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Home My WebLink AboutDSHW-2006-007000 - 0901a068801658cf CDRL 06 CEMS MONITORING PLAN Rev. 7 Date: 04-07-05 Chg. 1 Date: _XX-XX-XX_ STOP THINK ACT REVIEW Procedure Owner: Randy Roten Monitoring Manager Approved by: Gary McCloskey General Manager (Original signatures on file) CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 1 TABLE OF CONTENTS 1 PURPOSE............................................................................................................ 2 2 SCOPE................................................................................................................. 2 3 REFERENCES..................................................................................................... 3 4 ACRONYMS/DEFINITIONS................................................................................. 4 5 RESPONSIBILITIES............................................................................................. 5 5.1 Monitoring Program Description ................................................................ 5 5.2 Duties and Qualifications........................................................................... 5 5.3 Operator Certification............................................................................... 10 5.4 Operator Recertification........................................................................... 11 6 PROCEDURE..................................................................................................... 11 6.1 Pollutants and Diluents to be Measured and Expected Concentrations .. 11 6.2 Emissions Flow Diagrams and Flow Charts of Emissions and Emissions Monitoring Systems ................................................................................. 11 6.3 Sampling Locations ................................................................................. 11 6.4 Alternate Sampling Procedures ............................................................... 12 6.5 CEMS Site Description ............................................................................ 16 6.6 CEMS Equipment And Methods Description ........................................... 19 6.7 Certification, Audits, and Calibration........................................................ 28 6.8 Data Recording........................................................................................ 29 6.9 Quality Assurance.................................................................................... 32 6.10 Data Validation and Reporting................................................................. 36 6.11 CEMS Performance Specification Test Protocol...................................... 37 6.12 State Electronic Data Report (SEDR) (CEMS Quarterly Report)............. 37 7 RECORDS.......................................................................................................... 38 LIST OF TABLES Table 6.4-1. CEMS Operating Data............................................................................... 13 Table 6.5-1. CEMS Data............................................................................................... 17 CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 2 1 PURPOSE This Continuous Emissions Monitoring System (CEMS) Monitoring Plan describes the monitoring system used to provide evidence of compliance with the Tooele Chemical Agent Disposal Facility (TOCDF) RCRA and Title V permits. This plan does not include detailed Quality Assurance (QA) information about CEMS Certification or the annual Reference Method Audit (RMA). That information is included in the CEMS Certification Test Protocol Plan (EG 037) and the CEMS Quality Assurance Program Plan (EG 033). 2 SCOPE 2.1 This document includes the plan for complying with Title 40 of the Code of Federal Regulations (CFR) Part 266, 40 CFR Part 60, 40 CFR Part 63 subpart EEE, App. A, and Utah Air Conservation Rules R307 in the categories of: • Calibration of CEMS • Calibration Drift (CD) determination and adjustment of CEMS • Preventive Maintenance (PM) of CEMS (including spare parts inventory) • Data recording, calculations, and reporting • Corrective Action Program for malfunctioning CEMS 2.2 Information relating to analyzers used for Permit Compliance is included in this plan. The RCRA and Air Quality programs are administered by the State of Utah, Department of Environmental Quality. 2.3 Process control analyzers are used throughout the furnace systems, as deemed necessary by TOCDF, to monitor the process exhaust streams and to evaluate the operating condition of the respective furnace/incinerator. 2.4 There are spare analyzers located in the common stack spare racks which are certified for use in compliance locations. The analyzers have a "Certified" tag attached to the front panel. Only the analyzers will be relocated (not the sampling system or sample conditioning system). All compliance CEMS (RCRA, Air Quality, and certified spares) will be audited quarterly to ensure a sound audit trail for their accuracy from the time they are certified until they are used for compliance purposes. Only certified and audited analyzers will be used for compliance monitoring. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 3 2.5 Certified analyzers have a certification tag attached to the front panel with the following information: • Serial Number • Quarterly Audit Due Date • Quarterly Audit Completed Date • Annual Audit Due Date • "CERTIFIED" 2.6 The TOCDF has four separate incinerator systems that exhaust into a common stack. These four furnaces are monitored at the duct that feeds the effluent from each furnace into the stack. This design allows monitoring of the exhaust from individual furnaces rather than the combination of the exhaust from more than one furnace. Each furnace does, however, have its own pollution abatement system. 2.7 This plan includes detail about the location of all RCRA and Title V monitors as well as their sample points. This information is provided to show compliance with 40 CFR Part 60, 63 Subpart EEE, Part 266, and R307. 2.8 All the CEMS and analyzers are connected electronically to a computer in the Control Room from which furnace operations are controlled. All analyzer auditing, calibration, repair, and preventive maintenance (PM) are performed by trained TOCDF personnel. 