United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-454/R-00-040a
September 2000
Air
EVALUATION OF PARTICULATE MATTER
E PA (PM) CONTINUOUS EMISSION
MONITORING SYSTEMS (CEMS)
Final Report
Volume 1 — Technical Report
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Evaluation of Particulate Matter
Continuous Emission
Monitoring Systems
Final Report
Volume I—Technical Report
For U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emissions, Monitoring and Analysis Division
Emission Measurement Center
Research Triangle Park, North Carolina 27711
Attn: Mr. Dan Bivins
EPA Contract No. 68-W6-0048
Work Assignment No. 4-02
MRI Project No. 104703.1.002.07.01
September 25, 2000
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th rtoaf
Chicago, IL 60604-3590
Midwest Research Institute • 425 Volker Boulevard • Kansas City, Missouri 64110-2299
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Preface
This report was prepared by Midwest Research Institute (MRI) for the U.S.
Environmental Protection Agency (EPA) under Contract No. 68-W6-0048, Work
Assignment 4-02. Mr. Dan Bivins is the EPA Work Assignment Manager (WAM). This
report covers the 6-month endurance test period for the PM-CEMS (July 20, 1999 to
February 16, 2000) and includes the initial correlation tests as well as the two RCA/ACA
tests.
All of this work would not have been possible without the full cooperation of
Cogentrix personnel. The Cogentrix staff (especially Tracy Patterson, Air Quality
Manager, Steve Carter, Plant Manger, and Mike Chaffin, I&C Supervisor) were very
helpful and provided every possible assistance to make this a successful project.
This report consists of 1,238 pages, including the appendices.
MIDWEST RESEARCH INSTITUTE
Paul Gorman
Work Assignment Leader
Approved:
Joseph Pala
Program Manager
September 25, 2000
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Contents
Preface iii
Executive Summary ES-1
Section 1. Introduction 1-1
1.1 Summary of Test Program 1-1
1.1.1 Overall Purpose of the Program 1-1
1.1.2 Test Site 1-3
1.1.3 Summary of CEMS Evaluated 1-5
1.1.4 Emissions Measured 1-10
1.1.5 Dates of Tests 1-10
1.2 Key Personnel 1-11
Section 2. Sampling Location 2-1
2.1 Flue Gas Sampling Location 2-1
2.2 Sampling and Analytical Procedures 2-6
2.3 Process Sampling Locations 2-7
Section 3. Installation and Start-up of the CEMS 3-1
3.1 CEMS Delivery 3-2
3.2 Functional Acceptability Testing 3-2
3.3 Installation at the Test Site 3-4
3.4 Start-up Issues 3-6
Section 4. Durability, Availability, and Maintenance Requirements for CEMS 4-1
4.1 ESC-P5B 4-1
4.2 Durag DR 300-40 4-3
4.3 Durag F904K 4-4
4.4 HMP 235 Moisture CEMS 4-7
4.5 Summary 4-9
Section 5. Presentation and Discussion of Results 5-1
5.1 Objectives and Test Matrix 5-1
5.2 Field Test Changes and Problems 5-3
5.2.1 Initial Correlation Test Changes and Issues 5-3
5.2.2 First RCA Test Changes and/or Problems 5-5
5.2.3 Second RCA Test Changes and/or Problems 5-5
5.3 Presentation of Results 5-5
5.3.1 Process Data 5-6
5.3.2 M17 Test Results and H2O CEMS Results 5-6
5.3.3 PM-CEMS Drift Test Data and ACA Results 5-37
5.3.4 Initial Correlation and RCA Test Results 5-54
5.3.5 Investigation of Reason(s) for Non-agreement of
RCA Results 5-89
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Section 6. Internal QA/QC Activities 6-1
6.1 QA/QC Issues 6-1
6.1.1 Initial Correlation Test 6-1
6.1.2 First RCA Test 6-2
6.1.3 Second RCA Test 6-2
6.1.4 Final ACA 6-3
6.2 QA Audits 6-3
Appendices
Volume 2—Appendices A through G for Initial Correlation Tests
Volume 3—Appendices A through G for RCA No. 1
Volume 4—Appendices A through G for RCA No. 2
Volume 5—Appendix H (Daily Graphs)
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Tables
Table 4-1. Levels of Upscale Calibration Drift for the ESC P5B 4-2
Table 4-2. CEMS Data Unavailability 4-10
Table 4-3. Data Availability for Each CEMS 4-13
Table 5-1 A. Summary of Process Data for Each Run of the Initial Correlation
Tests 5-7
Table 5-1B. Summary of Process Data for Each Run 5-8
Table 5-1C. Summary of Process Data for Each Run of Second RCA Tests 5-9
Table 5-2A. Summary of M17 Sampling Data for Initial Correlation Tests 5-10
Table 5-2B. Summary of M17 Sampling Data for First RCA Tests 5-11
Table 5-2C1. Summary of M17 Sampling Data for Traversing Train A
(Second RCA Test) 5-12
Table 5-2C2. Summary of M17 Sampling Data (Train B—Single Point)
(Second RCA Test) 5-13
Table 5-3A. M17 Particulate Test Results for Initial Correlation Tests 5-14
Table 5-3B. M17 Particulate Test Results for First RCA Test 5-15
Table 5-3C1. M17 Particulate Test Results—Traversing Train
(Second RCA Test) 5-16
Table 5-3C2. M17 Particulate Test Results (Train B—Single Point)
(Second RCA Test) 5-17
Table 5-4A. Precision of Method 17 Dual Trains for Initial Correlation Tests 5-19
Table 5-4B. Precision of Method 17 Dual Trains for First RCA Tests 5-20
Table 5-5 A. Comparison of M17 Moisture Results for Initial Correlation Tests ... 5-24
Table 5-5B. Comparison of M17 Moisture Results for First RCA Test 5-25
Table 5-5C. Comparison of M17 Moisture Results for Second RCA Test 5-26
Table 5-6A. Summary of Moisture Results for Initial Correlation Tests
(CEM vs M17, and Calculated Correction Factor) 5-28
Table 5-6B. Summary of Moisture Results from the first RCA Test
(CEM versus M17) 5-31
Table 5-6C. Summary of Moisture Results for the Second RCA Tests
(CEMS versus Method 17) 5-32
Table 5-7A. Stack Temperature Comparison for Initial Correlation Tests
(M17 Versus H2O CEM 5-34
Table 5-7B. Stack Temperature Comparison for the First RCA Tests
(M17 Versus H2O CEM) 5-35
Table 5-7C. Stack Temperature Comparison for Second RCA Test
(CEMS versus Method 17) 5-36
Table 5-8. 7-Day Calibration Drift Results for the Three PM-CEMS 5-38
Table 5-9A. Daily Drift Results (July 20 to August 31, 1999) 5-40
Table 5-9B. Daily Drift Results (September 1 to November 20, 1999) 5-42
Table 5-9C. Daily Cal Drift Data (November 21 to February 16) 5-44
Table 5-10A. Results for Initial ACA 5-50
Table 5-10B. Results for 2nd ACA 5-51
Table 5-10C. Results for 3rd ACA 5-52
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Table 5-10D. Results for 4th ACA 5-53
Table 5-11A. Initial SVA Results 5-55
Table 5-11B. Second SVA Results 5-56
Table 5-11C. Third SVA Results 5-57
Table 5-11D. Fourth SVA Results 5-58
Table 5-12. Tabulation of Data from Initial Correlation Tests 5-60
Table 5-13. Selected Correlation Equation Values Versus Performance Criteria .. 5-70
Table 5-14. Tabulation of Data from First RCA Test 5-72
Table 5-15. Correlation Equation Results Using Combined Data from Initial
Correlation Tests and First RCA Tests (24 Total Data Points) 5-79
Table 5-16. Correlation Equation Results Using First RCA Test Data Only
(12 Data Points) 5-81
Table 5-17. Tabulation of Data from Second RCA Test 5-83
Table 5-18. Tabulation of Data for Single Point Train Versus Traversing Train . 5-105
Figures
Figure 1-1. Unit 1 Effluent Schematic 1-4
Figure 2-2. Location of GEMS and M17 Test Ports (Elevation Front View) 2-3
Figure 2-3. M17 Sampling Points and CEMS Locations 2-4
Figure 2-4. Schematic Elevation Side View of Baghouse Inlet/Outlet Ducts and
Perturbing Device 2-5
Figure 2-5. Analytical Scheme for M17 Train Components 2-8
Figure 5-1A. Bias of Train A versus Train B in Initial Correlation Tests 5-21
Figure 5-1B. Bias of Train A versus Train B in First RCA Tests 5-22
Figure 5-2. Comparison of Adjusted Moisture Monitor Readings with M17 Results,
from Initial Correlation Tests 5-30
Figure 5-3A. Linear Regression for ESC Light Scatter—P5B 5-63
Figure 5-3B. Linear Regression for Durag Light Scatter—DR 300-40 5-65
Figure 5-3C. Linear Regression for Durag Beta Gauge—F904K 5-67
Figure 5-4A. Comparison of Initial Correlation Equation with the First RCA Test
Data for ESC-P5B 5-73
Figure 5-4B. Comparison of Initial Correlation Equation with First RCA Test
Data for DR300-40 5-75
Figure 5-4C. Comparison of Initial Correlation Equation with First RCA Test
Data for F904K 5-77
Figure 5-5A. ESC-P5B Initial Correlation and all RCA Data 5-85
Figure 5-5B. DR300-40 Initial Correlation and all RCA Data 5-87
Figure 5-5C. F904K Initial Correlation and all RCA Data 5-89
Figure 5-6A. ESC-P5B Correlation for First RCA and Comparison with Data from
Second RCA 5-91
Figure 5-6B. DR300-40 Correlation for First RCA, and Comparison with Data from
Second RCA 5-93
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Figure 5-6C. F904K Correlation for First RCA, and Comparison with Data from
Second RCA 5-95
Figure 5-7. Velocity at Traverse Points through Port C—ICAL vs. First RCA 5-98
Figure 5-8A. November 15, 1999: Perturbing Device Closed 5-100
Figure 5-8B. November 17, 1999: Perturbing Device Open 5-101
Figure 5-9. Top View of Baghouse Outlet Duct 5-103
Figure 5-10. Paniculate Ratio vs. Concentration 5-107
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Executive Summary
EPA's Office of Air Quality Planning and Standards (OAQPS) is considering
paniculate matter continuous emission monitoring systems (PM-CEMS) for use in future
standards. Also, states may require them for State Implementation Plans (SIP) and
Economic Incentive Program (EIP) monitoring, and industry sources may use PM-CEMS
for Title V monitoring. EPA therefore desired evaluation of PM-CEMS technology on a
long-term, continuous basis.
The purpose of this demonstration program was to assess the performance of PM-
CEMS over an extended time. The program included three PM-CEMS and a moisture
CEMS installed at the Cogentrix coal-fired cogeneration facility in Battleboro, North
Carolina. These CEMS were:
• ESC P5B light scatter PM-CEMS
• Durag DR 300-40 light scatter PM-CEMS
• Durag F904K Beta gauge PM-CEMS
• Vaisala HMP 235 moisture CEMS
Due to limited space for installing the devices at this test site, they were necessarily
located only 2.1-2.6 diameters downstream of a 90° bend in the ductwork, which
minimally met the location guidance in draft PS-11. It was recognized that this location
might involve particulate stratification, but it was believed that any such stratification
would likely be constant rather than variable, and thus would inherently be accounted for in
development of the correlation relations for each PM-CEMS.
In addition to installing the PM-CEMS, a perturbing device was also installed that
allowed bypassing part of the flue gas from the baghouse inlet to the outlet in order to
increase the range of particulate emissions for the testing.
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Following installation and startup of the monitors, data were downloaded daily, and
three sets of tests were carried out: the initial correlation tests per draft Performance
Specification 11 (PS II)1 and two Response Correlation Audits/Absolute Correlation
Audits (RCA/ACA tests) per draft Procedure 2.2 These tests are discussed below, with the
two RCA/ACA tests referred to as "RCA #1" and "RCA #2." It should be noted that all
three PM-CEMS provided good data availability (over 95%) throughout the 6-month
period of their operation. The moisture CEMS did exhibit some problems with data
availability, probably due to constant vibration at the test location. All three PM-CEMS
met the daily drift criteria. They also met the applicable criteria in draft Procedure 2 for the
four separate ACAs performed on the light scatter PM-CEMS and the Sample Volume
Audits (SVAs) performed on the beta gauge PM-CEMS.
Initial correlation relation testing of the three PM-CEMS was carried out in July 1999,
and results met the draft PS-111 correlation criteria for all three PM-CEMS. An ACA was
also completed just before the initial correlation testing. In late August 1999, the first RCA
(RCA #1) and a second ACA of the PM-CEMS were carried out per draft EPA
Procedure 2.2 For all three PM-CEMS, only 7 of the 12 RCA data points fell within a 25%
tolerance interval of the initial correlation relation (Procedure 2 requires that 9 of the
12 data points fall within a ± 25% tolerance interval). The 12 RCA data points were then
used to develop a new correlation relation for all three PM-CEMS. These new correlations
were within the draft PS-11 correlation criteria for the F904K beta gauge but were just
outside the confidence interval and tolerance interval criteria for the ESC P5B and DR 300-
40 light scatter monitors.
Because the results from the first RCA, as discussed above, did not meet the draft
Procedure 2 criteria, the second RCA/ACA test objective was revised to include
1 PS-11, Performance Specification 11—Specifications and Test Procedures for Paniculate Matter
Continuous Emission Monitoring Systems in Stationary Sources (draft Revision 4, November 1998).
2 Procedure 2—Quality Assurance Requirements for Paniculate Matter Continuous Emission
Monitoring System (40 CFR 60, App. F, draft Revision 2, November 1998).
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investigation of possible reasons for the differences between the initial correlation and the
first RCA. The test plan was revised accordingly, and the test was carried out in mid-
November 1999. The revised plan included use of one traversing train and one single point
train in each run. The traversing train was intended to provide data like that obtained in the
previous tests, while the single point train would provide data to assess possible
stratification of particulate, and variability in that stratification, at the test location. Also
included were tests at reduced boiler load in order to obtain lower duct velocity and
determine any effects on particulate stratification.
Results from the second RCA test (RCA #2) showed that 5 of the 6 data points
obtained at full boiler load fell within the ±25% tolerance interval of the first RCA
correlation relation. These 5 runs had a nearly constant particulate stratification ratio,
ranging from 0.57 to 0.63 (see NOTE). The remaining run had a higher stratification ratio
of 1.09 and fell within the tolerance interval of the initial correlation relation. This finding
offers a plausible explanation for why the RCA #1 data did not fall within a 25% tolerance
interval of the initial correlation relation (i.e., the stratification ratio may have been
different in the two sets of tests). Sufficient data are not available to confirm this
explanation, but the difference may be related to the location of the perturbing device and
its possible effect on the particulate stratifications and/or particle size distribution, as
discussed below.
NOTE— Particulate stratification ratio is the particulate concentration measured by a single
point sampling train divided by the concentration measured by a simultaneous
multipoint traversing train.
The second RCA test also included 6 runs at reduced boiler load, and 5 of these 6 runs
did not match any of the previous test results (i.e., did not fall within a ± 25% tolerance
interval of either the initial correlation or the RCA #1 correlation) even though the
stratification ratio was essentially the same as in 5 of the 6 full load tests. Thus, the
reduced boiler load test results provided an indication of changes in particulate
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characteristics and consequently the response of the three specific PM-CEMS used in this
test program, as explained further in this report.
Results from the second RCA certainly showed that the particulate concentration is
stratified when the perturbing device is open in order to increase the particulate
concentration (as was done for the initial correlation relation testing and the RCA tests).
Close proximity of the perturbing device and baghouse compartment outlet ducts to the
PM-CEMS was undoubtedly the cause of the stratification.
As far as the primary objective of this project is concerned, the test results have shown
that the three PM-CEMS did meet the draft PS-11 initial correlation criteria, but did not
meet the draft Procedure 2 criteria for either of the two RCA tests.
One peer reviewer of this report believed that close proximity of the PM-CEMS to the
baghouse outlet and perturbing device (i.e., stratification) was the cause of the
non-agreement of the two RCA test results with the initial correlation. Conversely, a
second reviewer stated that he was not convinced by the information presented in the report
that stratification was responsible for the non-agreement. A third reviewer stated that the
initial correlation and RCA data suggest that several different correlations exist. These
comments illustrate the fact that no definite conclusion can be made as to the cause of the
non-agreement of the results.
It should be noted that one of the objectives of the project was to determine whether
the PM-CEMS satisfy all the requirements of draft PS-11 and draft Procedure 2, or
determine if changes are needed in those requirements. As a consequence of the
non-agreement discussed above, and related uncertainty about the effects of the perturbing
device on the test results, one of the changes that has been recommended in PS-11 is to
allow correlation data to be collected over the normal range of a facility's emissions
(without using a perturbing device), even if that range is very narrow (e.g., a baghouse
outlet). However, extrapolation of the resulting correlation relation is limited to 125% of
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the highest PM-CEMS response, above which additional data must be collected. It is
believed that this recommended change in draft PS-11 will help avoid problems that may
be associated with artificially increasing PM emissions (for correlation test purposes).
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Section 1.
Introduction
1.1 Summary of Test Program
1.1.1 Overall Purpose of the Program
EPA's Office of Air Quality Planning and Standards (QAQPS) is considering the
possible use of paniculate matter continuous emission monitoring systems (PM-CEMS) in
future standards. Also, states may require them for State Implementation Plans (SIP) and
Economic Incentive Program (EIP) monitoring, and industry sources may use PM-CEMS
for Title V monitoring. EPA therefore desired evaluation of PM-CEMS technology on a
long-term, continuous basis.
The purpose of this demonstration program was to assess the performance of PM-
CEMS over an extended time (i.e., 6 months).
The objectives of this EPA-sponsored PM-CEMS demonstration were to:
Demonstrate whether the PM-CEMS can provide reliable and accurate
information over an extended period of time
• Evaluate the PM-CEMS for durability, data availability, and setup/maintenance
requirements
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• Determine whether the PM-CEMS satisfy all the requirements of draft PS-11' and
QA criteria specified in draft Procedure 2,2 or determine if changes are needed in
the requirements of PS-11 and/or Procedure 2
Other related objectives of the project were to:
Determine if the PM-CEMS exhibit at least 80% data availability
• Document PM-CEMS maintenance requirements and operating and maintenance
(O & M) costs
• Determine if the PM-CEMS correlation remains true for a long period of time
after initial correlation, per draft Procedure 2
• Determine reliability and accuracy of the moisture CEMS
This report presents all the results of the project with emphasis on the results of the
initial correlation testing and comparison with results from the first and second RCA/ACA.
The report also contains daily results for the PM-CEMS during the entire period from
July 20, 1999, to February 16, 2000, and data availability during that period (excluding the
period of September 15-October 7, 1999, when no data were available due to Hurricane
Floyd and associated plant shutdown).
1 PS-11, Performance Specification 11—Specifications and Test Procedures for Paniculate Matter
Continuous Emission Monitoring Systems in Stationary Sources (draft Revision 4, November 1998).
2 Procedure 2—Quality Assurance Requirements for Particulate Matter Continuous Emission
Monitoring Systems (40 CFR 60, App. F, draft Revision 2, November 1998).
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All of the initial correlation testing and RCA testing involved manual reference
method determination of participate concentration, which was carried out in accordance
with EPA Method 17 (M17).3
1.1.2 Test Site
The test site was Cogentrix of Rocky Mount, Inc., located in Battleboro, NC.
Cogentrix is an electric utility cogeneration plant consisting of four identical boilers
powering two electric generating units. Each generating unit is rated at approximately
55-60 megawatts, for a total plant electrical capacity of 115 megawatts. Each of the
generating units is powered by a pair of Combustion Engineering stoker-grate power
boilers designated as Boilers A and B. Figure 1-1 is a simplified schematic of the
generating unit effluent flow. Each of the four boilers fires bituminous coal and is rated for
375 million BTU/hr heat input and 250,000 Ib stream/hr output. The combustion flue gas
from each boiler passes through a mechanical dust collector and a Joy Technologies, Inc.
dry SO2 absorber (scrubber) before entering the Joy Technologies pulse-jet fabric filter
(baghouse) for particulate control. The effluent from each pair of boilers is combined
downstream of the baghouses, exhausting through a common stack. Testing was carried
out on Unit 2-A boiler/baghouse.
3 40 CFR 60, Appendix A, Method 17—Determination of Particulate Emissions from Stationary
Sources (In-Stack Filtration Method).
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Fabric Filter Baghouse 2A
Opacity
Monitor
Boiler
2A
Mechanical
Dust Collector
2A
/
(
PM-CEMS
and M17
Sampling
Location
Fabric Filter Baghouse 2B
Boiler
2B
Mechanical
Dust Collector
2B
/
/ \
Stack
990464
Figure 1-1. Unit 1 Effluent Schematic (Units 1 and 2 are identical)
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1.1.3 Summary of OEMS Evaluated
For this PM-CEMS demonstration project, EPA purchased a total of three PM-CEMS
from two vendors. The following criteria were used by EPA to choose the PM-CEMS:
1. EPA wanted to demonstrate the viability of both a light scattering type and beta
gauge type PM-CEM and wanted at least one duplicate technology.
2. EPA wanted instruments that had been previously demonstrated on another test.
3. EPA wanted instruments capable of doing an automatic daily zero and upscale
calibration drift check.
4. EPA wanted instruments that were commercially available (i.e., no prototypes).
EPA decided to use the following PM-CEMS:
• Environmental Systems Corporation (ESC) model P5B light-scattering type PM-
CEM,
Durag model DR 300-40 light scattering type PM CEM,
• Durag model F904K beta gauge type PM CEM.
Descriptions of the PM CEMS are provided below. In addition to the three PM
CEMS, one additional CEMS, for monitoring stack gas moisture, was used (Vaisala
HMP 235 moisture CEMS).
1.1.3.1 ESCP5BPMCEM
The Environmental Systems Corporation model P5B light-scattering type PM-CEMS
detects paniculate matter in the stack by reading the back-scattered light (175°) from a
collimated, near-infrared light emitting diode (LED). Since this instrument measures in the
near infrared, it is less sensitive to changes in particle size, and it has a roughly constant
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response to particles in the 0.1 to 10 /im range. The P5B does have an interference from
condensed water droplets in the gas stream. This instrument's measuring range is
0.5 mg/m3 up to 20,000 mg/m3, and it has dual range capability; however, the dual range
feature was not used for this demonstration. The measuring volume is located 4.75 inches
from the physical end of the probe that contains both the transmitting and receiving optics.
The P5B is inserted into the flow through a four-inch port and flange with a bolt hole at the
12 o'clock position. The probe is purged with air to keep the optics clean and cool. The
P5B does automatic zero and upscale drift checks to meet daily QC check requirements.
This instrument was evaluated by EPA/OSW at the long-term field test at the DuPont
Experimental Field Station incinerator. The prototype to this instrument was evaluated at a
secondary lead smelter by the University of Windsor in 1976-1977. ESC has sold over
100 of these instruments worldwide.
1.1.3.2 Durag DR 300-40 PM CEM
The Durag model DR 300-40 light scattering type PM-CEMS detects paniculate
matter in the stack by reading the light scattered by the paniculate at 120°. The light beam
is generated by halogen lamp (400-700 nm) modulated at 1.2 kHz. The Durag DR 300-40
is sensitive to changes in particle characteristics (e.g., size, shape, and color) and presence
of condensed water droplets in the gas stream. This instrument's measuring ranges are
dependent on the size of aperture installed, and are approximately from 0 to 1 mg/m3 up to
0 to 100 mg/m3. Within a measuring range, the Durag DR 300-40 has three sensitivity
levels and automatically moves from one level to the next, where each level is 3 times less
sensitive than the previous level. The data acquisition system calculates a "range adjusted"
mA value that allows for a continuum in the output as the instrument changes levels. The
equations that are used to calculate the range adjusted milliamps are shown below, along
with the actual milliamp range and corresponding range adjusted milliamps.
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Actual mA Range adjusted
Equation range values
Level 1 As read 4.00-20 4-20
Level 2 Range adjusted mA = 3(mA-4) +4 9.33-20 20-52
Level3 Range adjusted mA = 9 (mA-4)+4 9.33-20 52-148
The sample volume for the DR 300-40 is located in an area 3 to 11 inches (centered at
6 inches) from the face of the instrument. Both the light source and the detector are
located in a single unit, thus requiring only one point of access (i.e., a 5-inch by 12-inch
rectangular flange is welded to the duct wall). The DR 300-40 does automatic zero and
upscale drift checks to meet daily QC check requirements and provides automatic
compensation for dirt on the optics (although the optics are protected by an air purge
system). This instrument was approved by the German TUV for all source categories, and
it was evaluated by EPA/OSW at the long-term field test at the DuPont Experimental Field
Station incinerator. Durag has sold over 500 of these instruments worldwide.
