DSHW-2006-010969 - 0901a06880187d3c

REQUEST FOR
CLASS 1 WITH APPROVAL MODIFICATION
TO THE
HAND DELIVERED
JUN 0 1 2006
UTAH DIVISION OF
SOLID & HAZARDOUS WASTE
TOCDF RCRA PERMIT
REQUEST NUMBER: TOCDF-CEMS-01 (WA)-0890
REQUEST TITLE: CONTINUOUS EMISSIONS MONITORING
SYSTEM (CEMS) MONITORING PLAN,
REVISION 7, CHANGE 1
EPA ID: UT 5210090002
TO: UTAH DIVISION OF SOLID AND HAZARDOUS WASTE
1460 WEST 288 NORTH
P. O. BOX 144880
SALT LAKE CITY, UTAH 84114-4880
TOCDF
TITLE: Continuous Emissions Monitoring System (CEMS) Monitoring Plan, Revision 7
Change 1
CLASS: Class 1 With Approval Modification - 40 CFR 270.42, (d) (2) (i)
INDEX
A. DESCRIPTION OF CHANGES page A
B. PERMIT CHANGE PAGES page B
C. FACILITY IMPACT page C
D. HEALTH/ENVIRONMENTAL IMPACT page D
E. JUSTIFICATION page E
TOCDF
A: DESCRIPTION OF CHANGES
The Continuous Emissions Monitoring System (CEMS) Plan is updated to Revision 7,
Change 1 in Attachment 20 of the TOCDF RCRA Permit. This modification incorporates
administrative updates to the plan for accuracy.
Changes proposed in this modification are summarized below:
• Operator certification requirements have been changed for Monitoring
Technicians.
• Monitoring Technician Levels I and II have been removed from the plan.
• CEMS Site Description has been updated.
• Notification of Testing requirements have been revised to be consistent with the
notification requirements for the Division of Air Quality.
Grammar, pagination and alignment have been adjusted throughout the document.
An electronic copy of the redline/strikeout text is provided to aid in the review of this
modification.
TOCDF requests this modification be classified as a Class 1 with approval in accordance
with 40 CFR 270.42, (d)(2)(i). The proposed changes do not substantially alter permit
conditions or reduce the capacity of the facility to protect human health or the
environment.
TOCDF
B: RCRA PERMIT CHANGE PAGES
CHANGE PAGES IN BODY OF PERMIT:
None
CHANGE PAGES IN ATTACHMENTS OF PERMIT:
Attachment 20 Cover Page
CHANGES TO DRAWINGS IN PERMIT:
None
ATTACHMENT #20
Continuous Emission Monitoring System (CEMS) Plans
Consisting of:
o CEM Certification Quality Assurance Program .Plan, EG 033, Revision 7, change 1, June
20,2005 incorporated by reference.
o CEMS Monitoring Plan, CDRL 06, Revision 7. Change 1. dated June 20. 2005*Approvai
Date*, incorporated by reference.
CEMS MONITORING PLAN
CDRL 06
Rev 7, Change 1
Junc 20,2005
*Approval Date*
This Plan has been incorporated in its entirety by reference.
A copy of this plan may be reviewed by contacting the Division of Solid and Hazardous Waste between
the hours of 8:00 a.m. and 5:00 p.m. on business days.
^^"^ A Om»K>n iM URS
PROCEDURE ROUTING FORM
DOCUMENT CONTROL
Procedure Number, Title: CDRL 06, OEMS Monitoring Plan
Existing Revision/Change No.: R7C0 New Revision/Change No.: R7C1
Is this an SOP Annual Review? ^YES DNO If YES, attach Procedure Review Comment Forms.
Route for Govemment Review OR routei Annual Review with the resulting Change or Revision.