3 REFERENCES 3.1 40 CFR Part 266 3.2 40 CFR Part 60 3.3 40 CFR Part 63 subpart EEE, App. A 3.4 EG 033 - CEMS Quality Assurance Program Plan 3.5 EG 037 – CEMS Certification Test Protocol Plan 3.6 TOCDF RCRA Permit 3.7 TOCDF Title V Permit 3.8 Utah Air Conservation Rules R307 CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 4 4 ACRONYMS/DEFINITIONS 4.1 ACA - Absolute Calibration Audit 4.2 AIT - Analyzer Indicating Transmitter 4.3 CD - Calibration Drift 4.4 CDRL - Contract Deliverable Requirements List 4.5 CDTF - Chemical Demilitarization Training Facility 4.6 CEMS - Continuous Emission Monitoring System 4.7 CERMS - Continuous Emission Rate Monitoring System 4.8 CFR - Code of Federal Regulations 4.9 DAQ - Department of Air Quality 4.10 DC - Direct Current 4.11 DCC - Document Control Center 4.12 DFS - Deactivation Furnace System 4.13 DSHW - Division of Solid Hazardous Waste (State of Utah) 4.14 EPA - Environmental Protection Agency 4.15 IGS - Inertial Gas Sampling 4.16 IR - Infrared 4.17 LIC - Liquid Incinerator 4.18 LOP - Laboratory Operating Procedure 4.19 M&TE - Measurement and Test Equipment 4.20 MPF - Metal Parts Furnace 4.21 MSB - Monitor Support Building 4.22 NIST - National Institute for Standards and Technology 4.23 PAS - Pollution Abatement System 4.24 PDARS - Process Data Acquisition and Recording System CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 5 4.25 PLC - Programmable Logic Controller 4.26 PM - Preventive Maintenance 4.27 PPM (ppm) - Parts per Million 4.28 PSIG (psig) - Pounds per Square Inch Gauge 4.29 QA - Quality Assurance 4.30 QC - Quality Control 4.31 RCRA - Resource Conservation and Recovery Act 4.32 RMA - Reference Method Audit 4.33 SEDR – State Electronic Data Report 4.34 SOW - Statement of Work 4.35 TOCDF - Tooele Chemical Agent Disposal Facility 4.36 TSCA - Toxic Substance Control Act 5 RESPONSIBILITIES 5.1 Monitoring Program Description 5.1.1 Organization The monitoring mission at TOCDF includes requirements to provide continuous monitoring for regulated environmental pollutants. The personnel listed in the organization charts are responsible for CEMS monitoring operations. Monitoring and QC personnel furnish coverage 24 hours a day, seven days a week. 5.2 Duties and Qualifications 5.2.1 Monitoring Manager 5.2.1.1 Responsible for the successful operation of the CEMS Program. 5.2.1.2 Ensures that personnel operate instruments and sampling systems provide reliable and accurate readings. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 6 5.2.1.3 Researches and understands permit requirements and supervises the monitoring staff to comply with those requirements. 5.2.1.4 Communicates with the Environmental Manager and staff for assistance in regulatory and interpretational matters. 5.2.1.5 Ensures that CEMS monitoring data is collected, documented, and reviewed. 5.2.1.6 Ensures that the data reflect the fact that the CEMS instruments and sampling system are certified, audited, and "in control" during all furnace operations and the data systems provide the furnace operators with reliable readings from which to make operational decisions. 5.2.1.7 Provides data to the Environmental Manager for inclusion in reports to the State of Utah. 5.2.1.8 Reviews the data archiving process to ensure that a complete and accurate audit trail of CEMS data is maintained. 5.2.1.9 Works with the Laboratory QC to develop and maintain a QC system that provides an independent overview of the operational status of the CEMS. 5.2.1.10 Ensures that corrective actions are developed and implemented for CEMS malfunctions. 5.2.1.11 Have the following qualifications: Successfully completed the course of study for CEMS conducted at the Chemical Demilitarization Training Facility (CDTF). 5.2.2 Continuous Emission Monitoring Specialist: 5.2.2.1 Is the on-site technical expert for the CEMS program. 5.2.2.2 Provides technical input to the content of the CEMS Monitoring Plan, Laboratory Operating Procedure (LOP), and the Statement of Work (SOW) for the CEMS certification contract. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 7 5.2.2.3 Testing of the Process Data Acquisition and Recording System (PDARS) for the CEMS instruments 5.2.2.4 Provides oversight of an independent contractor for the annual certification and for CEMS program in general. 5.2.2.5 Performs the majority of the CEMS work during plant operations. This effort is augmented by other qualified Monitoring personnel. These efforts include: Calibrations and calibration drift checks Preventive maintenance (PM) Malfunction correction Quarterly audits Oversight of the data collection requirements for above actions. Inventory maintenance of parts and consumables for the CEMS mission. The CEMS Specialist is responsible for technical overview of the CEMS and for providing improvements and developing corrective actions as they are warranted. 5.2.2.6 Have the following qualifications: Successfully completed the CEMS course at the CDTF Certified in operation of the CEMS 5.2.3 Monitoring Team Supervisor 5.2.3 LeadC1 5.2.3.1 Coordinate with the CEMS Specialist and assign qualifiedC1 Monitoring personnel to assist, as needed, to ensure the CEMS mission is successful. The CEMS Specialist is a day shift person, while Team Leaders and Instrument Technicians furnish coverage 24 hours a day, seven days a week. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 8 5.2.3.2 Inform the CEMS Specialist of any corrective actions performed by Monitoring shift personnel and of any parts and consumables the team uses, to facilitate ordering replacements.ensure proper recertification steps are taken IAW permit requirements. C1 5.2.3.3 Ensure that during off-shifts, the CEMS calibration drift checks are performed by Monitoring technicians. Responds to CEMS alarms and malfunctions when notified by Control Room Operators. 5.2.3.4 Have the following qualifications: Successfully completed the CEMS course taught at the CDTF Certified in CEMS operations 5.2.4 Monitoring Instrument Technicians C1 5.2.4 Senior Monitoring TechniciansC1 5.2.4.1 Supports the majority of the aspects of the CEMS monitoring during off-shifts. 5.2.4.2 Perform PM, repair, calibration and calibration drift checks. 5.2.4.3 Respond to alarms and malfunctions. 5.2.4.4 Ensures that the electronic data logging system is operating correctly. 5.2.4.5 Have the following qualifications: Successfully completed the CEMS course taught at the CDTF Successfully completed the Laboratory Equipment Maintenance course taught at the CDTF (Instrument Technician only)C1 Certified in CEMS operation. 5.2.5 Monitoring Technicians CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 9 5.2.5.1 Perform PM, calibration, and calibration drift checks. 5.2.5.2 Ensures that the electronic data logging system is operating correctly. 5.2.5.3 Have the following qualifications: Successfully completed the CEMS course taught at the CDTF Certified in CEMS operation. C1 5.2.5 Quality Control (QC) Manager 5.2.5.1 Reports to the EG&G Quality Management Manager. 5.2.5.2 Is responsible to provide an independent assessment of the CEMS monitoring mission. 