monthly average.
4.3.2  Periodic QA Checks

    The periodic QA procedures provide for checks of monitoring system
components and operational status that are unfeasible, impractical, or
unnecessary on a daily basis.  The periodic QA checks were intended to be
performed in  conjunction with the opacity GEMS routine maintenance program that
is performed  monthly at the  Sioux Station.  The periodic QA check procedures
included: (1) zero/span checks of the CEMS's as indicated by the panel meter,
chart  recorder, and DP-30 computer system, (2) a check of the reference
current,  (3)  verification that the AGC circuit is on, (4) a check of optical
alignment of  the transmissometer components, (5) determination of the zero
compensation  values before and after cleaning of the optical surfaces, and (6)
recording of  the minimum 6-minute average opacity for the 1-hour periods
preceding and following the  periodic QA check.  The last item was included in
order  to attempt to quantify the dust accumulation on the optical surfaces of
the transmissometer.

    A  total of eight periodic QA checks were performed for the Unit No.  1 CEMS,
and a  total of seven periodic QA checks were performed for the Unit No.  2
CEMS.   Summaries of the periodic QA check results for the Unit No.  1 and 2
CEMS's are  shown in Table 4-6.  The results of the attempted quantification  of
dust  accumulation  that were  based on the 6-minute average effluent  opacity
measurements  before and  after  the QA check are not included in Table 4-6.
Because of  fluctuations  in  the effluent opacity level, these measurements did
not provide a meaningful  indication of the quantity of dust accumulation on  the
optical surfaces.   Tne periodic QA check  results  support the following  findings:

Unit  No.  1, A-  and B-Side Monitors

     (1)  The reference  current for both  the  A- and B-side  monitors  was  very
          stable and was  consistently within  the  acceptable range.

     (2)  No exceedances  of the recommended zero  compensation  range (i.e.,
          +_ 0.018 OD)  were observed either before  or  after  cleaning the optical
          surfaces of the transmissometer.   Cleaning  of.  the optical surfaces  did
          not result in a systematic  change in the zero compensation values;  the
          changes were relatively small and seemed to fall  within the noise  level
          associated with the measurement.

-------
                                                                TABLE 4-6
                                                         PERIODIC QA CHECK RESULTS
                                                       PORTAGE DES SIOUX, UNIT NO. 1
DATE MONITOR
6/22/83

7/26/83

9/1 /83

10/14/83

11/22/83

1/12/84

2/19/84

3/21 /84

1-A
1-B
1-A
1-B
1-A
1-B
1-A
1-B
1-A
1-B
1-A
1-B
1-A
1-B
1-A
1-B
REF.
CURRENT
(mo)
19.2
19.4
20
19.25
19.5
19.2
19
19.1
19.2
19.4
19.1
19.1
19.5
19.5
19.5
18.5
ZERO COMP.
COD)
INITIAL
0.0065
-0.015
-0.005
0.002
-0.017
-0.005
0.007
-0.006
40*
50*
-0.01 1
0.013
-0.01
-0.005
0.015
0.01
ZERO CHECK
(95 OPACITY)
FINAL METER CHART
0
0
-0.01 1
-0.01 1
-0.01
-0.004
_. »
--
41*
42*
0.012
0.013
0.0
0.00
-0.01
-0.01
0
8
0
2
0
0
0
O(-)
0.0
—
0
0
0
0.0
0
0
0
8
0
2
0
0
0
O(-)
0.5
0.5
0
0
0
0.0
0
0
DP-30
0.39
895
0.54
2.74
-0.6
0.33
0.73
0.15
1.12
0.48
0.64
0.09
0.67
-0.12
0.48
0.48
SPAN CHECK
(95 OPACITY)
I*'
METER
68.3
70
67
66.3
66
65
66
65
66
65
65.5
65
66
65
66
66
CHART
69
71
68
68
68
66
67
66
69.5
68
67
67
68
66
66.5
66.1
DP-30
70.79
73.11
70.95
71.31
70.79
69.97
70.46
69.88
71.62
70.37
71.16
70.82
71.34
70.34
71.16
70.52
AGC
ON /OFF)
on
—
OH
on
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
ALIGNMENT TIME COMMENTS
O.K.
O.K.
O.K.
OK.
O.K..
O.K.
OK.
O.K.
OK.
O.K.
OK.
OK.
OK.
OK
OK.
OK.
_«
-" —
7:40-14:20
9 :30-1 4 :20
7:30-10:10
8:00-10.10
8:00-14:30
8:35-14:30
7:22-10:10
7:22-10:10
7:25-10:15
7:36-10:15
7:45-10.15
8:05-10:15
8 :00- —
8:15- —

(1)




(2)
(2)








U)  Corrective action necessary to resolve zero problem (corrective action log not yet available).  Problem found to be in MON B O.D  card. The cord
    was calibrated.
(2)  Chart recorder zero response on mechanical stop;  Job Request submitted.
*•   Operator recorder value from wrong scale on panel meter.

-------
                                                            (TABLE 4-6, continued)
                                                          PERIODIC QA CHECK RESULTS
                                                        PORTAGE DES SIOUX, UNIT NO. 2
DATE MONITOR
7/7/83

8/10/83

9/21 /83

10/25/83

12/7/83

1 /24/S4

3/14/84

2-A
2-B
2- A
2-B
2- A
2-B
2-A
2-B
2-A
2-B
2-A
2-B
2-A
2-B
REF.
CURREN1
(ma)
19.2
19.5
19.6
19.6
19.2
19.5
19.6
19.8
19.6
19.8
19.9
19.8
19.8
20.0
ZERO CQMP.
r (OD)
INITIAL
0
0.01
0
0.013
0.0158
0.006
0.014
0.014
0.013
0.015
0.005
0.007
0.006
0.005
ZERO CHECK
(5? OPACITY)
FINAL METER
0
0.005
0.008
0.002
0.018
0.008
O.Q07
-0.002
0.014
0.015
0005
0.001
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
CHART
0
0
0
0
0.8
0.8
0
0
0
0
0
0
0
0
DP-30
0.88
1.16
0.88
1.16
0.82
0.79
0.97
1.31
0.91
0.61
0.48
1.03
1.00
1.34
SPAN CHECK AGC
(% OPACITY) (ON/OFF)
METER
69
70
67
65.5
67
66
67
67
66.2
68.5
68
68.5
69
67.5
CHART
68
58
68
66
67
66.2
67
67
67.5
—
68
68
67
66.5
DP-30
71 .40
70.40
70.92
70.15
70.64
70.00
70.46
69.94
70.28
70.55
69.97
70.46
70.00
70.92

ON
ON
ON
ON
ON
ON
ON
OH
ON
ON
ON
ON
ON
ON
ALIGNMENT TIME COMMENTS
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
O.K.
7 :30-9 :45
12:45-3:00
7:30-11 :00
8:00-11 :00
7:40-10:00
8:00-10:00
7:30-13:15
8:30-13:15
7:00-11 .20
7 :00-1 1 :20
8:15-12:25
8:15-12:25
9:30-13:05
9:30-13:05
(1)
(2)





(3)






(1)  V,'ire disconnected for filter alarm. Vires were connected and the alarm was tested.  Alarm performed properly.
(21  Wire disconneted for filter alarm. Vires were reconnected and the alarm was tested. Submitted JR *217355 for transceiver side of duct.
(3)  Zero mirror lense was cracking. Replaced lense and calibrated.

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                                                                                55
    (3)   All of the panel meter,  chart recorder,  and UP-30 references fell
         within the +_ 2.5% opacity zero drift limit except for (1)  the values
         indicated by all three devices for the B-side monitor on 6/22/83 and
         (2) the DP-30 response on 7/26/83.   The problem identified during the
         6/22/83 periodic QA check was resolved at that time by recalibrating
         the optical density circuit board.   The exceedance that occurred on
         7/26/83 was small (i.e., tne monitor response was 2.74% opacity).

    (4)   All of the span check responses indicated by the DP-30 were within
         +_ 1.5% opacity of the correct value.  However, many of the span check
         responses indicated by the panel meter and chart recorder exceeded the
         + 2.5% span drift limit; a negative bias was generally observed for
         both of these recording devices.

    (5)   No problems with the automatic gain control (AGC) circuit or with the
         optical alignment of either of the opacity monitors were observed
         during any of the periodic QA checks.
Unit No. 2, A- and B-Side Monitors

    (1)  The reference current for both the A- and B-side monitors was very
         stable and was consistently within the acceptable range.

    (2)  No exceedances of the recommended zero compensation range (i.e.,
         + 0.018 OD) were observed either before or after cleaning of the
         optical surfaces of the transmissometers.  In all but one case,
         cleaning of the optical surfaces reduced the zero compensation value.

    (3)  All of the panel meter, chart recorder, and DP-30 zero check responses
         were within +_ 1.5% opacity; thus, the +_ 2.5% opacity zero check
         control limit was never exceeded.

    (4)  All of the span check responses indicated by the DP-30 output were
         within +_ 1.5% opacity of the correct value.  However, three of the
         panel meter span check responses and one of the chart recorder
         responses exceeded the +_ 2.5% opacity span check control limit.   As
         with the Unit No. 1 monitor, the panel meter and the chart recorder
         data both exhibited a negative bias relative to tne correct span value
         and to the DP-30 output.

    (5)  No problems with the AGC circuit or the optical alignment of either of
         the opacity monitors were observed during any of the periodic QA checks.

    In addition, several minor proDlems were identified for both the Unit No.  1
and 2 opacity GEMS's during the periodic QA checks.  In most cases, these
problems were resolved during the periodic QA check.  It can be determined from
the QA records that the time required to perform the periodic QA checks ranged
from approximately 2.5 to 7.5 hours.

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                                                                                56
4.3.3  Corrective Action

    The corrective action procedures and log were intended to provide a general
indication of what was done to resolve specific monitor problems and to document
the impact of adjustments/repairs on (1) fault lamp status, (2) zero and span
check responses, and (3) monitor calibration.  It was intended that a corrective
action log would be completed on each occasion when control limits were exceeded
in either the daily or the periodic QA checks and on all other occasions when
adjustments or repairs of the opacity CEMS's were performed.  In general, the
corrective action log required that measurements of various parameters be
recorded before and after corrective action, so that the effects of the
adjustments and repairs could be assessed.

    Notes and comments regarding corrective action are included in the daily
and periodic QA check logs.  In addition, Sioux Station personnel completed cor-
rective action logs on four occasions for the Unit No. 1 opacity GEMS, and on
five occasions for the Unit No. 2 opacity CEMS.  The data recorded on the cor-
rective action logs (from the checks conducted before and after corrective
action was performed) support the statements by source personnel regarding what
the problem was and what was done to correct it.  The following is a summary
(taken directly from information provided by source personnel) of the corrective
action performed for the Sioux Station opacity CEMS's during the 1-year field
study:
Unit No.  1
     7/21/83
- Digital/analog differential alarm activated.   Problem traced to
  the A-side monitor.  Adjustments were performed to eliminate the
  problem.
     10/19/83  - Excessive span drift  observed  in  daily  calibration.   Problem
                isolated to the A-side  monitor and subsequently  found to  be
                caused by a defective micro switch in the  transceiver.

     11/2/83  - Adjusted zero offset  control on opacity card.  Although the
                voltage value was within specifications at the time  the checks
                were performed, the zero value would occasionally drift below
                -0.01, thereby activating the  digital/analog alarm.

     12/30/83  - SHUTTER fault activated for the A-side  monitor.   Instrument  air
                line [used for this monitor in place of purge air blower]  was
                broken.  [Generating  unit was  off-line  during the period  that
                this problem occurred and was  resolved.]
 Unit No. 2
     7/19/83  - Repaired filter...[unreadable].... on B-side monitor.

     10/14/83 - WINDOW fault indicator activated for A-side monitor.  After a
                manual zero check was completed from the combiner unit, the
                problem corrected itself.  The zero compensation circuit was
                automatically updated during the zero check.  Cleaning of optical
                surfaces was not necessary.

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                                                                                57
    12/14/83 - REFERENCE and OVER RANGE fault indicators activated;  digital/
               analog differential alarm.   Output signals from A-side monitor
               were lost.  Found defective J-Box switch after much trouble
               shooting.  Problems were difficult to find because switch failed
               intermittently (would begin working if technician tapped on J-Box
               meter).

    1/10/84  - SHUTTER and WINDOW fault indicators activated.  Problem diagnosed
               as bad purge air blower.  Blower was replaced with one from spare
               parts inventory.

    2/3/84   - WINDOW fault indicator activated.  Abnormal calibration caused
               zero reflector to fall out of position.  The problem was
               corrected immediately when a manual zero check was performed.

    At the beginning of the study, the Sioux Station personnel completed all of
the blanks on the corrective action log.  However, as the study progressed, only
those sections of the log that were directly related to the problem that was
encountered were completed.  Union Electric Company personnel provided revisions
to the corrective action instructions and log to eliminate the need for
recording unnecessary data.  The Sioux Station personnel clearly demonstrated
that their level of expertise was such that recording only that data directly
related to the problems encountered was sufficient to facilitate expeditious and
reliable corrective actions.
4.4  SOURCE SELF AUDIT

    Personnel at the Sioux Station conducted performance audits of the Units No.
1 and 2 opacity CEMS's on January 26 and 27, 1984 using audit devices supplied
by the project team.  Source personnel had previously observed and/or
participated in the initial audit, had access to the detailed report for the
initial audit, and were furnished a copy of "Performance Audit Procedures for
Opacity Monitors" (EPA-340/1-83-010).  Using this information, the Sioux Station
personnel conducted the performance audits in accordance with the
prescribed procedures and completed the necessary data sheets (see Appendix B).
The results that were calculated from the data provided by the source self audit
are summarized in Tables 4-7 through 4-10 for the Unit No. 1 A- and B-side
monitors and the Unit No. 2 A- and B-side monitors, respectively.

    The following conclusions are apparent from the review of data and results
obtained from the Sioux Station opacity audits:

    1.  The Sioux Station personnel who conducted the audit did an excellent
        job.  All data forms were properly completed.  Wherever possible,
        measurement values were recorded from all three data display devices for
        each of the opacity CEMS's (i.e., panel meter, strip chart recorder, and
        computer).  In addition, to simulate the procedures used in the opera-
        tion and maintenance of the opacity CEMS's, a digital voltmeter was used
        to obtain measurements which otherwise are available only at the panel
        meter.

    2.  The only procedural error identified in the audit results calculated by
        the Sioux Station personnel was the use of the algebraic rather than the
        absolute value of the mean difference in the final determination of the
        calibration error test results.

