United States Office of Air Quality EPA-454/R-00-040a Environmental Protection Planning and Standards September 2000 Agency Research Triangle Park, NC 27711 Air 

# Evaluation of Particulate Matter

Continuous Emission Monitoring Systems Final Report Volume I—Technical Report For U.S. Environmental Protection Agency Office of Air Quality Planning and Standards

EPA Contract No. 68-W6-0048 Work Assignment No. 4-02 MRI Project No. 104703.1.002.07.01

September 25, 2000MRI-OPPT\\R4703-02-07 Revised.wpd 

### ii



# Preface This report was prepared by Midwest Research Institute (MRI) for the U.S. Environmental Protection Agency (EPA) under Contract No. 68-W6-0048, Work Assignment 4-02. Mr. Dan Bivins is the EPA Work Assignment Manager (WAM). This report covers the 6-month endurance test period for the PM-CEMS (July 20, 1999 to February 16, 2000) and includes the initial correlation tests as well as the two RCA/ACA tests. All of this work would not have been possible without the full cooperation of Cogentrix personnel. The Cogentrix staff (especially Tracy Patterson, Air Quality Manager, Steve Carter, Plant Manger, and Mike Chaffin, I&C Supervisor) were very helpful and provided every possible assistance to make this a successful project. This report consists of 1,238 pages, including the appendices. MIDWEST 

### R

ESEARCH 

### INSTITUTE



### Paul Gorman Work Assignment Leader Approved:
Joseph Palausky Program Manager
September 25, 2000MRI-OPPT\\R4703-02-07 Revised.wpd 

### iii



# Contents
Preface
................................................................. iii Executive Summary
..................................................... ES-1 Section 1. Introduction
................................................... 1-1

1.1 Summary of Test Program
................................... 1-1 1.1.1 Overall Purpose of the Program
....................... 1-1 1.1.2 Test Site
......................................... 1-3 1.1.3 Summary of CEMS Evaluated
......................... 1-5 1.1.4 Emissions Measured
............................... 1-10 1.1.5 Dates of Tests
.................................... 1-10 1.2 Key Personnel
........................................... 1-11 Section 2. Sampling Location
.............................................. 2-1

2.1 Flue Gas Sampling Location
................................. 2-1 2.2 Sampling and Analytical Procedures
............................ 2-6 2.3 Process Sampling Locations
................................. 2-7 Section 3. Installation and Start-up of the CEMS
................................ 3-1

3.1 CEMS Delivery
........................................... 3-2 3.2 Functional Acceptability Testing
............................... 3-2 3.3 Installation at the Test Site
................................... 3-4 3.4 Start-up Issues
........................................... 3-6 Section 4. Durability, Availability, and Maintenance Requirements for CEMS
.......... 4-1

4.1 ESC-P5B
............................................... 4-1 **4.2 Durag DR 300-40** 
........................................ 4-3 **4.3 Durag F904K** 
........................................... 4-4 **4.4 HMP 235 Moisture CEMS** 
................................ 4-7 4.5 Summary
................................................ 4-9 Section 5. Presentation and Discussion of Results
................................ 5-1

5.1 Objectives and Test Matrix
.................................. 5-1 5.2 Field Test Changes and Problems
.......................... 5-3 5.2.1 Initial Correlation Test Changes and Issues
............... 5-3 5.2.2 First RCA Test Changes and/or Problems
................ 5-5 5.2.3 Second RCA Test Changes and/or Problems
............. 5-5 5.3 Presentation of Results
.................................. 5-5 5.3.1 Process Data
.................................. 5-6 5.3.2 M17 Test Results and H 2

### O CEMS Results
............ 5-6 5.3.3 PM-CEMS Drift Test Data and ACA Results
........... 5-37MRI-OPPT\\R4703-02-07 Revised.wpd 

### iv 5.3.4 Initial Correlation and RCA Test Results
................ 5-54 5.3.5 Investigation of Reason(s) for Non-agreement of RCA Results
..................................... 5-84 Section 6. Internal QA/QC Activities
......................................... 6-1

6.1 QA/QC Issues
........................................... 6-1 6.1.1 Initial Correlation Test
............................... 6-1 6.1.2 First RCA Test
.................................... 6-2 6.1.3 Second RCA Test
................................. 6-2 6.1.4 Final ACA
....................................... 6-3 6.2 QA Audits
.............................................. 6-3 **Appendices** Volume 2—Appendices A through G for Initial Correlation Tests Volume 3—Appendices A through G for RCA No. 1 Volume 4—Appendices A through G for RCA No. 2 Volume 5—Appendix H (Daily Graphs)MRI-OPPT\\R4703-02-07 Revised.wpd 

### v



# Tables
Table 4-1. Levels of Upscale Calibration Drift for the ESC P5B
................. 4-2 Table 4-2. CEMS Data Unavailability
................................... 4-10 Table 4-3. Data Availability for Each CEMS
.............................. 4-13 Table 5-1A. Summary of Process Data for Each Run of the Initial Correlation