5.2.5.3 With QC personnel, inspects and monitorsauditsC1 all aspects of the CEMS program including but not limited to: Certification, calibration, and audits Inspection of the configuration of the CEMS instruments and the sampling systems. Inspect the data collection system to verify its accuracy. Observe CEMS Audits; both "Quarterly Audits" and "Annual Audits" 5.2.5.4 Lab QC Manager along with QC Monitoring inspectors ensures oversight of a representative portion of these audits to validate the performance of the CEMS. 5.2.5.5 Review CEMS documentation for accuracy with special attention to malfunction and corrective action documentations. 5.2.5.6 Have the following qualifications: Successfully completed the CEMS course at the CDTF. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 10 5.2.6 Quality Control Monitoring Inspectors 5.2.6.1 Perform surveillances of all CEMS aspects. 5.2.6.2 Randomly observe the actions of any CEMS operators 5.2.6.3 Randomly observe CEMS calibrations or calibration drift checks to verify the recorded data. 5.2.6.4 Randomly observe CEMS audits to verify that quarterly audits are performed correctly. 5.2.6.5 Spot check all CEMS documentation. 5.2.6.6 Have the following qualifications: Successfully completed the CEMS course at the CDTF. 5.3 Operator Certification CEMS operators will be certified by completing initial training at CDTF then completing a certification performance package that demonstrates the operator’s skill and knowledge of the CEMS. 5.3.1 Qualified Operator Upon successful completion of the CEMS course taught at CDTF an operator is considered a ‘Qualified’ operator. A qualified operator may perform CEMS operations under the direct supervision of a certified operator. The certified operator is responsible to directly supervise the actions of the qualified operator and ensure that applicable procedures are followed. All work performed by the qualified operator 5.3.2 Certified Operator When a sufficient amount of supervised training has been completed the qualified operator may become a ‘Certified’ operator by completing a CEMS Operator Certification Package. The package will consist of the successful completion of the following: • Calibration and a 74C1-Day Calibration Drift Test • Calibration Error Test or Absolute Calibration Audit or Cylinder Gas AuditC1 CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 11 • Response Time Test • Demonstrate basic knowledge of applicable operating permits and procedures that govern the operation of the CEMS Monitoring QC inspectors will audit and approve the certification package. Operators must calibrate at least one CEMS analyzer per calendar quarter to maintain certification. 5.4 Operator Recertification Previously certified operators that allow their certification to lapse may recertify by performing a calibration and a 4-Day calibration drift test on any analyzer. 6 PROCEDURE 6.1 Pollutants and Diluents to be Measured and Expected Concentrations See Table 6.4-1, CEMS Operating Data 6.2 Emissions Flow Diagrams and Flow Charts of Emissions and Emissions Monitoring Systems Drawings TE-6-F-501 and TE-6-FD-502 provide flow charts and CEMS sample locations for the incinerator and furnace systems. 6.3 Sampling Locations 6.3.1 Sampling point sites for the Title V and RCRA Compliance CEMS are in accordance with 40 CFR Part 60. 6.3.2 The following conditions must be met: • The sample point is at least two equivalent duct diameters downstream from the nearest control device, the point of pollutant generation, or other point at which a change in the pollutant concentration or emission rate may occur. • The sample point is at least one half-equivalent duct diameter upstream from the effluent exhaust or control device. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 12 6.3.3 When the above criteria can not be met, a stratification test will be performed at the time of the initial CEMS certification to validate the sampling efficiency of the CEMS probe. 6.3.4 The sample probe is extended into the duct or stack to cause the measurement point to be no less than 1.0 meter from the stack or duct wall, or within or centrally located over the centroidal area of the stack or duct cross-section or, no greater than 1 percent of the stack duct cross-sectional area. 6.4 Alternate Sampling Procedures 6.4.1 There are no alternate sampling procedures because there are back-up systems and previously certified spare analyzers that may be moved to serve as replacement units. 6.4.2 All analyzers used to monitor at compliance locations are certified, including spares. This allows them to be moved and replace malfunctioning compliance instruments. When a malfunctioning compliance CEMS instrument is replaced with a spare unit, the replacement unit will: • Measure the same parameter • Have the same operating range • Have been certified • Be calibrated before waste feed is started • Have a Response Time Test completed before waste feed is started • Have an Absolute Calibration Audit (ACA) completed before waste feed is started 6.4.3 There is a spare NOx analyzer operating at all times. However since both units share one probe and PDARS link, only one analyzer can monitor at a time. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 13 Table 6.4-1. CEMS Operating Data MPF Analyzers Tag Number Analyte Purpose Instrument Range Expected Conc. Accuracy Set point AIT-669 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA* AIT-670 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 AIT-384 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA AIT-82 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 The CO and O2 analyzers are specified by 40 CFR, part 266, 60, and 63. Set points are derived from the RCRA Permit and the Title V Operating Permit. Expected concentrations are determined from data seen at TOCDF. *HRA – Hourly Rolling Average. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 14 Table 6.4-1. CEMS Operating Data (cont.) DFS Analyzer Tag Number Analyte Purpose Instrument Range Expected Conc. Accuracy Set point AIT-207 CO RCRA 0-200 ppm 0-5000 ppm 0- 15ppm 6 ppm 150 ppm 100 ppm HRA* AIT-206 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 AIT-59 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA AIT-175 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 AIT-781 CO2 TSCA 0-20% 2-8% 0.5% CO2 LO 2% HI 8% AIT-781B CO2 TSCA 0-20% 2-8% 0.5%C O2 LO 2% HI 8% Common Stack Analyzers Tag Number Analyte Purpose Instrument Range Expected Conc. Accuracy Set point AIT-76A and AIT-76B NOX Title V Permit 0 -1000 ppm 20-100 ppm 25 ppm No Set point The CO and O2 analyzers are specified by 40 CFR, part 266, 60, and 63. Set points are derived from the RCRA Permit and the Title V Operating Permit. Expected concentrations are determined from data seen at TOCDF. *HRA – Hourly Rolling Average. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 15 Table 6.4-1. CEMS Operating Data (cont.) LIC I Analyzers Tag Number Analyte Purpose Instrument Range Expected Conc. Accuracy Set point AIT-78 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA* AIT-210 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 AIT-83 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA AIT-229 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 LIC 2 Analyzers Tag Number Analyte Purpose Instrument Range Expected Conc. Accuracy Set point AIT-716 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA AIT-717 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 AIT-778 CO RCRA 0-200 ppm 0-5000 ppm 0-15 ppm 6 ppm 150 ppm 100 ppm HRA AIT-798 O2 RCRA 0-25% 7-12% 0.5% O2 LO 3 HI 15 The CO and O2 analyzers are specified by 40 CFR, part 266, 60, and 63. Set points are derived from the RCRA Permit and the Title V Operating Permit. Expected concentrations are determined from data seen at TOCDF. *HRA – Hourly Rolling Average. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 16 6.5 CEMS Site Description 6.5.1 Type/Make of Instrument Shelter 6.5.1.1 All CEMS instrument shelters are constructed to provide weather protection and insulation. Each shelter is heated and cooled to provide temperature controlled environment for the CEMS instruments. All CEMS instrument shelters are an integral part of the site structures All the CEMS and process control analyzers are powered by commercial power and have Uninterruptible Power Supply backup. 1) Common Stack House (75-461) - located 60' above ground and surrounds the Common Stack. The house is approximately 22' by 50'. 1) C1 2) MPF/DFS Monitoring House (75-261) - located 18' above ground on the North East Side of the PAS building. The house is approximately 10' by 13'. 2) C1 3) LIC Monitoring House (75-262) - located 18' above ground on the South East Side of the PAS building. The house is approximately 10' by 13'. C1 6.5.2 Stack/Duct Description, Dimensions and Sample Points 6.5.2.1 Table 6.5-1 provides the sample point description information in a simplified format. When O2, CO, and/orC1 CO2 analyzers are co-located in a single rack, the sampling system is shared by all analyzers. 6.5.3 Alternate Gas Sampling Ports For each CEMS sampling port, there is an equivalent spare port, which is adjacent to the CEMS port. There are also two unused environmental sampling ports for each set of CEMS ports. The common stack has spare CEMS ports and environmental ports to be used for manual stack sampling such as during RCRA test burns. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 17 Table 6.5-1. CEMS Data CEM TAG ANALYTE CEM PURPOSE FURNACE SYSTEM UPSTREAM INTERFERENCE DISTANCE DIAMETERS INCHES DOWNSTREAM INTERFERENCE DISTANCE DIAMETERS INCHES DUCT/STACK INSIDE DIAMETER (INCHES) ANALYZER LOCATION ROOM NUMBER 13 AIT 083 CO RCRA LIC1 3.5 105 5 150 28 75-262 13 AIT 229 02 RCRA LIC1 3.5 105 5 150 28 75-262 24 AIT 078 CO RCRA LIC1 3 90 5.5 165 30 75-262 24 AIT 210 O2 RCRA LIC1 3 90 5.5 165 30 75-262 13 AIT 778 CO RCRA LIC2 13 390 6 180 28 75-262 13 AIT 798 02 RCRA LIC2 13 390 6 180 28 75-262 24 AIT 716 CO RCRA LIC2 15 450 4 120 27.5 75-262 24 AIT 717 O2 RCRA LIC2 15 450 4 120 27.5 75-262 16 AIT 059 CO RCRA DFS 3 138 1 46 46 75-261 16 AIT 175 O2 RCRA DFS 3 138 1 46 46 75-261 24 AIT 207 CO RCRA DFS 3 138 1 46 46 75-261 24 AIT 206 O2 RCRA DFS 3 138 1 46 46 75-261 16 AIT 781 CO2 TSCA DFS 3 138 1 46 46 75-261 16 AIT 781B CO2 TSCA DFS 3 138 1 46 46 75-261 CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 18 Table 6.5-1. CEMS Data (continued) CEM TAG ANALYTE CEM PURPOSE FURNACE SYSTEM UPSTREAM INTERFERENCE DISTANCE DIAMETERS INCHES DOWNSTREAM INTERFERENCE DISTANCE DIAMETERS INCHES DUCT/STACK INSIDE DIAMETER (INCHES) ANALYZER LOCATION ROOM NUMBER 24 AIT 669 CO RCRA MPF 1.5 40 1 26 26 75-261 24 AIT 670 O2 RCRA MPF 1.5 40 1 26 26 75-261 14 AIT 384 CO RCRA MPF 1.5 40 1 26 26 75-261 14 AIT 082 O2 RCRA MPF 1.5 40 1 26 26 75-261 24 AIT 9076 H20 Title V Permit COMMO N STACK 2 168 2.1 188 84 75-461 24 AIT 076 24 AIT 076A NOX Title V Permit COMMO N STACK 2 168 2.1 180 84 75-461 CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 19 6.6 CEMS Equipment And Methods Description 6.6.1 CO Analyzer 6.6.1.1 Manufacturer: Teledyne, Advanced Pollution Instrumentation Division (API) 6.6.1.2 Model: 300EM 6.6.1.3 Measurement Principle: Non-dispersive Infrared (NDIR) 6.6.1.4 Operating range: All API analyzers are dual range, auto- ranging analyzers 1) Range One: 0-200 ppm CO 2) Range Two: 0-5000 ppm CO 6.6.1.5 Theory of Operation: 1) The 300EM uses a beam of broad-band IR light with a known intensity (measured during calibration) and directs it through a multi-pass filter with sample gas. The sample cell uses mirrors at each end to reflect the IR beam back and forth through the sample gas to generate a 14m absorption path giving the analyzer maximum sensitivity to fluctuations in CO density. 2) The beam then passes through a band-pass filter that only allows light at a wavelength of 4.7µm to pass. The beam then strikes a photo- detector that converts it into a modulated voltage signal representing the attenuated intensity of the beam. 3) The 300EM uses a Gas Filter Correlation (GFC) Wheel in the light path to overcome the effects of interfering gases that also absorb light at 4.7µm, such as CO2 and H2O. 4) The GFC wheel contains two chambers; one that contains nitrogen (Measurement cell) and the other nitrogen and a high concentration of CO (Reference cell). CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 20 5) As the wheel spins IR light passes alternately thorough the two cell cavities. When the beam is exposed to the Reference cell, the CO in the gas filter wheel strips the beam of most of the IR at 4.7µm. When the beam is exposed to the Measurement cell, the N2 in the wheel does not absorb IR light. The fluctuation in the intensity of the IR light striking the photo-detector that results in the output of the detector resembles a square wave. The 300EM determines the amount of CO in the sample chamber by computing the ratio between the peak of the Measurement pulse and the peak of the Reference pulse. Once the 300EM has computed the ratio, a lookup table is used, with interpolation, to linearize the instrument. This linearized concentration value is combined with calibration SLOPE and OFFSET values to produce a CO concentration which is then corrected for changes in sample pressure. If interfering gases are introduced into the sample chamber the spectrum of the IR beam is changed in a way that is identical for both the Reference and the Measurement cells but without changing the ratio between the peak heights. In this way, the GFC wheel eliminates the effects of interfering gases so that the analyzer responds only to the presence of CO. 6.6.2 CO2 Analyzer 6.6.2.1 Manufacturer: Rosemount Analytical Inc 6.6.2.2 Model: NDIR 880 or 880A 6.6.2.3 Measurement Principle: Non-dispersive Infrared 6.6.2.4 C02 Operating Range: 0-20%. 