-------
                                                                                58
              TABLE 4-7.   SUMMARY OF PERFORMANCE AUDIT RESULTS
                             UNIT NO.  1,  MONITOR A
               UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM
                              -SOURCE SELF AUDIT-

MONITOR
Fault






COMPONENT ANALYSIS
Indicator Lamps:
Filter
Shutter
Reference Signal
Wi ndow
Over Range
AGC Circuit Status
Audit
Result

Off
Off
Off
Off
Off
On
Acceptable
Result

Off
Off
Off
Off
Off
On
  Stack Exit Correlation Error:
    Combiner
    Computer

  Combiner Panel Meter Status:
    Opacity Scale Factor
    Optical Density Scale Factor
    Input Scale Factor

  Reference Signal Analysis:
    Panel Meter
    Digital Volt Meter

  Internal Zero Error:
    (Chart Recorder)
    (DP-30 Analog)

  Internal Span Error:
    (Chart Recorder)
    (DP-30 Analog)
   0.08%
   0.00%
    1.05
    0.96
    1.00
   2.5%
   0.5%
 0.0% Opacity
 0.6% Opacity
•1.59% Opacity
 2.02% Opacity
   _+ 2%
   + 2%
0.98 to 1.02
0.98 to 1.02
0.98 to 1.02
   + 10%
   + 10%
_+ 2% Opacity
_+ 2% Opacity
_+ 2% Opacity
_+ 2% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)

  Zero Compensation:
        Before Audit
        After Audit
    Yes
   -0.001
   -0.006
   Yes
+_ 0.018 OD
+ 0.018 OD
  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
      ND
      ND
      ND
j< 2% Opacity
<_ 2% Opacity
< 4% Opacity
  (continued on next page)

-------
Table 4-7.  continued
                                                                               59
CALIBRATION ERROR ANALYSIS
  Low Range (17.0% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  Mid Range (38.0% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  High Range (74.1% Opacity)
     Panel Meter
     Chart Recorder
     Computer
Mean
Error
(Opacity)
-0.54%
0.32%
0.79%
-1.14%
-0.24%
1.53%
-2.21%
-0.15%
2.39%
95% CI
(Opacity)
0.44%
0.37%
0.19%
0.92%
0.54%
0.20%
0.26%
0.06%
0.11%
Calibration
Error
(Opacity)
0.98%
0.69%
0.98%
2.06%
0.78%
1.73%
2.47%
0.21%
2.51%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
1 3%
1 3%
< 3%
<^ 3%
< 3%
< 3%
< 3%

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                                                                                60
              TABLE 4-8.   SUMMARY OF PERFORMANCE AUDIT RESULTS
                             UNIT NO.  1,  MONITOR B
               UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM
                              -SOURCE SELF AUDIT-

MONITOR
Fault






COMPONENT ANALYSIS
Indicator Lamps:
Filter
Shutter
Reference Signal
Wi ndow
Over Range
AGC Circuit Status
Audit
Result

Off
Off
Off
Off
Off
On
Acceptable
Result

Off
Off
Off
Off
Off
On
  Stack Exit Correlation Error:
    Combiner
    Computer

  Combiner Panel Meter Status:
    Opacity Scale Factor
    Optical Density Scale Factor
    Input Scale Factor

  Reference Signal Analysis:
    Panel Meter
    Digital Volt Meter

  Internal Zero Error:
    (Chart Recorder)
    (DP-30 Analog)

  Internal Span Error:
    (Chart Recorder)
    (DP-30 Analog)
    0.08%
    0.00%
    1.06
    1.09
    0.97
    2.5%
    0.3%
 0.0%  Opacity
 0.7%  Opacity
-3.64% Opacity
 1.28% Opacity
   +_ 2%
   + 2%
0.98 to 1.02
0.98 to 1.02
0.98 to 1.02
   +_ 10%
   + 10%
+_ 2% Opacity
_+ 2% Opacity
_+ 2% Opacity
+2% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)

  Zero Compensation:
        Before Audit
        After Audit

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window.
        Total
     Yes
   -0.007
   -0.007
      ND
      ND
      ND
   Yes
+_ 0.018 OD
+ 0.018 OD
£ 2% Opacity
_< 2% Opacity
j£ 4% Opacity
  (continued on next page)

-------
Table 4-8. continued
                                                                               61
CALIBRATION ERROR ANALYSIS
  Low Range (17.0% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  Mid Range (38.0% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  High Range (74.1% Opacity)
     Panel Meter
     Chart Recorder
     Computer
Mean
Error
(Opacity)
-0.82%
0.42%
0.35%
-2.02%
-0.22%
0.82%
-3.67%
-1.27%
0.84%
95% CI
(Opacity)
0.50%
0.22%
0.05%
0.03%
0.34%
0.18%
0.68%
0.55%
0.38%
Calibration
Error
(Opacity)
1.32%
0.64%
0.40%
2.05%
0.56%
1.00%
4.34%
1.82%
1.22%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
_< 3%
_< 3%
< 3%
_< 3%
< 3%
< 3%
< 3%

-------
                                                                                62
              TABLE 4-9.   SUMMARY OF  PERFORMANCE AUDIT RESULTS
                            UNIT NO.  2,  MONITOR A
               UNION ELECTRIC  COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY  MONITORING SYSTEM
                              -SOURCE SELF AUDIT-

MONITOR
Fault






COMPONENT ANALYSIS
Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Audit
Result

Off
Off
Off
Off
Off
On
Acceptable
Result

Off
Off
Off
Off
Off
On
  Stack Exit Correlation Error:
    Combiner
    Computer

  Combiner Panel Meter Status:
    Opacity Scale Factor
    Optical Density Scale Factor
    Input Scale Factor

  Reference Signal Analysis:
    Panel Meter
    Digital Volt Meter

  Internal Zero Error:
    (Chart Recorder)
    (DP-30 Analog)

  Internal Span Error:
    (Chart Recorder)
    (DP-30 Analog)
   -0.95%
   0.0%
    1.00
    1.01
    0.99
    0.5%
    0.0%
 0.0% Opacity
 0.5% Opacity
-2.19%  Opacity
 1.58%  Opacity
   +_ 2%
   + 2%
0.98 to 1.02
0.98 to 1.02
0.98 to 1.02
     10%
     10%
+_ 2% Opacity
+_ 2% Opacity
+_ 2% Opacity
_+ 2% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)

  Zero Compensation:
        Before Audit
        After Audit

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
     Yes
    0.013
    0.013
      ND
      ND
      ND
   Yes
+_ 0.018 OD
+ 0.018 OD
^2% Opacity
_<_ 2% Opacity
< 4% Opacity
   (continued on next page)

-------
Table 4-9. continued
                                                                               63
CALIBRATION ERROR ANALYSIS
  Low Range (17.1% Opacity):
     Panel Meter
     Chart Recorder
     Computer


  Mid Range (38.3% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  High Range (74.4% Opacity):
     Panel Meter
     Chart Recorder
     Computer
Mean
Error
(Opacity)
-0.06%
-1.12%
0.06%
0.07%
-2.11%
-0.13%
-3.39%
-3.59%
-0.17%
95% CI
(Opacity)
0.46%
0.06%
0.25%
0.56%
0.22%
0.07%
0.01%
2.04%
0.05%
Calibration
Error
(Opacity)
0.52%
1. 18%
0.31%
0.63%
2.33%
0.20%
2.40%
5.63%
0.22%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
< 3%
< 3%
< 3%
1 3%
< 3%
1 3%
< 3%

-------
                                                                               64
              TABLE  4-10.   SUMMARY OF PERFORMANCE AUDIT  RESULTS
                            UNIT NO. 2,  MONITOR B
              UNION ELECTRIC COMPANY, PORTAGE  DBS  SIOUX STATION
                    LEAR  SIEGLER OPACITY  MONITORING SYSTEM
                             -SOURCE SELF AUDIT-

MONITOR
Fault






COMPONENT ANALYSIS
Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Audit
Result

Off
Off
Off
Off
Off
On
Acceptable
Result

Off
Off
Off
Off
Off
On
  Stack Exit Correlation Error:
    Combiner
    Computer

  Combiner Panel Meter Status:
    Opacity Scale Factor
    Optical Density Scale Factor
    Input Scale Factor

  Reference Signal Analysis:
    Panel Meter
    Digital Volt Meter

  Internal Zero Error:
    (Chart Recorder)
    (DP-30 Analog)

  Internal Span Error:
    (Chart Recorder)
    (DP-30 Analog)
   -0.953%
    0.00%
    1.02
    1.00
    0.99
    0.5%
    0.0%
 0.0% Opacity
 1.16% Opacity
-3.44%  Opacity
 0.73%  Opacity
   +_ 2%
   + 2%
0.98 to 1.02
0.98 to 1.02
0.98 to 1.02
   + 10%
   + 10%
+_ 2% Opacity
+2% Opacity
+_ 2% Opacity
+ 2% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)

  Zero Compensation:
        Before Audit
        After Audit

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
     Yes
     0.00
     0.00
      ND
      ND
      ND
   Yes
+_ 0.018 OD
+ 0.018 OD
j< 2% Opacity
£ 2% Opacity
_<_ 4% Opacity
  (continued on next page)

-------
Table 4-10. continued
CALIBRATION ERROR ANALYSIS
                                                                               65
  Low Range (17.1% Opacity):
     Panel Meter
     Chart Recorder
     Computer


  Mid Range (38.3% Opacity):
     Panel Meter
     Chart Recorder
     Computer

  High Range (74.4% Opacity)
     Panel Meter
     Chart Recorder
     Computer
Mean
Error
(Opacity)
0.76%
0.60%
0.77%
1.11%
-0.51%
0.63%
-0.29%
-1.39%
1.29%
95% CI
(Opacity)
0. 16%
0.52%
0.08%
0.68%
0.27%
0.05%
0.28%
0.01%
0.01%
Calibration
Error
(Opacity)
0.92%
1. 12%
0.85%
1.79%
0.78%
0.68%
0.57%
1.40%
1.30%
Acceptable
Calibration
Error
(Opacity)
<_ 3%
< 3%
<_ 3%
< 3%
< 3%
1 3%
< 3%
< 3%
< 3%

-------
                                                                                66
    3.  Exceedances of the "acceptable" range of audit results for the opacity,
        optical density, and input scale factors at the Sioux Station should be
        ignored, because station personnel typically use a digital voltmeter in
        place of the panel meter when performing adjustments of the opacity
        CEMS's.

    4.  If the status of the combiner panel meter is ignored, the Unit No. 1
        A-side monitor demonstrated acceptable performance relative to all of
        the audit criteria.

    5.  If the status of the combiner panel meter is ignored, the Unit No. 1
        B-side monitor demonstrated acceptable performance relative to all of
        the audit criteria except for (a) the internal span error as indicated
        by the chart recorder response (the computer response was within the
        acceptable range) and (b) the high range calibration error as indicated
        by the panel meter responses (both the chart recorder and the computer
        responses were within the acceptable range for this test).

    6.  The Unit No. 2 A-side monitor demonstrated acceptable performance for
        all of the audit criteria except for (a) the internal span error as
        indicated by the chart recorder response (the computer response was
        within the acceptable range) and (b) the high range calibration error
        as indicated by the chart recorder responses (both the panel meter and
        the computer responses were within the acceptable range for this test).

    7.  The Unit No. 2 B-side monitor demonstrated acceptable performance for
        all of the audit criteria except for the internal span error as
        indicated by the chart recorder response (the computer response was
        within the acceptable range).

    As part of the source self audit, it was requested that a zero alignment
check of the opacity monitors be performed.  Procedures were suggested for
conducting this test at the monitoring location.  This procedure was not
performed during the audit.  The letter transmitting the audit results included
the following statement:

             "The separate draft ZERO CHECK PROCEDURES were not tried
        because of physical constraints at our remote monitor locations.
        This type of check is performed at least once per year for all
        monitors as part of a bench calibration procedure performed in
        the controlled environment of the plant test shop."


4.5  FINAL PERFORMANCE AUDIT

    A final performance audit of the Sioux Station Unit No. 2 opacity CEMS was
conducted on June 7, 1984.  An audit of the Unit No. 1 opacity monitoring
system was not performed because of a problem evident in the DP-30 output for
the Unit No. 1 monitoring system.  Union Electric Company personnel agreed to
conduct an audit of this monitor after the problem was resolved.  Detailed
discussions of the  findings and  results of the final audit of the Unit No. 2
opacity CEMS are included in the June 1984 audit report for this station.

-------
                                                                                67
    The results of the final performance audit of the Unit No. 2 opacity GEMS
are summarized in Tables 4-11 and 4-12 for the A- and B-side monitors,
respectively.  The following conclusions were derived from the results of the
final audit of the Unit No. 2 GEMS:

    1.  The opacity monitoring system exhibited acceptable performance for all
        of the audit criteria evaluated during the June 1984 performance audit.

    2.  The analog and digital opacity values included in the DP-30 printout
        are equivalent within +_ 2% opacity.

    3.  The Unit No. 2 opacity monitoring system was accurately calibrated and
        very well maintained (as indicated by the lack of any detectable dust
        accumulation on optical surfaces) at the time the audit was performed.

    4.  The procedure,of determining the panel meter scale factors and internal
        zero and span errors simultaneously for the A- and B-side monitors by
        leaving both monitors in service and the analyzer select switch in the
        "Exit" position (a) is simpler than determining the same parameters for
        both monitors individually, (b) more closely approximates how plant
        personnel view the monitor in daily calibration checks, and (c) should
        be an adequate check of these parameters for determining whether a
        significant problem with the monitor exists.

    A final performance audit of the Sioux Station Unit No. 1 GEMS was con-
ducted on June 29, 1984 by Union Electric Company personnel after the
resolution of the problem that was evident in the DP-30 output at the time of
the final audit of the Unit No. 2 monitor.  Detailed discussions of the final
audit results for the Unit No. 1 GEMS are included in a memorandum dated
February 25, 1985.

    The results of the final performance audit of the Unit No. 1 opacity GEMS
are summarized in Tables 4-13 and 4-14 for the A- and B-side monitors, respec-
tively.  The following conclusions were derived from the results of this audit:


    1.  The A-side opacity monitor exhibited acceptable performance for all of
        the audit criteria evaluated.

    2.  The B-side opacity monitor exhibited acceptable performance for all of
        the audit criteria evaluated except for the mid range calibration error
        as indicated by the chart  recorder responses.  (Both the analog and the
        digital responses of the computer printout were within the acceptable
        limits for this test.)

    3.  The Sioux Station personnel performing the audit omitted those checks
        that are already included  in daily operating procedures (e.g., zero
        compensation checks) or routine operating procedures/periodic QA checks
        (e.g., dust accumulation on optical surfaces).

    4.  The personnel performing the audit omitted the determination of the
        combiner unit panel meter  scale factors, because the panel meter is not
        used by station personnel  for either opacity or optical density
        measurements.