1.1.3.3 Durag F904K PM-CEM
The Durag F904K beta gauge type monitor extracts a heated sample from the stack,
transports the sample to the instrument, and deposits particulate on a filter tape during user
defined sampling periods (e.g., 4 to 8 minutes). Sample is extracted from the stack at a
single point under isokinetic conditions at the normal process operating rate (i.e., isokinetic
sampling is not maintained as stack flow changes). The probe is inserted into the stack
through a 6-inch port and standard flange. The F904K introduces dilution air after the
sampling nozzle to (1) minimize particulate loss in the sampling system, (2) handle high
dust loadings (> 200 mg/dscm), and (3) sample wet or saturated stack gas. The measuring
range is determined by the length of the sampling period and the amount of dilution air
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introduced in the probe, but the instrument can accommodate a range of up to 6 to 8 mg of
particulate deposited on the filter tape during each sampling period.
Before and after each sampling period, the filter tape is moved between a
carbon 14 (14C) beta particle source and Geiger-Mueller detector. The amount (in units of
mg) of PM on the filter is determined by the reduction in transmission of beta particles
between the dirty tape (after sampling) and the clean tape (before sampling). The
attenuation of the beta particles is believed to be minimally sensitive to the composition of
the particulate. The sampled gas is dried and the flow rate measured, thus allowing
reporting of PM concentration on a dry basis. Further, the temperature of the dry sample
gas is measured and the sample gas volume is corrected to standard temperature (20°C).
The F904K does automatic zero and upscale drift checks to meet daily QC requirements.
The zero check is performed by measuring the same location on the filter tape twice in
succession with tape transport between measurements, without collecting a sample. The
upscale check is done by simulating beta attenuation at an upscale check value (i.e., 50%
transmission). The simulation of beta attenuation is done by counting beta particles for
240 seconds and comparing that count to the count from the first 120 second zero
measurement of the zero drift check.
A typical sampling cycle requires 120 seconds for zero measurement, 19 seconds of
tape transport, sampling period (300 seconds to 570 seconds), 19 seconds of tape transport,
120 seconds for sample measurement, 38 seconds for tape transport and print on tape. The
cycle then starts over with a new tape zero measurement.
The F904 version was approved by the German TUV for all sources. The F904
version was evaluated by EPA/OSW at the long-term field test at the DuPont Experimental
Field Station incinerator and by Eli Lilly (only during phase II) at a liquid waste
incinerator.
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1.1.3.4 Vaisala HMP 235 Moisture CEM
The Vaisala HMP 235 moisture monitor measures the relative humidity (RH) and
temperature of the stack gas and calculates the absolute humidity in units of grams per
cubic meter (g/m3). The two outputs from the instrument are absolute humidity (0 to
600 g/m3) scaled from 0 to 10 Vdc and temperature (-20 °C to 180°C) scaled from 0 to
10 Vdc. RH is detected with a HUMICAP® H-sensor, and temperature is measured with a
Pt 100 RTD. The HUMICAP® sensor operates on the principal of changes in capacitance
between its thin polymer films as they absorb water molecules.
The HMP 235's moisture readings were correlated to the Method 17 moisture results
from the initial correlation tests and compared with results from the two RCA tests. Those
results are presented in Section 5 of this report.
Note: Vaisala does not market the HMP 235 as a stack gas moisture monitor. The
monitor's application is in less harsh environments (e.g., food production processes) than
coal-fired boiler exhausts. Therefore, Vaisala would not guarantee the HMP 235's
performance for monitoring stack gas moisture. Vaisala indicated that the corrosive nature
of stack gas environments might destroy the thin polymer films that detect the amount of
water molecules in the air. A Vaisala technical representative estimated that the
HUMICAP® sensor would last for two to three months in a 50 ppm SO2 and 50 ppm NOX
stack gas. At that point, the approximately $250 sensor would have to be replaced. Noting
the potential use of this instrument as an accurate and economical stack gas moisture
monitor, EPA decided to examine the HMP 235 as a stack gas moisture monitor during this
test program. During this test program, the same HUMICAP® H-sensor was used for the
entire period.
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1.1.4 Emissions Measured
Emissions measured in these tests were particulate and moisture. Particulate
emissions determined by the M17 tests were calculated in mg/dscm and then converted to
units corresponding to those measured by each of the PM-CEMS (mg/acm for the light
scatter CEMS and mg/dscm for the extractive beta gauge PM-CEM). Moisture measured
by the dual M17 trains, in percent by volume, was used directly for correlation with the
moisture CEM.
1.1.5 Dates of Tests
This report covers operation of the CEMS during the 6-month endurance test (July 20,
1999-February 16, 2000). It also covers the initial correlation tests and the two RCA/ACA
tests.
Nine preliminary runs were carried out over the period of July 9-14 which were used
only for assessing the range of emissions and setting the measurement range on the PM-
CEMS. Thereafter, a total of 15 runs (Runs 10-24) were carried out during the period of
July 15-19 for the initial correlation tests. The first RCA/ACA test (12 runs) was carried
out on August 26-31, 1999. The second RCA test (12 runs) was done on November 16-20,
1999.
Results presented later in this report are from each of these three sets of tests and refer
to the run numbers within each test. The numbering of runs was as follows:
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Initial Correlation Tests
First RCA
Second RCA
Runs 13-24 (See Note)
Runs 1-12
Runs 31-42
NOTE—Runs 10, 11, and 12 were originally excluded from the initial correlation results,
as explained later in this report.
1.2 Key Personnel
The key personnel who planned and coordinated the test program are:
Dan Bivins EPA Work Assignment Manager (919) 541-5244
Paul Gorman Work Assignment Leader for
Contractor (MRI)
Craig Clapsaddle CEM Task Leader for Contractor
(MRI)
Tracy Patterson Air Quality Manager—Cogentrix
Steve Carter Plant Manager—Cogentrix
Mike Chaffin I&C Supervisor—Cogentrix
(816)753-7600x1281
(919) 851-8181 x5342
(804) 541-4246
(252) 442-0708
(252) 442-0708
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Section 2.
Sampling Location
2.1 Flue Gas Sampling Location
The PM-CEMS and manual participate sampling (EPA Method 17) locations are in the
flue gas duct exiting the fabric filter as shown in Figure 2-1, where it can be seen that the
PM-CEMS were located only about 2 diameters downstream from the 90° bend in the
baghouse outlet duct. This rectangular duct has inside dimensions of 5'6" x 4'9" with the
CEMS (and M17 ports) located on the 4'9" wall, as shown in Figure 2-2 and Figure 2-3.
In this rectangular duct, the gas flows downward toward the inlet to the induced draft fan.
The duct is under high negative pressure (-20"H2O). For the second RCA/ACA test,
Cogentrix installed one additional M17 sampling port (port F), which was used only for the
single point M17 sampling train as shown in Figure 2-3. A schematic diagram of the
baghouse outlet duct, showing the location of the perturbing device, is given in Figure 2-4.
The ESC P5B probe extends 10" inside the duct, with the "sample volume" 5" further
into the duct. It is 10" from the right side wall and 159" downstream from the 90° duct
bend. The Durag DR 300-40 is mounted on the stack wall, extending 2" outside the wall.
The "sample volume" covers 3" to 11" from the instrument; thus, the "sample volume" is
1" to 9" inside the wall. It is 13" from the left side wall and 132" downstream from the
90° duct bend.
The Durag F904K probe extends 24" inside the duct wall, and the probe is fitted with a
5-mm nozzle that provides near isokinetic sampling at the duct velocity of 90 ft/sec.
However, the sampling rate is not adjusted to maintain isokinetic sampling as velocity in
the duct changes. It is 15" from the right side wall and 128" downstream from the 90°duct
bend.
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Baghouse Outlet Duct
Gas Flow
5'6"
To ID Fan
82"
12"
128"
M17 Sampling Ports
Upper Platform
Durag Beta Gauge Probe (128")
Durag Light Scatter CEM (132")
159"
- ESC Light Scatter CEM
>' Moisture Monitor Probe
69"
Lower Platform
2000.521-1
Figure 2-1. Location of CEMS and M17 Test Ports (Elevation Side View)
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Gas Flow
Beam-
n
132" 159" 128"
Bottom of Baghouse
Outlet Duct
82" Single Point M17
•Sampling Port
M17 Sampling Ports
Upper grateing
Vaisala
HMP235
HaO monitor
P5B
ESC light scatter
PM-CEMS
F904K
Durag Beta Guage
PM-CEMS Probe
2000521-2
Figure 2-2. Location of CEMS and M17 Test Ports (Elevation Front View)
MRI-OPPT\\R4703-02-07 Revised wpd
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4'9"
(2133)
•
(2093)
•
(1836)
•
(2052)
•
(2172)
•
(2211)
•
(2093)
I
(2052)
(1969)
•
(2133)
•
(2211)
•
(1692)
•
(1925)^
(1831)
•
(1969)
t. 13.
(1789)
F904K ESC
- *-9; J
(1231)
•
C235(11^D
(1221)
•
(1536)
2" • 13.
T
(636)
•
>P5B
!£X .2Q,,.
(450)
•
(260)
(367)
A
DR300-4
xxxx
(687)
2" ^-6.6" -
T *
!}i
"'}'
t
D
i
~
^
sampl
>orts
4" pip
lipples
Jampl
>ortfo
>ingie
rain
[
28.E
; i
1
t
' \f\
5'6"
2000.521-3
Note: Values in parenthesis are the average stack velocity at each point, in m/min., as
measured during the initial correlation tests.
X depicts the "sampling location" of the CEMS in the duct.
O depicts the sampling point for the single point M17 train.
• depicts the sampling points for the M17 traversing train.
Figure 2-3. M17 Sampling Points and CEMS Locations
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Baghouse Outlet Duct
r~
\
To ID
Fan
)
+J
Sas Flow
, 30 R- »
i
|
1
X
I
^, ,- — 2^- -" — Outlets trom each ot
6 baghouse compartments
(3 on each side ot outlet duct)
. — z__^— 6"0 Insulated
p . Bypass Perturbing Device
/ Inlets to each of 6 baghouse
/ compartments (3 on each side of inlet duct)
s\'
i-/
Baghouse Inlet Duct
Figure 2-4. Schematic Elevation Side View of Baghouse Inlet/Outlet Ducts and Perturbing Device
MRI-OPPT\\R4703-02-07 Revised wpd
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The moisture CEM is equipped with a 48" long probe which extends 26" inside the
duct wall.
Based on the expectation that the particulate concentration at the sampling location
exiting the fabric filter would be quite low, a "perturbing device" was installed by the
facility for this project. This perturbing device consisted of an insulated 6" diameter pipe
and butterfly valve that allowed a portion of the gas to be diverted from the inlet of the
fabric filter to the outlet, thus raising the dust concentration in the outlet duct. This
allowed adjustment (increase) of the outlet PM concentration to cover a range of particulate
emissions for this project. The 6-inch insulated pipe was installed approximately 30 ft
upstream of the 90°bend in the outlet duct (See Figures 2-1 and 2-4). It was discovered
during the project that this distance may not have been sufficient to allow complete mixing
of the PM from the perturbing device with the baghouse outlet flow prior to the
PM-CEMS.
2.2 Sampling and Analytical Procedures
The sampling/analytical procedures used for the initial correlation tests and RCA tests
were determination of particulate and moisture concentration per EPA Method 17 (40 CFR
60, Appendix A) and associated requirements of draft PS-11 and Procedure 2.
Two EPA Method 17 sampling trains were used in each run. Each train consisted of
the following, along with an S-type pitot tube and thermocouple:
• Quartz nozzle
• 47 mm in-stack filter holder with quartz fiber filter
• Teflon ball cone check valve
• 10 ft. stainless steel probe
20 ft of thick wall latex tubing
• Impinger box
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• Umbilical cord
• Sampling console (dry gas meter and pump)
The two M17 sampling trains were operated simultaneously (except for a
2-minute offset) but were in different ports (i.e., simultaneous traverses were conducted).
There were a total of 5 ports (shown in Figure 2-3) with 5 sampling points in each port, for
a total of 25 traverse points. There was also a sixth port (port F in Figure 2-3) that was
used for a single point sampling train.
However, in the second RCA/AC A tests, one of the two M17 sampling trains was used
to sample at a single point (see Figure 2-3) rather than traversing to sample all 25 points.
All the M17 tests included determination of paniculate and moisture concentration per
EPA Method 17 (40 CFR 60, Appendix A) and associated requirements of drafts PS-11
and draft Procedure 2 (with the exception that precision was determined in only one run
during the second RCA test because one train was used for single point sampling in all
other runs).
Analytical procedures for the M17 samples are shown in Figure 2-5.
2.3 Process Sampling Locations
No process samples were collected for this test program, but the facility did provide a
computer printout of selected process operating data once every 15 min during each M17
test period.
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Container No. 1:
Filter
Place in dessicator
Weigh filter to
nearest 0.1 mg.
Container No. 2:
Acetone Rinse of nozzle
and filter holder
Clean off dust from
external surface of
probe nozzle and filter
holder. Rinse and brush
the nozzle and inside
of filter holder 3 times
with acetone into
glass container.
Empty contents into
250 ml beaker with
tared teflon liner.
Evaporate to dryness
at room temperature.
Dessicate for 24 hours.
Weigh to constant
weight.
Impingers and Silica Gel
Wipe off outside of
each impinger, then
weigh on field balance
to determine weight
of moisture collected.
Note:
Blank filters and
acetone blank are
analyzed the same
as shown for samples.
Figure 2-5. Analytical Scheme for Mil Train Components
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Section 3.
Installation and Start-up of the CEMS
For the purchase of the three PM-CEMS, a technical specification was written by MRI
and sent to the vendors. The vendors responded to the specification with their proposals,
and MRI issued purchase orders for the ESC P5B light-scattering PM-CEM, the Durag
DR 300-40 light-scattering PM-CEM, and the Durag F904K beta gauge PM-CEM on
May 20, 1998. As noted earlier, these PM-CEMS were selected for the following reasons:
1. Each successfully worked on another demonstration test
2. Each does an automatic daily zero and upscale calibration drift check
3. All are commercially available
In addition to the three PM-CEMS, a Vaisala HMP 235 moisture monitor was
purchased.
The purchase prices for the CEMS and the data acquisition system are listed in the
following table, which includes labor costs for programming the computerized data
acquisition system as discussed in Section 3.2.
GEM model
ESC P5B
Durag DR 300-40
Durag F904K
Vaisala HMP 235
Fluke Wireless Data
Logger 2625 A/WL
Programming of data
acquisition system
Base price
$12,750
$15,500
$36,515
$2,345
$6,100
$12,000
Additional items
$925 for non-standard 6 foot probe
None
$550 for stainless steel sample line
$120/ft for flexible sample line
$915 for temperature controller for flexible line
$2,375 for reinforced cabinet
$4,200 for cabinet air conditioner
$1 ,765 for filter tape printer
$10 for 6 foot power cord
$500 for two UPS units
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3.1 CEMS Delivery
In the PM-CEM vendor's proposals, they provided their lead time for delivery of the
instruments. Based on each vendor's delivery schedule, MRI requested the following
delivery dates:
PM-CEM model Delivery date
P5B June 21,1998
DR 300-40 June 05, 1998
F904K July 16, 1998
Since the selection of the test site was delayed, the vendors were not strictly required
to meet the delivery dates. The P5B was complete and ready for shipping to MRI by mid-
June, 1998, but the vendor requested and was given extra time to complete upgrades to the
instrument. The P5B was received by MRI on August 19, 1998. The DR 300-40 was
received by MRI on July 14, 1998. The F904K arrived in the Durag, USA, office from
Germany on July 22,1998, and Durag personnel completed work on the instrument and
finalized the operating manual. The F904K was scheduled for delivery to MRI on
October 27,1998; however, circumstances unrelated to the instrument delayed delivery
until December 2, 1998.
3.2 Functional Acceptability Testing
After receiving the instruments at MRI's facility, and before shipping them to the test
site, MRI conducted functional acceptability testing (FAT) on each CEM. The FAT
consisted of the following:
1. Unpacking and starting up each CEM according to the manufacturer's instructions
2. Wiring the signal and alarm status outputs to the datalogger
3. Logging instrument output by the data acquisition system (DAS)
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4. Initiating and recording zero and upscale calibration drift checks
5. Initiating and recording alarms
6. Conducting a 7 day drift test on the PM-CEMS
7. Checking the calibration of the HMP 235 moisture monitor against EPA Method 4
8. Developing a sample volume audit procedure for the F904K
At the conclusion of the FAT, the instruments were repackaged for shipment to the test
site. Conducting the FAT led to a much smoother installation and start-up of the PM-
CEMS in the field. The FAT of each PM-CEM required approximately the following man-
hours to complete:
PM-CEM
P5B
DR 300-40
F904K
FAT Man-hours
14
16
24
The PM-CEMS were connected to the data acquisition system and computer during the
FAT period at MRI, and a program was written to provide all the necessary data logging
capabilities. They included the following:
• Converting all CEM signals (mA) to computed values (e.g., mg/acm)
• Computing average 1 min values for readings taken every 15 sec
• Logging all 1 min avg values and daily calibration drift values
• Storing all 1 min readings every 24 hrs
• Handling error signals from the PM-CEMS and flagging all associated data
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• Providing on-line graphing of PM-CEM readings for any selected time interval,
including historic data (i.e., date for days prior to the current day)
• Loading the commercially available program titled "Remotely Possible" so that data
could by viewed and/or downloaded from other MRI offices (the test site office
trailer containing the computerized data acquisition system was unattended during
most of the 6 month test period).
The programming effort involved many details requiring several person-days of effort,
at a cost of $12,000. This allowed debugging of the system at MRI, which considerably
shortened the start-up time for the system when it was installed on site.
3.3 Installation at the Test Site
The CEMS were shipped via common carrier from MRI in Kansas City, Missouri, to
the test site in North Carolina. The boxes were stored at the test site until MRFs
installation team arrived. Test site personnel (Cogentrix) made the following site
modifications in preparation for the CEMS installation and initial correlation testing:
1. Installed five new ports for the Method 17 testing
2. Installed a new port for the DR 300-40
3. Installed a new port for the F904K
4. Installed an extension to an existing port for the P5B
5. Installed approximately 25 feet of 6-inch pipe and a multi-position butterfly valve to
bypass particulate from the inlet duct (dirty-side) to the outlet duct (clean-side) of
the baghouse
6. Installed a transformer and 60 amps of electrical power for the CEMS, Method 17
testing, and an office trailer
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Preparation effort by the test site personnel required approximately the following man-
hours to complete:
Activity
Install five new ports for the Method 1 7 testing
Install a new port for the DR 300-40
Install a new port for the F904K
Install an extension to an existing port
Install approximately 25 feet of 6-inch pipe
and a butterfly valve
Install a transformer and 60 amps "of electrical
power
Preparation Man-hours
12
6
3
2
10
20
For the installation effort, a crane was used to hoist four large boxes onto a platform
about 50 feet above grade. The CEMS and supporting materials (e.g., tools, datalogger,
computer, etc.) were unpacked and placed in their installation areas. Approximately
10 man-hours were needed to get the CEMS and supporting materials in place and ready
for installation. The CEMS and DAS were installed and started up according to the
manufacturer's instructions. The installation and start-up effort required approximately the
following man-hours to complete:
PM-CEM
P5B
DR 300-40
F904K
HMP 235
Installation Man-hours
6
8
241
2
1 Estimate of hours under normal circumstances. See discussion below about start-up issues.
Connecting all of the data communication and alarm wires and starting the datalogger
and DAS required an additional 6 man-hours.
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3.4 Start-up Issues
Startup of the P5B, DR 300-40, HMP 235, and datalogger/DAS proceeded without
incident. As noted above, conducting the FAT before shipping the PM-CEMS to the test
site expedited the start-up effort. The following two major problems were experienced
during start-up of the F904K:
1. Water passed through the conditioning system and flooded downstream components
2. Sample gas could not be extracted from the extremely negative pressure duct (about
-23 inches W.C.) when using dilution air
MRI and Durag personnel expended about 48 man-hours trying to rectify the
problems. Eventually, Durag personnel removed the instrument and transported it back to
their office to redesign the sampling system and repair the problems. The problems were
corrected by:
1. Replacing the leaking moisture condenser
2. Replacing the carbon vane pump that was damaged by the water
3. Moving the dilution air control valve from the exhaust side to the dilution side
4 Replacing the old electronic control system (motherboard with EPROMs
programmed in a cryptic language) with a state-of-the-art programmable logic
controller (PLC) system
The upgraded instrument was delivered to the test site and reinstalled by Durag
personnel. Start-up of the redesigned instrument proceeded without incident and the
instrument operated properly. The reinstallation and start-up required about 12 man-hours
of effort.
A few other problems with the PM-CEMS and moisture CEM did occur during the
subsequent 6-month endurance test period, which are described in the next section.
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Section 4.
Durability, Availability, and Maintenance
Requirements for CEMS
Data availability and maintenance requirements have been recorded throughout the
6-month endurance test period of July 20, 1999, to February 16, 2000.
During the subject period, operation of the CEMS was interrupted by Hurricane Floyd,
which flooded the transformer where Cogentrix ties into the electrical grid system.
Therefore, the plant was off-line from September 16 to about October 3, 1999. The CEMS
were restarted on October 7, 1999. After the system restart, several CEMS problems
occurred. The maintenance and data unavailability for each monitor during the 6-month
period are listed below, excluding the hurricane period. Also excluded are the short
periods each day (approximately 5-10 min) for the automatic zero and upscale drift checks,
and three short periods of data unavailability (30-60 min) when MRI performed an ACA on
the ESC-P5B and Durag DR 300-40. (The Durag F904K did not include any reference
standards for performing an ACA.)
4.1 ESC-P5B
• Data were unavailable for approximately 30 min on August 23,1999, while the drift
problem was corrected.
• The instrument experienced some upscale drift problems during the 6-month period.
The number of daily upscale drift checks that exceeded 2 percent are presented in
Table 4-1 and the corrective actions are discussed below.
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Table 4-1. Levels of Upscale Calibration Drift for the ESC P5B
Upscale drift exceeded Number of days
2%
3%
4%
5%
6%
101 days
65 days
24 days
6 days
1 day
On October 13 and 14, the upscale calibration drift was 6.17% and 5.50%,
respectively. Therefore, on October 15, the lenses and purge air filter were cleaned.
The reference calibration was reset, and the upscale calibration drift was reduced to
0.75%. During this procedure, 30 min of data were lost.
Since the filter for the purge air is located inside the instrument's protective
housing, ambient air that is used for purge air is drawn into the housing. In the
power plant environment, fine paniculate in the ambient air collects on all of the
instrument's components inside the protective housing. MRI recommends locating
the purge air filter separate from the rest of the instrument.
On October 20, the purge air filter was replaced. No data were lost during this
procedure.
On November 9 and 10, the upscale calibration drift was 5.08% and 4.08%,
respectively. Therefore, on November 11, the lenses were cleaned again, and the
upscale calibration drift was reduced to 0.92%. During this procedure, 15 min of
data were lost.
On November 20, the lenses and purge air filter were cleaned, resulting in 12 min of
lost data.
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On December 1 and 2 a malfunction error occurred because of low battery voltage.
The lenses were cleaned and a battery was replaced (39 hr of data were lost).
However, it is estimated that no more than 24 hr of data would have been lost if
plant personnel were responsible for such instrument problems. The replacement
battery was not a spare part and was shipped overnight from ESC.
December 10 and 30 the lenses were cleaned to correct drift problems. During each
cleaning procedure, 14 min and 12 min of data were lost, respectively.
January 11 and 19 the lenses were cleaned to correct drift problem. During each
cleaning procedure, 14 min and 13 min of data were lost, respectively.
During the period of January 30 through February 6 the upscale daily drift exceeded
4% and thus was out of control for 2 days. As a consequence, 2 days of data were
lost. However, this lost time would not have occurred at a permanent installation of
the PM-CEMS where plant personnel were responsible for correcting such
problems.
4.2 Durag DR 300-40
• Data were unavailable for approximately 60 min on August 26, 1999, while the
shutter mechanism was repaired.
• During the calibration drift check, conducted on Saturday, October 16, 1999, the
contamination rate value (i.e., dirty window check) exceeded a preset internal limit.
This error caused the instrument to actuate the data flag "OFF," and the data were
considered suspect. MRI personnel traveled to the site and corrected the error by
cleaning the protective lenses and initiating the calibration cycle on Wednesday,
October 20. About 4 days of data were lost. By contrast, we estimate that no more
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than 4 hours of data would have been lost if plant personnel had the responsibility
of responding to instrument errors.
During the February 9 calibration drift check a "dirty window" error occurred. On
February 10 the reference filter was cleaned to correct the problem, which took
about 1.5 hr. The flag was active for about 29 hr before the reference filter could be
cleaned. However, the data were still valid.