•fs»s5\ tif? -'•'t£Si:ai^SH!iEBi'?»«?SJiag«i '———'— —* ~ .Check;, if ^1
|requlred|^^^| i^(i|?reigurred'JbrMtenm:G^^
Procedure Ownen/
AL QC Manager
f^,.^^EIizabeth Lowge^/Vl \ c ><. ^ ^-^
la
•
•
•
•
•
•
•
•
Environmer
Joe Majesqc ///U/\
late
Deputy GM Y^echnicaJ Support & Risk Management
ShellvEttel^v)\V.lVjv CAV^ .\?CP
Date
Date
Procedure Writer Date
Other Reviewer (Titie) Date
Other Reviewer (Title) Date
Other Reviewer (Title) Date
Other Reviewer (Title) Date
Other Reviewer (Title) Date
Other Reviewer (Title) Date
Other Reviewer (Title) Date
Contractor's Subcontract Administrator Date
Date
Government Technical Representative
Linda Rae Johnson • • - . •
ate
Govemment Administrative Contracting Officer
Thaddeus A Rvba Jfrj
TOCDF Site Project Manager
Date
Date
PRP-DC-001-02.RIC1 Page 1 of 1
CDRL 06
CEMS MONITORING PLAN
Rev. 7 Date: 04-07-05
Chg. 1 Date:. XX-XX-XX
Procedure Owner: Randv Roten
Approved by:.
Monitoring Manager
Gary McCloskev
General Manager
(Original signatures on file)
CDRL 06 CEMS MONITORING PLAN
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
OEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
Page 1
CDRL 06 CEMS MONITORING PLAN
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).
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 RCFiA 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
deeimed 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.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
Page 2
CDRL 06 CEMS MONITORING PLAN
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 stacl<. 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 ail 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.
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
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
Page 3
CDRL 06 CEMS MONITORING PLAN
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
OEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
4.25 PLC - Programmable Logic Controller
4.26 PM - Preventive Maintenance
4.27 PPM (ppm) - Parts per Million
4.28 PSIG (pslg) - 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
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.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
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 GEMS.
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.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
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 Supen/isor
5.2.3 Lead^^
5.2.3.1 Coordinate with the CEMS Specialist and assign
qualifiod^^ 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.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
5.2.3.2 Inform the CEMS Specialist of any corrective actions
performed by Monitoring shift personnel and of any
parts and consumables the toam uses, to facilitate
ordering—replaoements.ensure proper recertification
steps are taken IAW permit requirements.
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
5T2r4 Monitoring Instrument Technicians
ci
5.2.4 Senior Monitoring Technicians'^^
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
operafing correctly.
5.2.4.5 Have the following qualificafions:
• Successfully completed the CEMS course taught
at the CDTF
• Successfully completed the Laboratory Equipment
Maintenance course taught at the CDTF
(Instrument Technician only)
• Certified in CEMS operafion.
§72T§—Monitoring Technicians
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
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— Havo the following qualifications:
*—Successfully completed the CEMS course taught at
tho CDTF
*—Certified in CEMS operation.
01
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 monitorsaudits^^ all
aspects of the CEMS program including but not
limited to:
• Certificafion, calibrafion, and audits
• Inspecfion of the configurafion 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 documentafion for accuracy with special
attention to malfuncfion and corrective acfion
documentafions.
5.2.5.6 Have the following qualificafions:
Successfully completed the CEMS course at the
CDTF.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
5.2.6 Quality Control Monitoring Inspectors
5.2.6.1 Perform surveillances of all CEMS aspects.
5.2.6.2 Randomly observe the acfions of any CEMS operators
5.2.6.3 Randomly observe CEMS calibrafions or calibrafion 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 documentafion.
5.2.6.6 Have the following qualificafions:
Successfully completed the CEMS course at the
CDTF.
5.3 Operator Certification
CEMS operators will be certified by complefing inifial 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 ofthe CEMS course taught at
CDTF an operator is considered a 'Qualified' operator. A
qualified operator may perform CEMS operafions under the
direct supervision of a certified operator. The certified operator
is responsible to directly supervise the acfions 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 complefing a CEMS Operator Certificafion Package.
The package will consist of the successful completion of the
following:
• Calibration and a 74^^-Day Calibrafion Drift Test
• Calibration Error Test or Absolute Calibration Audit or
Cylinder Gas Audit^^
OEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051. XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
• Response Time Test
• Demonstrate basic knowledge of applicable operafing
permits and procedures that govern the operafion of the
CEMS
Monitoring QC inspectors will audit and approve the certificafion
package.
Operators must calibrate at least one CEMS analyzer per
calendar quarter to maintain certificafion.
5.4 Operator Recertification
Previously certified operators that allow their certificafion to lapse may
recertify by performing a calibration and a 4-Day calibration drift test on
any analyzer.