-------
                                                                                68
           TABLE 4-11.   SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                            UNIT NO.  2,  MONITOR A
               UNION ELECTRIC  COMPANY,  PORTAGE DBS SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Wi ndow
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Combiner Panel Meter Status:
    Opacity Scale Factor (Exit)1
    Optical Density Scale Factor (Exit)
  Reference Signal Analysis
  Internal Zero Error (Chart)
  Internal Zero Error (DP-30)
  Internal Span Error (Exit)  (Chart)  -0.17% Opacity
    0.995
    0.990
   -0.5%
0.0% Opacity
0.48% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment (Centered)
  Zero Compensation:
        Before Cleaning
        After Cleaning

  Optical Surface Dust Accumulation:
                         Analog
   Transceiver Window     0.0%
   Reflector Window      -0.5% (0.0%)
   Total                 -0.5% (0.0%)

CALIBRATION ERROR ANALYSIS
     Yes

   -0.003 OD
   -0.002 OD
   Digital
 0.0% Opacity
 -0.5% Opacity (0.0%)
 -0.5% Opacity (0.0%)
             0.98 to 1.02
             0.98 to 1.02
                +_ 10%
             +^2% Opacity
             +_ 2% Opacity
             _+ 2% Opacity
                Yes

             jf.018 OD
             +.018 OD
              <_ 2% Opacity
              ^2% Opacity
              < 4% Opacity
      Low Range  (17.1% Opacity)
         Analog
         Digital

      Mid Range  (38.3 Opacity)
         Analog
         Digital

      High  Range  (74.4%  Opacity)
         Analog
         Digital
Mean
Error
(Opacity)
-0.24%
-0.80%
95% CI
(Opacity)
0.30%
0.31%
Calibration
Error
(Opacity)
0.54%
1.11%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
-0.04%
-1.11%
 2.07%
-0.09%
0.33%
0.61%
0.07%
0.00%
0.36%
1.72%
2.14%
0.09%
_< 3%
< 3%
_< 3%
< 3%
 (continued on next page)

-------
                                                                                69
Table 4-11. continued
^Opacity and optical density panel meter scale factors determined for the
 combiner (i.e., both Monitor A and Monitor B simultaneously) by comparison of
 panel meter response for the "Exit" condition to the correct value.

 Internal span error determined for the combiner (i.e., Monitor A and Monitor B
 simultaneously) by comparison of the chart recorder for the "Exit" condition
 to the correct value.

-------
                                                                                70
            TABLE 4-12.   SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                             UNIT NO.  2,  MONITOR B
               UNION ELECTRIC COMPANY,  PORTAGE DES SIOUX STATION
                    LEAR SIEGLER OPACITY MONITORING SYSTEM
MONITOR COMPONENT ANALYSIS
  Fault Indicator Lamps:
        Filter
        Shutter
        Reference Signal
        Window
        Over Range

  AGC Circuit Status
  Stack Exit Correlation Error
  Combiner Panel Meter Status:
    Opacity Scale Factor (Exit)
    Optical Density Scale Factor (Exit)
  Reference Signal Analysis
  Internal Zero Error (Chart)
 1
  Internal Zero Error  (DP-30)
                            2
  Internal Span Error  (Exit)
(Chart)
     Audit
     Result

      Off
      Off
      Off
      Off
      Off

      On
Not Determined

     0.995
     0.990
    +0.5%
 0.0% Opacity
 0.52% Opacity
-0.17% Opacity
MONITOR MAINTENANCE ANALYSIS
  Monitor Alignment  (Centered)
  Zero Compensation:
        Before Cleaning
        After Cleaning

  Optical Surface Dust Accumulation:
                            Analog
   Transceiver Window      0.0%  (0.0%)
   Reflector Window       -0.37% (0.0%)
   Total                  -0.34% (0.0%)

CALIBRATION ERROR ANALYSIS
               Yes

            -0.003  OD
            -0.003  OD
             Digital
           0.0% Opacity
           0.0% Opacity
           0.0% Opacity
  Acceptable
    Result

     Off
     Off
     Off
     Off
     Off

     On
     +_ 2%

  0.98 to 1.02
  0.98 to 1.02
     + 10%
  _+ 2% Opacity
  +_ 2% Opacity
  +2% Opacity
                            Yes
                          _     OD
                         +.018 OD
                         jC 2% Opacity
                         <_ 2% Opacity
                         <_ 4% Opacity
       Low Range (17.1% Opacity)
          Analog
          Digital

       Mid Range (38.3 Opacity)
          Analog
          Digital

       High Range (74.4% Opacity)
          Analog
          Digital
Mean
Error
(Opacity)
-0.57%
-1.94%
95% CI
(Opacity)
0.08%
0.00%
Calibration
Error
(Opacity)
0.65%
1.94%
Acceptable
Calibration
Error
(Opacity)
< 3%
< 3%
          -0.54%
          -2.06%
           1.75%
          -0.49%
            0.06%
            0. 14%
            0.04%
            0.00%
 0.60%
 2.20%
 1.79%
-0.49%
1 3%
< 3%
  3%
  3%
 (continued on next page)

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                                                                                71
Table 4-12. continued


 Opacity and optical density panel meter scale factors determined for the
 combiner (i.e., both Monitor A and Monitor B simultaneously) by comparison of
 panel meter response for the "Exit" condition to the correct value.
o
 Internal span error determined for the combiner (i.e., Monitor A and Monitor B
 simultaneously) by comparison of the chart recorder for the "Exit" condition
 to the correct value.

-------
                                                                                72
          TABLE 4-13.  SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                            UNIT NO.  1, MONITOR A
              UNION ELECTRIC COMPANY, PORTAGE  DES SIOUX STATION
                   LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Combiner Panel Meter Status:
Opacity Scale Factor
Optical Density Scale Factor
Reference Signal Analysis
Internal Zero Error (Chart)
Internal Zero Error (DP-30 Analog)
Internal Span Error (Chart)
Internal Span Error (DP-30 Analog)
MONITOR MAINTENANCE ANALYSIS
Monitor Alignment (Centered)
Zero Compensation:
Before Audit
After Audit
Optical Surface Dust Accumulation
Transceiver Window
Reflector Window
Total
CALIBRATION ERROR ANALYSIS4




Low Range (17.0% Opacity):
Chart Recorder
Analog
Digital
Mid Range (38.0 Opacity):
Chart Recorder
Analog
Digital
High Range (74.1% Opacity):
Chart Recorder
Analog
Digital
Audit
Result

Off
Off
Off
Off
Off
?1
ND2

ND
ND
0.0%
0.0% Opacity
-0.7% Opacity
-1.11% Opacity
+1.49% Opacity

Yes

+ 0.005 OD
+ 0.005 OD3
:
ND
ND
ND


Mean
Error 95% CI
(Opacity) (Opacity)

-1.3% 0.2%
-0.2% 0.0%
-0.2% 0.0%

-2.4% 0.2%
-0.2% 0.1%
-1.3% 0.1%

-1.7% 0.3%
2.1% 0.0%
-0.2% 0.1%
Acceptable
Result

Off
Off
Off
Off
Off
On
+_ 2%

0.98 to 1.02
0.98 to 1.02
+ 10%
+2% Opacity
+2% Opacity
+2% Opacity
+2% Opacity

Yes

+_ 0.018 OD
+ 0.018 OD

< 2% Opacity
< 2% Opacity
< 4% Opacity

Acceptable
Calibration Calibration
Error Error
(Opacity) (Opacity)

1.5% £ 3%
0.2% £ 3%
0.2% £ 3%

2.6% £ 3%
0.3% < 3%
1.3% £ 3%

2.0% £ 3%
2.1% £ 3%
0.2% £ 3%
(continued on next page)

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                                                                                73
Table 4-13. continued


1The AGC lamp status was checked as "OFF" on the data sheet.  Since the
 monitor performed well in the calibration error test (which would not be
 expected if the AGC circuit was malfunctioning), and since extensive experience
 has shown that the AGC circuit of the LSI RM-41 rarely malfunctions, it is
 believed that the reported "OFF" status is the result of confusion regarding
 the performance audit procedures.  The "OFF" position reflects proper monitor
 operation for all of the fault lamp indicators included on the combiner unit.
 However, proper monitor operation is indicated when the AGC LED on the
 transceiver is illuminated (i.e., "ON").  It is currently believed that the
 person performing the audit reported the AGC circuit lamp as "OFF" to indicate
 proper monitor performance.
O
 ND means  "not determined" during the audit.

3There is  no indication that the optics were cleaned or that a zero check of
 the monitor was performed after the initial zero compensation reading was
 obtained.  Thus, the "After Audit" zero compensation value should be the same
 as the "Before Audit" value, and it is.  In this case, the "After Audit" value
 provides  no additional information and can be disregarded.

Calibration error results are reported for (a) the strip chart responses,
 (b) the analog responses obtained from the DP-30 printout, and (c) the
 digital responses obtained from the DP-30 printout.  The opacity values
 associated with the low, mid, and high range tests are reported as the audit
 filter values corrected to stack exit conditions.  Those cases where the sum
 of the mean error and 95% confidence interval do not appear to equal the
 calibration error are due to rounding errors.  (See attached calculations.)

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                                                                       74
TABLE 4-14.  SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
                  UNIT NO.  1,  MONITOR B
    UNION ELECTRIC COMPANY,  PORTAGE DBS SIOUX STATION
         LEAR SIEGLER OPACITY MONITORING SYSTEM

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Combiner Panel Meter Status:
Opacity Scale Factor
Optical Density Scale Factor
Reference Signal Analysis
Internal Zero Error (Chart)
Internal Zero Error (DP-30 Analog)
Internal Span Error (Chart)
Internal Span Error (DP-30 Analog)
MONITOR MAINTENANCE ANALYSIS
Monitor Alignment (Centered)
Zero Compensation:
Before Audit
After Audit
Optical Surface Dust Accumulation
Transceiver Window
Reflector Window
Total
CALIBRATION ERROR ANALYSIS4




Low Range (17.0% Opacity):
Chart Recorder
Analog
Digital
Mid Range (38.0 Opacity):
Chart Recorder
Analog
Digital
High Range (74.1% Opacity):
Chart Recorder
Analog
Digital
(continued on next page)
Audit
Result

Off
Off
Off
Off
Off
?1
ND2

ND
ND
0.0%
0.0% Opacity
-0.42% Opacity
-0.61% Opacity
0.94% Opacity

Yes

+ 0.004 OD
ND3
J
ND
ND
ND


Mean
Error 95% CI
(Opacity) (Opacity)

-0.7% 1.3%
-0.4% 0.3%
-0.5% 0.1%

-2.5% 0.9%
-1.4% 0.2%
-1.8% 0.1%

-2.2% 0.3%
-0.3% 0.7%
-0.7% 0.1%

Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%

0.98 to 1.02
0.98 to 1.02
+ 10%
+2% Opacity
+2% Opacity
+ 2% Opacity
+_ 2% Opacity

Yes

+ 0.018 OD
+ 0.018 OD

< 2% Opacity
< 2% Opacity
< 4% Opacity

Acceptable
Calibration Calibration
Error Error
(Opacity) (Opacity)

1.9% <_ 3%
0.7% <_ 3%
0.6% <_ 3%

3.4% <_ 3%
1.6% < 3%
1.9% <_ 3%

2.5% £ 3%
1.0% £ 3%
0.8% <_ 3%


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                                                                                75
Table 4-14. continued
 The AGC lamp status was checked as "OFF" on the data sheet.  Since the
 monitor performed well in the calibration error test (which would not be
 expected if the AGC circuit was malfunctioning), and since extensive experience
 has shown that the AGC circuit of the LSI RM-41 rarely malfunctions, it is
 believed that the reported "OFF" status is the result of confusion regarding
 the performance audit procedures.  The "OFF" position reflects proper monitor
 operation for all of the fault lamp indicators included on the combiner unit.
 However, proper monitor operation is indicated when the AGC LED on the
 transceiver is illuminated (i.e., "ON").  It is currently believed that the
 person performing the audit reported the AGC circuit lamp as "OFF" to indicate
 proper monitor performance.
2
 ND means "not determined" during the audit.

 There is no indication that the optics were cleaned or that a zero check of
 the monitor was performed after the initial zero compensation value was
 obtained.  No value is provided for the "After Audit" zero compensation value
 on the attached data sheets.

 Calibration error results are reported for (a) the strip chart responses,
 (b) the analog responses obtained from the DP-30 printout, and (c) the
 digital responses obtained from the DP-30 printout.  The opacity values
 associated with the low, mid, and high range tests are reported as the audit
 filter values corrected to stack exit conditions.  Those cases where the sum
 of the mean error and 95% confidence interval do not appear to equal the
 calibration error are due to rounding errors.  (See attached calculations.)

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                                                                                76
4.6  GEMS DOWNTIME

    Figure 4-5 illustrates the total GEMS downtime for the Sioux Station,  Units
No. 1 and 2, as reported in excess emission reports from the first quarter of
1980 through the second quarter of 1984.   The data for 1980 through 1982 were
Detained from summaries prepared by the Missouri DNK;  the data for 1983 and
1984 were obtained from a detailed review of quarterly reports submitted by
Union Electric Company to the Missouri DNR.  (See " An Analysis of Opacity GEMS
Downtime in Excess Emission Reports: Opacity GEM Pilot Project," May 1986,  for
additional discussions and comparative results for otner sources.)

    As can be seen in Figure 4-5, GEMS downtime for both the Sioux Station
opacity GEMS's was maintained below 10% of the hours in the quarter for each
reporting period during 1983 and 1984 except for the second quarter of 1984 for
Unit No. 1.  Thus, even though the Sioux Station opacity CEMS's represent  a far
more complex monitoring application than is used at most sources (i.e., two
monitors per unit, analog combiner system, and digital computer), the levels of
GEMS availability were generally greater than 93%.

    A review of the GEMS downtime information included in excess emission
reports shows that the vast majority of problems resulting in GEMS downtime were
resolved in less than 10 nours (10 hours corresponds to approximately 0.5%
downtime).  The problems that more significantly impacted monitor availability
were as follow:

Unit No. 2
    First Quarter 1983

         o  59 hours: Combiner shut down by mistake.

         o  88 hours: Bus outage (i.e., power failure) on 2 occasions.

    First Quarter 1984

         o  76 hours: Bus outage (i.e. , power failure) on 3 occasions.

         o  20 hours: Computer not calculating results.

    Second Quarter 1984

         o  48 hours: Computer stopped; replaced I/O circuit board.
Unit No.  1
     Second Quarter  1984

          o  18  hours: Replace optical density circuit board and recalibrated.

          o 192  hours: Optical density circuit board defective; waiting on parts.

          o  48  hours: Computer  stopped; replaced I/O circuit board after trying
             to  reprogram  computer.

-------
           100.0
            10.0  •••
    CEttS
DOWNTIME PER
   QUARTER
     <*)
             1.0
             0.1  -1-
                                                                                                           1     2

                                                                                                           1984
                                                     YEAR AND QUARTER
                                                  "•> SIOUX UNIT 1  •*- SIOUX UNIT 2
                                FIGURE
4-5. CEMS DOWNTIME - UNION ELECTRIC COMPANY. SIOUX STATION UNITS 1 AND 2

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                                                                                78
4.7  CONCLUSIONS

    The evaluation of the results obtained from the performance audits and from
the implementation of quality assurance procedures shows that reliable opacity
monitoring data are provided by the two LSI opacity CEMS's installed at Union
Electric Company's Portage Des Sioux Station, Units No. 1 and 2.  Specific
conclusions regarding monitor performance and the effectiveness of the QA
procedures used during the study are provided below.