4.3 Durag F904K
• The cabinet air conditioner unit was not working when the system was restarted on
October 7 (after the hurricane). The air conditioner was removed and sent back to
the manufacturer. The problem was the compressor, and repairs, including
shipping, cost about $300. Removing and replacing the air conditioner required
about 4 man-hours. The air conditioner was out of service for 14 days, but the
monitor continued to function without the air conditioner.
• When the system was restarted on October 7, a high pressure air hose inside the
cabinet had become disconnected. The hose was reattached using the original hose
clamp.
• On October 11, the roll of filter tape was expended, and a new roll was installed on
October 12. Approximately 15 hours of data were lost; however, we estimate that
no more than 4 hours of data would have been lost if the plant's personnel were
responding to instrument errors.
• On October 12, about 9 hours after the filter tape was replaced, the high pressure air
hose became disconnected again. This problem caused a vacuum error, and the
instrument automatically shut down. MRI responded to this error on October 15
and reconnected the hose. Approximately 3 days of data were lost due to this
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problem; however, we estimate that at most 4 hours of data would have been lost if
the plant's personnel were responding to instrument errors.
• On October 15, about 8 hours after reconnecting the high pressure air hose, it
became disconnected again, causing the instrument to shut down. MRI responded
to this error on October 20 and installed a second hose clamp along with the
original. About 4.5 days of data were lost due to this problem. We estimate that no
more than 8 hours of data would have been lost if the plant's personnel were
responding to errors. (This estimate is longer than others because the error occurred
late at night, just after 2300 hours.)
• On October 22 and 24 and November 8 the boiler went off-line and was then
restarted. When the boiler is retired, the baghouse is bypassed, and the PM-CEMS
experiences high concentrations of particulate in the duct. Each time the boiler was
refired, the F904K would shut down due to high vacuum errors. This type of error
occurred on October 22 causing about 3 days of lost data, on October 29 causing
about 5 days of lost data, and on November 8 causing about 3 days of lost data. If
plant personnel were responding to each of these errors, we estimate that no more
than 2 hours of data would have been lost for each occurrence. (To help control the
amount of lost data, MRI recommends that Durag design an automatic restart to
activate one hour after a vacuum error shutdown.)
• Beginning on November 2, the F904K began to experience filter tear errors. Filter
tears occurred on November 2, 9, and 12. Upon close inspection of the filter
adapter, it was found that the left side of the adapter was not opening as far as the
right side. When the filter tape was moved backward after a zero measurement,
sometimes it would become pinched between the top and bottom of the filter
adapter and tear down the middle. We found that the mechanism which pulls down
the bottom half of the filter adapter had a worn part on the left side which was not
allowing the mechanism to move downward as far as required. MRI had a new part
made to replace the worn part, and we received a new mechanism as a spare.
MRI-OPPT\\R4703-02-07 Revisedwpd A r
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Troubleshooting and repair of this problem caused 3 days of lost data. (Since wear
on part of the mechanism that opens the filter adapter caused the instrument to
malfunction after about 6 months of continuous operation, MRI recommends that
Durag redesign the mechanism.)
• During the November 11 maintenance visit, MRI discovered that the automatic and
manual blowback of the sample line and probe was not working. During the second
RCA, the blowback seemed to work intermittently but not as expected. This
problem did not cause any loss of data but has not been solved.
• The F904K's response to particulate concentrations during the first two days of the
second RCA test program was not in agreement with the other two PM-CEMS or
any of the previous test results. During investigation on November 17, MRI found
that the resistance-heated stainless steel tube at the sample line/probe union had
melted, and ambient air was leaking into the sample gas. Troubleshooting and
repairing this problem required about 8 man-hours. At least 2 days of data were
invalid because of this problem, and F904K data from the first four test runs of the
second RCA test program were invalid. (Note that this problem would not have
been discovered without comparing actual measured PM concentrations to the
monitor's results. This finding suggests that some amount of manual field sampling
to verify the PM-CEMS values [e.g., 3 test runs done at 6- or 12-month intervals]
should be done between full RCAs.)
• A new roll of filter tape was installed on August 31, after the first RCA, and the
sample interval was increased from 8 to 9.5 min in order to use less filter tape and
still complete a sample and reporting cycle every 15 min. Only 16 operating days
had elapsed when the instrument was shut down because of the hurricane-caused
flood. The instrument ran for 4 days after restart before the filter tape was depleted
(i.e., 20 days of run-time on the roll of filter tape). A new roll of filter tape was
installed on October 11, and that roll lasted until November 21.
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The roll of filter tape was replaced again on December 10 and 30, January 19, and
February 7.
4.4 HMP 235 Moisture OEMS
The moisture monitor experienced several maintenance issues and was unavailable for
an extended period of time while it was sent back to the manufacturer for repair and
recalibration. Details are presented below.
• On Friday, September 10, the moisture monitor values were erratic. MRI
investigated this on Monday, September 13, and, through communication with the
manufacturer, determined the problem was a cold solder junction on the RTD
temperature probe. The junction was resoldered, and the monitor returned to proper
operation. About 3 man-hours were required to troubleshoot and repair the monitor.
About 3 days of data were lost; however, we estimate that no more than 6 hours of
data would have been lost if the plant's personnel were responding to instrument
errors.
• On Saturday, October 9, the moisture monitor began reporting -440% moisture.
MRI responded on Tuesday, October 12, and, with the manufacturer, determined
that the best course of action was to send the instrument back for repairs. About
4 man-hours were required to troubleshoot, remove, and ship the monitor. On
November 11, the moisture monitor was reinstalled. The manufacturer (Vaisala)
could not explain why the monitor did not work properly because it worked fine
when they turned it on. The service technician suggested simply disconnecting the
electrical power from the unit the next time the problem occurred. Reinstallation
effort was about 2 man-hours, and approximately one month of moisture data was
lost.
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• On November 15, the moisture monitor's temperature values appeared incorrect.
The probe was removed and the RTD was repaired. This effort required about
1 man-hour. The following day, the monitor's moisture values were much lower
than the moisture values from the Method 17 sampling runs (i.e., about 6%
compared to 12%). The probe was removed, and the RTD junction was resoldered.
This repair seemed to fix the problem, and the monitor's moisture values returned to
normal (12% H20). This repair effort was about 1 man-hour. In total,
approximately 33 hours of moisture data were lost due to these problems.
• Late on November 20 and into November 21, the moisture values gradually
increased from 12% to about 36%. The probe was removed, and the relative
humidity sensor was examined. A new sensor was installed, but it produced the
same readings. The old sensor was reinstalled, and the probe was inserted back into
the stack. The moisture values were normal. About 18 hours of moisture data were
lost due to this problem.
• Two other periods of obviously erroneous readings occurred on December 7 and
December 17, with about 14 hr of data lost.
• More erroneous readings started on December 25 and continued through
December 28, 1999. A total of 94 hr of data were lost until a field repair could be
made. However, it is estimated that only about 8 hr of data would have been lost if
site personnel were responsible for correcting such problems.
• Erroneous readings again occurred on January 3 through January 11 and 192 hr of
data were lost. Corrective action on January 11 included bracing the probe to help
reduce vibration, which may have been the cause of all the erroneous reading
problems. No further problems occurred thereafter (January 11 through
February 16).
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4.5 Summary
A summary of each monitor's data unavailability is presented in Table 4-2 (not
including the period of the hurricane outage or the short periods of daily drift checks or
performing the ACAs). Table 4-2 shows actual data unavailability and the estimated data
unavailability. The estimated data unavailability is considered more realistic, in that it
reflects what would be expected if on-site facility personnel were responsible for
responding to problems and/or performing maintenance on the CEMS.
The periods of estimated data unavailability shown in Table 4-2 were used to calculate
the percentage of time that data were available for each CEMS, as shown in Table 4-3, for
the entire period of July 20, 1999, to February 16, 2000. The total amount of time for that
period is 212 days, but when the hurricane period is excluded (21 days), a period of 100%
availability would be 191 days (4,584 hr).
As shown in Table 4-3, all three PM-CEMS and the H2O CEM exhibited data
availability of over 80%. The two light scatter type PM-CEMS had on availability of over
99%, and the beta gauge type PM-CEMS had an availability of over 96%. The moisture
monitor (HMP-235) had an availability of only 82% primarily because 30 days were lost
when it had to be sent back to the manufacturer for repair as discussed in Section 4.4.
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Table 4-2. CEMSData Unavailability
Event
Actual data
unavailability
Estimated data
unavailability3
ESC P5B
Aug 23 — Clean lenses to correct drift problem
Oct 1 5 — Lenses and purge air filter cleaned
and reference calibration reset
Nov 11 — Lenses cleaned
Nov 20 — Lenses and purge air filter cleaned
Dec 1 to 2 — Malfunction error; cleaned
lenses and replaced battery
Dec 10 — Cleaned lenses to correct drift
Dec 30 — Cleaned lenses to correct drift
Jan 11 — Cleaned lenses to correct drift and
replaced purge air filter
Jan 1 9 — Cleaned lenses to correct drift
Feb 7 — Cleaned lenses to correct drift
(drift out of control for 2 days,
February 5 and 6, but this would
not have occurred if site personnel
were available to correct the
problem)
0.5 hr
0.5 hr
0.25 hr
0.20 hr
39 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
48 hr
0.5 hr
0.5 hr
0.25 hr
0.20 hr
24 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
TOTAL = 26.70 hr
Durag DR 300-40
Aug 26 — Repaired shutter
Oct 17 — Contamination rate value over limit
Feb 9 to 1 0 — "Dirty Window" error. Cleaned
the reference filter
1 hr
about 4 days
1.5hr
1 hr
4hr
1.5hr
TOTAL = 6
5hr
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Table 4-2 (Continued)
Event
Actual data
unavailability
Estimated data
unavailability3
Durag F904K
Oct 11 — Filter tape replaced
Oct 12 — Vacuum error — high pressure air
hose off
Oct 1 5 — Vacuum error — high pressure air
hose off
Oct 22 — Vacuum error— boiler start-up,
high PM
Oct 29 — Vacuum error— boiler start-up,
high PM
Nov 8 — Vacuum error — boiler start-up,
high PM
Nov 2, 9, 12 — Filter tear error— repaired filter
adapter
Nov 17 — Low response — broken sample line
Nov 21 — Changed tape
Dec 1 0 — Changed tape
Dec 30 — Changed tape
Jan 1 9 — Changed tape
Feb 7 — Changed tape
15 hours
about 3 days
about 4.5 days
about 3 days
about 5 days
about 3 days
about 3 days
at least 2 days
0.25 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
4hr
4hr
8hr
2hr
2hr
2hr
72 hr
48 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
0.25 hr
TOTAL = 1 43.25 hr
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Table 4-2 (Continued)
Event
Actual data
unavailability
Estimated data
unavailability3
HMP 235
Sept 10 — Erratic moisture values — cold
solder junction problem
Oct 9 — Erroneous moisture values
(-440%)— sent back
to manufacturer for repair
Nov 15 — Erroneous temperatures
Nov 20 — High moisture values
Dec 7 — Erroneous readings*
Dec 1 7 — Erroneous readings*
Dec 25 — Erroneous readings*
January 3 to 1 1 — Erroneous readings*
about 3 days
about 30 days
33 hr
18 hr
7hr
7hr
94 hr
192hr
6hr
720 hr
33 hr
18 hr
7hr
7hr
8hr
8hr
TOTAL = 807 hr
* Erroneous readings were likely due to vibration of duct at probe location.
Corrective measures were taken (on January 1 1 , 2000) to reduce the vibration by
bracing the probe. No erroneous readings occurred
thereafter.
Assumes on-site facility personnel would be available to respond to problems.
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Table 4-3. Data Availability for Each CEMS
CEMS
ESC P5B
Durag DR300-40
Durag F904K
Vaisala HMP-235
Total estimated time of
data unavailability, from
Table 4-2 (hours)
26.70
6.5
143.25
807
Total time for period of
July 20, 1999, to
February 16,2000,
excluding hurricane
(hours)
4,584
4,584
4,584
4,584
Data availability
(%)
99.4
99.9
96.9
82.4
MR1-OPPT\\R4703-02-07 Revisedwpd
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Section 5.
Presentation and Discussion of Results
5.1 Objectives and Test Matrix
As was noted in Section 1, the primary objectives of this project were to:
• Demonstrate whether the PM-CEMS can provide reliable and accurate
information over an extended period of time
• Evaluate the PM-CEMS for durability, data availability, and setup/maintenance
requirements
• Determine whether the PM-CEMS satisfy all the requirements of draft PS-11 and
QA criteria specified in draft Procedure 2, or determine if changes are needed in
the requirements of PS-11 and/or Procedure 2
Other related objectives of the project were to:
• Determine if PM-CEMS exhibit at least 80% data availability (based on number
of hours of usable valid results for each month)
• Document PM-CEMS maintenance requirements and operating and maintenance
costs
• Evaluate a technique for perturbing (increasing) baghouse PM emissions.
• Determine if PM-CEMS correlation remains true for a long period of time after
the initial correlation, per PS-11
• Determine reliability and accuracy of the moisture CEMS
MR1-OPPT\\R4703-02-07 ReviseAwpd
5-1
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As discussed later, the first RCA tests did not meet all of the criteria in Procedure 2 for
any of the three PM-CEMS. It was determined that further testing was necessary to
investigate the reason for the difference between the initial correlation test results and the
results from the first RCA tests. Thus, the second RCA tests were carried out with two
important differences from the first RCA/ACA tests.
In the second RCA tests, two M17 sampling trains were again used in each run, but
only one was a traversing train, while the other sampled at a single point. [However, one
run (Run 33) was carried out with both trains traversing in order to check precision
between the two trains.] The purpose of this was to determine if the concentration
measured by the single point train was substantially different from that measured by the
traversing train (i.e., paniculate stratification) and, if so, determine whether the ratio of the
concentrations was constant. If the ratio was not constant, it would indicate that the
concentrations at the location of the PM-CEMS (which measure at a single point or small
area) would not necessarily be represented by the concentration measured by an M17
traversing train. If the ratio was constant, the stratification would automatically be
accounted for in the correlation.
A variable ratio of single point M17 measurements to M17 traversing measurements
would provide a plausible explanation for why the results of the first RCA did not meet
Procedure 2 criteria for agreement with the initial correlation. A variable ratio would
indicate that paniculate from the perturbing device (high concentration) is not well mixed
with the paniculate from the baghouse compartments (low concentration) prior to the
location of the PM-CEMS, and the extent of mixing is variable (i.e., shifting stratification).
The initial correlation tests and first RCA tests were carried out with all runs being at
or near full boiler load. Full boiler load conditions had a steam flow rate between
268-291 K Ib/hr. In the second RCA, some runs were purposely done at reduced boiler load
in order to obtain data at lower gas flow rates, which could affect paniculate stratification.
The reduced boiler load conditions (i.e., low load-LL) had steam flow rates of near
MRI-OPPT\\R4703-02-07 Revisedwpd
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205 K Ib/hr. This reduction in boiler load resulted in about an 18% decrease in the average
fine gas volumetric flow rate.
5.2 Field Test Changes and Problems
Some field test changes were made to correct problems before and during the initial
correlation tests and the RCA tests, as discussed below.
5.2.1 Initial Correlation Test Changes and Issues
There were four field test changes and/or problems in the initial correlation tests as
described below.
5.2.1.1 Durag Beta Gauge Changes
Prior to any testing, problems with one of the PM-CEMS (Durag F904K beta gauge)
necessitated major changes and repairs by the vendor as discussed previously in Section 4.
5.2.1.2 Re-ranging of PM-CEMS
An issue identified during the initial testing (Runs 1-9) was that the initial ranges of
the PM-CEMS were too wide; measuring up to four times the boiler's emission limit of
near 17.0 mg/acm. This meant that the PM-CEMS response at the emission limits was
only about 6 mA. Therefore, it was necessary to decrease the ranges on the PM-CEMS
(i.e., increase sensitivity) in order to expand the response to near 12 mA at the emission
limit, but attempting to avoid exceeding the maximum response (20 mA) during
momentary spikes in particulate concentration. The range for the ESC P5B was decreased
to 0-20 mg. The range for the Durag DR 300-40 was decreased as much as possible by use
MR1-OPPTAR4703-02-07 Revised.wpd
5-3
-------
of the maximum possible aperture (45 mm). The range for the Durag F904K was
decreased to 0-20 mg/dm3 at standard temperature (20°C). After completing this re-
ranging, the initial correlation testing (Runs 10-24) was carried out.
5.2.1.3 Moisture Differences in M17 Results
Differences noted in H2O content determined between the simultaneous dual
M17 trains resulted in procedural changes that were implemented to help minimize the
difference, as discussed in more detail later in this section.
5.2.1.4 Exclusion of Data for 3 Runs
Preliminary graphing of the PM-CEM initial correlation test results was done in the
field as data became available. But, only after results for the last 6 runs (Runs 19-24) were
available did it become fairly obvious that there was something different about results for
Run 10, 11, and 12. That is, these 3 runs did not appear to correlate well with the other
12 runs (Runs 13-24).
Subsequent inquiries with plant personnel revealed that the facility was burning a
different coal during runs 10,11, and 12, which they referred to as "met coal." This coal
caused ash removal problems for the facility in operation of the boilers, but MRI was
unaware of these problems at the time. Facility personnel indicated that receipt of "met
coal" has occurred less than three times in the past 9 years, and they were considering
refusing receipt of coal deliveries that included "met coal." Because operation of the
facility was atypical during these three runs it was decided to delete data for Runs 10, 11,
and 12 from the PM-CEMS correlations. (However, the results from the subsequent RCA
tests indicate that those data probably should not have been deleted, and they have been
included in subsequent discussion of results in this report.)
MRl-OPFn\R4703-02-07 Revised wpd
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5.2.2 First RCA Test Changes and/or Problems
There were no changes or problems of note. However, discrepancies were found
between the initial correlation test results and the first RCA results, as discussed in detail in
Section 5.3.
5.2.3 Second RCA Test Changes and/or Problems
There were two changes made in the second RCA tests as described previously in
Section 5.1 (i.e., use of a single point train and conducting some runs at reduced boiler
load.) In addition, there were two other minor changes.
The first was that the sampling period for the single point train (Train B) was changed
slightly after Run 34 so that it sampled continuously, including short periods when the
traversing train (Train A) was shut down for port changes.
The second change was that the first run (Run 30) was an experimental run. Data from
that run were not valid for use in any evaluation of the data from the second RCA tests. A
total of 12 valid runs were carried out (Run 31-42) as planned.
The only other problems were a few mechanical difficulties with the CEMS, as
discussed previously in Sections 3 and 4.
5.3 Presentation of Results
This section presents and discusses results from the initial correlation tests, the first
RCA test, and the second RCA test, arranged as follows:
5.3.1 Process Data
5.3.2 M17 Test Results and H20 CEM Results
MRI-OPPTAR4703-02-07 Revised, wpd
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5.3.3 PM-CEMS Daily Drift Test Data and AC A results
5.3.4 Initial Correlation and RCA Test Results
5.3.5 Investigation of Reasons for Non-agreement of RCA Results
5.3.1 Process Data
Selected process data were printed out by facility personnel every 15 min during each
test run. A summary of that data is given in Table 5-1 A, B, and C, with more detailed data
given in the Appendices. As shown in Table 5-1C, Runs 31-36 of the second RCA tests
were carried out at near full boiler load (269-277 K Ib/hr steam flow), whereas Runs 37-42
were at reduced boiler load (average steam flow of 199-217 K Ib/hr). The reduced boiler
load was sometimes steady (Runs 37, 38, 39) with steam flows of 200-210 K Ib/hr, and
sometimes variable (Runs 40, 41,42) with increasing or decreasing steam flow during the
test runs. (See Volume 4, Appendix A.)
5.3.2 M17 Test Results and H2O CEMS Results
5.3.2.1 M17 Sampling and Particulate Test Results
Results for the two M17 trains (Train A and Train B) are summarized in Tables 5-2 A,
B, Cl, and C2 and in Tables 5-3 A, B, Cl and C2. (Tables Cl and C2 for the 2nd RCA
tests contain results for the traversing train and single-point train.) Computer printouts of
all results are given in Appendix B, and copies of field sampling data sheets are contained
in Appendices C and D. Copies of post-test calibrations of the M17 sampling equipment
are provided in Appendix E. (See Appendices Volumes 2, 3, and 4 of this report).
It should be noted that the last two columns in Tables 5-3A, B, Cl, and C2 are the
M17 particulate concentration results that have been converted to units that are consistent
with the PM-CEMS measurements, as stipulated in PS-11. It is these particulate
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Table 5-1 A. Summary of Process Data for Each Run of the Initial Correlation Tests*
Date:
Run no.
Steam Flow (klb/hr)
Steam Temp (deg F)
Coal Flow (Ib/hr)
Boiler 02 (Avg)
East Undergate Air Flow (Ib/hr)
West Undergate Air Flow (Ib/hr)
Baghouse Inlet Temp (deg F)
Baghouse Outlet Temp (deg F)
Baghouse DP (in H2O)
ID Fan Suet. Press, (in H2O)
Stack Opacity
July 15, 1999
10
275.2
951
27755
3.5
128676
130777
186.8
187.8
6.9
-22.5
4.79
11
274.3
942
25747
4.1
130096
130218
185.2
184.6
6.8
-23.2
4.56
12
282.2
957
27998
3.2
130733
130834
191.7
184
8.1
-24.1
5.55
July 16, 1999
13
271.0
955
27916
3.5
128824
128754
185.1
180.9
7.4
-22.9
3.72
14
281.3
952
28695
2.9
132511
131928
183.9
186.9
6.6
-22.4
4.51
15
283.3
951
25850
2.7
134389
133130
184.7
180.9
6.9
-23.9
5.27
July 17, 1999
16
281.7
950
29892
3.2
134629
134112
183.1
179.8
6.7
-24
3.71
17
279.9
953
26862
3.6
134781
133363
186.1
180
7.2
-23.4
3.54
18
284.0
951
28527
3.7
133996
133820
183.2
180.6
7.4
-23.3
3.92
July 18, 1999
19
281.4
952
28255
3.1
134853
134659
185.2
179.7
6.3
-23
4.01
20
280.7
952
27524
4.2
133999
134057
185
180.2
6.9
-23.5
4.22
21
281.0
950
27228
3.3
133560
133113
183.7
180.2
6.7
-23.8
4.14
July 19, 1999
22
284.6
950
27765
3.2
136925
136150
184.8
179.3
6.8
-23.8
4.25
23
268.2
950
25809
3.5
128456
128523
189.6
179.6
6.3
-21.6
4.11
24
280.7
950
24219
3.0
129941
130108
186.1
179.8
7.1
-23.4
5.39
'Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).
MRI.OPPT\\R4703-02-07 Revised.wpd
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Table 5-lB. Summary of Process Data for Each Run of First RCA Tests*
Date
Run No.
Steam Flow (klb/hr)
Steam Temp (deg F)
Coal Flow (Ib/hr)
Boiler 02 (Avg)
East Undergrate Air Flow (Ib/hr)
West Undergrate Air Flow (Ib/hr)
Baghouse Inlet Temp (deg F)
Baghouse Outlet Temp (deg F)
Baghouse DP (in H2O)
ID Fan Suet. Press, (in H2O)
Stack Opacity
8/26/99
1
284.9
951
NA
3.0
133,132
132,370
185.0
179.1
8.2
-23.6
7.26
2
286.6
949
NA
3.4
132,958
131,757
186.5
179.4
7.4
-23.1
5.31
8/27/99
3
286.7
949
NA
2.6
131,609
131,202
186.8
182.5
8.1
-23.8
4.89
4
291.2
951
30,461
2.5
133,930
133,690
187.7
180.4
8.6
-24.2
5.09
8/28/99
5
279.7
949
28,493
3.1
125,199
127,846
185.6
179.5
7.7
-22.4
5.02
6
285.5
952
29.366
2.3
127,597
128,703
186
182.7
8.2
-22.2
6.23
7
285.3
951
28,402
2.5
128,255
128,918
188.1
190.6
9.1
-23.5
4.75
8/29/99
8
279.9
951
27,208
3.0
130,913
131,460
184.7
180
8
-23.2
4.05
9
267.6
952
26,364
3.0
124,918
126,814
184.4
181.9
7.4
-21.1
5.01
10
281.3
950
27,524
2.0
132,169
132,122
185.1
180.2
6.9
-23.9
5.82
8/30/99
11
271.7
952
25,803
3.9
136,230
135,646
185.1
180.7
7.6
-23.8
3.81
12
278.6
949
26,585
3.7
139,502
139,180
184.9
177.1
7.3
-24
3.80
NA—Not available. Monitor not operational.
"Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).
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Table 5-1C. Summary of Process Data for Each Run of Second RCA Tests*
Date
Run no.