Tests
.................................................... 5-7 Table 5-1B. Summary of Process Data for Each Run
.......................... 5-8 Table 5-1C. Summary of Process Data for Each Run of Second RCA Tests
......... 5-9 Table 5-2A. Summary of M17 Sampling Data for Initial Correlation Tests
.......... 5-10 Table 5-2B. Summary of M17 Sampling Data for First RCA Tests
............... 5-11 Table 5-2C1. Summary of M17 Sampling Data for Traversing Train A

(Second RCA Test)
........................................ 5-12 Table 5-2C2. Summary of M17 Sampling Data (Train B—Single Point)

(Second RCA Test)
........................................ 5-13 Table 5-3A. M17 Particulate Test Results for Initial Correlation Tests
............. 5-14 Table 5-3B. M17 Particulate Test Results for First RCA Test
................... 5-15 Table 5-3C1. M17 Particulate Test Results—Traversing Train

(Second RCA Test)
........................................ 5-16 Table 5-3C2. M17 Particulate Test Results (Train B—Single Point)

(Second RCA Test)
........................................ 5-17 Table 5-4A. Precision of Method 17 Dual Trains for Initial Correlation Tests
........ 5-19 Table 5-4B. Precision of Method 17 Dual Trains for First RCA Tests
............. 5-20 Table 5-5A. Comparison of M17 Moisture Results for Initial Correlation Tests
...... 5-24 Table 5-5B. Comparison of M17 Moisture Results for First RCA Test
............ 5-25 Table 5-5C. Comparison of M17 Moisture Results for Second RCA Test
.......... 5-26 Table 5-6A. Summary of Moisture Results for Initial Correlation Tests

(CEM vs M17, and Calculated Correction Factor)
................. 5-28 Table 5-6B. Summary of Moisture Results from the first RCA Test

(CEM versus M17)
........................................ 5-31 Table 5-6C. Summary of Moisture Results for the Second RCA Tests

(CEMS versus Method 17)
................................... 5-32 Table 5-7A. Stack Temperature Comparison for Initial Correlation Tests

(M17 Versus H

2

### O CEM
..................................... 5-34 Table 5-7B. Stack Temperature Comparison for the First RCA Tests

(M17 Versus H

2

### O CEM)
.................................... 5-35 Table 5-7C. Stack Temperature Comparison for Second RCA Test

(CEMS versus Method 17)
................................... 5-36 Table 5-8. 7-Day Calibration Drift Results for the Three PM-CEMS
............ 5-38 Table 5-9A. Daily Drift Results (July 20 to August 31, 1999)
................... 5-40 Table 5-9B. Daily Drift Results (September 1 to November 20, 1999)
............ 5-42 Table 5-9C. Daily Cal Drift Data (November 21 to February 16)
................ 5-44 Table 5-10A. Results for Initial ACA
...................................... 5-50MRI-OPPT\\R4703-02-07 Revised.wpd 

### vi

Table 5-10B. Results for 2nd ACA
....................................... 5-51 Table 5-10C. Results for 3rd ACA
........................................ 5-52 Table 5-10D. Results for 4th ACA
........................................ 5-53 Table 5-11A. Initial SVA Results
......................................... 5-55 Table 5-11B. Second SVA Results
....................................... 5-56 Table 5-11C. Third SVA Results
......................................... 5-57 Table 5-11D. Fourth SVA Results
........................................ 5-58 Table 5-12. Tabulation of Data from Initial Correlation Tests
................... 5-60 Table 5-13. Selected Correlation Equation Values Versus Performance Criteria
..... 5-70 Table 5-14. Tabulation of Data from First RCA Test
......................... 5-72 Table 5-15. Correlation Equation Results Using Combined Data from Initial

Correlation Tests and First RCA Tests (24 Total Data Points)
......... 5-79 Table 5-16. Correlation Equation Results Using First RCA Test Data Only

(12 Data Points)
........................................... 5-81 Table 5-17. Tabulation of Data from Second RCA Test
....................... 5-83 Table 5-18. Tabulation of Data for Single Point Train Versus Traversing Train
...... 5-105 

# Figures Figure 1-1. Unit 1 Effluent Schematic
....................................... 1-4 Figure 2-2. Location of CEMS and M17 Test Ports (Elevation Front View)
.......... 2-3 Figure 2-3. M17 Sampling Points and CEMS Locations
......................... 2-4 Figure 2-4. Schematic Elevation Side View of Baghouse Inlet/Outlet Ducts and

Perturbing Device
............................................ 2-5 Figure 2-5. Analytical Scheme for M17 Train Components
....................... 2-8 Figure 5-1A. Bias of Train A versus Train B in Initial Correlation Tests
.............. 5-21 Figure 5-1B. Bias of Train A versus Train B in First RCA Tests
................... 5-22 Figure 5-2. Comparison of Adjusted Moisture Monitor Readings with M17 Results,

from Initial Correlation Tests
................................... 5-30 Figure 5-3A. Linear Regression for ESC Light Scatter—P5B
..................... 5-63 Figure 5-3B. Linear Regression for Durag Light Scatter—DR 300-40
............... 5-65 Figure 5-3C. Linear Regression for Durag Beta Gauge—F904K
................... 5-67 Figure 5-4A. Comparison of Initial Correlation Equation with the First RCA Test