    1. Despite the complexity of the opacity CEMS's installed on Units
       No. 1 and 2, both CEMS's achieved high levels of availability during the
       study (i.e., greater than 96%).

       (These availability results are expressed relative to the total number
       of hours in each quarter, since the opacity CEMS's are operated even
       during boiler outages.)

    2. The LSI opacity CEMS's at the Sioux Station provide precise and accurate
       effluent opacity measurements.

       o  For both the Unit No. 1 and 2 opacity CEMS's, virtually all of the
          daily zero and span checks were within the j^ 2.5% opacity control
          limits during the entire 1-year study as indicated by the responses
          of the primary data recording system  (i.e.,  the DP-30).

       o  The accuracy of both the Unit No.  1 and 2 opacity CEMS's was
          consistently within +^3% opacity as indicated by calibration error
          checks based on the responses of the primary data recording system
          for all three performance audits conducted during the study.

       o  A  zero alignment check is performed at  least once per year for each
          monitor in order to establish the  equivalency of the monitor
          responses to the clear-path  condition and to the transceiver mirror.


     3. The  strip chart recorder provides  data of  sufficient accuracy and
       precision to be used  as a back-up  recording device during  computer
       outages.

        (Based on the  daily and periodic QA check  data  and on  the  results  of  the
       performance  audits that were  conducted,  it is apparent that  the  data
       displayed by  the  chart recorder are  less accurate  and  less precise than
       the  data recorded by  the  DP-30  computer  system.  However,  for  both the
       Unit No.  1  and 2  opacity  CEMS's,  the  daily and  periodic QA data  show
       that the chart recorder  and DP-30  responses usually  differ by  less than
       2% opacity.   The  three performance audits  show  that  the responses  of
       both devices  were  correct within +_ 5% opacity as  indicated by  the
       observed mean differences.   The accuracy and precision of  the  chart
       recorder data would be improved and would remain within control  limits
        if checks  and adjustments of  the chart recorders  were performed  on a
        routine basis.  Such checks and adjustments are recommended  only if the
        chart recorders  are to be used as back-up recording devices  during
        computer outages.)

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                                                                            79
4. The purge air system is properly operated and maintained, and the
   frequency of cleaning exposed optical surfaces is sufficient to maintain
   measurement errors resulting from dust accumulation on optical surfaces
   within less than 4% opacity.

   (No exceedances of the 4% opacity dust accumulation limit were observed
   in either the initial or the final performance audit.  [The level of
   dust accumulation was usually below the minimum detectable limit during
   the audits.]  Very few exceedances of the zero compensation control
   limit (i.e., +_ 0.018 or +_ 4% opacity) are apparent in the daily logs;
   some of the recorded exceedances are obviously due to reading/recording
   errors.  The WINDOW fault lamp was never activated for either the A- or
   B-side monitors of the Unit No. 1 opacity GEMS, and was infrequently
   activated for the Unit No.  2 opacity GEMS.  When the WINDOW fault was
   activated, the problem was often resolved simply by manually initiating
   a zero check; other problems were expeditiously resolved by appropriate
   corrective action.)
5. The combiner fault lamps and the flags and error messages provided by
   the computer data acquisition system are effective indicators of monitor
   operational problems.

   (The appropriate fault lamp indicators were activated when problems were
   encountered for both the Unit No. 1 and 2 opacity GEMS's.   The
   activation of the fault lamps and the presence of flags  and/or error
   messages in the DP-30 printout were found to be consistent with the
   other data that were recorded.  Conversely, extraneous fault indicators
   and/or computer messages were not observed when no problems existed.)


6. Periodic QA checks and performance audits are effective  for the identi-
   fication of monitor operational problems that may otherwise be overlooked.

   (The periodic QA checks for the Unit No. 1 GEMS resulted in the
   identification of problems (1) in the B-side monitor optical density
   circuit board, and (2) in the chart recorder zero response.  For the
   Unit No. 2 GEMS, problems with the filter alarm and the  zero mirror were
   identified.  For both the Unit No. 1 and 2 CEMS's, differences between
   the chart recorder and DP-30 span check responses were identified;
   however, these were not subsequently corrected, because  the chart
   recorders are not used as back-up recording devices.)


7. Sioux Station personnel have clearly demonstrated the necessary
   expertise and capability to operate and maintain the installed opacity
   CEMS's properly.

   (Prior to the 1-year study, station personnel had developed successful
   solutions for most of the previously encountered monitoring problems.
   During the study, station personnel completed the daily  and periodic QA
   checks and provided numerous suggestions for improving these proce-
   dures.  Station personnel clearly demonstrated that they are able to
   determine the cause of monitor problems and that they could accomplish
   all necessary corrective action quickly and properly.  They also

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                                                                         80
successfully conducted complex performance audits of the opacity CEMS's
using procedures that provided a comprehensive and representative
indication of monitor performance.  As evidenced by the results obtained
at the Sioux Station and by interviews conducted before and after the
study period, source personnel thoroughly understand how the CKMS works
and take pride in achieving successful monitor performance.)

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                                                                                81
             5.0  KANSAS CITY POWER AND LIGHT COMPANY, IATAN STATION


    This section provides relevant background information and a summary and
discussion of results obtained from both (1 ) the implementation of quality
assurance procedures and (2) the performance audits of the installed opacity CEMS
at Kansas City Power and Light Company's latan Station.  An overview of the field
study conducted for this unit is provided in Figure 5-1.


5.1  SOURCE AND MONITOR DESCRIPTIONS

5.1.1  Source Description

    latan Unit No. 1 (the only unit at latan) is a coal-fired electric utility
steam generator equipped with Lodge Cottrell electrostatic precipitators (ESP's)
for control of particulate emissions.  The unit is rated at approximately 630-700
MW and burns low sulfur Western coal.  latan Unit No. 1 is subject to the
requirements of 40 CFR 60 "Subpart D - Standards of Performance for Fossil-Fuel-
Fired Steam Generators for Which Construction is Commenced After August 17, 1971.'

5.1.2  Monitor Description

    The Lear Siegler, Inc. (LSI) RM41 opacity monitoring system utilized at the
latan Station consists of a single transmissometer (transceiver and retrore-
flector), a monitor control unit, and a strip chart recorder.  The transmis-
someter is installed within the annular space between the stack shell and liner
at approximately 280 feet above grade in the exhaust stack (see Figure 5-2).
The opacity monitor measurement path passes through the centroid of the stack
cross-section.  The only means of access to the monitoring location is a series
of ladders installed in the annular space between the stack wall and the stack
liner.

    The monitor control unit is mounted on the rear of the instrument panel in
the boiler control room.  Six-minute average opacity levels are displayed on a
strip chart recorder located on the front of the instrument panel.  The strip
chart recorder is the only automatic recording device used with the opacity
monitoring system; however, the boiler operators also maintain an hourly log of
effluent opacity measurements as displayed by the control unit panel meter.  The
log also contains notations regarding periods of excess emissions (i.e., periods
when the 6-minute average opacity exceeds 20%).  These periods are included in
quarterly reports submitted to the Missouri Department of Natural Resources.


5.2  INITIAL AUDIT

    An initial audit of the opacity CEMS installed at latan Station was per-
formed on March 8-9, 1983.  The audit included (1) a visual evaluation of the
monitor installation location, (2) a systems audit (i.e., a qualitative evalu-
ation of monitor operation, maintenance, and record keeping practices), and (3)
a  performance audit of the opacity CEMS (i.e., a quantitative evaluation of
monitor accuracy and precision).  Detailed discussions of the findings and
results of the initial audit are included  in the March  1983 audit report for
this station.

-------
BOILER
 DOVN
 MONITOR _
   DQVH

PERIODIC QA
 CHECKS/ -
CORRECTIVE
  ACTION

 DAILY QA
  CHECKS
AUDITS   -
            0
             3/8
            INITIAL
            AUDIT
I          I
                                    X  X

mim
           	1	1	j	1	1	1	1	1	1	1	1	1	1	i	i	P
           MAR.  APR.  HAY   JUNE  JULY   AUG  SEPT.  OCT.   NOV.   DI-T  ,JAH   FEB.  MAR   APR. '  MAY  ' JUNE '
                                    1.1 983)
                                                             MONTHS
                             IGUPE 5-1 KANSAS PITY POWER A. LlijHT COf iPAN'i1 |ji I AN ST AT ION' fPACIT1,' CEMS PROJEC I"
                                                                                                                       (X)
                                                                                                                       to

-------
                                                         83





















DIA.














/ .
•:;
'•:•
•f
|
|
X
1
i
•:_
j

S
1












/
>i
$
|


j

1
|


'i
I
'i
•;'
]
1
i
I
i
1
i
1

i
v M
                                         NOTE; DRAVING NOT
                                                TO SCALE
FIGURE 5-2  IATAN OPACITY  MONITORING LOCATION

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                                                                                84
    The results of the initial performance audit of the latan opacity GEMS are
summarized in Table 5-1.   The following conclusions were derived from the
initial audit of the opacity monitoring system.
Monitor Installation Location

    1. The opacity GEMS is installed in accordance with Performance
       Specification 1, Appendix B, 40 CFR 60.  The installation location
       provides opacity measurements that are representative of the entire
       effluent stream.

    2. The opacity GEMS is not subject to any known adverse environmental
       conditions.

    3. The difficult access to the installed transmissometer impacts the
       frequency of conducting monitor maintenance activities.
Monitor Operation, Maintenance, and Record Keeping

    1. The opacity GEMS operates reliably.  High levels of monitor availability
       are achieved, and infrequent adjustment of zero and/or span values is
       required.

    2. Successful solutions for previously encountered monitor problems have
       been devised by source personnel (e.g., installation of a lightning
       protection device, resolution of circuit board problems, etc.).

    3. Significant effluent opacities are sometimes present during boiler
       outages.  Tne existence of the residual opacity prohibits conducting an
       on-stack clear-path calibration check of the opacity monitor.
Monitor Performance

     1. The  latan  opacity monitoring  system was  found to exhibit acceptable
       performance for  all  criteria  evaluated during the performance  audit.

     2. The  slight degree of optical  misalignment  observed  during  the  audit may
       have been  due  to the unit  outage.   (The  alignment of  the monitor  should
       be checked when  the  generating  unit is operating and  the stack
       temperature is within the  normal  operating range.)

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                                                                                85
           TABLE 5-1.  SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
             KANSAS CITY POWER AND LIGHT COMPANY,  IATAN UNIT NO.  1
               LEAR SIEGLER MODEL RM41 OPACITY MONITORING SYSTEM
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Filter
        Shutter
        Reference Signal
        Window
        Over Range

  AGC Circuit Status
  Stack Exit Correlation Error
    Audit
    Result
     Off
     Off
     Off
     Off
     Off

     On
     0%
                                                                Acceptable
                                                                  Result
           Off
           Off
           Off
           Off
           Off

           On
           + 2%
  Control Panel Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)
  Zero Compensation:
        Before Cleaning
        After Cleaning

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total

CALIBRATION ERROR ANALYSIS
      1.01
      0.98

      1.0%
 0.0% Opacity
 0.1% Opacity
  Borderline

      .000 OD
     -.001 OD
  0.9% Opacity
  1.1% Opacity
  2.0% Opacity
        0.98  to  1.02
        0.98  to  1.02

           +_ 10%
        _+ 2%  Opacity
        +_ 2%  Opacity
           Yes

          .018 OD
          .018 OD
        £2% Opacity
        _£ 2% Opacity
        <^ 4% Opacity
                                       Mean
                                       Error
                                     (Opacity)
             Calibration
                Error
              (Opacity)
            Acceptable
           Calibration
              Error
            (Opacity)
  Low Range  (9.0% Opacity)
      Panel  Meter
      Strip  Chart

  Mid Range  (20.5% Opacity)
      Panel  Meter
      Strip  Chart

  High  Range (51.5% Opacity)
      Panel  Meter
      Strip  Chart
-0.3%
-1.0%
-0.5%
-1.4%
-1.4%
-2.3%
0.5%
0.5%
1.5%
< 3%
< 3%
< 3%

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                                                                                86
5.3  QUALITY ASSURANCE PROCEDURES

    Draft quality assurance procedures were developed for the latan opacity
CEMS.  The QA procedures consisted of daily checks, periodic QA procedures,
and criteria and general procedures for use in performing corrective action
for the opacity CEMS.  During the initial audits of the opacity CEMS,
additional information was obtained which allowed for revision of the draft QA
procedures.  (A copy of the QA procedures utilized during the study is
included in Appendix C of this report.)  Implementation of the QA procedures
began on June 19, 1983.  Based on a review of the QA data obtained during the
first 8 months of the field study, recommendations for revisions to the QA
procedures were developed.  The following section provides a brief description
of the QA procedures, a summary of the QA data, and a discussion of the
results of implementing the QA program.
5.3.1  Daily QA Checks

    The daily check procedures involve only simple checks of monitor operation
that can be performed at the monitor control unit.  The purpose of these
checks is  to determine whether the opacity CEMS is apparently operating
properly or if corrective  action  is necessary.  For the LSI RM41 opacity CEMS
at  latan,  these procedures involved: (1)  a check of whether fault lamps were
illuminated, (2)  recording of the reference current,  (3) a check of the zero
compensation value, and  (4) zero  and span checks for  both the panel meter and
the strip  chart recorder.   The time required to perform the QA checks  was also
noted  on the daily log.  An example daily log  is shown in Figure 5-3.

    Monthly summaries of all of the daily QA check results from June  14,  1983
until  February 1,  1984 are included in Appendix C of  this report.  These
summaries  contain all of the information  recorded on  the daily logs in a
condensed  format.  A review of the monthly summaries  shows that many  of the
daily  checks were not performed.  For the first 2 months of the study, station
personnel  completed the  daily log each day.  However, after this initial
period, the frequency of the daily QA checks was continuously reduced: 12
daily  logs were  completed  for November;  10 daily logs were completed  for
December;  and 6  daily logs were  completed for  January 1984.  Based on a review
of the data  recorded  in  the daily logs for the first  8 months of the  QA
 implementation,  the pilot  project team agreed  with the practices adopted  by
the latan Station personnel and  recommended  that the  checks previously
 scheduled to  be  conducted  on a  daily basis be  performed  instead only  on a
weekly basis.
     Fault Lamp Indicators

     The RM41 opacity monitor is equipped with five fault lamps which, when
 illuminated, indicate operational problems with the monitor.  These fault
 lamps and brief explanations of their functions are as follow:

     (1 ) REF        - Indicates when reference current level is outside of
                      acceptable range.