Steam Flow (klb/hr)
Steam Temp (deg F)
Coal Flow (Ib/hr)
Boiler O2 (Avg)
East Undergrate Air Flow (Ib/hr)
West Undergrate Air Flow (Ib/hr)
Baghouse Inlet Temp (deg F)
Baghouse Outlet Temp (deg F)
Baghouse DP (in H2O)
ID Fan Suet. Press, (in H2O)
2A SDA Outlet Temp (deg F)
2A Atomizer KW (KW)
U2 % Solids (%)
2A Lime Flow (gpm)
Stack Opacity
11/16/99
31
269.1
945
27,621
3.0
129,895
130,976
185
174
10.2
-25.5
188.9
64.0
35.0
4.5
8.67
11/17/99
32
274.6
951
28,096
4.0
125,586
127,925
185
174
11.5
-26.3
185.0
66.0
34.4
3.8
9.53
33
277.4
955
29,286
2.7
123,375
124,288
185
174
10.7
-23.1
184.8
69.5
34.9
4.3
9.74
34
276.4
954
28,460
3.4
121,533
120,292
185
175
10.7
-25.9
184.7
68.8
35.4
5.5
9.38
11/18/99
35
275.4
951
28,819
3.4
119,891
120,611
185
176
10.9
-25.4
185.1
63.8
34.7
5.6
8.52
36
272.7
951
28,028
3.5
119,534
120,671
185
175
12.1
-25.7
184.2
67.0
34.3
5.5
10.49
37
205.0
951
19,642
5.0
100,875
99,163
185
173
6.3
-16.6
184.4
49.6
34.8
5.6
9.65
11/19/99
38
204.3
950
19,641
4.9
100,759
98,441
186
174
5.5
-15.2
185.6
49.8
34.8
4.8
7.84
39
205.9
951
20,261
5.0
101,711
100,332
185
173
5.7
-16.4
186.5
49.2
34.5
5.2
7.76
11/20/99
40
199.4
953
21 ,742
5.5
101,675
99,141
185
176
5.8
-16.0
186.1
47.8
35.0
6.8
41
217.9
949
21,921
4.7
101,686
100,244
183
176
6.8
-17.7
184.8
55.3
35.3
4.6
42
217.0
946
22,029
4.6
102,958
102,405
185
178
7.8
-16.8
187.3
54.6
35.2
5.2
Opacity data not available
'Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).
MRI-OPPTV\R4703-02-07 Revised wpd
5-9
-------
Table 5-2A. Summary of M17 Sampling Data for Initial Correlation Tests
Orsat analysis
Run
10A
10B
11 A
11 B
12A
12B
13A
13B
14A
14B
15A
15B
16A
16B
17A
17 B
18A
18B
19A
19B
20 A
20 B
21 A
21 B
22 A
22 B
23 A
23 B
24 A
24 B
Sampling
time
(min)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Sample gas
volume
(dscm)
1.678
1.653
1.619
1.686
1.668
1.621
1.632
1.637
1.655
1.633
1.653
1.687
1.887
1.910
1.841
1.800
1.834
1.856
1.627
1.640
1.685
1.655
1.626
1.686
1.655
1.647
1.597
1.587
1.608
1.607
Oxygen
(%)
5.0
5.0
5.0
5.0
4.5
4.5
5.8
5.8
4.7
4.7
4.7
4.7
5.1
5.1
5.0
5.0
5.1
5.1
5.2
5.2
5.2
5.2
5.4
5.4
5.0
5.0
5.0
5.0
5.0
5.0
Carbon
dioxide
(%)
14.6
14.6
14.5
14.5
14.8
14.8
13.6
13.6
14.6
14.6
14.6
14.6
14.6
14.6
14.6
14.6
14.5
14.5
14.6
14.6
14.6
14.6
14.1
14.1
14.7
14.7
14.8
14.8
14.8
14.8
Average stack
Water temperature Isokinetic
(%) ( F) (%)
12.8
13.2
12.7
13.0
14.1
14.8
11.9
11.9
13.1
13..4
13.0
13.2
13.3
13.4
12.2
14.2
12.7
14.0
13.1
13.2
15.0
15.5
13.9
14.2
13.5
13.7
12.9
13.5
13.9
14.2
194
195
191
191
190
190
186
187
192
193
186
187
185
186
185
186
186
186
185
185
185
186
185
186
184
185
185
185
185
185
100.7
101.0
100.9
101.3
102.1
102.5
99.7
99.4
100.7
100.9
100.6
100.9
100.8
101.1
99.8
101.6
99.9
101.1
99.9
100.0
101.5
102.0
100.7
101.1
99.8
99.9
99.8
100.2
100.1
100.3
Stack
velocity
(m/min)
1,430
1,445
1,405
1,447
1,423
1,421
1,413
1,409
1,415
1,431
1,437
1,451
1,444
1,460
1,444
1,420
1,413
1,435
1,419
1,416
1,445
1,452
1,428
1,467
1,428
1,455
1,390
1,372
1,392
1,422
Stack gas
flow rate
(dscm/min)
2,306
2,316
2,271
2,330
2,261
2,238
2,315
2,306
2,275
2,289
2,325
2,340
2,334
2,354
2,371
2,277
2,289
2,289
2,306
2,295
2,299
2,296
2,284
2,336
2,297
2,333
2,264
2,217
2,225
2,266
MRI-OPPT\\R4703-02-07 Revised, wpd
5-10
-------
Table 5-2B. Summary of Mil Sampling Data for First RCA Tests
Orsat analysis
Run
1 A
1 B
2A
2B
3A
3B
4A
4B
5A
5B
6A
6B
7A
7B
8A
8B
9A
9B
10A
10B
11 A
11 B
12A
12B
Sampling
time
(min)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Sample gas
volume
(dscm)
1.610
1.634
1.773
1.802
1.812
1.820
1.746
1.790
1.538
1.551
1.550
1.549
1.544
1.560
1.593
1.581
1.539
1.490
1.598
1.552
1.622
1.575
1.653
1.629
Oxygen
(%)
4.2
4.2
4.2
4.2
4.2
4.2
4.2
4.2
4.2
4.2
4.1
4.1
4.2
4.2
4.0
4.0
4.2
4.2
4.0
4.0
4.8
4.8
5.1
5.1
Carbon
dioxide
(%)
15.0
15.0
15.0
15.0
15.0
15.0
15.1
15.1
15.0
15.0
15.2
15.2
15.0
15.0
15.2
15.2
15.0
15.0
15.2
15.2
14.0
14.0
14.3
14.3
Average stack
Water temperature |SOkinetic
(%) ( F) (%)
14.3
14.3
14.1
14.2
14.3
14.8
14.3
14.8
14.1
13.7
13.8
13.9
13.7
14.0
13.8
13.7
13.9
13.7
14.2
14.7
11.9
12.1
12.6
12.3
184
185
185
185
188
189
185
186
185
186
188
188
195
197
185
186
186
187
185
186
186
186
182
183
101.2
104.1
101.3
101.4
101.5
102
101.6
102.1
99.5
99.2
99.7
99.8
99.5
99.8
99.9
99.8
99.7
99.6
100.4
100.8
97.9
98.1
98.7
98.4
Stack Stack gas
velocity flow rate
(m/min) (dscm/min)
1,405
1,405
1,434
1,443
1,411
1,421
1,415
1,437
1,348
1,374
1,351
1,381
1,376
1,411
1,383
1,404
1,355
1,324
1,393
1,386
1,430
1,406
1,432
1,444
2,225
2,222
2,274
2,285
2,227
2,225
2,233
2,255
2,163
2,212
2,152
2,195
2,172
2,212
2,209
2,242
2,161
2,116
2,204
2,177
2,318
2,272
2,319
2,341
MR1-OPPT\\R4703-02-07 Reviseiwpd
5-11
-------
Table 5-2C1. Summary of M17 Sampling Data for Traversing Train
(Second RCA Test)
Orsat analysis
Run
31 A
32 A
33 Aa
33 Ba
34 A
35 A
36 A
37 Ab
38 A"
39 A"
40 A"
41 A"
42 A"
Sampling
time
(min)
75
75
100
100
75
75
75
75
75
75
75
75
75
Sample gas
volume
(dscm)
0.776
0.748
0.987
1.001
0.757
0.729
0.703
0.638
0.640
0.629
0.611
0.642
0.625
Oxygen
(%)
4.5
4.8
3.3
3.3
4.2
3.8
3.8
6.1
5.7
5.3
6.3
5.9
5.1
Carbon
dioxide
(%)
14.6
14.7
15.4
15.4
14.6
15.0
14.9
13.5
13.0
13.3
12.5
13.3
14.1
Average stack
Water temperature Isokinetic
(%) ( H (%)
12.2
11.3
12.3
11.6
13.0
12.0
11.6
10.5
11.4
10.4
12.4
12.4
12.4
177
177
178
180
179
179
179
177
177
177
179
180
181
101.5
100.0
101.4
100.5
101.7
100.7
100.3
99.7
101.6
100.3
99.4
99.9
99.6
Stack
velocity
(m/min)
1,402
1,343
1,325
1,350
1,368
1,299
1,255
1,100
1,096
1,075
1,089
1,144
1,120
Stack gas
flow rate
(dscm/min)
2,291
2,242
2,187
2,237
2,230
2,170
2,101
1,917
1,890
1,878
1,843
1,927
1,880
a Run 33 was a test for precision of the Method 17 sampling.
b Runs 37-42 were reduced load tests.
MRI-OPPT\\R4703-02-07 Revised.wpd
5-12
-------
Table 5-2C2. Summary of M17 Sampling Data (Train B—Single Point)
(Second RCA Test)
Run
31 B
32 B
33 B
34 B
35 B
36 B
37 Ba
38 Ba
39 Ba
40 Ba
41 Ba
42 Ba
Sampling
time
(min)
75
80
85
80
80
80
80
80
80
80
80
Orsat
Sample gas Oxygen
volume
(dscm) (%)
0.794
0.812
0.818
0.786
0.758
0.652
0.662
0.668
0.607
0.681
0.641
4.5
4.8
No single
4.2
3.8
3.8
6.1
5.7
5.3
6.3
5.9
5.1
analysis
Carbon
dioxide
(%)
14.6
14.7
point train
14.6
15.0
14.9
13.5
13.0
13.3
12.5
13.3
14.1
Water
(%)
11.0
11.9
used in
12.5
11.4
12.5
9.8
10.1
10.3
12.4
12.4
11.2
Average stack
temperature Isokinetic
( F) (%)
180
180
Run 33 (precision
182
181
182
179
180
179
181
182
184
100.8
100.7
run).
101.4
100.3
101.2
100.6
100.4
100.0
99.3
99.4
98.9
Stack
velocity
(m/min)
1,430
1,372
1,307
1,312
1,274
1,041
1,062
1,076
1,018
1,146
1,076
Stack gas
flow rate
(dscm/min)
2,359
2,265
2,134
2,201
2,104
1,821
1,852
1,876
1,716
1,924
1,821
Runs 37-42 were reduced load tests.
MRI-OPPT\\R4703-02-07 Revised.wpd
5-13
-------
Table 5-3A. Mil Particulate Test Results for Initial Correlation Tests
Amount found
in probe rinse
Run (mg)
10A
10B
11A
11 B
12A
12B
13A
13B
14A
14B
15A
15B
16A
16B
17A
17B
18A
18B
19A
19B
20 A
20 B
21 A
21 B
22 A
22 B
23 A
23 B
24 A
24 B
7.7
12.4
13.9
13.0
11.9
8.9
4.8
4.0
4.3
4.7
7.4
3.4
2.4
1.8
1.4
1.6
2.3
1.7
5.2
4.6
3.9
3.6
4.0
3.6
4.7
3.1
2.3
2.4
5.3
4.5
Amount
found on
filter (mg)
57.1
54.3
54.8
56.4
69.1
73.0
23.6
23.9
29.4
30.9
29.5
32.3
6.2
6.9
6.0
5.6
6.7
7.1
35.2
34.8
22.4
23.9
19.8
20.0
33
36.0
18.7
18.3
40.7
40.7
Total
paniculate
weight (mg)
64.8
66.7
68.7
69.4
81.0
81.9
28.4
27.9
33.7
35.6
36.9
35.7
8.6
8.7
7.4
7.2
9.0
8.8
40.4
39.4
26.3
27.5
23.8
23.6
37.7
39.1
21
20.7
46.0
45.2
Gas volume
sampled
(dscm)
1.678
1.653
1.619
1.686
1.668
1.621
1.632
1.637
1.655
1.633
1.653
1.687
1.887
1.91
1.841
1.8
1.834
1.856
1.627
1.64
1.685
1.655
1.626
1.686
1.655
1.647
1.597
1.587
1.608
1.607
Particulate
concentration
(mg/dscm)
38.6
40.4
42.4
41.2
48.6
50.5
17.4
17
20.4
21.8
22.3
21.2
4.6
4.6
4.0
4.0
4.9
4.7
24.8
24.0
15.6
16.6
14.6
14.0
22.8
23.7
13.1
13.0
28.6
28.1
M17 Particulate
converted
corresponding
ESC and Durag
light scatter
(mg/acm)
25.6
26.6
28.2
27.3
31.8
32.8
11.7
11.5
13.5
14.4
14.9
14.1
3.0
3.0
2.7
2.6
3.3
3.1
16.6
16.1
10.2
10.8
9.7
9.2
15.1
15.7
8.8
8.7
18.8
18.5
concentration
to units
to PM CEMs
Durag beta
gauge
(mg/dscm)
38.6
40.4
42.4
41.2
48.6
50.5
17.4
17
20.4
21.8
22.3
21.2
4.6
4.6
4.0
4.0
4.9
4.7
24.8
24.0
15.6
16.6
14.6
14.0
22.8
23.7
13.1
13.0
28.6
28.1
MRI-OPPTOR4703-02-07 Revised, wpd
5-14
-------
Table 5-3B. M17 Particulate Test Results for First RCA Test
Amount found
in probe rinse
1 A
1 B
2A
2B
3A
3B
4A
4B
5A
5B
6A
6B
7 A
7B
8A
8B
9A
9B
10A
10B
11 A
11 B
12A
12 B
12.4
12.5
1.1
0.4
0.2
1.3
0.8
0.5
4.0
2.6
1.0
2.7
5.3
6.8
10.6
9.4
14.9
12.0
2.1
9.2
5.6
5.6
11.5
10.9
Amount Total
found on paniculate
filter (mq) weight (mq)
59.9
54.9
4.1
4.8
6.7
6.1
6.1
6.7
18.4
20.6
18.5
17.0
21.9
20.1
42.9
43.8
41.7
42.2
61.5
56.3
24.8
26.2
35.4
36.1
72.3
67.4
5.2
5.2
6.9
7.4
6.9
7.2
22.4
23.2
19.5
19.7
27.2
26.9
53.5
53.2
56.6
54.2
63.6
65.5
30.4
31.8
46.9
47.0
Gas volume
sampled
(dscm)
1.610
1.634
1.773
1.802
1.812
1.820
1.746
1.790
1.538
1.551
1.550
1.549
1.544
1.560
1.593
1.581
1.539
1.490
1.598
1.552
1.622
1.575
1.653
1.629
Particulate
concentration
(mq/dscm)
44.9
41.2
2.9
2.9
3.8
4.1
4.0
4.0
14.6
15.0
12.6
12.7
17.6
17.2
33.6
33.7
36.8
36.4
39.8
42.2
18.7
20.2
28.4
28.9
M1 7 Particulate
converted
corresponding
ESC and Durag
light scatter
(mq/acm)
29.3
26.9
1.9
1.9
2.5
2.6
2.6
2.6
9.6
9.9
8.2
8.3
11.5
11.1
22.1
22.1
24.2
23.9
25.9
27.3
12.5
13.4
18.9
19.3
to units
to PM GEMS
Durag beta
gauge
(mg/dscm)
44.9
41.2
2.9
2.9
3.8
4.1
4.0
4.0
14.6
15.0
12.6
12.7
17.6
17.2
33.6
33.7
36.8
36.4
39.8
42.2
18.7
20.2
28.4
28.9
MRI-OPPT\\R4703-02-07 Revised wpd
5-15
-------
Table 5-3C1. M17 Particulate Test Results—Traversing Train
(Second RCA Test)
M17 Particulate concentration
converted to units corresponding
to PM-CEMS
Amount found
in probe rinse
Run (mg)
31 A
32 A
33Aa
33Ba
34 A
35 A
36 A
37 A
38 A
39 A
40 A
41 A
42 A
2.8
2.1
2.4
0.7
2.8
1.0
1.6
4.4
4.0
3.8
1.0
2.4
5.2
Amount
found on
filter (mg)
26.4
18.7
25.5
25.3
8.8
13.4
25.5
46.8
29.1
27.3
9.7
19.9
29.4
Total
paniculate
weight (mg)
29.3
20.8
27.9
26.0
11.6
14.4
27.1
51.2
33.1
31.1
10.7
22.3
34.6
Gas volume
sampled
(dscm)
0.776
0.748
0.987
1.001
0.757
0.729
0.703
0.638
0.640
0.629
0.611
0.642
0.625
Particulate
concentration
(mg/dscm)
37.8
27.8
28.3
26.0
15.3
19.7
38.5
80.2
51.7
49.5
17.5
34.7
55.4
ESC and Durag
light scatter
(mg/acm)
25.4
19.1
19.2
17.7
10.3
13.6
26.6
57.6
36.7
35.6
12.2
24.1
38.3
Durag beta
gauge
(mg/dscm)
37.8
27.8
28.3
26.0
15.3
19.7
38.5
80.2
51.7
49.5
17.5
34.7
55.4
Run 33 was a test for precision of the Method 17 sampling.
MRI-OPFT\\R4703-02-07 Revised \vpd
5-16
-------
Table 5-3C2. M17 Particulate Test Results (Train B—Single Point)
(Second RCA Test)
M17 Particulate concentration
converted to units corresponding
to PM-CEMS
Amount found Amount Total
in probe rinse found on particulate
Run (mg) filter (mg) weight (mg)
31 B
32 B
33 B
34 B
35 B
36 B
37 B
38 B
39 B
40 B
41 B
42 B
0.7
0.8
0.3
0.0
0.0
1.3
2.3
2.0
2.1
0.5
1.0
18.1
13.4
13.4
8.8
17.1
32.0
19.9
20.8
6.8
13.1
20.0
18.8
14.2
No single point
13.7
8.8
17.1
33.3
22.2
22.8
8.9
13.6
21.0
Gas volume Particulate ESC and Durag
sampled concentration light scatter
(dscm) (mg/dscm) (mg/acm)
0.794
0.812
train used in
0.818
0.786
0.758
0.652
0.662
0.668
0.607
0.681
0.641
23.7
17.5
Run 33 (precision run).
16.7
11.2
22.6
51.1
33.5
34.1
14.7
20.0
32.8
16.1
11.9
11.3
7.7
15.3
36.8
24.1
24.5
10.2
13.8
22.8
Durag beta
gauge
(mg/dscm)
23.7
17.5
16.7
11.2
22.6
51.1
33.5
34.1
14.7
20.0
32.8
MRI-OPPR\R4703-02-07 Revised, wpd
5-17
-------
concentration values, and the associated PM-CEMS response, that were used to develop the
initial correlation relations and to evaluate results from RCA # 1 and # 2 as discussed later
in Section 5.3.4.
During each test run of the initial correlation tests and the first RCA tests, dual M17
trains were operated simultaneously. Each train sampled 4 minutes at each of the
25 traverse points for an elapsed test run time of approximately 110 minutes (100 minutes
of actual sample time). To facilitate moving the sampling trains from point to point, Train
A was started 2 minutes before Train B.
During each test run of the second RCA tests, two M17 trains were again operated
essentially simultaneously. But, one train (Train A) was used to traverse the stack,
sampling for 3 min at each of 25 points for a total of 75 min. The other train (Train B) was
used to sample at a single point for a total of 80 min. In Run 33, both Train A and Train B
were traversing trains, sampling for 4 min at each point to recheck precision of the
measurements. Except for Run 33, only the results from Train A were used in evaluating
the results relative to correlation with PM-CEMS response discussed later in this report.
The dual train particulate results were used to determine the precision of each test
run's M17 data and screen the M17 data for outliers. The precision of the dual trains is
presented in Table 5-4 A and B and shows that precision criteria were met in all 15 runs of
the initial correlation tests and in all 12 runs of the first RCA test. The precision criteria
were also met for the one run (Run 33) in the second RCA test.
In addition to the precision criteria, the dual trains were checked for systematic data
bias, according to the equation presented in Section 10.1.2 of draft Procedure 2. If no bias
exists, a plot of Train B versus Train A would generate a straight line correlation, passing
through the origin, with a slope of 1.0. The criteria in draft Procedure 2 stipulate that the
slope calculated in the regression analysis must fall between 0.93 and 1.07. The plots of
Train B particulate concentration versus Train A particulate concentration for the initial
correlation tests and first RCA test are presented in Figures 5-1A and B. The calculated
MR1-OPPT\\R4703-02-07 Revised, wpd
5-18
-------
Table 5-4A. Precision of Method 17 Dual Trains for Initial Correlation Tests
Run no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Train A
(mg/dscm)
38.6
42.4
48.6
17.4
20.4
22.3
4.6
4.0
4.9
20.8
15.6
14.6
13.5
13.1
28.6
Train B
(mg/dscm)
40.4
41.2
50.5
17.0
21.8
21.2
4.6
4.0
4.7
20.0
16.6
14.0
13.7
13.0
28.1
RSD
(%)
2.28
•1.44
1.92
1.16
3.32
2.53
0.00
0.00
2.08
1.96
3.11
2.10
0.74
0.38
0.88
Criteria
(See note)
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 19%
RSD < 20%
RSD < 18.7%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Note:
Acceptance limit for precision of paired trains is:
RSD < 10% if cone is > 10 mg/dscm
RSD < 25% if cone is < 1 mg/dscm.
At between 1 and 10 mg/dscm, the allowable RSD decrease linearly from 25% to 10%.
% RSD is defined as 100 x (CA - CB)/(CA + CB).
MRI-OPPT\\R4703-02-07 Rcvisciwpd
5-19
-------
Table 5-4B. Precision of Method 17 Dual Trains for First RCA Tests
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
Train A
(mg/dscm)
44.9
2.9
3.8
4
14.6
12.6
17.6
33.6
36.8
39.8
18.7
28.4
Train B
(mg/dscm)
41.2
2.9
4.1
4
15
12.7
17.2
33.7
36.4
42.2
20.2
28.9
Avg.
(mg/dscm)
43.05
2.9
3.95
4'
14.8
12.65
17.4
33.65
36.6
41
19.45
28.65
RSD
(%)
4.30
0.00
3.80
0.00
1.35
0.40
1.15
0.15
0.55
2.93
3.86
0.87
Criteria
(See note)
RSD < 10%
RSD < 21 .8%
RSD < 20.0%
RSD < 20.0%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
RSD < 10%
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Note:
Acceptance limit for precision of paired trains is:
RSD < 10% if cone is > 10 mg/dscm
RSD < 25% if cone is < 1 mg/dscm
At between 1 and 10 mg/dscm, the allowable RSD decrease linearly from 25% to 10%.
% RSD is defined as 100 x (CA - CB)/(CA + CB).
MRI-OPFRNR4703-02-07 Revised wpd
5-20
-------
60
50
I 40
w
E, 30
CD
£ 20
10
M17 Train Comparison
y = 1.0213x- 0.3455
R2 = 0.9954
10
20 30
Train A (mg/dscm)
40
50
60
Figure 5-1A. Bias of Train A versus Train B in Initial Correlation Tests
MRJ OPPT\\R4703-02-07 Revised wpd
5-21
-------
M1 7 Train Comparison
50 -
45 -
40 -
35 -
o on
tn 3O -
5
O)
Er>c
. , 25 -
m
.= 20 -
(O
h-
15 -
1O -
-
V = 0.977X + 0.5597 * ^^ *
R2 = 0.9909 ^^^
^^
^^
^ s^^ _ — ___ —
^^
^^
4^
-) , r - • -I 1 1 • • ' •
0 5 10 15 20 25 30 35 40 45 50
Train A (mg/dscm)
Figure 5-1B. Bias of Train A versus Train B in First RCA Tests
MJU-OPPT\\R4703-02-07 Revised.wpd
5-22
-------
slope of 1.02 and 0.977 falls within the Procedure 2 criteria; therefore, the M17 sampling
results met the criteria in both sets of tests.
5.3.2.2 M17 H2O Results
Moisture results for the M17 trains (shown previously in Tables 5-2 A, B, and C) have
been retabulated in Table 5-5A, B, and C.