PROCEDURE
6.1 Pollutants and Diluents to be Measured and Expected
Concentrations
See Table 6.4-1, CEMS Operafing 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 locafions for the incinerator and furnace systems.
6.3 Sampling Locations
6.3.1 Sampling point sites for the Tifie V and RCFiA Compliance
CEMS are in accordance with 40 CFR Part 60.
6.3.2 The following condifions 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.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0.07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
6.3.3 When the above criteria can not be met, a stratificafion test will
be performed at the fime of the inifial CEMS certificafion 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 sen/e as replacement units.
6.4.2 All analyzers used to monitor at compliance locafions are
certified, including spares. This allows them to be moved and
replace malfuncfioning 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 Calibrafion Audit (ACA) completed before
waste feed is started
6.4.3 There is a spare NOx analyzer operafing at all fimes. However
since both units share one probe and PDARS link, only one
analyzer can monitor at a fime.
OEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
Table 6.4-1. CEMS Operafing Data
MPF Analyzers
Mlnstrumenftf^; ^^SSMttmi^MMMi
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 Operafing Permit.
Expected concentrations are determined from data seen at TOCDF.
*HRA- Hourly Rolling Average.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
Table 6.4-1. CEMS Operafing Data (cont.)
DFS Analyzer
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
insfrument ?
Rpnge -WAcGuracysj
AIT-76A and
A1T-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 RCF?A Permit and the Title V Operating Permit.
Expected concentrations are determined from data seen at TOCDF.
*HF^ - Hourly Rolling Average.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
Table 6:4-1. CEMS Operafing Data (conL)
LIC I Analyzers
r InstrumentiJi'
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 Analyzeid
l^^^^igv^fs^^if^^^
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 RCF^A Permit and the Tifie V Operafing Permit.
Expected concentrafions are determined from data seen at TOCDF.
*HF^ - Hourly Rolling Average.
CEMS Monitoring Plan
CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
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CDRL 06 CEMS MONITORING PLAN
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 Uninterrupfible Power Supply backup.
4^—Common Stack House (75-461) - located 60'
above ground and surrounds the Common
Stack. The house is approximately 22' by 50'.
1) 01
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) ci
3) LIC Monitoring House (75-262) - located 18'
above ground on the South East Side of the
PAS building. The house is approximately 10'
6.5.2 Stack/Duct Description, Dimensions and Sample Points
6.5.2.1 Table 6.5-1 provides the sample point descripfion
informafion in a simplified format. When O2, CO,
and/or^^ 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.
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CDRL 06 CEMS MONITORING PLAN
Table 6.5-1. CEMS Data
OEM TAG ANALYTE
.•f''-:!riC-
PURPOSE -~
.•. • •t' -
-:FURNACE"
S'i'Sf EM
UPSfREfM^i
INTERFERENCE ,
- ' DISTANCE ' *,'"
DIAMETERS '
'INCrtES
7%dV\^NSTSEAM'.
!;IMERFERE"NCE
? .^DISTANCE -
/ DIAMETERS \
- ' MNGflES. . •
DUCT/STACK "
INSIDE
DIAMETER .