6.6.2.5 Theory of Operation 1) Infrared (IR) Radiation is produced in two different paths. One beam is directed toward a sample cell and the other beam is directed toward a reference cell. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 21 2) A chopper wheel alternately interrupts the radiation passing through the sample and reference cells. 3) The sample cell contains sample gas from the stack. 4) The reference cell is sealed. Each IR beam passes through its respective cell, in which the CO2 in the sample gas absorbs a portion of the IR radiation. The quantity of the radiation absorbed is proportional to the concentration of CO2. 5) A Luft detector converts the difference in energy of the cells into a signal representative of the concentration of CO2. The concentration value is displayed on the front panel, the control room console, strip chart recorder, and PDARS. 6.6.3 O2 Analyzer 6.6.3.1 Manufacturer: Ametek, Thermox Instrument Division 6.6.3.2 Model: Thermox FCA Micro-Control 6.6.3.3 Measurement Principle: Zirconium oxide electrochemical cell 6.6.3.4 Operating Range: Adjustable from 0-1% to 0-100%. 02 analyzers will be operated in the 0-25% range. 6.6.3.5 Theory of Operation The O2 analyzer uses a zirconium oxide (ZrO2) ceramic sensing element to determine the concentration of O2 in the stack gas. The CEMS rack O2 system is made up of two major components; the Detector and the Control Unit. 1) The Detector contains the following: a. A furnace b. Thermocouple c. Cell housing CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 22 d. Oxygen cell 2) The furnace and thermocouple maintain the environment for the oxygen cell. The oxygen cell is a closed tube made up of zirconium oxide and is coated with porous platinum on the inside and outside of the cell. The cell operates at a temperature of approximately 695 degrees C. 3) The cell measures the oxygen concentration by comparing the oxygen pressure of the sample side of the oxygen cell to the pressure on the reference side of the cell. 4) Sample gas is drawn from the sample probe and enters the Flowblock inlet. Most of the gas passes through the Flowblock and out the exhaust; however, some gas flows up into the cell housing over the oxygen cell, through the return loop into the Flowblock, and back out the exhaust. 5) If the pressure of the gas on the sample side differs from that of the reference side, a signal is produced. 6) The internal circuitry in the CEMS quantifies the signal generated by the oxygen cell and displays it as percent oxygen on the front panel. 7) Control Unit The control unit operates all functions of the O2 analyzer components. The control unit also displays: a. The current oxygen concentration reading b. The current oxygen alarm status (only in the event of an alarm) c. The current cell temperature d. The current error status (only in the event of a system malfunction) CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 23 6.6.4 CO/O2 CEMS Sampling System Theory of Operation 6.6.4.1 There are instances where O2, CO and CO2 analyzers share a common sampling system. 6.6.4.2 The CEMS rack system draws stack emissions through the stack probe assembly and transports it to the CEMS rack system through a heat traced sample transport tube bundle. 6.6.4.3 The gas sample is drawn through stage one of the sample cooler/condenser, the first head of the sample pump, under a vacuum, and exits the pump head under positive pressure into the second stage of the sample cooler; where: 1) The sample stream temperature is lowered to ambient 2) Additional particulates are washed away 6.6.4.4 The sample then passes through the coalescing filter to remove any fine liquid mist carryover from the sample cooler. 6.6.4.5 The gas sample then passes through a sample pressure regulator that regulates line pressure at 4-11 pounds per square inch gauge (PSIG). 6.6.4.6 Then through the inner tube of the reflux permeation dryer to further dry the sample stream. 6.6.4.7 The sample stream then splits into two streams, if both O2 and CO are to be measured: 1) One stream flows through the O2 flow indicator/controller and into the O2 analyzer. 2) The other stream flows through the CO flow indicator/controller and into the CO analyzer. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 24 6.6.4.8 The analyzer exhaust is drawn from the analyzers under negative pressure by means of the second head of the sample pump; the line is maintained at slight negative to zero pressure by the reflux pressure regulator. 6.6.4.9 The gas then passes through the outer tube of the reflux permeation dryer and into the second head of the pump. 6.6.4.10 The gas sample is then exhausted under positive pressure back to the source. 6.6.5 CERMS Sampling System The CERMS consist of three components; the NOx analyzer, the moisture analyzer, and the stack flow meter. 6.6.5.1 NOX Analyzer Manufacturer: Rosemount Analytical Inc. 1) Model: 951A 2) Measurement Principle: Chemiluminescent Method. 3) Operating Range: 0-1000 ppm 4) Theory of Operation When the analyzer is in the NO mode of operation, sample NO is quantatively converted into NO2 by gas phase oxidation with molecular ozone supplied by an external cylinder. As a result of this conversion process (reaction), approximately 10% of the NO2 molecules are elevated to an electronically excited state, followed by their immediate reversion to a non- excited state. As this change of energy state occurs, it is accompanied by the emission of photons of light. The photons impinge on a photomultiplier detector, generating a low-level direct current (DC). The current is amplified to drive a front panel meter and sent to a panel mounted strip chart recorder. 5) When the analyzer is in the NOx mode of operation, the detection process is the same except that, before entry into the reaction chamber, the sample passes through a CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 25 converter where the NO2 component is dissociated to form NO. Instrument response is proportional to total NO in the converted sample, that is, the sum of NO present in the original sample plus the NO produced by dissociation of NO2. 6) The Control Room readings and the PDAR results for NOx must be in "pounds per hour". The pounds per hour are calculated automatically by using the input from a stack flow meter and moisture analyzer. All of the readings are sent electronically to the Control Room where software performs the calculations "real time." During certification, the complete system is compared to a reference method system provided by the Certification Contractor. 