Moisture results for the M17 trains in the initial correlation tests, given in Table 5-5A,
show that results for Train B were higher than Train A in almost all runs, with the largest
absolute difference occurring in Runs 17 and 18 (2.0 and 1.3% H2O, respectively). After
corrective actions (discussed in Section 6) were implemented for Runs 19-24, the
difference ranged from 0.1% H2O to 0.6% H2O. The absolute differences in the first RCA
tests (Table 5-5B) had a similar range, from 0 to 0.5% H2O. The absolute differences in the
second RCA test (Table 5-5C) had a somewhat higher range of 0 to 1.3% H2O. In this
second RCA test, the trains were not identical (i.e., Train A traversing, Train B single
point), but it was expected that the gas sampled by both trains would have the same
moisture content. Thus, the reason for the differences is not known.
5.3.2.3 H2O CEM Results
EPA included testing of the Vaisala HMP 235 moisture CEM in this project to
determine if it may be applicable to moisture monitoring in some types of facilities such as
the Cogentrix coal fired power plant (with low SO2 emissions).
MRI-OPPT\\R4703-02-07 Revised wpd
5-23
-------
Table 5-5A. Comparison of M17 Moisture Results for Initial Correlation Tests
Run no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Train A
(traversing)
(% H2O)
12.8
12.7
14.1
11.9
13.1
13.0
13.3
12.2
12.7
13.1
15.0
13.9
13.5
12.9
13.9
Train B
(traversing)
(% H2O)
13.2
13.0
14.8
11.9
13.4
13.2
13.4
14.2
14.0
13.2
15.5
14.2
13.7
13.5
14.2
Average
(% H2O)
13.00
12.85
14.45
11.90
13.25
13.10
13.35
13.20
13.35
13.15
15.25
14.05
13.60
13.20
14.05
Differences A-B
(% H2O)
-0.4
-0.3
-0.7
0
-0.3
-0.2
-0.1
-2.0
-1.3
-0.1
-0.5
-0.3
-0.2
-0.6
-0.3
MR]-OPFn\R4703-02-07 Revised wpd
5-24
-------
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
Train A
(traversing)
(% H2O)
14.3
14.1
14.3
14.3
14.1
13.8
13.7
13.8
13.9
14.2
11.9
12.6
Train B
(traversing)
(% H2O)
14.3
14.2
14.8
14.8
13.7
13.9
14.0
13.7
13.7
14.7
12.1
12.3
Average
(% H2O)
14.30
14.15
14.55
14.55
13.90
13.85
13.85
13.75
13.80
14.45
12.00
12.45
Differences A-B
(% H2O)
0
-0.1
-0.5
-0.5
+0.4
-0.1
-0.3
+0.1
+0.2
-0.5
-0.2
+0.3
MRI-OPPT\\R4703-02-07 Revisedwpd
5-25
-------
Table 5-5C. Comparison of M17 Moisture Results for Second RCA Test
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
Train A
(traversing)
(% H2O)
12.2
11.3
12.3
13.0
12.0
11.6
10.5
11.4
10.4
12.4
12.4
12.4
Train B
(single point)*
(% H2O)
11.0
11.9
11.6*
12.5
11.4
12.5
9.8
10.1
10.3
12.4
12.4
11.2
Differences A-B
(% H2O)
+1.2
-0.6
+0.7
+0.5
+0.6
-0.9
+0.7
+1.3
+0.1
0
0
+1.2
* Train B was a traversing train in Run 33.
MRI-OPPT\\R4703-02-07 Revised wpd
5-26
-------
The Vaisala H2O CEM outputs a 0-10 Vdc signal that is proportional to the moisture
content of the gas in terms of absolute humidity (0-600 g/acm). In order to convert the
CEM response to %H2O by volume, the following equation was used:
%H2O = (0.029)(Vdc)(t + 273)
where t = stack temperature in °C.
NOTE: This equation is based on the assumption of a constant stack pressure of
13.7 psia (i.e., -24" H2O).
Since the stack gas environment at this specific facility might have an effect on the
accuracy of the H2O CEM, the readings taken during each run of the initial correlation tests
were compared with the corresponding average M17 H2O results. That comparison was
used to develop a correction factor that was incorporated into the above equation, as
discussed below. Thereafter, the H2O CEM and average M17 H2O results obtained for each
run in the first and second RCA were used to assess the accuracy of the H2O CEM.
The data in Table 5-6A show the H2O results from the initial correlation tests which
were used to calculate a correction factor for the moisture monitor as follows:
% H,O by M17 IT 45
H7O Correction Factor - - = ±±Z£. = 1.180
% H2O reported by CEM 11.38
This correction factor was applied to the original equation shown above that is used to
convert the H2O CEM response (Vdc) to % H2O, as follows:
%H2O = (1.182) (0.029) (Vdc)(t + 273)
= (0.034)(Vdc)(t + 273)
MRI-OPPT\\R4703-02-07 Revised.wpd
-------
Table 5-6A. Summary of Moisture Results for Initial Correlation Tests
(CEM vs M17, and Calculated Correction Factor)
Run no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
H2O CEM (% by vol)
10.95
10.96
11.15
11.10
10.92
11.35
11.72
11.36
11.33
11.71
11.78
11.88
11.56
11.29
11.57
Avg 1 1 .38
M17(%byvol)*
13.00
12.85
14.45
11.90
13.25
13.10
13.35
13.20
13.35
13.15
15.25
14.05
13.60
13.20
14.05
Avg. 13.45
Calculated Correction Factor = 13.45/11.38 = 1.182.
'Average results for Train A and B.
MRI-OPPR\R4703-02-07 Revised wpd
5-28
-------
Using this equation, the H2O CEM results were recalculated and plotted as shown in
Figure 5-2. This figure still shows considerable spread in the data, with differences as wide
as 1.3% H2O. However, an error of 1% H2O, at a 10% moisture level, (e.g., 10% as 11%)
would result in an error of only about 1% in conversion of particulate concentration in
mg/dscm to mg/acm.
Since the range of H2O content measured in these tests had a narrow range of only
11.90% to 15.25%, it was not possible to evaluate accuracy of the H2O CEM at higher
moisture levels (e.g., 30-40%).
The reason for the difference between the H2O CEM results and the M17 results is not
known, but may reflect the fact that the range of the instrument is 600 g/acm, or near 100%
H2O by volume, corresponding to an output signal of 10 Vdc. Thus, a difference of 1%
H2O is a difference of only 0.1 Vdc. It should also be noted that the difference between
dual M17 trains may be as much as 1% H2O, as discussed previously
Regardless of the reason for the difference in the H2O CEM and M17 results, the
equation shown above, with the correction factor, was incorporated into the data
acquisition system computer program in order to convert the H2O CEM output to % H2O.
Those values were used in the RCA tests to determine accuracy of the H2O CEM, by
comparison with the M17 H2O results.
Results for the H2O CEM in the first RCA tests are tabulated in Table 5-6 B, and show
that the CEM met the criteria in the QAPP, with a difference of less than 1% H2O, and
relative accuracy (RA) better than 10%.
A comparison of the M17 H2O (Train A) test results for the second RCA with the H2O
CEMS data is provided in Table 5-6C and shows that the H2O CEMS always read lower
than the M17 result. The average difference was 2.0% H2O and an RA of 23%, which did
not meet the criteria specified in the QAPP of ±1% H2O or RA < 10%. Also, Section 3 and
4 discussed the fact that there were some operational problems with the H2O CEMS at
MRI-OPPT\\R4703-02-07 Revised, wpd
5-29
-------
"o
> 14.5-
1 „
f 14 -
e
£
s
oc
s ^
•
* X*
^^^ •• ^
^
*
11.00 11.50 12.00 12.50 13-00 13.50 14.00 14.50 15.00 15.50 16.00
Adjusted Moisture Monitor <% Water by Volume)
Figure 5-2. Comparison of Adjusted Moisture Monitor Readings with Mil Results, from Initial Correlation Tests
MRI-OPPTttR4703-02-07 Revised wpd
5-30
-------
Table 5-6B. Summary of Moisture Results from the first RCA Test
(CEM versus M17)
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
H2O CEM
(% by vol)
14.69
14.28
14.24
14.69
14.00
13.85
13.45
14.23
14.01
14.18
12.17
12.50
M17
(% by vol)
14.30
14.15
14.55
14.55
13.90
13.85
13.85
13.75
13.80
14.45
12.00
12.45
Difference
(% H2O by vol)
-0.39
-0.14
+ 0.30
-0.15
-0.10
0
+ 0.40
-0.48
-0.21
+ 0.27
-0.17
-0.05
Note: Relative accuracy of the H2O CEM was 0.83% and the average
difference was < 0.1% H2O.
MRI-OPPT\\R4703-02-07 Revised, wpd
5-31
-------
Table 5-6C. Summary of Moisture Results for the Second RCA Tests
(CEMS versus Method 17)
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
H2O GEM
(% by vol)
NA*
10.6
10.7
10.7
10.7
10.5
9.1
8.9
9.0
9.3
9.1
8.5
M1 7 Train A
(% by vol)
12.2*
11.3
12.0
13.0
12.0
11.6
10.5
11.4
10.4
12.4
12.4
12.4
Difference
(% by vol)
-
0.7
1.3
2.3
1.3
1.1
1.4
2.5
1.4
3.1
3.3
3.9
* Moisture CEMS was malfunctioning and was repaired.
Note: Relative accuracy of the H2O GEM was 23% and the average
difference was 2.0% H2O.
MRI-OPPn\R4703-02-07 Revised, wpd
5-32
-------
about the time of the second RCA. These problems may have been caused by the constant
vibration of the H2O CEM probe, which may have put severe stresses on the sensor in the
CEMS probe. Even so, the H2O CEMS data were very useful on a day-to-day basis since
this data often provided a good indication of plant operational problems or shutdowns.
(The PM-CEMS readings were normally quite low and did not show significantly different
readings during most plant operational problems or shutdowns.)
The Vaisala HMP 235 moisture CEM also includes a temperature sensor that is used
to monitor stack temperature and is also used in the calculation of percent H2O by volume
as discussed in the previous section.
The HMP 235 temperature is output as a 0-10 Vdc signal, with a temperature range of
-20° to + 180°C signal. Thus, the equation used to calculate temperature was:
Temp in °C = 20 (Vdc) - 20
In order to evaluate the accuracy of the HMP 235 temperature readings, they were
compared with the average M17 stack thermocouple data for each run of the initial
correlation tests, as given in Table 5-7A. These results show that the HMP 235
temperatures were an average of 2.0°C lower than the M17 data. Although this met the
QA criteria of ±2°C, the equation above was changed slightly in order to improve the
accuracy of the temperature readings, as shown in the equation below.
Temp in °C = 20 (Vdc)-18
The temperature results from the first RCA (which used the modified equation above)
are presented in Table 5-7B and show that the CEM met the accuracy criteria of ±2°C.
The same comparison for the second RCA tests in Table 5-7C showed that the H2O CEM
reading was always higher than the Ml7 temperature measurement but did meet the QA
criteria of ±2°C.
MR1-OPPT\\R4703-02-07 Revised.wpd , __
-------
Table 5-7A. Stack Temperature Comparison for Initial Correlation Tests
(M17 Versus H,O CEM)
Run no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Average
Stack temperature°C
M17
90
88
88
85.5
89
86
85
85
86
85
85.5
85
85
85
85
86.2
H2O CEM
87.8
85.7
85.5
84.1
87.1
83.8
83.0
83.5
83.8
83.1
83.7
83.5
82.7
82.9
83.4
84.2
Difference
-2.2
-2.3
-2.5
-1.4
-1.9
-2.2
-2.0
-1.5
-2.2
-1.9
-1.8
-1.5
-2.3
-2.1
-1.6
-2.0
MR1-OPPT\\R4703-02-07 Revised wpd
5-34
-------
Table 5-7B. Stack Temperature Comparison for the First RCA Tests
(M17 Versus KUO CEM)
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
Average
Stack temperature °C
M17
84.7
85.0
86.9
85.3
85.3
86.7
91.1
85.3
85.8
85.3
85.6
83.6
85.9
H2O CEM
84.7
84.8
86.7
85.4
85.2
87.0
90.8
85.7
86.2
85.7
85.7
84.0
86.0
Difference
0
-0.2
-0.2
+0.1
-0.1
+0.3
-0.3
+0.4
+0.4
+0.4
+0.1
+0.4
+0.1
MRI-OPPTftR4703-02-07 Revised wpd
5-35
-------
Table 5-7C. Stack Temperature Comparison for Second RCA Test
(CEMS versus Method 17)
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
Average
Stack temperature (°C)
Method 17
80.6
80.6
81.7
81.7
81.6
81.6
80.6
80.6
80.6
81.7
82.2
82.8
81.4
H2O CEM
NA
82.2
83.1
83.8
84.0
83.4
82.1
82.1
82.0
83.4
83.4
84.2
83.1
Difference
-
+1.6
+1.4
+2.1
+2.4
+1.8
+1.5
+1.5
+1.4
+1.7
+1.2
+1.4
+1.6
MR1-OPPT\\R4703-02-07 Revised, wpd
5-36
-------
5.3.3 PM-CEMS Drift Test Data and ACA Results
The three PM-CEMS operated since the beginning of the 6-month evaluation period
(July 20,1999) through the end of the 6-month test period (February 16, 2000) except for
the downtime of September 15 to October 7 due to Hurricane Floyd. During this period, an
initial 7-day drift test was performed, and thereafter the four PM-CEMS have performed
automatic daily zero and upscale drift checks. Also, four ACAs were carried out for the
two light scatter PM-CEMS as well as sample volume audits (SVA) on the beta gauge
CEMS. Results for these tests are presented in the sections below.
5.3.3.1 7-day Zero and Upscale Drift Test Results
Calibration drift data for the 7-day drift test were collected, as prescribed in
Section 8.5 of PS-11, beginning after the shakedown period and before the initial
correlation test. Calibration drift data for the ESC P5B and Durag DR 300-40 were taken
during the period July 1 through July 7, but the Durag F904K had been removed and was at
Durag's office undergoing repairs and upgrades.
The 7-day drift test results for the Durag F904K were collected starting July 10,1999,
after the instrument was reinstalled on July 9, 1999. Drift test results are discussed below
and are presented in Table 5-8.
• ESC P5B. The zero reference value for the ESC P5B was 4.05 mA, and the
upscale reference value was 12 mA. The largest zero drift was 0.25% of the
upscale reference value. The largest upscale drift was 1.33% of the upscale
reference value. These results show that the ESC P5B met the 7-day zero and
upscale drift criteria of < 2% of the upscale reference value.
MRJ-OPPT\\R4703-02-07 Revised wpd
5-37
-------
Table 5-8. 7-Day Calibration Drift Results for the Three PM-CEMS
ESC P5B 7-Dav
Date
7/1/99
7/2/99
7/3/99
7/4/99
7/5/99
7/6/99
7/7/99
Zero
reading (mA)
4.02
4.02
4.02
4.02
4.02
4.02
4.02
Calibration Drift Test Results
Zero drift (%)
0.25
0.25
0.25
0.25
0.25
0.25
0.25
Upscale
reading (mA)
11.90
11.85
11.91
11.93
11.93
11.89
11.84
Upscale drift (%)
0.83
1.25
0.75
0.58
0.58
0.92
1.33
Duras DR 300-40 7-Dav Calibration Drift Test Results
Date
7/1/99
7/2/99
7/3/99
7/4/99
7/5/99
7/6/99
7/7/99
Zero
reading (mA)
4.03
4.03
4.03
4.03
4.03
4.03
4.03
Zero drift (%)
0.20
0.20
0.20
0.20
0.20
0.20
0.20
Upscale
reading (mA)
15.06
15.06
15.07
15.06
15.13
15.07
15.06
Upscale drift (%)
0.40
0.40
0.47
0.40
0.87
0.47
0.47
Durag F904K 7-Dav Calibration Drift Test Results
Date
7/10/99
7/11/99
7/12/99
7/13/99
7/14/99
7/15/99
7/16/99
Zero
reading (mA)
4.10
4.17
4.10
4.02
4.02
4.17
4.10
Zero drift (%)
0.69
1.17
0.69
0.14
0.14
1.17
0.69
Upscale
reading (mA)
14.48
14.40
14.56
14.56
14.48
14.40
14.48
Upscale drift (%)
0.55
1.10
0.00
0.00
0.55
1.10
0.55
MRl-OPPTl\R4703-02-07 Revised wpd
5-38
-------
Durag DR 300-40. The zero reference value for the Durag DR 300-40 was 4.0
mA, and the upscale reference value was 15 mA. The largest zero drift was
0.20% of the upscale reference value. The largest upscale drift was 0.87% of the
upscale reference value. These results show that the DR 300-40 met the 7-day
zero and upscale drift criteria of < 2% of the upscale reference value.
Durag F904K. The zero reference value for the Durag F904K was 4.0 mA, and
the upscale reference value was 14.56 mA. The largest zero drift was 1.17% of
the upscale reference value. The largest upscale drift was 1.10% of the upscale
reference value. These results show that the F904K met the 7-day zero and
upscale drift criteria of < 2% of the upscale reference value.
5.3.3.2 Daily Zero and Upscale Drift Test Results
Daily zero and upscale drift checks, as prescribed in draft Procedure 2, were carried
out automatically by all three PM-CEMS. Daily calibration drift data for the 6-month
endurance test period was collected in segments corresponding with the RCA tests, as
follows:
July 20, 1999, to August 31, 1999 (See Table 5-9A)
September 1, 1999, to November 20,1999 (See Table 5-9B)
November 21,1999, to February 16, 2000 (See Table 5-9C)
Daily drift data for the period of July 20 to August 31, 1999, show that all three PM-
CEM were within the out-of-control limits. (The drift test criteria in draft Procedure 2
specify that a CEM must be adjusted if the drift exceeds 4% of the upscale value, and that
the CEM is out of control if the drift exceeds 4% for five consecutive days or exceeds 8%
in any one day.) It was noted that for the ESC-P5B, the upscale drift was progressively
increasing and exceeded 4% for three consecutive days (August 21 to August 23, 1999).
Therefore, on August 24,1999, the manufacturer's procedures were used to re-adjust the
instrument, which decreased the subsequent upscale drift values.
MRI-OPPTMW03-02-07 Revised, wpd
5-39
-------
Table 5-9A. Daily Drift Results (July 20 to August 31,1999)
Date
7/20/99
7/21/99
7/22/99
7/23/99
7/24/99
7/25/99
7/26/99
7/27/99
7/28/99
7/29/99
7/30/99
7/31/99
8/1/99
8/2/99
8/3/99
8/4/99
8/5/99
8/6/99
8/7/99
8/8/99
8/9/99
8/10/99
8/11/99
8/12/99
8/13/99
8/14/99
8/15/99
8/16/99
ESC PM CEM
Zero = 4.05mA Ref. Value = 12 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.25 11.83 1.42
4.02 0.25 11.82 1.50
4.02 0.25 11.82 1.50
4.02 0.25 11.83 1.42
4.02 0.25 11.78 1.83
4.02 0.25 11.8 1.67
4.02 0.25 11.77 1.92
4.02 0.25 11.75 2.08
4.02 0.25 11.76 2.00
4.02 0.25 11.7 2.50
4.02 0.25 11.7 2.50
4.02 0.25 11.73 2.25
4.02 0.25 11.71 2.42
4.02 0.25 11.68 2.67
4.02 0.25 11.6 3.33
4.02 0.25 11.59 3.42
4.02 0.25 11.57 3.58
4.02 0.25 11.63 3.08
4.02 0.25 11.57 3.58
4.02 0.25 11.59 3.42
4.02 0.25 11.55 3.75
4.02 0.25 11.56 3.67
4.02 0.25 11.54 3.83
4.02 0.25 11.58 3.50
4.02 0.25 11.61 3.25
4.02 0.25 11.58 3.50
4.02 0.25 11.53 3.92
4.02 0.25 11.57 3.58
Duraq DR 300-40 PM CEM Ref. Value = 1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.13 15.06 0.40
4.02 0.13 15.06 0.40
4.02 0.13 15.07 0.47
4.03 0.20 15.06 0.40
4.03 0.20 15.07 0.47
4.03 0.20 15.08 0.53
4.02 0.13 15.06 0.40
4.03 0.20 15.07 0.47
4.02 0.13 15.08 0.53
4.03 0.20 15.07 0.47
4.03 0.20 15.07 0.47
4.03 0.20 15.08 0.53
4.03 0.20 15.08 0.53
4.03 0.20 15.07 0.47
4.02 0.13 15.06 0.40
4.02 0.13 15.06 0.40
4.02 0.13 15.06 0.40
4.03 0.20 15.06 0.40
4.03 0.20 15.06 0.40
4.03 0.20 15.07 0.47
4.03 0.20 15.07 0.47
4.02 0.13 15.05 0.33
4.02 0.13 15.05 0.33
4.03 0.20 15.07 0.47
4.02 0.13 14.99 0.07
4.03 0.20 15.07 0.47
4.02 0.13 15.04 0.27
4.02 0.13 15.06 0.40
Duraq F904K PM CEM Ref. Value =14.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.56 0.00
4.18 1.24 14.48 0.55
4.02 0.14 14.48 0.55
4.1 0.69 14.48 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.63 0.48
4.02 0.14 14.48 0.55
4.18 1.24 14.56 0.00
4.02 0.14 14.56 0.00
4.1 0.69 14.48 0.55
4.18 1.24 14.41 1.03
4.18 1.24 14.48 0.55
4.02 0.14 14.48 0.55
4.1 0.69 14.48 0.55
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.02 0.14 14.48 0.55
4.1 0.69 14.48 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.18 1.24 14.72 1.10
4.02 0.14 14.56 0.00
4.1 0.69 14.48 0.55
MRJ-OPPT\\R4703-02-07 Revised wpd
5-40
-------
Table 5-9A (Continued)
Date
8/17/99
8/18/99
8/19/99
8/20/99
8/21/99
8/22/99
8/23/99
8/24/99
8/25/99
8/26/99
8/27/99
8/28/99
8/29/99
8/30/99
8/31/99
ESC PM CEM
Zero = 4. 05m A Ref. Value = 12 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.25 11.56 3.67
4.02 0.25 11.55 3.75
4.02 0.25 11.54 3.83
4.02 0.25 11.53 3.92
4.02 0.25 11.46 4.50
4.02 0.25 11.41 4.92
4.02 0.25 11.47 4.42
4.03 0.17 11.94 0.50
4.02 0.25 11.92 0.67
4.02 0.25 11.82 1.50
4.03 0.17 11.92 0.67
4.03 0.17 11.94 0.50
4.05 0.00 11.89 0.92
4.09 0.33 11.83 1.42
4 02 0 25 1 1 75 2 08
Duraq DR 300-40 PM CEM Ref. Value = 1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.13 15.06 0.40
4.02 0.13 15.06 0.40
4.03 0.20 15.06 0.40
4.02 0.13 15.06 0.40
4.02 0.13 15.07 0.47
4.02 0.13 15.06 0.40
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.03 0.20 15.07 0.47
4.02 0.13 15.05 0.33
4.02 0.13 15.05 0.33
4.03 0.20 15.06 0.40
4.03 0.20 15.06 0.40
4.02 0.13 15.06 0.40
402 0.13 15.05 0.33
Duraq F904K PM CEM Ref. Value =1 4.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.48 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.02 0.14 14.48 0.55
4.1 0.69 14.48 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.64 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
MRI-OPPT\\R4703-02-07 Revised wpd
5-41
-------
Table 5-9B. Daily Drift Results (September 1 to November 20,1999)
Date
9/1/99
9/2/99
9/3/99
9/4/99
9/5/99
9/6/99
9/7/99
9/8/99
9/9/99
9/10/99
9/11/99
9/12/99
9/13/99
9/14/99
9/15/99
ESC PM CEM
Zero =4.05 mA Ref . Value = 1 2 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.25 11.76 2.00
4.02 0.25 11.76 2.00
4.02 0.25 11.82 1.50
4.02 0.25 12 0.00
4.02 0.25 11.87 1.08
4.02 0.25 11.93 0.58
4.02 0.25 11.88 1.00
4.02 0.25 11.9 0.83
4.02 0.25 11.87 1.08
4.02 0.25 11.84 1.33
4.02 0.25 11.75 2.08
4.02 0.25 11.73 2.25
4.02 0.25 11.7 2.50
4.02 0.25 11.75 2.08
4.02 0.25 11.81 1.58
System off-line due to Hurricane Floyd
10/7/99
10/8/99
10/9/99
10/10/99
10/11/99
10/12/99
10/13/99
10/14/99
10/15/99
10/16/99
10/17/99
10/18/99
10/19/99
10/20/99
10/21/99
4.02 0.25 11.91 0.75
4.02 0.25 11.62 3.17
4.02 0.25 11.46 4.50
4.02 0.25 11.56 3.67
4.02 0.25 11.61 3.25
4.02 0.25 11.5 4.17
4.02 0.25 11.26 6.17
4.01 0.33 11.34 5.50
4.02 0.25 11.97 0.25
4.02 0.25 11.87 1.08
4.01 0.33 11.98 0.17
4.01 0.33 11.95 0.42
4.02 0.25 11.84 1.33
4.01 0.33 11.92 0.67
4.01 0.33 11.89 0.92
1
Duraq DR 300-40 PM-CEM Ref. Value =1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.13 15.05 0.33
4.02 0.13 15.05 0.33
4.02 0.13 15.02 0.13
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.03 0.20 15.07 0.47
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.02 0.13 15.06 0.40
4.03 0.20 15.06 0.40
4.02 0.13 15.04 0.27
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.06 0.40
4.02 0.13 15.04 0.27
4.02 0.13 15.06 0.40
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.06 0.40
DR 300-40 is out-of-service, dirty window check
too high
4.02 0.13 15.04 0.27
&
Duraq F904K PM-CEM Ref. Value =1 4.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.18 1.24 14.48 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.18 1.24 14.64 0.55
4.1 0.69 14.41 1.03
4.02 0.14 14.64 0.55
4.02 0.14 14.56 0.00
4.17 1.17 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.18 1.24 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14* '" 14.64 " * *"~^p
4.03 0.21 14.49 0.48
4.1 0.69 14.48 0.55
4.02 0.14 14.49 0.48
4.02 0.14 14.49 0.48
4.1 0.69 14.64 0.55
F904K is out-of-service; air conditioner broken;
Pressurized air line came disconnected
4.1 0.69 14.41 1.03
F904K is out-of-service; pressurized air line off
ii
»
u
4.1 0.69 14.48 0.55
4.02 0.14 14.56 0.00
MRI-OPPT\\R4703-02-07 Revised wpd
5-42
-------
Table 5-9B (Continued)
Date
10/22/99
10/23/99
10/24/99
10/25/99
10/26/99
10/27/99
10/28/99
10/29/99
10/30/99
10/31/99
11/1/99
11/2/99
11/3/99
11/4/99
11/5/99
11/6/99
11/7/99
11/8/99
11/9/99
11/10/99
11/11/99
11/12/99
11/13/99
11/14/99
11/15/99
11/16/99
11/17/99
11/18/99
11/19/99
11/20/99
ESC PM CEM
Zero -4.05 mA Ref . Value - 1 2 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.01 0.33 11.84 1.33
4.02 0.25 11.65 2.92
4.02 0.25 11.58 3.50
4.01 0.33 11.62 3.17
4.01 0.33 11.68 2.67
4.02 0.25 11.65 2.92
4.02 0.25 11.57 3.58
4.01 0.33 11.73 2.25
4.02 0.25 11.61 3.25
4.01 0.33 11.66 2.83
4.01 0.33 11.66 2.83
4.01 0.33 11.68 2.67
Data logger off line 11/3 a.m.