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                                                                                   87
                          Opacity Monitoring System

                                  DAILY LOG

        KANSAS CITY POWER AND LIGHT          IATAN STATION

  I.   GENERAL INFORMATION
      Name:
Date:
Time Start:
Time Complete:
      Hours Boiler Down:

 II.   FAULT LAMPS
             Hours Monitor Down:
FAULT LAMPS ON?
Filter
Shutter
Ref
Windows
Over Range
NO





YES





III.  PANEL METER DATA
      "REF" value (ma):
      Zero Compensation (OD):

Does
Does
"REF"
"ZERO
value
COMP "
exceed
exceed
acceptable
acceptable
range
range
(17
(+
.9-22
.018
.2
OD)
ma)?
?
NO


YES


IV.  STRIP CHART DATA

     Zero Calibration (% opacity):
     Span Calibration (% opacity):

Does
Does
zero
span
value
value
exceed
exceed
acceptable
acceptable
limits
limits
Of

+ 2
^.b
.0%
+ '1
opacity?
.0% opacity?^
NO


YES


     IF YES ANSWERS ARE INDICATED FOR ANY OF THE ABOVE QUESTIONS, CORRECTIVE
     ACTION SHOULD BE INITIATED AS SOON AS POSSIBLE.

  V.  COMMENTS:
      FIGURE 5-3.  EXAMPLE OPACITY GEMS DAILY LOG:   KANSAS  CITY POWER  & LIGHT
                    COMPANY,  IATAN STATION

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                                                                                88
   (2) WINDOW     - Indicates when zero compensation and,  thus,  dust accumula-
                    tion on the transceiver optics exceeds acceptable range.

   (3) OVER RANGE - Indicates that measurement value exceeds selected optical
                    density range.

   (4) SHUTTER    - Indicates that the protective shutter  has been inserted
                    into the light path to protect the monitor from the
                    effluent.

   (5) FILTER     - Indicates a problem with purge air system.

   Only one occasion was noted on the daily log sheets when a fault lamp was
illuminated during the 8 month period for which QA data were reviewed.  On
this occasion (7/2/83), the REF fault lamp was illuminated.  The reference
current at this time was 18.3 ma, which is within the acceptable range of 17.9
to 22.2 ma.  The notes on the daily log sheet indicate that station personnel
replaced a transceiver circuit board and returned the monitor to proper
operation at 1530 on 7/2/83, approximately 7-1/2 hours after the problem was
first detected.  The daily check data for the following day, 7/3/83, also
indicated that proper monitor operation had been restored.
   Reference Current Checks

   For the LSI RM41 GEMS, the reference current signal is used for comparison
with the measurement current signal to determine the transmittance and, thus,
the opacity of the effluent.  The accuracy of the opacity measurement is
therefore directly dependent on the accuracy and the stability of the refer-
ence current signal over time.  Because of the importance of this parameter,
recording of the  reference signal level was included in the daily QA procedures.
Acceptable performance  is indicated when the reference signal level falls within
the range of 17.9 to 22.2 ma, according to the manufacturer? reference signals
outside these control limits indicate the need for corrective action.

   The RM41 reference current signal was consistently within the specified
control limits during the study.  On the one occasion described above, a REF
fault occurred when the reference current was observed to be 18.3 ma.  However,
all of the other  reported reference current values were within the range of  19.8
to 20.5 ma, which is less than 25 percent of the allowable  range recommended  by
the manufacturer. Therefore, for the latan monitor, the reference current
appears to be very stable, and the REF fault lamp has been  observed to be
activated before  the applicable  control  limits are reached.
    Zero Checks

    A check of the opacity monitoring system1s response at the zero opacity level
 is performed at least once per day using the RM41  zero mirror to simulate clear
 path conditions.  The monitor response to this check as indicated by the panel
 meter and on the strip chart was recorded on the daily log.   According to the QA
 procedures, adjustment of the monitor was to be performed when the monitor
 response exceeded +_ 2% opacity during the zero check.

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                                                                                89
    For the strip chart records, no exceedances of the +_ 2% opacity zero
control limits were indicated during the field study.  The zero check response
as indicated by the panel meter exceeded the +_ 2% opacity limit on only one
occasion (7/19/83), when a value of 2.2% opacity was recorded.  (The value
indicated on the strip chart for the same day was 2.0% opacity.)  The only
corrective action taken with respect to the zero check values occurred on
9/24/83, when the mechanical zero on the panel meter was reset to eliminate a
high bias of 1% opacity.
    Zero Compensation Checks

    The LSI RM41 opacity monitor is equipped with a zero compensation feature
which automatically adjusts the measured opacity value to compensate for dust
accumulation on the exposed optical surfaces of the transceiver unit.
According to the draft QA procedures, cleaning of the optical surfaces should
be performed when the level of zero compensation exceeds +_ 0.018 optical
density (i.e., +_ 4% opacity).

    For the data recorded at the Tatan Station, zero compensation values
ranged from -0.005 to +0.016 optical density (i.e., within acceptable limits)
on all except for two occasions when exceedances of the + 0.018 optical
density control limit were indicated.  One of the two exceedances occurred on
7/2/83 and is attributable to the problem with the reference current level
which occurred on the same day.  The second exceedance of the zero compen-
sation control limit was recorded on 12/4/83 (0.07 optical density).  This
value is probably due to an error either in reading the panel meter or in
recording the result, since both the preceding and subsequent zero compen-
sation levels are recorded as 0.009 optical density.

    The daily QA check zero compensation data for the latan Station indicate
that (1) the zero compensation feature appears to function properly, and (2)
cleaning of the exposed surfaces of the transceiver is performed with
sufficient frequency to maintain the level of zero compensation within the
range of +_ 0.018 optical density.  No corrective action was initiated at any
time during the study in response to the zero compensation values.


    Span Checks

    An upscale check of the opacity monitor's response is performed once daily
using an internal span filter and the zero mirror of the RM41.  The monitor
response to the span check as indicated by both the panel meter and the strip
chart was recorded on the daily log.  According to the QA procedures,
adjustment of the monitor was to be performed when the monitor response
exceeded +_ 2% opacity relative to the correct value of the span filter (i.e.,
32.5% opacity).

    The span check values obtained from the panel meter ranged between 31.0
and 33.5% opacity on all except for three occasions.  Tne three occasions when
the +_ 2% opacity span value control limit was exceeded were: (1) on the first
day of the QA implementation (6/14/83), when a value of 30% opacity was
recorded;  (2) on 7/2/83, when the reference fault was activated; and (3) on
10/25/83,  when a value of 30.2% opacity was recorded.  Based on the available
data, it is not possible to determine if the apparent exceedances of the span
control limit indicated by the panel meter on 6/14/83 and 10/25/83 were due to

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                                                                                90
reading/recording errors or to actual drift problems with the monitor.
Nevertheless, the values recorded for these days indicate a low bias,  and the
two values exceeded the control limit by only 0.5% opacity and 0.3% opacity,
respectively.

    For the span check values obtained from the strip chart record, only two
exceedances of the +_ 2% opacity span control limit were noted.  These values
occurred: (1) on 7/2/83, when the reference fault lamp was activated;  and (2)
on 10/25/83 (the same day an exceedance of the span control limit was indicated
by the panel meter), when a span check value of 30.2% opacity was recorded.
All other span values were within the QA control limits.

    Based on the span check data, it is concluded that: (1) the accuracy of the
monitor calibration at the span check value is consistently within +2% opacity
in all except for extremely rare instances when a low bias may be observed; and
(2) the panel meter and the strip chart record provide an adequate and consistent
indication of monitor performance relative to the daily span checks.


    Time Required for Daily Checks

    The time required to perform the daily checks of the latan Station opacity
monitoring system can be determined from the daily log sheets.  Six different
individuals performed the daily checks on various occasions during the first
8 months of the QA procedure implementation.  Four of these people performed
checks at the very beginning of the QA implementation period (i.e., 6/14-30/83).
The time necessary to perform the daily checks during this period ranged from
3 to 13 minutes and averaged 7.1 minutes.  As the monitor operators became more
experienced, a reduction in the amount of time necessary to perform the daily
checks is apparent from the tabulated data.  The time required to perform the
daily checks during December 1983 and January 1984 ranged from 1 to 6 minutes
and averaged 4.3 minutes.  This represents a reduction of nearly 40% in the
average time required to perform the daily check procedure over the 8 month
period during which the QA procedures were implemented.


5.3.2  Periodic QA Checks/Corrective Action

    The periodic QA procedures provide for checks of monitoring system
components and operational status that are unfeasible, impractical, or
unnecessary on a daily basis.  These checks were intended to be performed in
conjunction with the routine preventive maintenance program that is performed
three times per year at latan.  The periodic QA check procedures included: (1)
zero and span checks of both the panel meter and the chart recorder, (2) checks
of the reference current and zero compensation values,  (3) a check of the AGC
circuit, (4) a check of the optical alignment of the transmissometer compo-
nents, (5) a check  of the purge air system status, and  (6) a determination of
the apparent dust accumulation on the optical surfaces.

    According to station personnel, all of these checks except  for  the
determination of dust accumulation on optical surfaces were already included in
the routine  maintenance program.   (Window cleaning was  included in the  routine
maintenance  program.)

-------
    Statements by station personnel indicated that the difficult access to the
monitor installation location (300-foot ladder) was a major consideration in
the performance of maintenance activities for the monitor.  Routine maintenance
activities are roughly scheduled to be performed only three times per year, and
non-rountine maintenance is peformed only as it is indicated necessary by
problems observed at the monitor control unit.  Whenever a problem occurs that
requires a trip to the monitoring location, all monitor maintenance activities
and a complete system check-out are performed in order to avoid a separate trip
for routine maintenance.  Thus, the routine maintenance schedule remains very
flexible to take advantage of corrective action activities and because of other
factors, such as (1) weather conditions (climbing the ladder is avoided during
all of winter and whenever there is a chance of thunderstorms), and (2)
availability of instrument technicians.

    Because of the factors described above, the periodic QA check and
corrective action procedures were substantially modified at the latan Station.
Although periodic QA check logs and corrective action logs were not received
with the other QA documentation reviewed for the pilot project, these
activities were delineated in quarterly reports submitted to the Missouri DNR.
The following list describes the periodic QA and corrective action procedures
performed at the latan Station during the 1-year study.
                                Activity

                  REF lamp illuminated.  Replaced RM41
                  transceiver circuit board and cleaned
                  transmissometer windows.
GEM Downtime
 5.5 hours
    7/11/83       Replaced plugged purge air system filters.    1 hour

    9/2/83        Replaced integrator circuit board in          5.1 hours
                  opacity monitor control unit and recorder
                  amplifier circuit board in chart recorder.

    10/10/83      Replaced purge air system filters and         5 hours
                  performed preventive maintenance for
                  transmissometer.

    4/5-6/84      Removed monitor from stack and peformed       28.2 hours
                  off-stack zero check and clear-path audit.

    4/9/84        Performed on-stack audit checks.              3.2 hours

    5/25-26/84    Optical density circuit board failure in      29 hours
                  monitor control unit.  Replaced circuit
                  board.
    As can be seen from the above activities, the primary problem affecting
opacity GEMS performance at the latan Station was the failure of circuit
boards, both in the transceiver and in the monitor control unit.  However,
station personnel have demonstrated that they are able to resolve these
problems in an expeditious fashion.

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                                                                                92
5.4  SOURCE SELF AUDIT/OFF-STACK ZERO CHECK

    Personnel at the latan Station conducted an off-stack zero check and audit
of the opacity CEMS on April 5-6, 1984 using audit devices supplied by the
project team.  Source personnel had previously observed and/or participated in
the initial audit, had access to the detailed report for the initial audit,
and were furnished a copy of "Performance Audit Procedures for Opacity
Monitors" (EPA-340/1-83-010).  Station personnel removed the transmissometer
from its installed location and set up the transceiver and reflector in their
laboratory, using the same separation distance for the monitor components as
is used when the monitor is installed on the stack.  Proper zero alignment was
established (i.e., equivalency of the monitor responses to the clear path
condition and to the zero mirror).  Station personnel conducted the perfor-
mance audit of the opacity monitor in the laboratory generally in accordance
with the prescribed procedures and completed the necessary data sheets (see
Appendix C).  However, since the audit was performed off-stack, some of the
parameters normally included in a performance audit were not evaluated.
On-stack checks of the opacity CEMS were reported to have been made on April
9, 1984, after the monitor was reinstalled at the monitoring location.

    The results that were calculated from the data provided by the source self
audit are summarized in Table 5-2.  The results of this audit show that the
latan opacity CEMS met all of the audit criteria evaluated during the
off-stack tests.  It should be noted that only two measurements for each of
the three filters were obtained  for the calibration error test, instead of the
five measurements normally obtained.  Therefore, it is not possible to
determine the confidence interval or the calibration error (i.e., the sum of
the mean difference and confidence interval) for the monitor.  In view of the
very small mean errors which were observed at the  low, mid, and high range
levels, it is expected that  the CEMS would have passed the calibration error
test at all  three levels if  the  five measurement repetitions had been
performed.
 5.5  FINAL PERFORMANCE AUDIT

     A final performance audit of the latan opacity CEMS was conducted on
 June 27,  1984.   During the final audit,  station personnel indicated that no
 adjustments to the opacity CEMS and no QA checks had been performed since the
 May 6-25,  1984 boiler overhaul outage, and that several other brief outages
 resulting from boiler problems had occurred after the overhaul.   The final
 performance audit marked the end of the  1-year field study at latan.  Detailed
 discussions of the findings and results  of this audit are included in the June
 1984 audit report for this station.

     The results of the final performance audit of the latan opacity CEMS are
 summarized in Table 5-3.  The following conclusions were derived from the
 performance audit results:

     1.  The opacity monitoring system exhibited acceptable performance for most
         of the criteria evaluated during the performance audit.

     2.  Readings obtained from the control unit panel meter are biased low
         relative to readings obtained from the strip chart record.

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                                                                                93
              TABLE 5-2.  SUMMARY OF PERFORMANCE AUDIT RESULTS
                  KANSAS CITY POWER AND LIGHT COMPANY, IATAN
               LEAR SIEGLER MODEL RM41 OPACITY MONITORING SYSTEM
                             - SOURCE SELF AUDIT -

MONITOR COMPONENT ANALYSIS
Fault Indicator Lamps:
Filter
Shutter
Reference Signal
Window
Over Range
AGC Circuit Status
Stack Exit Correlation Error
Audit
Result

Off
Off
Off
Off
Off
On
Not Determined
Acceptable
Result

Off
Off
Off
Off
Off
On
+ 2%
  Panel Meter Status:
    Opacity Spale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS1
  Monitor Alignment (Centered)
  Zero Compensation:
        Before Cleaning
        After Cleaning

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total

CALIBRATION ERROR ANALYSIS2
     1.00
     1.00

      0.0%
 -0.1% Opacity
 -0.0% Opacity
Yes (Off-Stack)

      NA
      NA
      NA
      NA
      NA
0.98 to 1.02
0.98 to 1.02

   +_ 10%
+_ 2% Opacity
_+ 2% Opacity
   Yes

  0.018 OD
  0.018 OD
£ 2% Opacity
£ 2% Opacity
j< 4% Opacity
Mean Confidence
Error Interval
(Opacity)
Low
Mid
High
Range
Range
Range
(3.5%
(23.0
(47.
Opacity)
Opacity)
5% Opacity)
0.
-0.
-0.
0%
5%
75%
(Opacity)
ND
ND
ND
Calibration
Error
(Opacity)
ND
ND
ND
Acceptable
Calibration
Error
(Opacity)
£ 3%
1 3%
1 3%
 The performance audit checks were performed off-stack immediately after a recali-
 bration and zero alignment of the monitor.  These procedures require establishing
 proper monitor alignment, cleaning of optics, and resetting the monitor's zero
 value and primary calibration.  Measurements of these parameters during the off-
 stack audit are not applicable.
2
 Only two measurements per audit filter were made.  Therefore, the confidence
 interval and calibration error results cannot be determined.