6.6.5.2 Moisture analyzer 1) Manufacturer: MAC Instruments 2) Model: MAC 120 3) Measurement Principle: IR Source/Pyroelectric Detector 4) Operating Range: 0 to 100% 5) Theory of Operation (Analyzer is an In-Situ) Stack gas is drawn through a probe, passed across the moisture sensors, and then exhausted back into the stack. 6.6.5.3 Stack Flow Meter 1) Model: Panametrics Model CEM68 2) Measurement Principle: Ultrasonic 3) Operating Range: 0.03 – 45 m/s (0.1 – 150ft/sec) 4) Theory of operation The meter consists of two parts; a measurement section including ultrasonic CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 26 transducers and holders, and the electronics section necessary to operate the transducers and process data. 5) The measurement section uses two ultrasonic transducers to send ultrasonic pulses back and forth across the diameter of the stack. 6) The electronic section measures the time ultrasonic pulses take to travel the diameter of the stack. Pulses travel faster in the direction of the flow because the flow helps the pulse travel. The upstream and downstream transit times are compared. The difference is proportional to the velocity of the flow in the stack. Corrections are made to the measurement to compensate for temperature and pressure that could affect the speed of the pulse. 6.6.6 CEMS Rack 6.6.6.1 Sampling Equipment 6.6.6.2 Pre-Insulated Sample Tube Bundle - The sample tubing bundle is electrically heated and contains several Teflon lines used to transport sample, calibration, exhaust gases and instrument air between the CEMS rack and the source. The temperature of the sample tube bundle is regulated by a controller located in the rack for each CEMS system. The controller uses thermocouple feedback to sense the temperature of the bundle. 6.6.6.3 Stack Probe Assembly - The stack probe assemblies used in the TOCDF program are made up of the following components: 1) Probe Ceramic or stainless probes are used for sampling. Probes of either material are 1/2" outside diameter (OD). The actual length of the probe depends upon the diameter of the stack or duct. The end of the probe is cut to a 45 degree angle and is faced downstream to help avoid collection of particulates. 2) Inertial Gas Sampling (IGS) Filter CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 27 The IGS filter is used for sampling of hot gases. This filter is not usable for sampling wet gases. The IGS filter is used to remove particulates from the sample. As sample gas is extracted through the ceramic probe a clean sample flow develops radially through the porous tube wall at a very low face velocity (0.005 fps), passing into the housing annulus and out the sample tube. 3) Eductor - The purpose of the eductor is to create a vacuum which draws the gases through the probe then the IGS filter. The eductor is very similar in operation to a venturi flow nozzle. The eductor is driven by pressure regulated instrument air. Once the instrument air passes through the eductor, it is discharged back into the stack. 4) Three-way Air Motor Actuated Valve The three-way air motor actuated valve is a two- position valve used to configure the stack probe assembly into either "blowback" or "sample" mode. When in blowback mode, the sample flow path is isolated from the probe assembly. Instrument air is used to back-flush the IGS filter and the probe to clean it out. The valve motor actuator is operated by instrument air supplied via the sample transport tube bundle from the CEMS rack. Instrument air used for the back flush is supplied locally via the air regulator (not from the sample transport line). This configuration allows the sampling probe to be operated remotely from the CEMS rack so the operator does not have to go to the probe to change modes (sample or blowback). The three- way valve is normally aligned in the sample mode (no instrument air applied). The valve is switched to the blowback mode by applying instrument air to the valve actuator. With this configuration, a loss of instrument air will cause the sample probe to remain in or return to the sample position. 5) Calibration Gas Inlet - The calibration gas inlet features a check valve (one-way valve) to prevent sample gas from entering the calibration CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 28 gas line during normal sampling operations. The inlet is attached to the sample line where it connects to the probe. This configuration allows calibration gases to flow through every part of the sampling system except the probe assembly. 6.6.7 Cylinder Gas Calibration Equipment 6.6.7.1 Each CEMS rack has its own calibration system. With this system, each analyzer's accuracy can be verified at the zero and span response values against a known reference. Calibration gas is controlled at the CEMS rack and sent through the heated sample line bundle into the sampling system at the Calibration Gas Inlet. 6.7 Certification, Audits, and Calibration 6.7.1 Certification 6.7.1.1 CEMS analyzers and associated equipment used in compliance locations will be certified annually in accordance with EG-37 (Continuous Emission Monitoring System (CEMS) Certification Test Protocol) using the applicable methods in CFR 40 Parts 60 App. B and/or 266 Appendix IX. An independent contractor will be used to perform reference method tests. 6.7.2 Audits 6.7.2.1 Quarterly 1) Quarterly Audits will be performed once each calendar quarter using cylinder gas standards 2) Successive quarterly audits will not occur closer than 60 days apart. 6.7.2.2 Absolute Calibration Audit (ACA) The Absolute Calibration Audit (ACA) will be performed quarterly for three of the four quarters in each calendar year. It will be performed by Monitoring personnel identified Section 5.2. EPA Protocol 1 gases will be used. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 29 6.7.2.3 Reference Method Audit (RMA) A Reference Method Audit (RMA) will be performed annually by an independent contractor in accordance with EG-37 (Continuous Emission Monitoring System (CEMS) Certification Test Protocol) 6.7.3 Calibration and Calibration Drift Checks Analyzers will be checked for calibration drift daily by introducing zero and span concentrations of calibration gas to the analyzer. The drift will be calculated by comparing the analytical results from the analyzer to the target concentration value of the gas. Drift tolerances are defined in Section 6.9.8, Control Limits and Actions. At least once per week all analyzers will be calibrated regardless of drift. 