4.01 0.33 11.43 4.75
4.01 0.33 11.34 5.50
4.01 0.33 11.45 4.58
4.01 0.33 11.51 4.08
4.01 0.33 11.61 3.25
4.01 0.33 11.39 5.08
4.01 0.33 11.51 4.08
4.01 0.33 12.11 0.92
4.02 0.25 12.03 0.25
4.02 0.25 11.97 0.25
4.01 0.33 12.08 0.67
4.02 0.25 12.04 0.33
4.01 0.33 12.06 0.50
4.02 0.25 12.03 0.25
4.01 0.33 11.88 1.00
4.01 0.33 11.8 1.67
4.02 0.25 11.89 0.92
Duraq DR 300-40 PM-CEM Ref. Value =1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.01 0.07 15.03 0.20
4.02 0.13 15.05 0.33
4.01 0.07 15.04 0.27
4.01 0.07 15.03 0.20
4.02 0.13 15.02 0.13
4.02 0.13 15.22 1.47
4.02 0.13 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.06 0.40
4.02 0.13 15.05 0.33
4.02 0.13 15.06 0.40
Data logger off line 1 1/3 a.m.
4.01 0.07 15.03 0.20
4.01 0.07 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.01 0.07 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.05 0.33
4.01 0.07 15.03 0.20
4.01 0.07 15.05 0.33
4.01 0.07 15.04 0.27
4.01 0.07 15.04 0.27
4.02 0.13 15.03 0.20
Duraq F904K PM-CEM Ref. Value -1 4.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.56 0.00
F904K is out-of-service; 3 vacuum errors on 10/22/99
ii
ii
4.18 1.24 14.41 1.03
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
F904K is out-of-service; 3 vacuum errors on 10/29/99
ii
ii
F904K is out-of-service; filter tear.
4.02 0.14 14.64 0.55
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
F904K is out-of-service; 3 vacuum errors on 1 1/8/99
F904K is out-of-service; filter tear.
F904K repaired but no drift check
4.02 0.14 14.49 0.48
F904K is out-of-service; filter tear.
"
H
F904K back in service, no calibration
4.1 0.69 14.49 0.48
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.49 0.48
MRI-OPPT\\R4703-02-07 Revised wpd
5-43
-------
Table 5-9C.
Date
11/21/99
11/22/99
11/23/99
11/24/99
11/25/99
11/26/99
11/27/99
11/28/99
11/29/99
11/30/99
12/1/99
12/2/99
12/3/99
12/4/99
12/5/99
12/6/99
12/7/99
12/8/99
12/9/99
12/10/99
12/11/99
12/12/99
12/13/99
12/14/99
12/15/99
12/16/99
12/17/99
12/18/99
12/19/99
12/20/99
12/21/99
ESC PM CEM
Zero=4.05mA Ref. Value = 12 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.25 11.8 1.67
4.02 0.25 11.8 1.67
4.02 0.25 11.62 3.17
4.02 0.25 11.64 3.00
4.02 0.25 11.64 3.00
4.02 0.25 11.66 2.83
4.02 0.25 11.6 3.33
4.02 0.25 11.61 3.25
4.01 0.33 11.57 3.58
4.02 0.25 11.49 4.25
4.01 0.33 11.41 4.92
4.01 0.33 12.09 0.75
4.01 0.33 12.24 2.00
4.02 0.25 11.73 2.25
4.02 0.25 12.03 0.25
4.02 0.25 11.78 1.83
4.01 0.33 11.67 2.75
4.02 0.25 11.62 3.17
4.01 0.33 11.62 3.17
4.02 0.25 11.76 2.00
4.01 0.33 11.99 0.08
4.02 0.25 11.83 1.42
4.01 0.33 11.97 0.25
4.02 0.25 11.96 0.33
4.02 0.25 11.85 1.25
4.01 0.33 11.85 1.25
4.02 0.25 11.72 2.33
4.02 0.25 11.7 2.50
4.02 0.25 11.7 2.50
4.02 0.25 11.81 1.58
4.02 0.25 11.76 2.00
Daily Cal Drift Data (November 21 to February 16)
Durag DR 300-40 PM CEM Ref. Value = 1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.02 0.13 15.05 0.33
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.01 0.07 15.03 0.20
4.01 0.07 15.02 0.13
4.01 0.07 15.05 0.33
4.01 0.07 15.02 0.13
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.05 0.33
4.01 0.07 15.02 0.13
4.01 0.07 15.03 0.20
4.01 0.07 15.02 0.13
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
4.01 0.07 15.03 0.20
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.01 0.07 15.03 0.20
4.02 0.13 15.04 0.27
4.01 0.07 15.02 0.13
4.02 0.13 15.05 0.33
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.02 0.13 15.04 0.27
Durag F904K PM CEM Ref. Value = 14.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.41 1.03
4.18 1.24 14.64 0.55
4.02 0.14 14.57 0.07
4.18 1.24 14.64 0.55
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.49 0.48
4.02 0.14 14.64 0.55
4.1 0.69 14.49 0.48
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.1 0.69 14.48 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.1 0.69 14.4 1.10
4.1 0.69 14.64 0.55
4.02 0.14 14.49 0.48
4.1 0.69 14.64 0.55
4.1 0.69 14.64 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.64 0.55
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.48 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.56 0.00
MRI-OPPT\\R4703-02-07 Revised wpd
5-44
-------
Table 5-9C (Continued)
Date
12/22/99
12/23/99
12/24/99
12/25/99
12/26/99
12/27/99
12/28/99
12/29/99
12/30/99
12/31/99
1/1/00
1/2/00
1/3/00
1/4/00
1/5/00
1/6/00
1/7/00
1/8/00
1/9/00
1/10/00
1/11/00
1/12/00
1/13/00
1/14/00
1/15/00
1/16/00
1/17/00
1/18/00
1/19/00
1/20/00
ESC PM CEM
Zero=4.05mA Ref. Value = 12 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.25 11.73 2.25
4.01 0.33 11.68 2.67
4.01 0.33 11.67 2.75
4.01 0.33 11.56 3.67
4.01 0.33 11.49 4.25
4.01 0.33 11.57 3.58
4.01 0.33 11.55 3.75
4.02 0.25 11.52 4.00
4.02 0.25 11.52 4.00
4.02 0.25 11.9 0.83
4.02 0.25 11.78 1.83
4.02 0.25 11.82 1.50
4.02 0.25 11.88 1.00
4.02 0.25 11.91 0.75
4.02 0.25 11.75 2.08
4.02 0.25 11.65 2.92
4.02 0.25 11.65 2.92
4.02 0.25 11.59 3.42
4.02 0.25 11.61 3.25
Durag DR 300-40 PM CEM Ref. Value = 1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.01 0.07 15.03 0.20
4.01 0.07 15.04 0.27
4.01 0.07 15.04 0.27
4.01 0.07 15.03 0.20
4.01 0.07 15.02 0.13
4.01 0.07 15.03 0.20
4.02 0.13 15.03 0.20
4.01 0.07 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.02 0.13 15.05 0.33
4.02 0.13 15.03 0.20
4.01 0.07 15.03 0.20
4.02 0.13 15.04 0.27
4.01 0.07 15.02 0.13
4.02 0.13 15.04 0.27
Durag F904K PM CEM Ref. Value = 1 4.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.56 0.00
4.02 0.14 14.49 0.48
4.02 0.14 14.56 0.00
4.1 0.69 14.49 0.48
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.49 0.48
4.18 1.24 14.33 1.58
4.1 0.69 14.49 0.48
4.02 0.14 14.56 0.00
4.1 0.69 14.4 1.10
4.1 0.69 14.49 0.48
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
4.1 0.69 14.64 0.55
4.1 0.69 14.56 0.00
Computer problem; no drift data taken
4.02 0.25 11.65 2.92
4.02 0.25 12.01 0.08
4.02 0.25 12 0.00
4.02 0.25 11.95 0.42
4.02 0.25 11.89 0.92
4.01 0.33 11.87 1.08
4.01 0.33 11.91 0.75
4.02 0.25 11.84 1.33
4.01 0.33 11.81 1.58
4.02 0.25 11.93 0.58
4.01 0.07 15.03 0.20
4.02 0.13 15.03 0.20
4.02 0.13 15.04 0.27
4.01 0.07 15.04 0.27
4.02 0.13 15.03 0.20
4.01 0.07 15.03 0.20
4.02 0.13 15.03 0.20
4.01 0.07 15.03 0.20
4.01 0.07 15.03 0.20
4.01 0.07 15.04 0.27
4.02 0.14 14.56 0.00
4.1 0.69 14.56 0.00
4.02 0.14 14.56 0.00
4.02 0.14 14.56 0.00
4.1 0.69 14.57 0.07
4.1 0.69 14.56 0.00
4.1 0.69 14.49 0.48
4.1 0.69 14.49 0.48
4.01 0.07 14.56 0.00
4.02 0.14 14.56 0.00
MRI-OPPT\\R4703-02-07 Revised wpd
5-45
-------
Table 5-9C (Continued)
Date
1/21/00
1/22/00
1/23/00
1/24/00
1/25/00
1/26/00
1/27/00
1/28/00
1/29/00
1/30/00
1/31/00
2/1/00
2/2/00
2/3/00
2/4/00
2/5/00
2/6/00
2/7/00
2/8/00
2/9/00
2/10/00
2/11/00
2/12/00
2/13/00
2/14/00
2/15/00
2/16/00
ESC PM CEM
Zero=4.05 mA Ref. Value = 12 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) 1%) (mA) (%)
4.01 0.33 11.93 0.58
4.01 0.33 11.92 0.67
4.01 0.33 11.9 0.83
4.01 0.33 11.86 1.17
4.01 0.33 11.69 2.58
4.01 0.33 11.7 2.50
4.01 0.33 11.66 2.83
4.01 0.33 11.59 3.42
4.01 0.33 11.56 3.67
4.01 0.33 11.41 4.92
4.01 0.33 11.42 4.83
4.01 0.33 11.44 4.67
4.01 0.33 11.44 4.67
4.01 0.33 11.39 5.08
4.02 0.25 11.43 4.75
4.01 0.33 11.42 4.83
4.01 0.33 11.39 5.08
4.02 0.25 12.02 0.17
4.02 0.25 12.02 0.17
4.01 0.33 11.86 1.17
No data due to maintenance
Durag DR 300-40 PM CEM Ref. Value = 1 5 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4 0.00 15.03 0.20
4.01 0.07 15.02 0.13
4.01 0.07 15.02 0.13
4.01 0.07 15.03 0.20
4 0.00 15.02 0.13
4.01 0.07 15.03 0.20
4 0.00 15.02 0.13
4 0.00 15.02 0.13
4.01 0.07 15.03 0.20
4.01 0.07 15.03 0.20
4.01 0.07 15.03 0.20
4.01 0.07 15.01 0.07
4.01 0.07 15.03 0.20
4.01 0.07 15.02 0.13
4.01 0.07 15.03 0.20
4.01 0.07 15.04 0.27
4.01 0.07 15.03 0.20
4.01 0.07 15.05 0.33
4.01 0.07 15.04 0.27
4.01 0.07 15.03 0.20
4.02 0.13 15.05 0.33
Durag F904K PM CEM Ref. Value = 1 4.56 mA
Zero Upscale
reading Zero drift reading Upscale drift
(mA) (%) (mA) (%)
4.02 0.14 14.49 0.48
4.09 0.62 14.56 0.00
4.01 0.07 14.56 0.00
4.01 0.07 14.49 0.48
4.01 0.07 14.56 0.00
4.09 0.62 14.64 0.55
4.01 0.07 14.48 0.55
4.01 0.07 14.56 0.00
4.09 0.62 14.48 0.55
4.01 0.07 14.56 0.00
4.09 0.62 14.56 0.00
4.01 0.07 14.56 0.00
4.01 0.07 14.56 0.00
4.02 0.14 14.56 0.00
4.09 0.62 14.41 1.03
4.09 0.62 14.48 0.55
4.01 0.07 14.56 0.00
4.09 0.62 14.48 0.55
4.17 1.17 14.48 0.55
4.09 0.62 14.56 0.00
4.09 0.62 14.56 0.00
Operator error caused no calibration drift data to be available for any of the PM CEMSs
4.02 0.25 11.92 0.67
4.01 0.33 11.89 0.92
4.01 0.33 12.08 0.67
4.02 0.25 11.92 0.67
402 0.25 11.9 0.83
4.01 0.07 15.04 0.27
4.01 0.07 15.03 0.20
4.01 0.07 15.04 0.27
4.01 0.07 15.04 0.27
4.01 0.07 15.04 0.27
4.01 0.07 14.49 0.48
4.09 0.62 14.48 0.55
4.09 0.62 14.64 0.55
4.02 0.14 14.48 0.55
4.02 0.14 14.56 0.00
MRJ-OPPT\\R4703-02-07 Revised wpd
5-46
-------
Daily drift results for the period of September 1 to November 20, 1999, are given in
Table 5-9B. These data show that none of the three PM-CEMS exceeded the out-of-
control limits given above. It was noted that for the ESC P5B, the upscale drift was
progressively increasing and exceeded 4% for three consecutive days (October 12-14).
Therefore, on October 15,1999, the manufacturer's procedures were used to clean the
lenses and to change the purge air filter, which decreased the subsequent upscale drift
values. The upscale drift again exceeded 4% on November 9 and 10, and the above
corrective procedure was used on November 11, 1999.
Daily drift results for the period of November 21, 1999, to February 16, 2000, are
given in Table 5-9C. These also show that the three PM-CEMS did not exceed the out-of-
control limits discussed above, except as noted below. That is, it was necessary to perform
corrective action on the ESC-P5B six times during the period, to correct the upscale drift
problem as noted previously in Section 4.1. The upscale drift exceeded 4% for 7
consecutive days and therefore was out of control for 2 days (February 5 and 6, 2000).
However, this out-of-control period would not have occurred if on-site personnel were
responsible for responding to such problems.
5.3.3.3 Absolute Correlation Audit Results
Absolute correlation audits (ACA) were conducted on the ESC-P5B and Durag
DR 300-40 according to procedures given in draft Procedure 2. Audit standards (i.e.,
reference materials) for the ACAs were provided by the two PM-CEM manufacturers. No
such reference materials were available from Durag for the F904K beta gauge, so the
ACAs for this PM-CEM were limited to performing sample volume audits (SVA).
For the ESC-P5B, the manufacturer provided three "reference tubes" with assigned
reference values of 34.6 mg, 57.8 mg, and 105.2 mg. To conduct the ACAs on the ESC
P5B, the sensor was removed from the probe and each reference tube was alternately
MR1-OPPT\\R4703-02-07 Revised wpd
5-47
-------
attached to the sensor until each tube had been applied three times. The readings (in mg)
were read directly from the instrument display.
For the Durag DR 300-40, the manufacturer used a combination of light filters in a
"filter box" to establish the reference standards. The manufacturer initially established the
reference values in the field on June 6, 1999. The first AC A was carried out on July 8,
1999, using those initial reference values. However, it later became necessary to change
the range on the PM-CEMS (as discussed previously in Section 5.2.1.2), which affected the
reference values. Therefore, on July 14, 1999, MRI re-established the reference values, as
given below, which were used in all the subsequent ACAs. Since the DR300-40 has three
operating ranges (i.e., levels) the reference values are range adjusted milliamps, as was
explained in Section 1.1.3.2.
Reference values in
Range adjusted milliamps
range change
Range
Range 1
Range 2
Range 3
Range 3
For each ACA of the Durag DR 300-40, the instrument was removed from the duct
and placed on the filter box. Each reference filter was alternately applied to the instrument
according to the manufacturer's instructions until each reference was applied three times.
The readings, in range adjusted mA, were obtained from the 1 min averages generated by
the DAS, which were compared with the reference values.
Initial values
established
June 6. 1999
16.39 mA
32.83 mA
67.81 mA
144.76 mA
Later values after range change
established Julv 14. 1999
14.53
28.60
61.42
133.78
MR1-OPPT\\R4703-02-07 Revised wpd - . Q
-------
A total of four ACAs were performed on the ESC-P5B and DR 300-40, as follows:
June 30 and July 8, 1999 Initial ACA
August 26, 1999
November 15,1999
February 7, 2000
2nd ACA
3rd ACA
4th ACA
Prior to start of 6-month endurance test period
on July 20, 1999
Prior to first RCA on August 27,1999
Prior to second RCA on November 17,1999
Prior to end of 6-month endurance test on
February 16, 2000
Results for all four ACAs are given in Table 5-10A, B, C, and D and show that the
ESC-P5B and DR 300-40 met the draft Procedure 2 criteria in all four ACAs.
5.3.3.4 Sample Volume Audit Results
The Durag F904K beta gauge is an extractive PM-CEM, as was explained in
Section 1.1.3.3. Particulate matter is collected on a paper tape during each sample cycle.
The amount (mg) of paniculate matter on the filter is determined by the reduction in
transmission of beta particles, before and after sampling. During each sampling period the
F904K measures the volumetric flowrate of sample gas in order to determine the total
volume of gas sampled during the sampling cycle. Thus, the output signal from the
monitor (mA) is proportional to the mass of particulate per unit volume of gas (i.e.,
mg/dscm).
Since the measurement of the gas volume is a critical parameter in the results, EPA
draft Procedure 2 (dated November 1998) specifies that a Sample Volume Audit (SVA) be
performed every quarter, and that the PM-CEM be considered out of control if results
exceed ±5% of the average sample volume audit value.
The procedure used for the SVAs was to connect the sample gas exhaust from the
F904K to the inlet of the dry gas meter (DGM) on one of the calibrated sampling consoles
MRI-OPPTttR4703-02-07 Revised.wpd
5-49
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Table 5-10A. Results for Initial ACA
ESC P5B ACA Result
Test dale
June 30, 1999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by manf.)
ACA%
Pass/Fail 1 5% Criteria
Low (mg)
35.1
35.0
35.0
35.0
34.6
1.16
Pass
Audit points
Mid (mg)
57.2
57.4
57.3
57.3
57.8
0.87
Pass
High (mg)
104.9
105.2
104.4
104.8
105.2
0.35
Pass
Durag DR 300-40 ACA Result
Test date
JulyS, 1999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by manf. in field)
ACA%
Pass/Fail 1 5% Criteria
Range 1
A (ra mA)
15.42
15.72
15.76
15.63
16.39
4.64
Pass
Audit points
Range 2
B (ra mA)
30.67
31.25
31.33
31.08
32.83
5.32
Pass
(See note)
Range 3
C (ra mA)
63.64
64.15
64.57
64.12
67.81
5.44
Pass
Range 3
D (ra mA)
137.86
138.79
139.45
138.70
144.76
4.19
Pass
Note: Units shown in columns (ra mA) are range adjusted milliamps.
MR1-OPPT\\R4703-02-07 Revisedwpd
5-50
-------
Table 5-10B. Results for 2nd ACA
ESC P5B ACA Result
Test date
August 26, 1999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by manf.)
ACA%
Pass/Fail 1 5% Criteria
Low (mg)
35.1
35.3
34.8
35.7
34.6
1.35
Pass
Audit points
Mid (mg)
56.9
56.9
56.4
56.7
57.8
1.85
Pass
High (mg)
104.0
105.1
104.2
104.4
105.2
0.73
Pass
Durag DR 300-40 ACA Result
Audit points (See note)
Test date
August 26, 1 999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by MRI on July 14, 1999)
ACA%
Pass/Fail 1 5% Criteria
Range 1
A (ra mA)
14.64
14.60
14.64
14.63
14.53
0.67
Pass
Range 2
B (ra mA)
28.57
28.66
28.78
28.67
28.6
0.24
Pass
Range 3
C (ra mA)
61.82
61.74
61.93
61.83
61.42
0.67
Pass
Range 3
D (ra mA)
132.90
133.40
133.70
133.33
133.78
0.33
Pass
Note: Units shown in columns (ra mA) are ranged adjusted milliamps.
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Table 5-10C. Results for 3rd ACA
ESC P5B ACA Result
Test date
November 15, 1999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by manf.)
ACA%
Pass/Fail 1 5% Criteria
Low (mg)
35.4
34.9
35.2
35.17
34.6
1.64
Pass
Audit points
Mid (mg)
57.9
57.4
57.1
57.47
57.8
0.58
Pass
High (mg)
105.8
104.8
105.1
105.23
105.2
0.03
Pass
Durag DR 300-40 ACA Result
Test date
November 15, 1999
Challenge 1
Challenge 2
Challenge 3
Average
Reference value (by
MRI on July 14, 1999)
ACA%
Pass/Fail 1 5% Criteria
Range 1
A (ra mA)
15.14
15.16
15.15
15.15
14.53
4.27
Pass
Audit points
Range 2
B (ra mA)
29.95
29.98
29.98
29.97
28.6
4.79
Pass
(See note)
Range 3
C (ra mA)
64.57
64.66
64.66
64.63
61.42
5.23
Pass
Range 3
D (ra mA)
140.94
141.07
141.16
141.06
133.78
5.44
Pass
Note: Units shown in columns (ra mA) is ranged adjusted milliamps.
MR1-OPPT\\R4703-02-07 Revised, wpd
5-52
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Table 5-10D. Results for 4th ACA
ESC P5B ACA Result
Test date
February 7, 2000
Challenge 1
Challenge 2
Challenge 3
Average
Reference value
(by manf.)
ACA%
Pass/Fail 1 5% Criteria
Low (mg)
35.0
34.7
34.6
34.77
34.6
0.48
Pass
Audit points
Mid (mg)
57.3
57.2
56.8
57.10
57.8
1.21
Pass
High (mg)
103.2
104.0
103.7
103.63
105.2
1.49
Pass
Durag DR 300-40 ACA Result
Audit points (See note)
Test date
February 7, 2000
Challenge 1
Challenge 2
Challenge 3
Average
Reference value (by
MRI on July 14, 1999)
ACA%
Pass/Fail 1 5% Criteria
Range 1
A (ra mA)
14.74
14.72
14.77
14.74
14.53
1.47
Pass
Range 2
B (ra mA)
25.39
28.99
29.00
27.79
28.6
2.82
Pass
Range 3
C (ra mA)
62.23
62.18
62.14
62.18
61.42
1.24
Pass
Range 3
D (ra mA)
135.50
135.10
136.00
135.53
133.78
1.31
Pass
Note: Units shown in columns (ra mA) are ranged adjusted milliamps.