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                                                                                94
            TABLE 5-3.  SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
             KANSAS CITY POWER AND LIGHT COMPANY,  IATAN UNIT NO.  1
               LEAR SIEGLER MODEL RM41 OPACITY MONITORING SYSTEM
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Filter
        Shutter
        Reference Signal
        Window
        Over Range

  AGC Circuit Status
  Stack Exit Correlation Error

  Panel Meter Status:
    Opacity Scale Factor
    Optical Density Scale Factor

  Reference Signal Analysis
  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS
    Audit
    Result
      Off
      Off
      Off
      Off
      Off

      On
       0%
      1.10
      1. 10

      0.05%
  -1.0% Opacity
  -2.4% Opacity
        Acceptable
          Result
           Off
           Off
           Off
           Off
           Off

           On
           + 2%
        0.98  to 1.02
        0.98  to 1.02

          _+  10%
        +_ 2%  Opacity
        +2%  Opacity
  Monitor Alignment (Centered)
  Zero Compensation:
        Before Cleaning
        After Cleaning

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total

CALIBRATION ERROR ANALYSIS
  Low Range  (9.0% Opacity)
      Strip Chart

  Mid Range  (20.5% Opacity)
      Strip Chart

  High Range  (51.5% Opacity)
      Strip Chart

  Second Filter  Set Check
      Low  (8.5%  Opacity)
      Mid  (19.0% Opacity)
      High (44%  Opacity)
      Yes

   0.025 OD
   0.014 OD
   0.0% Opacity
   0.05% Opacity
   0.05% Opacity
           Yes

        +_ 0.018 OD
        + 0.018 OD
        £ 2% Opacity
        <_ 2% Opacity
        <^ 4% Opacity
                                       Mean
                                       Error
                                     (Opacity)
+0.04%
-1.92%
-4.54%
-0.4%
-2.5%
-4.0%
             Calibration
                Error
              (Opacity)
0.11%
2.41%
4.65%
 NA
 NA
 NA
           Acceptable
           Calibration
              Error
            (Opacity)
< 3%
< 3%
< 3%
 NA
 NA
 NA

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                                                                                95
    3. The internal span error exceeded the +_ 2% span drift control limit
       included in the O.A procedures.

    4. As indicated by the calibration error test results, the monitor
       exhibits an increasing negative bias with increasing effluent opacity.

    5. The monitor's responses to the internal span check and the calibration
       error checks are consistent.  Thus, adjustment of the monitor to
       eliminate the internal span error would eliminate the observed
       calibration bias at high effluent opacity conditions.
5.6  GEMS DOWNTIME

    Figure 5-4 illustrates the opacity CEMS downtime for latan as reported in
excess emission reports from the second quarter of 1981 through the second
quarter of 1984.  The data for 1981 and 1982 were obtained from summaries
prepared by the Missouri DNR; the data for 1983 and 1984 were obtained from a
detailed review of quarterly reports submitted by Kansas City Power and Light
to the Missouri DNR.  (See " An Analysis of Opacity CEMS Downtime in Excess
Emission Reports: Opacity CEM Pilot Project," May 198t>, for additional
discussions and comparative results for other sources.)

    As can be seen from Figure 5-4, CEMS downtime decreased from a value of
approximately 20% (4i>0 hours) , for the first quarter that data were reported,
to a minimum level, which was consistently below 3% (65 hours), for all
subsequent reporting periods.  Thus, the opacity CEMS at latan achieved very
high levels of monitor availability (i.e., greater than 97% during the entire
field study).  Almost all of the very minimal CEM downtime that occurred
auring the field study was due to malfunctioning circuit boards and to the
off-stack zero check that was performed during April of 1984.
5.7  CONCLUSIONS

    The evaluation of tne results obtained from the performance audits and
from the implementation of quality assurance procedures shows that reliable
opacity monitoring results are provided by the LSI RM41 opacity CEMS installed
at Kansas City Power and Light Company's latan Station.  Specific conclusions
regarding monitor performance and the effectiveness of QA procedures are
provided below.

    1. The LSI opacity CEMS installed at latan achieved high levels of monitor
       availability during the study (  i.e., greater than 97% for each calendar
       quarter).

       (These availability results are expressed relative to the total number
       of hours in each calander quarter, since the opacity CEMS is operated
       even during boiler outages.)

-------
         too.00 r
          10.00 ••.
  CEtfS
       PER
QUARTER
  rvi
           1.00
           0.10 •-.
           0.01 L
                                            1234
                     1234
1234
                        1981
  1982

YEAR AND QUARTER
                                                              1983
1       2

 1984
                           FIGURE 5-4. CEMS DOWNTIME - KANSAS CITY POWER AND LIGHT COMPANY. IATAN STATION
                                                                                                                               CTi

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                                                                            97
2. The LSI opacity GEMS is capable of providing precise and accurate
   effluent opacity measurements.

   o  A review of 8 months of data shows that all of the daily zero check
      results and all except two of the daily span check results were
      within +_ 2% opacity of the correct value.

   o  The accuracy of the opacity CEMS was consistently within +_ 5% opacity
      as indicated by calibration error check results for three performance
      audits conducted during the study.  The calibration error results
      exceeded 3% opacity only during the final audit and only for the high
      range test.  This exceedance would not have occurred if adjustments
      had been made to eliminate the - 2.4% opacity span error that was
      observed during the audit.

   o  A zero alignment check was performed during the study in order to
      establish the equivalency of the monitor responses to the clear-path
      condition and to the transceiver zero mirror.
3. Adequate protection for and sufficient cleaning of exposed optical
   surfaces are provided to maintain measurement errors due to dust
   accumulation on optical surfaces to within + 4% opacity.

   (All but two of the recorded zero compensation values were within the
   applicable control limit, and the WINDOW fault lamp was never
   illuminated during the 8-month period.  The initial and final audit
   results show that the total dust accumulation on optical surfaces was
   equivalent to less than 2% opacity.)
4. Weekly checks of some monitor parameters that were initially included in
   the daily QA check procedures are sufficient to maintain the opacity
   CEMS within control limits at latan.

   (The time required to perform daily QA checks during the study typically
   averaged 4 to 7 minutes.  Reference current values were found to be very
   stable, and the REF fault indicator was observed to be illuminated
   before the reference current control limits specified by the manu-
   facturer were reached.  Virtually all of the zero compensation values
   recorded during the 8-month period were within the control limit.  Zero
   and span check responses indicated by the panel meter and chart recorder
   provided consistent indications of monitor performance.  These results
   show that both the checks of the reference current and the zero compen-
   sation values as well as the comparison of the panel meter and chart
   recorder responses are only necessary on a weekly basis.  Daily
   performance of zero and span checks of the chart recorder responses is
   required by the applicable regulations, and thus should continue to be
   performed.  Fault indicators should be checked at least once each day.)

-------
                                                                           98
   The difficult access  to  the monitor  installation  location significantly
   impacts  the frequency and scheduling of maintenance  and periodic QA
   check activities  for  the opacity GEMS.  Station personnel have  developed
   adequate and effective maintenance practices  that minimize  the  number  of
   trips to the monitoring  location.

   (A 300-foot ladder provides access to the monitoring location.  Routine/
   preventive maintenance activities are scheduled to be conducted only
   three times per year. The routine maintenance schedule  remains flexible
   to allow performance  of  these activities  when unplanned  trips to  the
   monitor are necessary.  According to plant personnel, a  complete  system
   check-out is performed during each trip to the monitoring  location.
   Performance of monthly QA checks  is  neither practical nor  necessary  at
   latan.)
6. Station personnel have developed effective procedures for resolving the
   most frequently encountered monitor-related problems at latan (i.e.,
   failure of electronic components within the opacity GEMS.)

   (Problems in the transceiver circuit board, the integrator and optical
   density circuit boards of the control unit, and the chart recorder
   amplifier board required the replacement of these components at various
   times during the 1-year study.  An adequate inventory of source parts is
   maintained, and station personnel have demonstrated their capability to
   perform necessary repairs so that GEMS downtime is minimal.)

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                                                                                99
                   6.0  ST. JOSEPH LIGHT AND POWER COMPANY,
                         LAKE ROAD STATION, UNIT NO. 5
     This section provides relevant background information and a summary and
discussion of results obtained from both (1) the implementation of quality
assurance procedures and (2) the performance audits of the installed opacity
GEMS at St. Joseph Light and Power Company, Lake Road Station, Unit No. 5.  An
overview of the field study conducted for this unit is provided in Figure 6-1.
6.1  SOURCE AND MONITOR DESCRIPTIONS

6.1.1  Source Description

     Lake Road Unit No. 5 is a coal-fired electric utility steam generator
equipped with an electrostatic precipitator for control of particulate
emissions.  Unit No. 5 is capable of producing the same amount of steam as a
boiler rated at approximately 25 MW.  However, since Unit No. 5 is connected
to a common steam header with all other boilers at the Lake Road Station
except Unit No. 6, and since steam produced by Unit No. 5 is supplied to local
industries, a specific MW production rate is not applicable.  Unit No. 5 is
subject to a Missouri opacity limit of 20%.


6.1.2  Monitor Description

     The Contraves Goerz Model 400 opacity monitoring system utilized at Lake
Road Unit No. 5 consists of a single transmissometer (transceiver and
reflector), a monitor control unit, and a strip chart recorder.  The
transmissometer is installed at approximately 85 feet above grade in the
exhaust stack.  The monitor control unit is mounted on an instrument panel in
the boiler control room.  Normally, 6-minute average effluent opacity levels
are displayed on the control unit strip chart recorder.  The strip chart
recorder is the only automatic recording device used with the opacity
monitoring system.


3.2  INITIAL AUDIT

     An initial audit of the opacity CEMS installed at the Lake Road Station
Unit No. 5 was performed on March 10, 1983.  The audit included (1) a visual
evaluation of the monitor installation location, (2) a systems audit (i.e., a
qualitative evaluation of monitor operation, maintenance, and record keeping
practices), and (3) a performance audit of the opacity CEMS (i.e., a
quantitataive evaluation of monitor accuracy and precision).  Detailed
discussions of the findings and results of the initial audit are included in
the March 1983 audit report for this station.

     The results of the initial performance audit of the Lake Road Station
Unit No. 5 opacity CEMS are summarized in Table 6-1.  The following conclus-
ions were derived from the initial audit:

-------
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                                                                                101
           TABLE 6-1.  SUMMARY OF INITIAL PERFORMANCE AUDIT RESULTS
           ST. JOSEPH LIGHT AND POWER COMPANY,  LAKE ROAD, UNIT NO. 5
              CONTRAVES GOERZ MODEL 400 OPACITY MONITORING SYSTEM
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Dirty Window
        Stack Power

  Stack Exit Correlation Error

  Control Panel Meter Correction Factor

  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total

CALIBRATION ERROR ANALYSIS
  Low Range  (9.0% Opacity)
      Panel  Meter
      Strip  Chart

  Mid Range  (20.5% Opacity)
      Panel  Meter
      Strip  Chart

  High Range (51.5% Opacity)
      Panel  Meter
      Strip  Chart
   Audit
   Result
    Off
    On

    0%

    1.01

0.0% Opacity
0.0% Opacity
    Yes
2.0% Opacity
0.5% Opacity
2.5% Opacity
Acceptable
  Result
   Off
   On

   +_ 2%

0.98 to 1.02

_+ 2% Opacity
+^2% Opacity



   Yes
^2% Opacity
^2% Opacity
< 4% Opacity

Mean
Error
(Opacity)
-2.4%
-3.3%
-3.2%
-3.6%
-2.0%
-2.1%

Calibration
Error
(Opacity)

3.6%
__.._
3.9%
_— — —
2.4%
Acceptable
Calibration
Error
(Opacity)
1 3%

1 3%

1 3%


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                                                                                102
Monitor Installation Location

    1. The opacity GEMS is installed in accordance with the provisions of
       Performance Specification 1, Appendix B, 40 CFR 60.  The measurement
       location provides opacity measurements that are representative of the
       entire effluent stream.

    2. The opacity GEMS is not subject to any known adverse environmental
       conditions except for the moisture and dust emitted from the nearby
       steam vent on the ash handling system.

    3. The access provided for the opacity GEMS is adequate.
Monitor Operation, Maintenance, and Record Keeping

    1. Maintenance/calibration activities for the opacity GEMS were performed
       on 18 occasions during the 2-year period preceding the audit.

    2. Although the opacity GEMS achieves relatively high levels of
       availability, uncertainty regarding the accuracy of the monitor
       calibration increases the level of maintenance efforts required and
       reduces the usefulness of the monitoring data, according to plant
       personnel.
Monitor Performance

    1. The Lake Road Unit No. 5 opacity monitoring system was found to exhibit
       acceptable performance for all criteria evaluated during the performance
       audit except for calibration error.

    2. The results of the calibration error test show that the opacity GEMS
       data are biased low by more than 3% opacity in the 9-21% opacity range
       and that the bias decreases to about 2% opacity at the 51% opacity
       range.
 6.3  QUALITY ASSURANCE PROCEDURES

    Draft  quality  assurance procedures were developed for  the Lake Road Unit
 No. 5  opacity GEMS.   The QA procedures consisted of daily  checks, periodic QA
 procedures, and criteria and  general procedures for use  in performing
 corrective action  for the  opacity GEMS.  During the initial  audit of the
 opacity GEMS, additional information was obtained that allowed  for revision of
 the draft  QA procedures.   (A  copy of the QA procedures utilized during the
 study  is included  in Appendix D  of  this report.)  Implementation of the QA
 procedures began on March  11,  1983, which was  the day following the initial
 audit  of the  opacity GEMS.  Based on a review  of the QA  data obtained during
 the  first 7 months of the  field  study, recommendations for revisions to the QA
 procedures were developed.  The  following section provides a brief description
 of the QA procedures, a  summary  of  the QA data, and a discussion of the results
 of implementing the QA program.