(INCHES)
' : ANALYSER-J
LOCATION ;
,,.R6,OM
^NUi^BER
13 AIT 083 CO RCRA UC1 3.5 105 5 . 150 28 75-262
13 AIT 229 O2 RCRA LICl 3.5 105 5 150 28 75-262
24 AIT 078 CO RCRA LICl 3 90 5.5 165 30 75-262
24 AIT 210 02 RCRA LIC1 3 90 5.5 165 30 75-262
13 AIT 778 CO RGRA LIC2 13 390 6 180 28 75-262
13 AIT 798 02 RCRA L1C2 13 390 6 180 28 75-262
24 AIT 716 CO RCRA LIC2 15 450 4 120 27.5 75-262
24 AIT 717 02 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 02 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 02 RCRA DFS 3 138 1 46 46 75-261
16 AIT 781 C02 TSCA DFS 3 138 1 46 46 75-261
16 AIT 781B G02 TSCA DPS 3 138 1 46 46 75-261
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CDRL 06 CEMS MONITORING PLAN
Table 6.5-1. CEMS Data (confinued)
CEM TAG ANALYTE
•1^1—- ,
• - GEM
PURPOSE
FURNA'eE
SYSTEM
, UPSTRE^^MC^-
INTERFERENSE
': DISTANG-E-S^l;"
DIAMETERS ?-
INCHES'f"
DOWNSliREAM-^
iFJTERFiREr^QE
DISTANCE ?*;
DIAMETERS"'-
INCHES
,BUCJ/SMCK-
INSIDEV;%S
"DIAMETERS
(INCHES)"
:/XNALYZER • -
rfLOCATION
"' 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 02 RCRA MPF 1.5 " 40 1 26 26 75-261
24 AIT
9076
H20 Title V
Pemiit
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
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6.6 CEMS Equipment And Methods Description
6.6.1 CO Analyzer
6.6.1.1 Manufacturer: Teledyne, Advanced Pollufion
Instrumentation Division (API)
6.6.1.2 Model: 300EM
6.6.1.3 Measurement Principle: Non-dispersive Infrared (NDIR)
6.6.1.4 Operafing 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 Operafion:
1) The 300EM uses a beam of broad-band IR iight
with a known intensity (measured during
calibrafion) 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 absorpfion path giving the analyzer
maximum sensitivity to fiuctuations in CO
density.
2) The beam then passes through a band-pass
filter that only allows light at a wavelength of
4.7pm to pass. The beam then strikes a photo-
detector that converts it into a modulated
voltage signal represenfing 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
4.7pm, 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).
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CDRL 06 CEMS MONITORING PLAN
5) As the wheel spins IR light passes alternately
thorough the two cell cavifies. 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 4.7pm. When the beam is exposed to the
Measurement cell, the N2 in the wheel does not
absorb IR light. The fluctuafion 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
compufing the rafio 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
calibrafion 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 idenfical 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 Analyfical Inc
6.6.2.2 Model: NDIR 880 or 880A
6.6.2.3 Measurement Principle: Non-dispersive Infrared
6.6.2.4 C02 Operafing 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.
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CDRL 06 CEMS MONITORING PLAN
2) A chopper wheel alternately interrupts the
radiafion 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 radiafion. The quanfity of the radiafion
absorbed is proportional to the concentration of
CO2.
5) A Luft detector converts the difference in energy
of the cells into a signal representafive 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 Operafing Range: Adjustable from 0-1% to 0-100%. O2
analyzers will be operated in the 0-25% range.
6.6.3.5 Theory of Operafion
The O2 analyzer uses a zirconium oxide (Zr02)
ceramic sensing element to determine the
concentrafion 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
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CDRL 06 CEMS MONITORING PLAN
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 plafinum 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 ofthe 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 Flowbtock, 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 qu'antifies 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 malfuncfion)
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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 posifive pressure into the second stage of the
sample cooler; where:
1) The sample stream temperature is lowered to
ambient
2) Addifional 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 permeafion
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.
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CDRL 06 CEMS MONITORING PLAN
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) Operafing Range: 0-1000 ppm
4) Theory of Operafion
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
operafion, the detection process is the same
except that, before entry into the reacfion
chamber, the sample passes through a
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CDRL 06 CEMS MONITORING PLAN
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 dissociafion 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
automafically 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 fime." During certification, the complete
system is compared to a reference method
system provided by the Certificafion 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: Oto 100%
5) Theory of Operafion (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) Operafing 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
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CDRL 06 CEMS MONITORING PLAN
transducers and holders, and the electronics
section necessary to operate the transducers
and process data.
5) The measurement secfion uses two ultrasonic
transducers to send ultrasonic pulses back and
forth across the diameter of the stack.
6) The electronic secfion measures the time
ultrasonic pulses take to travel the diameter of
the stack. Pulses travel faster in the direcfion 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-lnsulated 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
collecfion of particulates.
2) Inertial Gas Sampling (IGS) Filter
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CDRL 06 CEMS MONITORING PLAN
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 fliter
and the probe to clean it put. 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
configurafion 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 (sanlple 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
conflgurafion, 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-vyay valve) to
prevent sample gas from entering the calibration
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CDRL 06 CEMS MONITORING PLAN
gas line during normal sampling operations. The
inlet is attached to the sample line where it
connects to the probe. This configurafion 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 Calibrafion 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 (Confinuous Emission
Monitoring System (CEMS) Certificafion 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 Calibrafion 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.