MRI-OPPT\\R4703-02-07 Revised wpd
5-53
-------
used in the M17 tests in order to determine the volume of gas exhausted over a sampling
cycle. This assumed that the exhaust volume was equal to the sampled volume, which is
true as long as there are no leaks in the dilution air line or sample line upstream of the
sample pump. The volume measured by the DGM was then compared with the volume
reported by the F904K. (The F904K only reported volume to the nearest liter.)
For this project a total of four SVAs were carried out. Each audit consisted of
three sampling cycles, but several three-cycle audits were done during some of the SVAs
since draft Procedure 2 does not specify how many should be done.
The four SVAs were carried out on the following dates:
Initial SVA July 12 to 18, 1999 During the initial correlation testing
Second SVA August 26 to 31, 1999 During first RCA
Third SVA November 16 to 20, 1999 During second RCA
Fourth SVA February 7, 2000 Prior to end of 6-month endurance test
period
Results for the four SVA are presented in Table 5-11 A, B, C, and D, and show that the
F904K met the criteria (5%) in all the SVAs.
5.3.4 Initial Correlation and RCA Test Results
Probably the most important objective of this project was to carry out the initial
correlation tests to determine if the data met the draft PS-11 criteria, and later to carry out
RCA tests to determine if those data met the draft Procedure 2 criteria, which is that 75%
of the data points must fall within a ±25% tolerance interval of the initial correlation
relation.
MRI-OPPT\\R4703.02-07 Revised.wpd ^ ^- .
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Table 5-11A. Initial SVA Results
Durag F904K
Date
7/12/99
7/13/99
7/14/99
7/15/99
7/16/99
7/17/99
7/18/99
Run no.
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
Reference F904K
volume (N liters)
95.3
94.9
95.4
F904K volume
(N liters)
95
95
95
Difference
(N liters)
0.3
-0.1
0.4
Average
93.8
93.5
93.6
95
95
95
-1.2
-1.5
-1.4
Average
94.8
93.6
92.8
95
94
94
-.02
-0.4
-1.2
Average
95.8
92.2
93.0
95
93
94
-0.8
-0.8
-1.0
Average
93.2
94.4
92.3
94
95
96
-0.8
-0.6
-3.7
Average
93.9
94.4
93.6
94
95
94
-0.1
-0.6
-0.4
Average
94.4
92.9
94.7
95
93
96
-0.6
-0.1
-1.3
Average
Percent of
reference (%)
0.3
-0.1
0.4
0.2
-1.3
-1.6
-1.5
-1.5
-0.2
-0.4
-1.3
-0.6
0.8
-0.9
-1.1
-0.4
-0.9
-0.6
-4.0
-1.8
-0.1
-0.6
-0.4
-0.4
-0.6
-0.1
-1.4
-0.7
Criteria 5%
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass
N liters refers to Normal liters (i.e., standard conditions of 20°C and 760 mm Hg).
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Table 5-11B. Second SVA Results
DuragF904K
Date
8/26/99
8/27/99
8/28/99
8/29/99
8/30/99
8/31/99
Run no.
1
2
3
Reference F904K
volume (N liters)
96.4
96.6
95.4
F904K volume
(N liters)
94
94
93
Difference
(N liters)
2.4
2.6
2.4
Average
1
2
3
96.5
97.2
96.8
95
95
94
1.5
2.2
2.8
Average
1
2
3
96.3
96
96.5
93
93
95
3.3
3
1.5
Average
1
2
3
99.1
99.1
96.9
96
96
95
3.1
3
1.9
Average
1
2
3
98.1
98.1
96.3
94
95
94
4.1
3.1
2.3
Average
1
2
3
95.6
97.7
98.5
93
94
95
2.6
3.7
3.5
Average
Percent of
reference (%)
2.5
2.7
2.5
2.6
1.6
2.3
2.9
2.2
3.4
3.1
1.6
2.7
3.1
3.0
2.0
2.7
4.2
3.2
2.4
3.2
2.7
3.8
3.6
3.4
Criteria 5%
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
N liters refers to Normal liters (i.e., standard conditions of 20°C and 760 mm Hg).
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Table 5-11C. Third SVA Results
Durag F904K
Date
11/16/99
11/17/99
11/18/99
11/19/99
11/20/99
Test no.
1
2
3
Reference F904K
volume (N liters)
96.7
96.7
97
1
2
3
99.1
94.7
95.5
F904K volume
(N liters)
93
94
93
94
92
94
1
2
3
94.2
95.1
92.8
93
94
92
Difference
(N liters)
3.7
2.7
4
Average
5.1
2.7
1.5
Average
1.2
1.1
0.8
Average
1
2
3
94.2
93.8
93.8
93
92
93
1.2
1.8
0.8
Average
1
2
3
94.1
96.6
96.8
91
95
94
3.1
1.6
2.8
Average
Percent of
reference (%)
3.8
2.8
4.1
3.6
5.1
2.9
1.6
3.2
1.3
1.2
0.9
1.1
1.3
1.9
0.9
1.3
3.3
1.7
2.9
2.6
Criteria 5%
Pass/Fail
Pass
Pass
Pass
Pass
Pass
N liters refers to Normal liters (i.e., standard conditions of 20°C and 760 mm Hg).
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Table 5-1 ID. Fourth SVA Results
Durag F904K
Date
2/7/00
Test no.
1
2
3
Reference F904K
volume (N liters)
113.9
112.6
114.2
F904K volume
(N liters)
112
112
113
Difference
(N liters)
1.9
0.6
1.2
Average
Percent of
reference (%)
1.7
0.5
1.1
1.1
Criteria 5%
Pass/Fail
Pass
N liters refers to Normal liters (i.e., standard conditions of 20°C and 760 mm Hg).
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The initial correlation tests were carried out on July 15-19, 1999, just prior to the start
of the 6-month endurance test period on July 20, 1999. The first RCA was carried out
August 27 to August 30,1999. The second RCA was carried out on November 17 to 20,
1999. Results for each of these tests are described in the following three sections:
5.3.4.1 Initial Correlation Test Results and Correlation Relations
5.3.4.2 First RCA Test Results and Comparison with Initial
Correlation Relations
5.3.4.3 Second RCA Test Results and Comparison with Initial
Correlation Relations
5.3.4.1 Initial Correlation Test Results and Correlation Relations
The initial correlation tests consisted of 15 runs, but only 12 runs were used for
determining the initial correlation relations because 3 of the runs (Run 10, 11 and 12)
appeared to be outliers. It was discovered that the facility was burning a very unusual coal
("met coal") during these 3 runs, as was explained in Section 5.2.1.4. These runs were
therefore not included in the statistical calculations specified in draft PS-11. (However, the
later results from the RCA tests indicated that these three data points probably should not
have been excluded, and they have been included in the later discussion of the results and
graphs from the first and second RCA.)
The start of each test run was coordinated with the beginning of a sampling period for
the F904K. Since the time required for M17 port changes was short (2-3 min), port change
times were not removed from the PM CEMS test run averages. The average of the PM-
CEM readings was computed after each run for comparison with the average of M17
results for each run. Those data are shown in Table 5-12 and were used to develop the
correlation relations, as prescribed in draft PS-11, Section 12.3.
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Table 5-12. Tabulation of Data from Initial Correlation Tests
Tabulation of Data for ESC P5B and Durag 300-40
Run
no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Concentration*
(mg/acm)
26.13
27.75
32.28
11.61
13.92
14.46
3.03
2.68
3.20
16.33
10.52
9.42
15.38
8.75
18.65
ESC P5B
response (ma)
11.40
11.76
13.88
9.60
10.01
10.54
5.87
5.78
6.00
12.00
9.45
8.97
13.16
9.57
14.50
DR300-400 response
(Range Adj: ma)
20.06
21.62
27.83
15.45
17.22
19.36
6.42
6.44
7.28
20.93
15.80
14.32
24.54
15.68
30.88
Not included in
initial correlation
relations
* Average particulate concentration measured by M17, converted to units
consistent with PM-CEMS (See Table 5-3A)
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Table 5-12 (Continued)
Tabulation of Data for Durag F904K
Run no.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Concentration*
(mg/dscm)
39.5
41.8
49.5
17.2
21.1
21.8
4.6
4.0
4.8
24.4
16.1
14.3
23.3
13.1
28.4
F904K Response
(ma)
11.74
11.71
14.49
8.58
9.24
9.98
5.04
5.09
5.21
10.48
8.07
8.05
10.95
8.08
12.27
Not included in
initial correlation
relations
*Average particulate concentration measured by M17, converted
to units consistent with PM-CEMS (See Table 5-3A)
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Polynomial and linear correlation equations were generated for each PM-CEM. The
correlation for each PM-CEM was done in units consistent with the results of the
PM-CEM's measurements. The ESC P5B and Durag DR 300-40 correlations were done in
units of mg/acm, while the Durag F904K correlation was done in units of mg/dscm. The
regression equations and corresponding correlation coefficients (r) are listed below. The
graphs for the linear correlations are shown in Figures 5-3A, B, and C. (All the CEM data
for each run are tabulated in Volume 2, Appendix F, and statistical results are shown in
Volume 2, Appendix G.) Emission limits for the facility are shown on the Figures 5-3 A,
B, and C, in units consistent with those measured by the PM-CEMS, as a horizontal dashed
line (i.e., 17 mg/acm or 25.5 mg/dscm).
ESC P5B:
Polynomial Equation (r = 0.970)
mg/acm = -0.098 * mA2 + mA - 16.06
Linear Equation (r = 0.964)
mg/acm = 1.89 * mA - 7.50
(See Figure 5-3A)
Durag DR 300-40:
Polynomial Equation (r = 0.972)
mg/acm = -0.018 * mA2 + 1.33 * mA - 5.29
Linear Equation (r = 0.955)
mg/acm = 0.71 * mA - 0.82
(See Figure 5-3B)
Durag F904K:
Polynomial Equation (r = 0.988)
mg/dscm = -0.11 * mA2 + 5.12 * mA -19.13
Linear Equation (r = 0.988)
mg/dscm = 3.37 * mA - 12.38
(See Figure 5-3C)
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ESC P5B - Linear
25 n
20
0
y=1.89x-7.50
Emission Limit = 17 mg/acm
6
—i—
8
10
mA
12
14
Figure 5-3A. Linear Regression for ESC Light Scatter—P5B
• Initial Corr.
ylin
Cllow
Clhigh
Tl low
Tl high
16
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Durag DR 300-40 - Linear
30
25
20
CB
10
y=0.71x-0.82
Emission Limit = 17 mg/acm
12
16 20
Range adjusted mA
24
28
Figure 5-3B. Linear Regression for Durag Light Scatter—DR 300-40
Initial Corr.
ylin
Cllow
Clhigh
Tl low
Tl high
32
MRI-OPPTOR4703-02-07 Revised.wpd
5-65
-------
Durag F904K - Linear
oo -
Qn
ou
25
on
E
u
15 -
•in
1U
n
y = 3.37x - 12.38
,''••'
s .'
*''>'' /
/.•••//.••;
Emission Limit = 25.5 mg/dscm _, ' ,• .s ^-' ,
' +'' / -' ^'
/ .*S\.-' ''
^' •' / •* ^
. S ' / , ' /*
S .'"jr.''' /
S ' ' 's^. "' S^
'' >'//''' ''
,'''+s'ss''
'' ..'•/$''' /
''.. ••:/!••+,''
/' •••'/'•' S
S " S + *
s .' / ,' *'
s' ''/.'' ''
' '-' / • /
X* sr * S
>' / >' '
•' / >' '
''<<••'''''
«'•••/'
/
• Initial Corr.
ylin
ail-UAl
ahinh
Tl low
Tl high
8 10
mA
12
14
Figure 5-3C. Linear Regression for Durag Beta Gauge—F904K
MRI-OPPT\\R4703-02-07 Revised.wpd
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The test (specified in Section 18.2.3 of draft PS-11) to determine the best correlation
fit at the 95% confidence level revealed: (1) for the ESC P5B the linear regression gave
the best fit, (2) for the Durag DR 300-40 the polynomial regression gave the best fit, and
(3) for the Durag F904K the linear regression gave the best fit. (Details of these
calculations are presented in Appendix G.)
Since the polynomial equation gave the best fit for the DR 300-40, a check to
determine the location of the maxima was done. This check was carried out by taking the
derivative of the equation, setting it equal to zero, and solving for mA. The maxima check
showed that the maxima occurred at a range adjusted mA value of 36.9. Although the
highest average mA reading obtained during the initial correlation test was only 31, 1-min
average readings of greater than 36.9 did occur during the testing. Therefore, the
polynomial equation for the DR 300-40 was not appropriate, so the linear regression
equation was used.
The PS-11 performance criteria for the selected correlation equations are presented in
Table 5-13 and show that (1) the ESC P5B met all three correlation test performance
specifications, (2) the Durag DR 300-40 met two of the three correlation test performance
specifications, and (3) the Durag F904K met all three correlation test performance
specifications.
The Durag DR 300-40 PM-CEM had a confidence interval at the emission limit
(10.4%) that was just outside the performance specification (10%). However, if the
polynomial equation had been used, which gave the better fit but contained a maxima, the
DR 300-40 would also have met all three performance specifications. Therefore, all three
PM-CEMS were considered to have met all three performance specifications.
Although the initial correlation data met the criteria for confidence interval (CI)
percentage (< 10%) and tolerance interval (TI) percentage (< 25%), the same was not true
for the first RCA data, as discussed in the next section. It is important to point out that
these percentages are calculated using the emission limit; therefore a facility's emission
limit has a direct impact on the TI % and CI % and, thus, a direct impact on whether or not
the criteria are met.
MRI-OPPT\\R4703-02-07 Revised.wpd
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-------
Table 5-13. Selected Correlation Equation Values Versus Performance Criteria
Criterion
Correlation
Coefficient (r)
Confidence Interval
(Cl) at Emission Limit
(See note)
Tolerance Interval
(Tl) at Emission Limit
ESC P5B
0.964
9.20%
17.94%
Durag
DR 300-40
0.955
10.42%
20.20%
Durag F904K
0.988
5.37%
10.73%
Criteria
limit
>0.85
<10%
< 25%
Note: This facility's emission limit is 0.02 lb/106 BTU. This limit was converted
to concentration units of 17.0 mg/acm and 25.5 mg/dscm in order to
determine the confidence interval and tolerance interval at the emission
limit. However, the conversion to concentration units is not exact since
the calculation is dependent on percent O2 and percent H2O, as well as
temperature and pressure, which are variable.
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5.3.4.2 First RCA Test Results and Comparison with Initial Correlations
The primary purpose of the first RCA/AC A test was to compare the RCA test results
with the initial correlations discussed above. That is, the initial correlation tests were used
to develop graphs (and confidence/tolerance intervals) which relate instrument response
(e.g., ma) to paniculate concentration (e.g., mg/acm). For the RCA tests, the instrument
response and the measured particulate concentration can be plotted on the initial correlation
graphs. Ideally, all of the RCA data would fall within the tolerance interval of the initial
correlation graph. However, EPA's draft Procedure 2 specifies that at least 75% of the
RCA data (i.e., 9 of 12 runs) must fall within a tolerance interval of ± 25% of the emission
limit value, drawn as two lines parallel with the initial correlation line.
The data from the first RCA test are presented in Table 5-14, and these data have been
plotted on the graphs developed from the initial correlation tests as shown in Figures 5-4A,
B, and C (the 12 RCA runs are shown as triangles). Examination of Figures 5-4A, B, and
C clearly shows that for each of the three PM-CEMS, no more than 7 of the 12 RCA tests
fell within the ± 25% tolerance interval.
These results were unexpected, especially since it occurred for all three PM-CEMS.
Preliminary review of all the procedures and data did not provide an explanation for these
results and the failure to meet the RCA criteria in draft Procedure 2.
Draft Procedure 2 does provide procedures to follow if a PM-CEMS correlation fails
to meet the RCA criteria. The first step is to combine the RCA data with the initial
correlation data, and the combined data are then used to perform the mathematical
calculations defined in PS-11 for development of a new PM-CEMS correlation, including
examination of alternate forms of the correlation relation (e.g., polynomial). If results for
the combined data meet the PS-11 criteria, the revised correlation is to be used. This
combining of the data was investigated for this project, with results for the best-fit equation
shown in Table 5-15.
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-------
Table 5-14. Tabulation of Data from First RCA Test
Tabulation of First RCA Data for ESC P5B and Durag 300-40
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
Concentration
(mg/acm)
28.09
1.90
2.54
2.59
9.77
8.29
11.30
22.12
24.05
26.62
12.97
19.10
ESC P5B response
(ma)
14.66
6.38
6.41
6.40
8.51
8.35
7.70
10.34
11.23
11.92
9.07
10.17
DR300-40 response
(Range Adj: ma)
28.77
6.11
6.59
6.75
11.72
11.92
10.80
16.22
18.60
21.53
12.62
14.59
Tabulation of First RCA Data for Durag F904K
Run no.
1
2
3
4
5
6
7
8
9
10
11
12
Concentration
(mg/dscm)
43.05
2.90
3.95
4.00
14.80
12.65
17.40
33.65
36.60
41.00
19.45
28.65
F904K response
(ma)
14.20
5.04
5.07
4.99
7.30
6.99
6.88
9.71
10.71
11.65
7.57
8.42
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-------
ESC P5B - Linear
Emission limit = 17 mg/acm
mA
* Init. Corr.
A RCA#1
• 3 MET coal runs
Correlation Line
25% Tl
+ 25% Tl
Figure 5-4A. Comparison of Initial Correlation Equation with the First RCA Test Data for ESC-P5B
MR1-OPPTOR4703-02-07 Revised.wpd
5-73
-------
Durag DR 300-40 - Linear
Emission limit = 17 mg/acm
• Init. Corr.
A RCA#1
• 3 MET coal runs
Correlation Line
25% Tl
+ 25% Tl
Range Adjusted mA
Figure 5-4B. Comparison of Initial Correlation Equation with First RCA Test Data for DR300-40
MR1-OPPTOR4703-02-07 Revised.wpd
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-------
Durag F904K - Linear
o
I
Emission limit = 25.5 mg/dscm
mA
• Init. Corr.
A RCA*B
• 3 MET coal runs
Correlation Line
25% Tl
+ 25% Tl
Figure 5-4C. Comparison of Initial Correlation Equation with First RCA Test Data for F904K
MR1-OPPT\\R4703-02-07 Revised.wpd
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Table 5-15. Correlation Equation Results Using Combined Data from Initial
Correlation Tests and First RCA Tests (24 Total Data Points)
Criterion
Correlation
Coefficient (r)
Confidence Interval (Cl)
at Emission Limit
(See note)
Tolerance Interval (Tl)
at Emission Limit
ESC
P5B
(Linear)
0.87
12.0%
36.9%
Durag
DR 300-40
(Polynomial)
0.85
14.8%
39.8%
Durag
F904K
(Linear)
0.92
9.6%
30.5%
Criteria limit
>0.85
<10%
< 25%
Note: This facility's emission limit is 0.02 lb/106 BTU. This limit was converted to concentration
units of 17.0 mg/acm and 25.5 mg/dscm in order to determine the confidence interval and
tolerance interval at the emission limit. However, the conversion to concentration units is
not exact since the calculation is dependent on percent O2 and percent H2O, as well as
temperature and pressure, all of which are variable.
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None of the three PM-CEMS met all of the draft PS-11 criteria for the combined data.
Although all three PM-CEMS met the correlation coefficient criterion (> 0.85), only one
met the confidence interval criterion (< 10%), and none met the tolerance interval criterion
(< 25%). (More details on these calculations and associated graphs are given in Volume 2,
Appendix G-2.)
In circumstances where combined data, as discussed above, do not meet the PS-11
criteria, Procedure 2 specifies that a new PM-CEM correlation must be developed based on
revised data, which may include the RCA test results but not include the original
correlation data.
Therefore, the first RCA test data were evaluated per the calculation procedures in
PS-11. The results for the best-fit equations (polynomial) are given in Table 5-16, which
shows that only the Durag beta gauge (F904K) met all three criteria. The other two
PM-CEMS met the correlation coefficient criterion but did not meet the confidence
interval and tolerance interval criteria. (More details on these calculations and associated
graphs for the first RCA are given in Volume 3, Appendix G-3). Again, it should be noted
that meeting these criteria is a function of the facility's emission limit.
As mentioned earlier, the fact that the results from the first RCA were considerably
different from the initial correlation data and did not meet the draft Procedure 2 criteria,
was unexpected and caused considerable concern, especially in view of the fact that the
initial correlation relation met all the draft PS-11 criteria and all three PM-CEMS had been
maintained in proper working order (e.g., the two light scatter PM-CEMS passed AC A
criteria and the beta gauge passed the sample volume audits). Therefore, the test scenario
for the planned second RCA was modified in an effort to obtain additional data that might
explain the reason(s) for the non-agreement between the initial correlation and the first
RCA, as described in the next section.
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Table 5-16. Correlation Equation Results Using First RCA Test Data Only
(12 Data Points)
Criterion
Correlation
Coefficient (r)
Confidence
Interval (Cl) at
Emission Limit
Tolerance
Interval (Tl) at
Emission Limit
ESC
P5B
(Polynomial)
0.97
1 1 .6%
26.5%
Durag
DR 300-40
(Polynomial)
0.97
1 1 .5%
26.6%
Durag
F904K
(Polynomial)
0.98
9.3%
21 .2%
Criteria limit
>0.85
<10%
< 25%
Note: This facility's emission limit is 0.02 lb/106 BTU. This limit was converted to concentration
units of 17.0 mg/acm and 25.5 mg/dscm in order to determine the confidence interval and
tolerance interval at the emission limit. However, the conversion to concentration units is
not exact since the calculation is dependent on percent O2 and percent H2O as well as
temperature and pressure, all of which are variable.
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5.3.4.3 Second RCA Test Results and Comparison with Initial Correlations and
First RCA Test Results
The primary goal of the second RCA was to obtain data for direct comparison with
the initial correlations and the first RCA test results. However, it was decided to replace
one of the dual traversing trains (previously used in the initial correlation and first RCA
tests) with a single-point train. Only the traversing train data (referred to as Train A) were
used for comparison with the initial correlation relations and first RCA test results.
A second change in the test plan for the second RCA was that some runs would
purposely be carried out at reduced boiler load. All the runs in the initial correlation tests
and first RCA tests had been done at near full boiler load with a steam production rate of
268-291 K Ib/hr. In RCA #2, the low load (LL) runs had steam production rates of
200-210 K Ib/hr. Some runs were done at variable load (VL) where steam production was
increasing or decreasing between the low load and full load steam rates.
As stated above, the primary purposes of the second RCA test was to compare the test
results with the initial correlations developed previously from the initial correlation testing
and with the first RCA test results. Results from the second RCA test (traversing Train A)
are tabulated in Table 5-17 and have been plotted (red dots) on the graphs of the initial
correlation results (black diamonds) along with results from the first RCA (blue triangles),
as shown in Figure 5-5 A, B, and C and discussed below. (Detailed data for the second
RCA test are contained in Volume 4, Appendices F and G.)
Figures 5-5A, B, and C show the initial correlation data (black diamonds) and the best
fit equation (linear) along with a ± 25% tolerance interval, and also show the data points
from both the first and second RCA. The initial correlation data met all the draft PS-11
criteria as discussed previously. However, data for three runs of the initial correlation were
excluded since those runs appeared to be outliers, as was discussed in Section 5.3.4.1.
Those 3 data points are included in Figures 5-5A, B, and C (green diamonds).
MRJ-OPPT\\R4703-02-07 Revised, wpd
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Table 5-17. Tabulation of Data from Second RCA Test
Tabulation of Second RCA Data for ESC P5B and Durag 300-40
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
Concentration
(mq/acm)
25.4
19.1
18.4
10.3
13.6
26.6
57.6
36.7
35.6
12.2
24.1
38.3
ESC P5B
response (ma)
11.69
10.06
9.60
9.42
7.95
11.00
13.44
10.53
11.08
7.54
8.87
12.74
DR300-40 response
(Range Adj: ma)
22.41
18.64
17.77
17.32
13.31
22.72
23.69
16.92
17.76
11.07
14.90
28.30
Concentration measured by M17 Traversing Train (Train A) except Run 33 used
average for the two traversing trains.
Tabulation of Second RCA Data for Durag F904K
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
Concentration*
(mq/dscm)
37.8
27.8
27.2
15.3
19.7
38.5
80.2
51.7
49.5
17.5
34.7
55.4
F904K Response
(ma)
NA-probe broken
NA-probe broken
NA-probe broken
NA-probe broken
7.14
10.28
14.80
11.15
11.34
6.35
7.86
10.92
* Concentration measured by M17 Traversing Train (Train A) except
Run 33 used average for the two traversing trains.