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                                                                                103
6.3.1  Daily QA Checks

    The daily check procedures involve only simple checks of monitor operation
that can be performed at the monitor control unit.  The purpose of these checks
is to determine whether the opacity GEMS is apparently operating properly or if
corrective action is necessary.  For the Contraves Goerz Model 400 opacity GEMS
at the Lake Road Station, these procedures involved:  (1) a check of whether
fault lamps were illuminated and (2) zero and span checks of the opacity GEMS.
For the first few months, zero and span check responses for both the chart
recorder and the panel meter were recorded during the daily checks; subse-
quently, recording of the panel meter responses was discontinued.  The daily
log was designed so that the time required to perform the QA checks, as well as
the boiler and monitor downtime during the preceding 24-hour period, would both
be recorded on the daily log.  An example daily log is shown in Figure 6-2.

    Summaries of all of the daily QA check results from March 11,  1983 until
October 12, 1983 are included in Appendix D of this report.  These summaries
contain all of the information recorded on the daily logs in a condensed
format.  With very few exceptions, the daily log sheets were completed each
day, including those periods during which the boiler was not operating.
    Fault Lamp Indicators

    The Contraves Goerz Model 400 opacity monitor installed at the Lake Road
Station Unit No. 5  is equipped with two fault  lamps that  are used to  indicate
operational problems with the monitor:

    1. STACK POWER  - Indicates when electrical power  is interrupted at the
                     monitoring  location.

    2. WINDOW       - Indicates when dust accumulation on  the transceiver  optics
                     exceeds the acceptable  range.


    During the approximate  7-month period for  which daily QA check logs are
available, there were eight occasions, totalling 16 days, when the WINDOW fault
lamp  was  illuminated.   In some additional cases, the  daily logs  are confusing,
since the various people who completed the logs used  different conventions for
recording the  status of fault indictors.  The  frequency with which the WINDOW
fault was activated shows that either  (1) the  purge air system does not
adequately protect  the  exposed optical surfaces of the transceiver from
contamination, or  (2) the fault  system is not  an accurate indicator of the
condition of the transceiver window.
     Zero Checks

     A check of the opacity monitoring system"s  response at the  zero opacity
 level is performed at least once per day using  the zero portion of  the rotating
 transceiver chopper to simulate clear path conditions.   For the first  4 months
 of the study,  the monitor zero check responses  indicated by both the panel
 meter and the  strip chart were recorded on the  daily  log.   For  the  last 3 months
 of the 7-month period, only the responses of the  chart  recorder were noted.
 According to the QA procedures, adjustment of the monitor was to be performed
 when the monitor response exceeded +^2% opacity during  the zero check.

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                                                                             104
                          Opacity Monitoring System

                                  DAILY LOG

        ST.  JOSEPH  LIGHT AND POWER CO.        LAKE ROAD STATION, UNIT #5

  I.   GENERAL INFORMATION

      Name:                      Date:
      Hours Boiler Down:

 II.   FAULT LAMPS
	  Time  Start:
       Time  Complete:

 Hours  Monitor Down:
FAULT LAMPS ON?
Stack Power
Dirty Window
NO


YES


III. STRIP CHART DATA
     Zero Calibration (% opacity):

Does
Does
zero
span
value
value
exceed
exceed
acceptable
acceptable
limits
limits
ot
ot
+ 2
± 2
.0%
.IU
opacity?
opacity?
NO


YES


     IF YES ANSWERS ARE INDICATED FOR ANY  OF  THE  ABOVE QUESTIONS, CORRECTIVE
     ACTION SHOULD BE INITIATED AS SOON  AS POSSIBLE.

 IV.  COMMENTS:
    FIGURE 6-2.  EXAMPLE OPACITY GEMS DAILY LOG:   ST.  JOSEPH  LIGHT  & POWER
                  COMPANY, LAKE ROAD STATION

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                                                                                105
    For the 7-month period for which data are available, the zero check
response as indicated by the panel meter never exceeded the +_ 2% opacity
limit.  However, since some of the operators recorded negative zero drift as
"-0" or "below zero" on the daily logs, no determination of whether excessive
negative drift occurred is possible.

    For the chart recorder, only one exceedance of the +_ 2% opacity zero
control limit occurred during the 7-month period; on 6/27/83 the chart recorder
zero response was noted as + 4% opacity.  The same zero check response was
recorded in a periodic QA check conducted on 6/30/83; corrective action was
initiated on the same day and completed on 7/1/83.  The zero response was
recorded as "-1.5" on 7/2/84.

    The review of the daily log revealed many notations such as "+0" and "-0."
Such entries were assumed to represent relatively insignificant variations
around the indicated value, since any other assumption would prohibit
interpretation of the data.  However, it is recognized that the mechanical
limit of the chart recorder in conjunction with the lack of a positive zero
offset prohibited an accurate quantification of negative zero drift for the
chart recorder at Lake Road Unit No. 5.
    Span Checks

    An upscale check of the opacity monitor response is performed once daily
using the span portion of the rotating transceiver chopper.  The monitor
responses to the span check as indicated by both the panel meter and the chart
recorder were entered on the daily log for the first 4 months of the 7-month
period.  Only the  response indicated by the chart recorder was noted for the
last 3 months.  According to the QA procedures, adjustment of the monitor was
to  be performed when the chart recorder response exceeded +_ 2% opacity relative
to  the correct value for the span check.  At the beginning of the 7-month
period, the correct value of the span check was assumed to be 64% opacity.

    Prior to mid-June, the panel meter span check values ranged between 62% and
66% opacity on all except for two occasions.  The two occasions when
exceedances of the +_ 2% opacity span drift limit occurred were the  second and
third days of the  QA implementation  (3/12-13/83), when a value of 61% opacity
was recorded.  This span check value (1) indicates a low bias of the monitor
and (2) exceeds the control limit by 1.0% opacity.

    Prior to mid-June, the chart recorder span check values indicated only one
exceedance of the  +_ 2% opacity span  control limit.  This value occurred on
5/2/83, when 67% opacity was recorded.  However, no corrective action was
initiated to resolve this problem.  All other span values were within the
control limits until 6/23/83.

    Beginning 6/23/83, a slight shift in the monitor calibration is apparent.
Both  the panel meter and the chart recorder responses to the calibration check
were  biased  low by 3-4% opacity.  A periodic QA check/corrective action were
initiated on 6/30  and completed on 7/1/83 to resolve both  (1) the indicated
window  fault condition, and  (2) the  zero check responses that exceeded the
control limit.  Several adjustments  to the monitor were performed at this time,
and although the exact nature of these adjustments and their impact on the
monitor are  unclear, it appears that after these actions, the typical monitor

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                                                                                106
response to the span check was 62% opacity.  It should be noted that this is
the same span check value that had been used until two days prior to the
initial audit of the monitor (in March of 1983).

    A "correct" span check value of 62% opacity was assumed for the review of
the QA data for the 3-1/2 month period following the corrective action com-
pleted on 7/1/83.  Relative to this value, two apparent exceedances of the
+ 2% opacity span drift limit were observed.  On 7/9/83, a panel meter span
response of 59% opacity was noted; however, the chart recorder span check
response was 62% opacity for the same day.  On 9/28/83, a chart recorder span
response of 59% opacity was observed.  This value is 1% opacity below the
control limits, and indicates a low bias in the opacity monitoring data.
Corrective action was not taken to resolve either of the above problems.
Nevertheless, the span check values on each of the following days was within
the span drift limit.

    A comment included in the daily check log  (6/fc>/83) raises concern with
respect to the consistency of reading/recording panel meter and chart recorder
responses: "Operators continue to misread panel meter and data recorder."

    Time Required for Daily Checks

    The time required to perform tne daily checks of the Unit No. b opacity
GEMS can be estimated from the daily log sheets.  During the 7 months of
implementation of the QA procedures, approximately 14 different individuals
performed the daily checks on various occasions.    Based on the log sheets,
the time required to perform the daily checks  during this period typically
ranged between 1 and 7 minutes per day; however, on seven occasions, more than
10 minutes were  required to complete the daily checks.  Lake Road Station
personnel offered the following clarification  of the tabulated results:

    "The personnel responsible for completing  these forms must account
    for their time and normally the  smallest increment  they report is 1/10
    of an hour.  This resulted in a  great  deal of 6 minutes or more time
    periods  being  reported.  Although  1 minute is more  typical of the time
    required to  perform  the daily checks."

6.3.2  Periodic  QA Checks/Corrective Action

    The periodic QA  procedures provide for checks of monitoring  system
 components  and operational  status that are unfeasible,  impractical, or
 unnecessary on a daily basis.  The periodic QA checks  were  intended to  be
 performed in conjunction with routine  maintenance activities  for the  opacity
 GEMS.   At the beginning of  the project,  the periodic QA checks were scheduled
 to be performed monthly.  The periodic QA check procedures  included:  (1)  zero
 and span checks of the opacity monitor according to both the  panel meter  and
 the chart recorder,  (2)  a check  of  optical alignment  of the transmissometer
 components, (3)  a determination of  the apparent dust  accumulation  on  the
 optical surfaces,  and (4)  a check of the monitor calibration  at  0% and 100%
 opacity using a zero jig.

     The corrective action procedures and log were intended to provide a general
 indication of what was done to resolve specific monitor problems and to
 document the impact of adjustments/repairs on (1)  fault lamp  status,  (2)  zero
 and span check  responses, and (3) monitor calibration.  It was intended that a
 corrective action log would be completed on each occasion when control limits
 were exceeded in either the daily or the periodic QA checks and on all other
 occasions when  adjustments or repairs of the opacity CEMS were performed.

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                                                                                107
    Periodic QA check logs and/or corrective action logs were completed on six
occasions between 6/30/83 and 4/20/84 for the field study that was conducted at
Lake Road Unit No. 5.  The data forms are included in Appendix D of this
report.  In each case, the same individual conducted the checks and completed
the data forms.  For five of the six occasions, both a periodic QA check log
and a corrective action log were submitted.  Most of the data forms contain
numerous entries regarding specific electronic measurements and adjustments
that were made.  However, the impact of these adjustments on the overall
performance of the opacity GEMS is often difficult or impossible to determine
from the recorded data.  The following is a summary of the periodic QA/correc-
tive action activities that were performed:

    6/30/83 -  The dirty window fault indicator was activated.  Electronic
               adjustments to the window status sensitivity circuitry were made
               to correct the fault conditions.  The data sheet indicates that
               a circuit board affecting the window status sensitivity had been
               replaced on 6/24/83.  No corrective action log for this repair
               was submitted with the other QA documentation.

               A chart recorder zero check response of 4% opacity (which
               exceeds the +_ 2% opacity zero drift limit) was noted on the
               daily log for 6/27/83 and was also noted in the periodic QA
               corrective action documentation.  Electronic measurements
               indicated that the problem was not in the transceiver; sub-
               sequent efforts indicated the problem was in the linearizer/
               integrator board.  Additional measurements were made; the
               manufacturer (Contraves Goerz) was called for advice; the
               problem was apparently resolved after additional adjustments
               recommended by the manufacturer were made.
    8/24/83 -  A periodic QA check was performed, apparently because the dirty
               window fault indicator was activiated.  The QA log indicates
               that the windows were cleaned; however, both the effluent
               opacity measurements and the window status indicator remained
               unchanged.  Electronic adjustments to the window status circuit
               and the transceiver meter were made.  Filters were used to check
               the monitor calibration, and the QA log states "readings were
               satisfactory after slight adjustment of zero"; however, filter
               response data were not provided.
     10/7/83 -  Adjustments were made to calibrate the system and to correct the
               dirty window fault indicator that was activated on 10/6/83
               according to the daily QA log.  The chart recorder calibration
               was checked in both the "instantaneous" and "integrate" modes,
               and was found to be acceptable.  A minor shift in the optical
               alignment was observed; however, the alignment was reported to
               be within acceptable limits, and no adjustments were performed.
     10/13/83 - The reason station personnel conducted the periodic QA check/
               corrective action on this date is not clear from any of the QA
               records.

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                                                                                108
    10/13/83    The QA  documentation  indicates  that  the  power supply board was
    (cont'd)    replaced because  improper  results  were obtained during the most
               recent  voltage  checks  (the dates of  these checks are unknown).
               Voltage measurements  were  not made after the power  supply board
               was replaced.

               A  gasket was  found  in the  transceiver tube that was reportedly
               obstructing the light beam and  biasing the monitoring results
               high  by approximately 8% opacity.  The gasket was removed.

               The optical alignment of the transmissometer was found to be
               unacceptable.   Adjustments were made to  restore proper
               alignment.

               Calibration checks  of the  transceiver meter, panel  meter, and
               chart recorder  were made at 0%,  18.1%, 52.0%,  and 100% opacity
               using the Unit  No.  5  zero  jig and  a  set  of neutral  density
               filters.  Zero  and  span checks  were  also performed,  and the
               responses provided  by all  three data display devices were
               compared.  Errors in  the chart  recorder  responses ranged from 1%
               to 6% opacity.   Adjustments were made to correct the chart
               recorder calibration.
     1/5/84  - Notes in the QA documentation state,  "Transmissometer  totally
               inaccurate due to systems  failure.   Found faulty power supply.
               Replaced [power supply]  and calibrated transmissometer."


    4/20/84  - According to the QA documentation,  a representative from
               Contraves Goerz (1) serviced the monitor, (2)  performed a
               clear-path test in the shop, (3) replaced the  timing diodes  in
               the transceiver, (4) attempted to align the transceiver optics,
               (5) performed electronic adjustments, and (6)  adjusted the dirty
               window indicator sensitivity.  Station personnel and the
               Contraves representative reinstalled the monitor and completed
               final calibration checks.   (The Contraves field service report
               also stated that, "Light source is slightly clipped at air
               nozzle.")
    The repairs and adjustments performed by the Contraves representative were
apparently not totally successful, according to the quarterly report submitted
by St. Joseph Light and Power Company, Lake Road Station to the Missouri DNR
for the second quarter of 1984.  This report contains the following statement:
               "During the time period of April 16th through the 19th,
           the opacity monitors on both Units 5 and 6 were inspected
           and calibrated by a Contraves Service Repairman.  This was
           a routine inspection.  During this inspection a problem
           with the optical alignment on the opacity monitor on Unit 5
           was discovered.  An attempt was made to align the optics in
           the field, but could not be performed to the Service
           Repairman's requirements.  His suggestion was that the unit
           be sent back to the factory for repair.

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                                                                                 109
               On May 17th, the monitor was removed and sent back to
           the factory.  Due to damage occurred [sic] during shipment
           and some unexplained delays, the unit was returned on June
           27th and installed in the stack on July 2nd.  Since this
           time, the monitor has had no other maintenance problems."
6.4  SOURCE SELF AUDIT

    Personnel at the Lake Road Station conducted a performance audit of the
Unit No. 5 opacity CEMS on July 23, 1984 using audit devices supplied by the
project team.  Source personnel had previously observed and/or participated in
the initial audit, had access to the detailed report for the initial audit, and
were furnished a copy of "Performance Audit Procedures for Opacity Monitors"
(EPA-340/1-83-010).  Using this information, the Lake Road Station personnel
conducted the performance audit generally in accordance with the prescribed
procedures and completed the necessary data sheets (see Appendix D).  The
results that were calculated from the data provided by the source self audit
are summarized in Table 6-2 for the Unit No. 5 CEMS.