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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 (Confinuous Emission Monitoring System
(CEMS) Certification Test Protocol)
6.7.3 Calibration and Calibrafion Drift Checks
Analyzers will be checked for calibrafion drift daily by
introducing zero and span concentrafions 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 Secfion 6.9.8,
Control Limits and Acfions.
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 calibrafion 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 posifion at the CEMS instrument before
the calibrafion, the computer will differentiate
between calibration data and process data. The
PDARS software allows compilation of
calibration data in electronic and hard copy
reports.
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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 informafion:
a. Date
b. Time
c. Operator name or identification number
d. Readings generated by the calibrafion-, drift
check.
e. Reading after calibrafion adjustment
3) CEMS Rack Logbook
The above calibrafion information is also entered
in the instrument logbook.
6.8.2 Process Data Acquisifion 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 operafing CEMS are connected
to the PDARS.
6.8.2.2 Each gas analyzer is equipped with a switch marked
-"Calibration" and "Oporato". " "ON", "OFF".*^'' The
switch allows the PDARS computer to differentiate
between process data and calibrafion data.
6.8.3 CEMS Certificafion Data
Certificafion of the CEMS is performed by an independent
contractor. The certification contractor will:
6.8.3.1 Comply with EG-033, CEM Certificafion Quality
Assurance Program Plan and EG-037, Confinuous
Emission Monitoring System Certification Test
. Protocol.
6.8.3.2 Provide a report documenfing all data generated from
the performance specification tests required for
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CDRL 06 CEMS MONITORING PLAN
certificafion. The report will also include an
explanation of the test parameters, calculations, and
results of all tesfing.
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 permanentiy 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 instrurhent and actions taken
on any equipment in the rack; including acfions by
Monitoring and QC personnel. Each entry will
include the date, fime, a descripfion of actions taken
or miscellaneous annotafions, 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 Hardcopy
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 unfil
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.
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CDRL 06 CEMS MONITORING PLAN
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 jend 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 Nafional 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 calibrafion records. Protocol
1 gases will be used for both calibration and cylinder gas
^••audits.
6.9.3 Quality Control Calculafions
6.9.3.1 The calculations used to evaluate calibrafion 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 operafion, preventive
maintenance, and calibrafion of the CEMS. All LOPs require
approval by the TOCDF Project Manager. Before approval,
they must be validated. The validation consists of performing
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CDRL 06 CEMS MONITORING PLAN
all of the steps in the LOP with operational equipment, while
being witnessed by a QC Monitoring Inspector, and a
Government Technical Representafive.
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 certificafion,
calibrafion, 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 calibrafions 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, Dufies
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
thePM.
6.9.6.2 The major part of the Preventive Maintenance Program
consists of documenfing diagnosficoperafional'"^
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
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CDRL 06 CEMS MONITORING PLAN
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 certificafion 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 demonstrafing 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 Acfions
6.9.8.1 The control limits and acfions stated here relate to daily
operations of the CEMS. These limits and acfions do
not apply to CEMS certification. Certification of GEMS
is described in the TOCDF CEMS Quality Assurance
Program (EG-033) and the CEMS Certificafion Test
Protocol (EG-037).
6.9.8.2 Calibrafion Drift (CD) is evaluated daily to determine if it
is excessive. The following describes control limits and
acfions required to correct excessive drift:
1) O2
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.
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 monitonng.
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CDRL 06 CEMS MONITORING PLAN
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 GEMS 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.
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CDRL 06 CEMS MONITORING PLAN
The occurrence of the excessive drift
shall be included in the quarteriy 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 nofified
immediately to allow them to take appropriate actions
relative to plant operafions.
6.10.3.3 The cause for the missing data will be determined and
the following accomplished:
1) Replicafion ofthe missing data if possible.
2) Documentafion 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.
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CDRL 06 CEMS MONITORING PLAN
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 tesfing of the CEMS is performed by an
independent subcontractor in accordance with EG-037, CEMS
Certificafion Test Protocol, CFR 40 Part 266, 60, and 63.
6.11.2 The CEMS Specialist will make Notificafion of Tesfing
6.11.2.1 The Utah DSHW will be notified 4445^^ days prior to
certificafion or annual recertification of CEMS
analyzers
6.11.2.2 The Utah DAQ will be notified 45 days prior to
certificafion 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.