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Figures 5-5A, B, and C include the results from the first RCA tests (blue triangles) and
show that no more than 7 of the 12 runs in the first RCA test fell within the ± 25%
tolerance interval of the initial correlation (EPA draft Procedure 2 specifies that 9 of 12
runs (75%) must fall within a ± 25% tolerance interval of the initial correlation). Only 1 of
the 12 runs in the second RCA test fell within this ± 25% tolerance interval.
Therefore, the results from the second RCA were compared with results from the first
RCA alone. That is, the first RCA data had been used for development of separate new
correlations as discussed previously in Section 5.3.4.2. Even though these correlations did
not meet the confidence interval and tolerance interval criteria for two of the PM-CEMS,
they were used to evaluate the data from the second RCA.
As shown in Figures 5-6A, B, and C, no more than 6 of the 12 runs from the second
RCA fell within a ± 25% tolerance interval of the first RCA correlation relation. The next
section of this report presents an investigation of possible reasons for the non-agreement of
the results from both the first and the second RCA.
5.3.5 Investigation of Reason(s) for Non-agreement of RCA Results
It was originally recognized that the location of the PM-CEMS very near the outlet of
the baghouse compartments was not the most desirable location since it only minimally
met the PS-11 guidance (i.e., only two duct diameters downstream of a 90° bend).
However, it was the only possible location at this facility to install three PM-CEMS and a
moisture monitor. The location had a potential for particulate stratification, but this was
not thought to be a serious problem since much of the large particulate would have been
removed from the flue gas by the mechanical dust collector and dry SO2 absorber upstream
of the baghouse. It was also thought that if particulate stratification existed it would be
constant.
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ESC P5B - Linear
60
50
VL = Variable Load
LL = Low Load
Emission limit = 17 mg/acm
mA
• Init. Corr.
A RCA#1
• 3 MET coal runs
• RCA#2
Correlation Line
25% Tl
+ 25% Tl
Figure 5-5A. ESC-P5B Initial Correlation and all RCA Data
MRI-OPPTOR4703-02-07 Revised.wpd
5-85
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Durag DR 300-40 - Linear
60
50
40
30
10
-10
VL = Variable Load
LL = Low Load
LL
y = 0.71x-0.82
LL
VL0
Emission limit = 17 mg/acm
12
16
20
24
28
* Init. Corr.
A RCA#1
• 3 MET coal runs
• RCA#2
Correlation Line
25% Tl
+ 25% Tl
32
Range adjusted mA
Figure 5-5B. DR300-40 Initial Correlation and all RCA Data
MRJ-OPPT«R4703-02-07 Revised.wpd
5-87
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Durag F904K - Linear
90
80
70
60
50
o»
-10
VL = Variable Load
LL = Low Load
LL
y = 3.37x- 12.38
LL
10
12
14
mA
Figure 5-5C. F904K Initial Correlation and all RCA Data
Init. Corr.
RCA#1
3 MET coal runs
•
A
Correlation Line
25% Tl
+ 25% Tl
16
MRJ-OPPTOR4703-02-07 Revised.wpd
5-89
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ESC P5B - Polynomial
VL = Variable Load
LL = Low Load
y = -46.95 + 9.46x - 0.29xA2
Emission limit = 17 mg/acm
A RCA#1
• RCA #2
Correlation
Curve
25% Tl
+ 25% Tl
mA
Figure 5-6A. ESC-P5B Correlation for First RCA, and Comparison with Data from Second RCA
MRI-OPPT\\R4703-02-07 Revised.wpd
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Durag DR 300-40 - Polynomial
VL = Variable Load
LL = Low Load
y = -16.11 + 3.04x - 0.051xA2
Emission limit =17 mg/acm
RCA#1
• RCA #2
Correlation
Curve
25% Tl
+ 25% Tl
Range Adjusted mA
Figure 5-6B. DR300-40 Correlation for First RCA, and Comparison with Data from Second RCA
MR1-OPPT\\R4703-02-07 Revised.wpd
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Durag F904K - Polynomial
u
(A
I
mA
A RCA #1
• RCA #2
Correlation
Curve
25% Tl
+ 25% Tl
Figure 5-6C. F904K Correlation for First RCA, and Comparison with Data from Second RCA
MRI-OPPT\\R4703-02-07 Revised.wpd
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That is, stratification would not be a problem if the ratio of the paniculate
concentration at any single point in the duct was constant, relative to the average
concentration in the duct. If this ratio was constant, the concentration that existed at any
single point (i.e., PM-CEMS location) would be proportional to the average concentration
as measured by a traversing train.
Investigation of possible reasons for why the RCA results did not meet the draft
Procedure 2 criteria relative to the initial correlation test results is discussed in the
following subsections and included the investigation of:
• Differences in velocity distribution
• Spikes in PM-CEMS response and causal relation between baghouse cleaning
cycle and operation/location of perturbing device
• Particulate concentration ratio for single point train versus traversing train
It should be noted that the results from each RCA showed similar patterns for all three
PM-CEMS (i.e., higher emissions relative to PM-CEMS response). This indicated that
changes in paniculate characteristics (e.g., size distribution, etc.) probably were not the
cause of non-agreement of RCA results, since beta-gauges are not believed to be affected
by such changes.
5.3.5.1 Velocity Distribution
The initial correlation test data showed that the velocity distribution across the duct
was highly skewed, with the highest velocity toward the duct wall opposite the M17 test
ports and the PM-CEMS (see Figure 2-1). An example of this skewed velocity distribution
is shown in Figure 5-7. Velocity measurements (made through the middle sampling port
C) show that the velocity ranges from nearly 1800 meters/minutes (m/min) down to only
200-300 m/min nearest the M17 sampling ports (i.e., Point Cl).
MR]-OPPT\\R4703-02-07 Revised.wpd
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2200
2000-
1800-
1600-
1400-
1200-
1000-
800-
600-
400-
200-
0
ICAL
RCA
Back
side
of duct
C5
C4
C3
Port/Point
C2
C1
ICAL Runs 13-15 and 19-24
RCA Runs 1 and 5-12
Front
side
of duct
990763-1
Figure 5-7. Velocity at Traverse Points through Port C—ICAL vs. First RCA
MR1-OPPT\\R4703-02-07 Revised wpd
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Data like those in Figure 5-7 also show that at the points of highest velocity (C5-C3)
the velocity measured during the initial correlation tests was somewhat higher than that
measured during the first RCA. This led to a suspicion that the lower velocity in the first
RCA test might also be associated with a change in particulate stratification. If so, this
might be the reason why the results from the first RCA did not fall within the tolerance
interval of the initial correlation data. This was investigated further in the second RCA
test, where particulate stratification was measured with a single point and traversing trains,
at different velocities (i.e., different loads) as discussed in Section 5.3.5.4.
5.3.5.2 Spikes in PM-CEMS Response
It had been observed during all of the tests that there were spikes in the response of the
two light scatter PM-CEMS (ESC-P5B and Durag DR300-40). It was also observed that
the spikes were much larger when the perturbing device was open in order to obtain higher
concentrations. Moreover, the spikes occurred every 24 minutes with a 4 minute offset
between the spike for the ESC-P5B and the DR-300-40. This phenomenon is shown in
Figures 5-8A and 5-8B.
Figure 5-8A for November 15 shows the response for the two PM-CEMS over time,
when the perturbing device was closed so particulate concentration was low (about
2 mg/acm). The peaks from both monitors occur at the same time and represent relatively
small changes in particulate concentration (approx. 0.20 mg/acm). These peaks are likely
caused by the brief puff of particulate when a cleaned compartment is first opened.
Figure 5-8B for November 17 shows the response of the two PM-CEMS when the
perturbing device was open so particulate concentration was high (about 12 mg/acm). The
peaks are much greater (about 4-6 mg/acm) and occur every 24 minutes, with the peak for
the ESC-P5B occurring 4 minutes after the peak for the DR300-40.
MR1-OPPT\\R4703-02-07 Revised, wpd
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I
i
PM-CEM Response
Converted to (mg/acm)
O
o
t
OO
f
n
cr
en
v
ore
o
en
n
a
1
-------
PM-CEM Response
Converted to (mg/acm)
1
f
oo
03
o-
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so
aro
re
re
O
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-------
The normal behavior of a baghouse is that there is a PM spike from a freshly cleaned
compartment for a brief time until the dust cake on the compartment bags is re-established.
However, this is not consistent with what is shown in Figure 5-8B. Moreover, the spike is
too large to be attributed to the brief spike that occurs after a compartment cleaning.
Rather, the phenomena is caused by the baghouse cleaning cycle and its effect on the
particulate from the perturbing device, as explained below.
5.3.5.3 Effect of Baghouse Cleaning Cycle on Spikes in PM-CEMS Response
In order to understand the cause of the peaks in the response of the two light-scatter
type PM-CEMS, it is necessary to understand the baghouse geometry, the cleaning cycle,
and the location of the perturbing device.
Figure 5-9 is a schematic top view of the baghouse outlet duct and outlet ducts from
each baghouse compartment. There are six baghouse compartments, and the outlet from
each is connected to the common outlet duct. The ducts from each compartment contain a
damper (valve) that closes whenever that compartment undergoes a cleaning cycle. Each
compartment is cleaned for 4 minutes, so the cycle for all six compartments is 24 minutes.
Figure 5-9 also shows the location of the perturbing device, a 6-in. diameter pipe
which is connected into the bottom of the baghouse outlet duct. The other end of this pipe
is connected to the inlet duct to the baghouse. There is a butterfly valve in the 6-in.
diameter pipe which provides a means of regulating the amount of particulate that bypasses
the baghouse, flowing directly from the inlet duct to the outlet duct. The purpose of this
bypass was to increase the PM concentration, simulating a broken bag. However, as
mentioned in Section 2.1, the location of the perturbing device may not have been
sufficient to allow complete mixing with the baghouse effluent prior to the location of the
PM-CEMS.
MR1-OPPT\\R4703-02-07 Revised. wpd
<-
-------
Compartment
No. 6
Compartment
No. 4
Compartment
No. 2
90° elbow
where flow turns
downward
6" perturbing
device (at bottom
of baghouse
exhaust duct)
PM GEMS
Sampling Ports
located on this
wall, below
outlet duct
Compartment
No. 5
Compartment
No. 3
Compartment
No. 1
Figure 5-9. Top View of Baghouse Outlet Duct
MRI-OPPT\\R4703-02-07 Revised.wpd
5-103
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"Dirty" gas passing through the perturbing device has a very high paniculate
concentration, probably 100 to 1,000 times the concentration in the baghouse outlet ducts.
The intent is for this dirty gas to mix thoroughly with the clean gas in the baghouse outlet
duct prior to the location of the PM-CEMS. This is most difficult to achieve when
compartment 5 or 6 undergoes cleaning. When the compartment 5 damper closes at the
beginning of its cleaning cycle, the clean gas from the open compartment 6 pushes the
higher particulate gas in the common outlet duct toward the compartment that is closed
(No. 5), causing a sudden rise in response of the Durag DR 300-40 located in the same side
of the duct until the air flow pattern becomes stable. Four minutes later, the No. 5 damper
reopens and the opposite damper (No. 6) closes, pushing the higher particulate gas in the
opposite direction, toward compartment 6, and causing a peak in the response of the ESC
P5B located on the other side of the duct until the air flow pattern becomes stable again.
This phenomenon was observed during all the tests when the bypass was open and
helped to explain the peaks in the PM-CEMS response and the offset between those peaks.
This analysis shows that the location of the PM-CEMS relative to the location of the
perturbing device is just as important as their location relative to the outlet of the control
device. That is, if a perturbing device is used to bypass gas around a control device in
order to increase outlet particulate concentration, then the PM-CEMS must be located far
enough downstream of the point where the low and high concentration gases come together
for them to become well mixed before the gas reaches the PM-CEMS (and the Ml7
sampling points). Also, devices which can introduce dilution air or otherwise disturb the
air flow pattern must be well upstream of the PM-CEMS sampling location.
5.3.5.4 Particulate Concentration Ratio for Single Point Train versus Traversing
Train
Data for the single point train (B) and traversing train (A) used in the second RCA
tests are presented in Table 5-18, including the calculated ratio for the two trains in each
MRI-OPPT\\R4703-02-07 Revised.wpd
C
-------
Table 5-18. Tabulation of Data for Single Point Train Versus Traversing Train
Run no.
31
32
33
34
35
36
37
38
39
40
41
42
Load
High
High
Precision run
High
High
High
Low
Low
Low
Variable
Low — High
Variable
B-Single point
(mg/dscm)
23.7
17.5
NA
16.7
11.2
22.6
51.1
33.5
34.1
14.7
20.0
32.8
A-Traversing
(mg/dscm)
37.8
27.8
NA
15.3
19.7
38.5
80.2
51.7
49.5
17.5
34.7
55.4
Ratio (B/A)
0.627
0.630
—
1.092
0.569
0.587
0.637
0.648
0.689
0.840
0.576
0.592
MR1-OPPTOR4703-02-07 Revised.wpd _ , ,, _
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run. These data are also presented graphically in Figure 5-10, and show that the ratio was
essentially constant, covering a narrow range of ratios from 0.569 to 0.689 over a wide
range of paniculate concentration, except for 2 of the 11 runs (Runs 34 and 40). It can be
concluded from these results that the paniculate is stratified (i.e., single point values are
different from the traversing train values), but that the stratification was essentially
constant except in 2 runs (Runs 34 and 40) (i.e., the ratio varies over a narrow range in
most runs, even for a wide range in paniculate concentration). This indicates that a change
in boiler load did not have much effect on paniculate stratification.
All of the initial correlation tests and first RCA tests were done at full load (steam
flowrates of 268-291 K Ib/hr). In the second RCA, six of the tests were done at full load
while the other six were done at reduced or variable load (see Volume 4, Appendix A).
Results for five of the six full load tests done in RCA #2 fell within the ± 25% tolerance
interval of the RCA #1 correlation relation, with stratification ratios varying over a narrow
range of 0.57 to 0.63. The other high load test (Run 34) had a higher ratio of 1.09, and the
results for that run fell within the ± 25% tolerance interval of the initial correlation relation.
Thus, a change in the stratification ratio may be a possible explanation for why the RCA #1
correlation was different than the initial correlation.
Five of the six reduced load tests had stratification ratios about the same as the full
load tests, but fell outside (above) the ± 25% tolerance interval of both the initial
correlation relation and RCA #1 correlation relation. This suggests that the two light
scatter monitors responded differently to the paniculate at reduced load as compared to
high load. If this was due to changes in the light scatter characteristics of the paniculate
(e.g., different particle size distribution), then light scatter type PM-CEMS may not be
appropriate for sources that change load or otherwise make changes that affect light scatter
characteristics of the paniculate.
The above represents a possible explanation for why the data for the light scatter
monitors at the five reduced load tests did not match either of the two tolerance intervals,
but it does not explain why the results for the F904K beta gauge also did not fall within
MRI-OPPT\\R4703-02-07 Revised, wpd j- «
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MRI-OPPT\\R4703.fl2-07 Revised wpd
Figure 5-10. Particulate Ratio vs. Concentration
5-107
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either tolerance interval since beta-gauges are not supposed to be susceptible to changes in
particle characteristics. However, the reduced load tests did involve lower duct velocities,
which affect the isokinetic sampling rate of the beta gauge. The beta gauge samples at a
constant rate and was installed to sample near isokinetically at full load (i.e., the normal
operating condition). Therefore, at reduced load it samples at a rate higher than isokinetic,
which could produce a low bias in the concentration of particulate sampled by the beta
gauge, and thus a lower than expected response.
It should be noted that a difference in the particle size distribution between the full
load and low load tests may have been caused by the perturbing device rather than an
actual change in the process. That is, the gas in the baghouse inlet duct must make a 90°
change in direction in order to enter the perturbing device (6" pipe). At full load (high duct
velocity), it is more difficult for larger particles to make this change in direction; but at low
load (lower duct velocity), more of the larger particles could enter the perturbing device
(i.e., the particulate size distribution at low load would shift to more large particles). This
is consistent with the discussion in the above two paragraphs, but no particle size
measurements were done in any of the tests.
5.3.5.5 Summary
Results from the second RCA confirmed that the velocity distribution is highly
skewed, and that the particulate concentration was stratified but was relatively constant
over 9 of 11 runs done in RCA #2. Investigation of spikes in the response of the two light-
scatter PM-CEMS certainly indicated that there is short-term variability in the particulate
stratification, but such variability is apparently dampened out over the M17 sampling
periods of 75 to 100 min. This dampening of short-term variability is evidenced by the
narrow range of stratification ratios measured during 9 of the 11 runs in RCA #2 and by the
fact that the dual M17 trains used in the initial correlation tests and RCA #1 tests met all of
the precision and bias criteria per draft Procedure 2.
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The primary purpose of the RCA #2 tests was to obtain data on particulate
stratification at full load and reduced load in order to try to determine why the RCA #1
results did not meet the draft Procedure 2 criteria relative to the initial correlation relation.
The discussion in Section 5.3.5.4 provides a possible explanation for that finding, but it
does not change the fact that the RCA #1 and RCA #2 test results did not meet the draft
Procedure 2 criteria.
It is clear that the location of the PM-CEMS was less than ideal, but the location
selected was the only suitable location available at this facility. This location minimally
met the guidance in draft PS-11. Thus, the inability to meet the draft Procedure 2 criteria in
the two RCA tests may have been due, at least in part, to the location of the PM-CEMS
rather than the PM-CEMS themselves.
The low load tests done in RCA #2 do indicate possible limitations in the PM-CEMS.
That is, if changes in process operating conditions cause changes in particle size
distribution, the light scatter PM-CEMS may respond differently to the same particulate
concentration. Further, if changes in process operating conditions cause changes in flue
gas flowrate, then extractive PM-CEMS, that do not maintain isokinetic sampling, may
also respond differently to the same particulate concentration.
One peer reviewer of the report commented that the data suggest that several different
correlations exist, but except for the 3 "met coal" runs, there was no indication of changes
in the coal or process operating conditions between the 3 sets of tests that would produce
different correlations.
One peer reviewer seemed convinced that the non-agreement of the two RCA results
with the initial correlation was entirely due to the location of the PM-CEMS relative to the
baghouse outlet and perturbing device (i.e., stratification). But, conversely, another
reviewer stated that he did not think, based on the information shown, that stratification at
the PM-CEMS location could be the cause of the non-agreement. These peer review
comments and the discussion presented above demonstrate that no definite conclusion can
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be made as to the cause of the non-agreement of the results from the RCA tests with the
initial correlation, and thus, inability to demonstrate long-term stability of the initial
correlation. But, this finding and many other results from the project have been very useful
in enabling recommendations for several changes in draft PS-11 and draft Procedure 2,
which should be published as a supplementary proposal in the Federal Register in the near
future.
MRI-OPPT\\R4703-02-07 Revisedwpd
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Section 6.
Internal QA/QC Activities
6.1 QA/QC Issues
The QA/QC issues are discussed below for the initial correlation tests, first RCA,
second RCA, and final ACA.
6.1.1 Initial Correlation Test
Two QA/QC issues occurred during the initial correlation testing as described below:
6.1.1.1 Re-ranging of PM-CEMS
After the first 9 runs it was clear that the range on the three PM-CEMS was too broad,
considering the facility's paniculate emission limit (~ 17 mg/acm). It was therefore
necessary to change (decrease) the range on the GEMS. This necessitated performing the
entire set of 15 runs after the range on the PM-CEMS had been changed.
6.1.1.2 Difference in M17 Moisture Contents
It was observed that the moisture content determined in the dual M17 trains
sometimes differed by as much as 2.0% H2O (e.g., 12.2% vs. 14.2% in Run 17). This
might have been caused by using an H2O squirt bottle to identify sources of leaks in an
impinger train that did not pass initial leak check. However, even when that had not been
done, the difference in some runs was higher than expected.
Investigation of the problem revealed that additional water flowed into the first
impinger if the latex transfer line was elevated to help draw water out of the line, while
MR1-OPPT\\R4703-02-07 Revised wpd
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maintaining flow of air through the sampling system using the sampling console pump.
(This was done after the end of a run and after completing all leak checks.) This procedure
was used in all runs after Run 18, and in the later RCA tests, as well as eliminating the use
of water in troubleshooting any leak check problems.
It should be noted that investigation of two sets of similar multiple train data from
other stack tests revealed that moisture differences of at least 1% H2O have occurred for a
moisture level of 10-15%, and differences of at least 2% for a moisture level of ~ 50%. In
both sets of data the filter/impinger box was directly connected to the probe, or a heated
Teflon transfer line was used to connect the probe to the filter/impinger box.
In many emission tests, the moisture content is of minimal importance when
particulate emissions are in terms of mg/dscm. However, moisture content does affect
conversion to other units (e.g. mg/acm).
An error of 1% H2O causes a similar error (1%) in converting mg/dscm to mg/acm, for
a moisture level of 10% in the gas. However, an error of 1% H2O causes an error of about
2% in the conversion to mg/acm, for a moisture level of 50% in the gas. Moreover,
examination of other test data indicated that in high moisture stack gas, the difference in
H2O measured by dual trains can exceed 1% H2O (up to as much as 2.3% H2O).
6.1.2 First RCA Test
No QA/QC problems or issues occurred during the first RCA tests.
6.1.3 Second RCA Test
There were some operational and maintenance problems with the CEMS during the
second RCA, primarily the H2O CEMS and the F904K PM-CEMS, as discussed earlier in
this report. No other QA/QC problems occurred during the second RCA/ACA testing.
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6.1.4 Final ACA
After the second RCA (November 16 to November 20,1999) the logging of data from
all the PM-CEMS continued to the end of the 6-month endurance test period (February 16,
2000). Near the end of that period (February 7, 2000) a final ACA and SVA was carried
out. Although there was some maintenance performed to correct operational problems on
some of the CEMS during this period (as discussed previously), there were no QA/QC
problems.
6.2 QA Audits
Absolute correlation audits of the two light scatter PM-CEMS were performed four
times during the 6-month endurance test, as discussed previously in Section 5, using audit
materials supplied by the vendors (no audit materials were available for the Durag F904K).
In addition, all three PM-CEMS automatically perform a daily calibration drift check. The
ESC P5B was the only one that sometimes exceeded the drift criteria of < 4% of the
upscale value, but corrective action prevented it from exceeding the 4% criteria for 5
consecutive days (i.e. the out-of-control criteria). Also, four sets of sample volume audits
were performed on the Durag F904K, which met the criteria of ±5% of the audit value (i.e.,
volume measured by the calibrated dry gas meter).
For all the M17 sampling, the crew chief reviewed all of the raw data sheets, and these
were also spot checked by the WAL. Post-test calibration checks of the sampling meter
boxes were performed using calibrated critical orifices after the initial correlation and the
two RCA tests. Results for both meter boxes were within the acceptable range of 5% after
each set of tests. These QA checks, as well as those for thermocouples, barometer, and
pi tot tubes are contained in Appendix E.
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An audit of the initial correlation relationship was also carried out. This consisted of
an independent calculation of all statistical results for one PM-CEMS by an MRI
statistician. That is, the M17 results and the average response for the Durag beta gauge, for
all 12 runs, were used to carry out all the statistical calculations per PS-11. These
independently determined results were then compared with those computed for the initial
correlation relations. Some minor discrepancies were identified and corrected, including
any that affected results for the other two PM-CEMS.
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1. REPORT NO.
EPA-454/R-00-040a
4. TITLE AND SUBTITLE
EVALUATION OF PARTICULAR
MONITORING SYSTEMS
Volume 1
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
2.
E MATTER CONTINUOUS EMISSION
7. AUTHOR(s> Dan Bivins
Emission Monitoring and Analysis Division
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
15. SUPPLEMENTARY NOTES
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE September
6. PERFORMING ORGANIZATION
8. PERFORMING ORGANIZATION
2000
CODE
REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D-98-027
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
16. ABSTRACT
This final report describes an extended field demonstration of three particulate matter (PM) continuous
emission monitoring systems (CEMS) at a coal-fired boiler equipped with a lime slurry scrubber and
baghouse for air pollution control. The primary objectives of the field study were to: (1) demonstrate whether
the PM CEMS could provide reliable and accurate data over an extended period, (2) evaluate the PM CEMS
for durability, data availability, and setup/maintenance requirements, and (3) determine whether the PM
CEMS satisfy all the requirements of draft PS-11 and the quality assurance (QA) criteria specified in draft
Procedure 2, or determine if changes are needed in the requirements of PS-11 and/or Procedure 2. This
report presents the results of the study involving two different PM CEMS technologies (light scatter and beta
gauge) at the coal-fired boiler. The report consists of five separate volumes.
7 KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
'S-ll 1 - , .
Method 17
'rocedure 2
Moisture CEMS 4
>emonstration
'articulate Matter
MCEMS
S. DISTRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
.Air Pollution control
', ' '
19. SECURITY CLASS (Report)
Unclassified
20. SECURITY CLASS (Page)
Unclassified
c. COSATI Field/Group
21. NO. OF PAGES
152
22. PRICE
V Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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