    The results of the source self audit show that the Unit No. 5 opacity CEMS
met all of the audit criteria except for high range calibration error.

    The apparent failure of the opacity CEMS to meet the calibration error
limit for the high range test is believed to be due to a reporting error, and
is not considered to be representative of actual monitor performance.  This
situation occurred because an administrative error was made when the audit
filters were transmitted the to Lake Road Station.  The value of the high range
filter provided to the Lake Road Station personnel for use in the self audit
was 42% opacity.  This value was incorrect; the correct value of the high range
filter was 46% opacity, as is indicated by filter calibration data obtained
prior to and after the audit.  The monitor responses for the high range
calibration error tests reported by the Lake Road personnel for the self audit
were exactly equal to the incorrect filter value (i.e., 42% opacity) for five
consecutive measurements.  It should be noted that the high range calibration
error test results for the self audit are not supported by the results of the
final audit that was conducted less than three weeks later (see Section 6.5
below).
6.5  FINAL PERFORMANCE AUDIT

    A final performance audit of the Lake Road Station Unit No. 5 opacity CEMS
was conducted on August 16, 1984.  This audit marked the end of the  1-year
field study at the Lake Road Station.  Detailed discussions of the findings and
results of the final audit are included in the August 1984 audit report for
this station.

    The results of the final performance audit of the Unit No. 5 opacity CEMS
are summarized in Table 6-3.  The following conclusions were derived  from the
results of the final performance audit:

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                                                                                110
               TABLE 6-2.  SUMMARY OF PERFORMANCE AUDIT RESULTS
           ST. JOSEPH LIGHT AND POWER COMPANY, LAKE ROAD, UNIT NO. 5
              CONTRAVES GOERZ MODEL 400 OPACITY MONITORING SYSTEM
                             - SOURCE SELF AUDIT -
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Dirty Window
        Stack Power

  Stack Exit Correlation Error
    Audit
    Result
    On*
    On

    0%
Acceptable
  Result
   Off
    On

   + 2%
  Panel Meter Correction Factor
  Transceiver Meter Correction Factor

  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
    1.0
    1.02

+1.0% Opacity
-0.5% Opacity
    Yes
 0.0% Opacity
 0.0% Opacity
 0.0% Opacity
0.98 to 1.02
0.98 to 1.02

+_ 2% Opacity
+_ 2% Opacity
   Yes
£ 2% Opacity
£ 2% Opacity
£ 4% Opacity
CALIBRATION ERROR ANALYSIS




Low Range
Mid Range
High Range




(9.0% Opacity)
(21.0% Opacity)
(46.0% Opacity)**

Mean
Error
(Opacity)
-0.4%
0.4%
-4.0%

Confidence
Interval
(Opacity)
0.7%
0.6%
0.0%

Calibration
Error
(Opacity)
1. 1%
1.0%
4.0%
Acceptable
Calibration
Error
(Opacity)
< 3%
<_ 3%
< 3%
   Plant personnel indicated that an electrical short circuit caused this
   fault lamp to be illuminated.   Plant personnel had not been able to locate
   the problem but were aware that the dirty window indicator was defective.

   The high range calibration error test result is believed to be due to a
   reporting error and is not considered to be representative of actual monitor
   performance.

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                                                                                 111
            TABLE 6-3.  SUMMARY OF FINAL PERFORMANCE AUDIT RESULTS
           ST. JOSEPH LIGHT AND POWER COMPANY, LAKE ROAD, UNIT NO. 5
              CONTRAVES GOERZ MODEL 400 OPACITY MONITORING SYSTEM
MONITOR COMPONENT ANALYSIS

  Fault Indicator Lamps:
        Dirty Window
        Stack Power

  Stack Exit Correlation Error

  Transceiver Meter Correction Factor

  Internal Zero Error
  Internal Span Error

MONITOR MAINTENANCE ANALYSIS

  Monitor Alignment (Centered)

  Optical Surface Dust Accumulation:
        Transceiver Window
        Reflector Window
        Total
         Audit
         Result
         On*
         On

         0%

         0.93

      0.0% Opacity
      0.5% Opacity
         Yes
      1.0% Opacity
      2.0% Opacity
      3.0% Opacity
               Acceptable
                 Result
                  Off
                   On

                  +_ 2%

               0.98 to 1.02

               +_ 2% Opacity
               +_ 2% Opacity



                  Yes
               £2% Opacity
               ^2% Opacity
               £ 4% Opacity
CALIBRATION ERROR ANALYSIS
  Low Range (11.3% Opacity)
      Transceiver Meter
      Strip Chart

  Mid Range (19.6% Opacity)
      Transceiver Meter
      Strip Chart

  High Range  (31.4% Opacity)
      Transceiver Meter
      Strip Chart
Mean
Error
(Opacity)
-1.0%
-0.9%
-1.2%
-0.6%
Confidence
Interval
(Opacity)
0.2%
0.7%
0.5%
0.0%
Calibration
Error
(Opacity)
1.2%
1.6%
1.7%
0.6%
Acceptable
Calibration
Error
(Opacity)
1 3%
1 3%
-1.4%
-1.0%
0. 1%
0.7%
1.5%
1.7%
< 3%
 Plant personnel indicated that an electrical short circuit caused this
 fault lamp to be illuminated.  Plant personnel had not been able to locate
 the problem but were aware that the dirty window indicator was defective.

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                                                                                112
    1.  The Unit No. b opacity monitoring system exhibited acceptable per-
        formance for all of the criteria evaluated during the August 1984
        performance audit.

    2.  The dirty window fault indicator was malfunctioning during the audit;
        the levels of dust accumulation on the transceiver and reflector optics
        were within acceptable limits.

    3.  Both the strip chart recorder and the transceiver meter provided
        accurate and precise measurements, as indicated by the calibration
        error results.  In addition, the outputs provided by the two data
        display devices were very consistent during the audit.
6.6  GEMS DOWNTIME

    Figure 6-3 illustrates the total GEMS downtime for the Lake Road Station,
Unit No. 5, as reported in excess emission reports from the first quarter of
1980 through the second quarter of 1984.   The data for 1980 through 1982 were
obtained from summaries prepared by the Missouri DNR;  however, no information
was available for many of the quarters.  The GEM downtime data for 1983 and
1984 were obtained from a detailed review of quarterly reports submitted by St.
Joseph Light and Power Company to the Missouri DNR.   (See " An Analysis of
Opacity GEMS Downtime in Excess Emission Reports: Opacity GEM Pilot Project,"
May 1986, for additional discussions and comparative results for other
sources.)

    As can be seen from Figure 6-3, GEMS downtime for Unit No. 5 was highly
variable.  The GEMS downtime decreased from an initial value of approximately
78% to a value of less than 1% for the first two reporting periods, varied
significantly during tne pilot project field study,  and eventually rose to a
value of approximately 50% for the second quarter of 1984, when tne monitor was
returned to the manufacturer for repairs.  With the exception of the second
quarter of 1984, the vast majority of the reported GEMS downtime was due to
problems witn (1) the strip chart recorder drive (it often ran slow or not at
all), and (2) the 6-minute integration circuit of the monitor.  Thus, the
transinissometer portion of the GEMS achieved high levels of monitor
availability; however, the data averaging ana recording mechanisms did not.

    The daily O.A check log and instructions provided a blank for the recording
of the hours of monitor downtime during the 24-hour period preceding eacn daily
check.  The monitor operators recorded only those periods when the transmis-
someter was inoperative and ignored the downtime associated with the averaging
and recording mechanisms of the GEMS.  Thus, the GEMS downtime recorded in the
daily logs completed during the field study is only a small fraction of the
GEMS downtime reported to the Missouri DNR in quarterly excess emission
reports.  This result supports the GEMS availability findings based on the
information contained in tne reports submitted to the Missouri DNR.

6.7  CONCLUSIONS

    The  following conclusions are based on the evaluation of the results
obtained from performance audits and implementation of quality assurance
procedures for  the Contraves Goerz Model 400 opacity GEMS installed at St.
Joseph Light and Power Company's Lake Road Station, Unit No. b.

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          100.0 T   •
               *	
           10.0 T
    CEMS
DOWNTIME PER
  QUARTER
     C»
            1.0
                                                                  3     A
                                                             1982
                                                YEAR AND QUARTER
1234
      1983
1     2
1984
                         FIGURE 6-3. CEMS DOWNTIME - ST. JOSEPH LIGHT AND POWER COMPANY. LAKE ROAD UNIT NO. 5

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                                                                            114
1.  The Contraves Goerz opacity GEMS installed at Lake Road Unit No.  5  did
   not achieve consistently high levels of availability during the study.
   GEM downtime varied greatly and significantly exceeded 10% for three
   reporting periods.
   (CKMS downtime was approximately 20% for the second quarter of 19b3
   (i.e., the beginning of the field study),  increased to approximately 28%
   for the next quarter, decreased to less than 5% for the next two quar-
   ters, ana then increased to approximately 50% for the second quarter of
   1984, when the monitor was returned to the manufacturer for repairs.
   Prior to the second quarter of 1984,  most of the GEMS downtime was due
   to problems with the chart recorder drive and/or with the b-minute
   integrator circuit, rather than to problems with the actual transmissometer.)
2.  The accuracy and precision of the opacity CEMS data were within + 4%
   opacity relative to the correct values for the daily zero and span checks
   during a period of 7 months.

   (Only one exceedance of the +_ 2% opacity zero check control limit
   occurred based on the chare recorder responses.  However, confusing
   notations in the daily logs and the lack of a zero offset relative to the
   mechanical limit of the chart recorder prohibited accurate quantification
   of negative zero drift.  Only two exceedances of the +_ 2% opacity span
   check control limit occurred.  However, the assigned span value changed
   from 64% opacity to 62% opacity midway through the 7-month period,
   apparently as a result of adjustments performed on 6/30 - 7/1/83 during a
   periodic yA check/corrective action.)
3. The accuracy of the opacity CEMS data significantly improved as a result
   of the repairs performed by the manufacturer.

   (At the beginning of the study, the accuracy of the opacity CEMS data was
   within 4% opacity as indicated by the calibration error check results for
   tne initial performance audit.  However, because of uncertainty regarding
   the status of the zero alignment and because ot the 2% opacity span value
   shift that subsequently occurred, it may only be assumed that the actual
   accuracy of the opacity CEMS data was within +_ 6% opacity.  Following the
   repairs performed at the manufacturer's facility and the reinstallation
   of the opacity monitor (which included a zero alignment check), the
   accuracy of the opacity CEMS data was within +_ 2% opacity as indicated by
   the calibration checks conducted during the source self-audit and the
   final audit.)
4. For the Lake Road Unit No. 5 CEMS, either the WINDOW fault system is not
   an accurate indicator of the dust accumulation on the transceiver window,
   or the purge air system does not adequately protect the exposed optical
   surface of the transceiver from contamination.

    (During the first 7 months of the study, there were at least eight
   occasions, totalling at least 1b days, when the WINDOW fault indicator
   was activated.  This very high frequency of WINDOW faults shows that

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                                                                            115
   either the fault indicator is defective,  or that the transceiver windows
   are rapidly contaminated (possibly from particulate matter emitted by the
   stream vent on the ash handling system).   The quantity of dust accumu-
   lated on the optical surfaces could not be determined from the periodic
   QA checks.  The WINDOW fault circuit was malfunctioning due to an
   electronic short circuit that occurred before and during the final audit
   (i.e., after monitor repairs were made by the manufacturer).  However, it
   is not possible to determine whether the initially observed problems were
   related to the short circuit observed before and during the final audit.)
5. The periodic QA check and corrective action documentation for the Lake
   Road Unit No. 5 opacity CEMS does not provide sufficient information to
   determine whether the monitor was operating properly.

   (The periodic QA. checks were scheduled to be performed on a monthly
   basis, but were instead usually performed in conjunction with corrective
   action activities.  Only six periodic QA checks/corrective actions were
   performed by station personnel during the 1-year study.  In many cases,
   (1) the dust accumulation on the optical surfaces, (2) the effects of
   zero or span adjustments, or (3) the effects of various repairs that were
   made were impossible to quantify because of the nature of the monitoring
   problems that occurred (i.e., off-scale monitor responses, power supply
   failures, etc.) and because of the manner in which the QA documentation
   was completed.  For some cases, the reported information is not adequate
   to determine if the opacity CEMS was operating within applicable control
   limits after corrective action was completed.)

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                                  TECHNICAL REPORT DATA
                           (Please read Instructions on the reverse before completing)
U REPORT NO.
    68-02-396
                                                           3. RECIPIENT'S ACCESSION NO.
ft. TITL.!"WNTr§UBTITLE
  MISSOURI  OPACITY GEMS PILOT PROJECT:
  Evaluation of Opacity CEMS Reliability  &  QA Procedures
  Volume I  - Text and Volume II - Appendices
             5 REPORT DATE
                 May  1986
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
         W.  Peeler
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Entropy Environmentalists, Inc.
   P.O.  Box 12291
   Research Triangle Park, North  Carolina 27709
                                                           10. PROGRAM ELEMENT NO,
             11. CONTRACT/GRANT NO.

               68-02-3962
12. SPONSORING AGENCY NAME AND ADDRESS
   U.  S.  EPA, Stationary  Source  Compliance Division
   Waterside Mall
   401 M Street, SW
   Washington, DC  20460
             13. TYPE OF REPORT AND PERIOD COVERED
               Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
    A study  was conducted in Missouri  to  evaluate the reliability  of opacity monitoring
data and  to  facilitate the development and evaluation of QA procedures for opacity
GEMS's.   The study included opacity CEMS's installed on six coal-fired electric utility
generating units at four generating stations,  each owned by a different company.  The
sources were representative of a wide  range of monitoring applications and conditions,"
and were  equipped with contemporary opacity monitoring instrumentation.  For each
station,  monitor- and source-specific  opacity CEMS QA procedures were developed and "- "
CEMS audits  were conducted at the beginning of the study.  Plant personnel implemented
and revised  the QA procedures and conducted a performance audit during a 6- to 8-month
period.   Performance audits were also  conducted at the end of the  study.

  This report presents evaluations both of opacity CEMS reliability (i.e.-, accuracy,
precision, and availability) and of the QA procedures that were used din this study.  In
summary,  appropriate and effective QA  procedures can be developed  and implemented for a
varietj' of opacity monitoring equipment and applications without imposing an undue
burden on the monitor operators.  Such procedures are inherently source- and monitor-
specific.  Reliable opacity monitoring data are obtained when appropriate QA procedures
are implemented.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                           c. COSATI Field/Group
    Air Pollution
    Monitoring
Opacity Monitoring  System:
Continuous Emission
   Monitoring
CEMS Reliability
Duality Assurance
   Procedures
 18. DISTRIBUTION STATEMENT

    Release to Public
19. SECURITY CLASS (This Report)
 Unclassified
21. NO. OF PAGES
  403
                                              2O. SECURITY CLASS (Tins page)

                                               Unclassified
                                                                         22. PRICE
 EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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