• Identificafion and locafion of monitor in the CEMS.
• Manufacturer and model number of each monitor.
• Report of data from quarteriy audits.
• Malfunctions and out-of-control condifions of CEMS,
corrections and correcfive actions taken to prevent future
occurrences. Results of retest after corrections.
• Breakdown reports (plant failures causing excess
emissions).
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CDRL 06 CEMS MONITORING PLAN
• Reports of any excessive emissions.
• 7-Day Calibration Drift Test
• Absolute Calibration Audit
• Response Time Test
• Performance Specification
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.
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CDRL 06 CEMS MONITORING PLAN
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CDRL 06 Rev 7 Chg. 0. 07 April 051, XX-XXX-XX
TOCDF
C: FACILITY IMPACT
There is no facility impact associated with the administrative updates to this plan.
TOCDF
D: HEALTH/ENVIRONMENTAL IMPACT
There is no health/environmental impact with this modification.
TOCDF
E: JUSTIFICATION
The justification is described in Section A.
REQUEST NUMBER:
REQUEST TITLE:
TOCDF
<
NOTICE TO THE MAILING LIST
TOCDF-CEMS-01 {WA)-0890
CONTINUOUS EMISSIONS MONITORING SYSTEM
(CEMS) PLAN, REVISION 7, CHANGE 1
SUMMARY: The Continuous Emissions Monitoring System (CEMS) Plan is
updated to Revision 7, Change 1 in Attachment 20 of the RCRA
Permit. This modification incorporates administrative updates to
the plan for accuracy and completeness.
REPLY TO
ATTENTION OF:
DEPARTMENT OF THE ARMY
us ARMY CHEMICAL MATERIALS AGENCY
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UTAH 84071
May 30, 2006
HAND DELIVERED
JUN 0 1 2006
UTAH DIVISION OF
SOLID & HAZARDOUS WASTE
Tooele Chemical Agent Disposal Facility PM-60321
SUBJECT: TOCDF RCRA Class 1 Pennit Modification Request, TOCDF-CEMS-Ol(WA)-
0890, Continuous Emissions Monitoring System (CEMS) Monitoring Plan,
Revision 7, Change 1
Mr. Dennis Downs, Director
Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
288 North 1460 West
Salt Lake City, Utah 84116-0690
Dear Mr. Downs:
RCRA Class 1 Pennit Modification Request TOCDF-CEM-01(WA)-0890, "CEMS
Monitoring Plan, Revision 7, Change 1", is being submitted to the Utah Division ofSolid and
Hazardous Waste in accordance with the TOCDF RCRA Permit.
If you have any questions regarding this issue, please contact Ms. Elizabeth A. Lowes at
[phone] or Mr. T. Trace Salmon at [phone].
Gary W. McCloskey
EG&G Defense Materials, Inc.
•CERTIFICATION STATEMENT
Sincerely,
J'. Trace Salrnbn
TOCDF Deputy Site Project Manager
•CERTIFICATION STATEMENT
Copies Fumished:
CMA Risk Management Directorate (Mr. Stang)
DCD Risk Management Directorate (Mr. Levi)
TOCDF FO Representative (Ms. Snow)
File
• I CERTIFY UNDER PENALTY OF LAW THAT THIS DOCUMENT AND ALL ATTACHMENTS WERE PREPARED UNDER MY DIRECTION OR SUPERVISION IN
ACCORDANCE WITH A SYSTEM DESIGNED TO ASSURE THAT QUALIFIED PERSONNEL PROPERLY GATHER AND EVALUATE THE INFORMATION SUBMITTED. BASED
ON MY INQUIRY OF THE PERSON OR PERSONS WHO MANAGE THE SYSTEM, OR THOSE PERSONS DIRECTLY RESPONSIBLE FOR GATHERING THE INFORMATION, THE
INFORMATION SUBMITTED IS, TO THE BEST OF MY KNOWLEDGE AND BELIEF, TRUE, ACCURATE AND COMPLETE. I AM AWARE THAT THERE ARE SIGNIHCANT
PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLUDING THE POSSIBILITY OF FINE AND IMPRISONMENT FOR ICNOWING VIOLATIONS.