6.8 Data Recording 6.8.1 Daily Calibration Check 6.8.1.1 When each daily calibration or calibration drift check is performed, the readings are recorded in three locations: 1) PDARS The PDARS computer in the Control Room records all CEMS readings. By changing a switch position at the CEMS instrument before the calibration, the computer will differentiate between calibration data and process data. The PDARS software allows compilation of calibration data in electronic and hard copy reports. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 30 2) Strip Chart Recorder CEMS readings are recorded as chart deflections on a paper chart recorder. After the daily calibration is performed, the operator marks the chart with at least the following information: a. Date b. Time c. Operator name or identification number d. Readings generated by the calibration , drift check. C1 e. Reading after calibration adjustment 3) CEMS Rack Logbook The above calibration information is also entered in the instrument logbook. 6.8.2 Process Data Acquisition and Recording System (PDARS) 6.8.2.1 The Process Data Acquisition and Recording System (PDARS) is a computerized data recording system which receives its data through Programmable Logic Controllers (PLCs). The data is stored on disc and/or hard copy. All of the operating CEMS are connected to the PDARS. 6.8.2.2 Each gas analyzer is equipped with a switch marked "“Calibration" and "Operate". ” “ON”, “OFF”.C1 The switch allows the PDARS computer to differentiate between process data and calibration data. 6.8.3 CEMS Certification Data Certification of the CEMS is performed by an independent contractor. The certification contractor will: 6.8.3.1 Comply with EG-033, CEM Certification Quality Assurance Program Plan and EG-037, Continuous Emission Monitoring System Certification Test Protocol. 6.8.3.2 Provide a report documenting all data generated from the performance specification tests required for CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 31 certification. The report will also include an explanation of the test parameters, calculations, and results of all testing. 6.8.4 CEMS Data during Operations 6.8.4.1 The analytical results from CEMS instruments are collected on duplicate systems. Each CEMS analyzer is connected to a chart recorder and a link to the PDARS for data recording. The PDARS records all CEMS readings. 6.8.4.2 CEMS Instrument Log A permanently bound log book with consecutively numbered pages will be located in the proximity of each CEMS instrument. The log will contain a running history of the instrument and actions taken on any equipment in the rack; including actions by Monitoring and QC personnel. Each entry will include the date, time, a description of actions taken or miscellaneous annotations, and the signature of the person making the entry. 6.8.5 CEMS Data Archiving CEMS data is stored in two formats, hard copy and computer software disc. 6.8.5.1 Hard Copy CEMS data hardcopy (logbooks, forms, chart recorder charts, etc.) are maintained by Monitoring personnel for a minimum of one month. The data are then turned over to the TOCDF Document Control Center (DCC) where they are stored until placed in permanent archives. 6.8.5.2 Computer Software Copy CEMS data collected by PDARS are kept on disc. The data disc is maintained by the PDARS Engineer for 45 days. The discs are then sent to the DCC where they are stored until placed in permanent archives. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 32 6.9 Quality Assurance 6.9.1 Independent Audits 6.9.1.1 Each year, the annual Reference Method Technical Audit will be performed by an outside contractor. An outside contractor is used to lend validity to the accuracy and reliability of the CEMS. The requirements the contractor must comply with are specified in the contract Statement of Work (SOW). 6.9.1.2 Non-scheduled audits will be performed by the Laboratory Quality Control Inspectors who have successfully completed the CEMS course of study at the CDTF. 6.9.2 National Institute for Standards and Technology (NIST) Traceability The measurement accuracy for the standards used to calibrate the CEMS and the M&TE is traceable to the NIST. The accuracy certificate for the CEMS calibration gases is maintained on file and made a part of certification and calibration records. Protocol 1 gases will be used for both calibration and cylinder gas C1audits. 6.9.3 Quality Control Calculations 6.9.3.1 The calculations used to evaluate calibration drift are performed each day per the following equation: 1) TC-FC = CD 2) TC – Target Concentration 3) FC – Found Concentration 4) Calibration Drift must not exceed the control limits specified in Section 6.9.8. 6.9.4 Operational Procedures Laboratory Operating Procedures (LOPs) are posted in the MSB. At least once per year, the CEMS operators will read the LOPs and sign a statement that they understand the LOPs, including detailed procedures for operation, preventive maintenance, and calibration of the CEMS. All LOPs require approval by the TOCDF Project Manager. Before approval, they must be validated. The validation consists of performing CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 33 all of the steps in the LOP with operational equipment, while being witnessed by a QC Monitoring Inspector, and a Government Technical Representative. 6.9.5 Quality Control 6.9.5.1 Type/Frequency of Quality Checks 1) Review Certificates of Compliance for cylinder gas standards used for CEMS certification, calibration, and audits to ensure they are NIST traceable and meet EPA protocol requirements. 2) Periodic procedure, instrument and logbook surveillances. 3) Random audits of CEMS instruments at the discretion of the Laboratory QC Manager to validate the accuracy of calibrations and calibration drift checks. 4) Periodic review of quarterly CEMS audit documentation. 5) CEMS Operator Certification Packages and training records of the personnel who perform CEMS operations stated in Section 5.2, Duties and Qualifications. 6.9.6 Preventive Maintenance Program 6.9.6.1 The PM Program is administered by the CEMS Specialist who performs the major part of the "hands-on" PM. Other qualified Monitoring personnel may also perform the PM. 6.9.6.2 The major part of the Preventive Maintenance Program consists of documenting diagnosticoperationalC1 readings or measurements from gauges, meters etc. that indicate proper operation of the CEMS. 6.9.6.3 Other PM may include the periodic replacement of consumable parts to prevent failure of a system. 6.9.7 Instrument Calibration 6.9.7.1 M&TE used in support of certification, technical audits, CEMS calibrations, and preventive maintenance is CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 34 calibrated using standards that are traceable to the NIST. 6.9.7.2 Any M&TE used to support annual certification by the sub-contractor shall be calibrated and the certificate included in the CEMS certification or audit data package. 6.9.7.3 M&TE that is used by the Monitoring personnel may be calibrated either onsite or off site. 1) Standards used to perform onsite calibrations shall be NIST traceable and a copy of the calibration certificate demonstrating NIST traceability shall be kept on file at TOCDF. 2) Equipment that is calibrated offsite shall have a certificate demonstrating NIST traceability that must also be kept on file at TOCDF. 6.9.8 Control Limits and Actions 6.9.8.1 The control limits and actions stated here relate to daily operations of the CEMS. These limits and actions do not apply to CEMS certification. Certification of CEMS is described in the TOCDF CEMS Quality Assurance Program (EG-033) and the CEMS Certification Test Protocol (EG-037). 6.9.8.2 Calibration Drift (CD) is evaluated daily to determine if it is excessive. The following describes control limits and actions required to correct excessive drift: 1) O2 a. The CD for the O2 analyzer is determined to be excessive if the Zero or Span reading differs from the reference value by more than 0.5% O2. If the CD is excessive the analyzer must be recalibrated. b. If, on any given check the CD exceeds 1% O2 the analyzer is considered “out of control” and a successful ACA must be performed to verify the analyzer is “in control” before it can be used for compliance monitoring. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 35 2) CO a. The CD for the CO analyzer is determined to be excessive if the Zero or Span reading differs from the reference value by more than six ppm for the low range (0-200 ppm). Or the Zero or Span reading differs more than 150 ppm from the reference value at the high range (0-5000). If the CD is excessive the analyzer must be recalibrated. b. If, on any given check the CD exceeds two times the limits the analyzer is considered “out of control” and a successful ACA must be performed to verify the analyzer is “in control” before it can be used for compliance monitoring. 3) CO2 The CD for the CO2 CEMS is determined to be excessive if the zero or span reading differs from the reference value by more than 0.5% CO2. If the CD is excessive the analyzer must be recalibrated. 4) NOx a. The CD for the NOx CEMS is determined to be excessive if the zero or span reading differs from the reference value by 25 ppm. If the CD is excessive the analyzer must be recalibrated. The CD is determined to be ‘out of control’ if the zero or span reading differs from the reference value by more than 100 ppm in “one time” or 50 ppm for "five consecutive days". b. If the daily drift check indicates that the NOx is ‘out of control’, the following steps will be taken: i. Identify and correct the cause for the excessive drift ii. Evaluate if any corrective action is necessary to prevent future occurrences of the same type of problem. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 36 iii. The occurrence of the excessive drift shall be included in the quarterly technical audit report to the State Division of Air Quality. 6.10 Data Validation and Reporting 6.10.1 Calibration Drift Data Calibration drift data is validated by the individual performing the calibration drift check. The CEMS Specialist shall screen data to observe for trouble spots. The QC Monitoring Inspector observes CD tests on a spot check basis. 6.10.2 Data Validation Data entered on the Daily CEMS Calibration Sheets, PDARS and the CEMS logbooks are all reviewed by the CEMS Specialist on an on-going basis to determine accuracy and consistency. All errors or irregularities are corrected with an annotation indicating the circumstance. 6.10.3 Missing Data 6.10.3.1 Because of redundant data collection methods for CEMS data, it is highly unlikely that there will be any missing data. 6.10.3.2 Should there be missing data, the Environmental Manager shall be notified immediately. If necessary the Control Room Operators will be notified immediately to allow them to take appropriate actions relative to plant operations. 6.10.3.3 The cause for the missing data will be determined and the following accomplished: 1) Replication of the missing data if possible. 2) Documentation that data was lost to provide an accurate audit trail. 3) Corrective action taken to prevent a future reoccurrence of missing data. 6.10.3.4 All of the above will be included in the CEMS quarterly report. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 37 6.10.3.5 The appropriate notifications will be made to the Environmental Manager. 6.11 CEMS Performance Specification Test Protocol 6.11.1 Certification Certification testing of the CEMS is performed by an independent subcontractor in accordance with EG-037, CEMS Certification Test Protocol, CFR 40 Part 266, 60, and 63. 6.11.2 The CEMS Specialist will make Notification of Testing 6.11.2.1 The Utah DSHW will be notified 1445C1 days prior to certification or annual recertification of CEMS analyzers 6.11.2.2 The Utah DAQ will be notified 45 days prior to certification or annual recertification of CEMS analyzers. 6.11.3 New CEMS analyzers used for monitoring in compliance locations will be certified prior to use. 6.12 State Electronic Data Report (SEDR) (CEMS Quarterly Report) A quarterly SEDR is submitted to the State of Utah DSHW and the Division of Air Quality no later than 30 days after the end of each calendar quarter. The SEDR is compiled and submitted by the Environmental Manager. 6.12.1 The Quarterly SEDR includes: • Source owner/operator name and address. • Identification and location of monitor in the CEMS. • Manufacturer and model number of each monitor. • Report of data from quarterly audits. • Malfunctions and out-of-control conditions of CEMS, corrections and corrective actions taken to prevent future occurrences. Results of retest after corrections. • Breakdown reports (plant failures causing excess emissions). CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX Page 38 • Reports of any excessive emissions. • 7-Day Calibration Drift Test • Absolute Calibration Audit • Response Time Test • Performance Specification 7 RECORDS 7.1 Information Assets 7.1.1 All information generated by this CDRL is considered to be an information asset. (Documents, forms, databases, etc.) 7.1.2 The following information assets were developed as a result of implementation of this CDRL. Documents with an asterisk (*) are considered Records. None 7.2 Retention/storage of records PRP-EV-041 identifies individual record retention requirements. CDRL 06 CEMS MONITORING PLAN CEMS Monitoring Plan CDRL 06 Rev 7 Chg. 0, 07 April 051, XX-XXX-XX LIST OF EFFECTIVE PAGES LIST OF EFFECTIVE PAGES PAGE NO. REV/CHG NO. 1 - 38 R7C1 2 – 6 R7 7 – 12 R7C1 13 – 15 R7 16 R7C1 17 – 18 R7 19 – 20 R7C1 21 – 29 R7 30 R7C1 31 R7 32 – 33 R7C1 34 R7 35 R7C1 36 R7 37 R7C1 38 R7