Data for ESC-P5B
.......................................... 5-73 Figure 5-4B. Comparison of Initial Correlation Equation with First RCA Test

Data for DR300-40
.......................................... 5-75 Figure 5-4C. Comparison of Initial Correlation Equation with First RCA Test

Data for F904K
............................................. 5-77 Figure 5-5A. ESC-P5B Initial Correlation and all RCA Data
...................... 5-85 Figure 5-5B. DR300-40 Initial Correlation and all RCA Data
..................... 5-87 Figure 5-5C. F904K Initial Correlation and all RCA Data
........................ 5-89 Figure 5-6A. ESC-P5B Correlation for First RCA and Comparison with Data fromMRI-OPPT\\R4703-02-07 Revised.wpd 

### vii Second RCA
............................................... 5-91 Figure 5-6B. DR300-40 Correlation for First RCA, and Comparison with Data from Second

RCA
..................................................... 5-93MRI-OPPT\\R4703-02-07 Revised.wpd 

### viii

Figure 5-6C. F904K Correlation for First RCA, and Comparison with Data from

Second RCA
............................................... 5-95 Figure 5-7. Velocity at Traverse Points through Port C—ICAL vs. First RCA
....... 5-98 Figure 5-8A. November 15, 1999: Perturbing Device Closed
.................... 5-100 Figure 5-8B. November 17, 1999: Perturbing Device Open
..................... 5-101 Figure 5-9. Top View of Baghouse Outlet Duct
............................. 5-103 Figure 5-10. Particulate Ratio vs. Concentration
.............................. 5-107MRI-OPPT\\R4703-02-07 Revised.wpd 

### ES-1



# Executive Summary EPA’s Office of Air Quality Planning and Standards (OAQPS) is considering particulate matter continuous emission monitoring systems (PM-CEMS) for use in future standards. Also, states may require them for State Implementation Plans (SIP) and Economic Incentive Program (EIP) monitoring, and industry sources may use PM-CEMS for Title V monitoring. EPA therefore desired evaluation of PM-CEMS technology on a long-term, continuous basis. The purpose of this demonstration program was to assess the performance of PM-CEMS over an extended time. The program included three PM-CEMS and a moisture CEMS installed at the Cogentrix coal-fired cogeneration facility in Battleboro, North Carolina. These CEMS were:

• ESC P5B light scatter PM-CEMS

• Durag DR 300-40 light scatter PM-CEMS

• Durag F904K Beta gauge PM-CEMS

• Vaisala HMP 235 moisture CEMS Due to limited space for installing the devices at this test site, they were necessarily located only 2.1-2.6 diameters downstream of a 90 E 

### bend in the ductwork, which minimally met the location guidance in draft PS-11. It was recognized that this location might involve particulate stratification, but it was believed that any such stratification would likely be constant rather than variable, and thus would inherently be accounted for in development of the correlation relations for each PM-CEMS. In addition to installing the PM-CEMS, a perturbing device was also installed that allowed bypassing part of the flue gas from the baghouse inlet to the outlet in order to increase the range of particulate emissions for the testing.1

### PS-11, Performance Specification 11—Specifications and Test Procedures for

Particulate Matter Continuous Emission Monitoring Systems in Stationary Sources (draft Revision 4, November 1998). 2

### Procedure 2—Quality Assurance Requirements for Particulate Matter Continuous Emission Monitoring System (40 CFR 60, App. F, draft Revision 2, November 1998).

MRI-OPPT\\R4703-02-07 Revised.wpd 

### ES-2 Following installation and startup of the monitors, data were downloaded daily, and three sets of tests were carried out: the initial correlation tests per draft Performance Specification 11 (PS 11) 1

### and two Response Correlation Audits/Absolute Correlation Audits (RCA/ACA tests) per draft Procedure 2. 2

### These tests are discussed below, with the two RCA/ACA tests referred to as “RCA #1” and “RCA #2.” It should be noted that all three PM-CEMS provided good data availability (over 95%) throughout the 6-month period of their operation. The moisture CEMS did exhibit some problems with data availability, probably due to constant vibration at the test location. All three PM-CEMS met the daily drift criteria. They also met the applicablecriteria in draft Procedure 2 for the four separate ACAs performed on the light scatter PMCEMS and the Sample Volume Audits (SVAs) performed on the beta gauge PM-CEMS. Initial correlation relation testing of the three PM-CEMS was carried out in July 1999, and results met the draft PS-11 1

### correlation criteria for all three PM-CEMS. An ACA was also completed just before the initial correlation testing. In late August 1999, the first RCA (RCA #1) and a second ACA of the PM-CEMS were carried out per draft EPA Procedure 2. 2

### For all three PM-CEMS, only 7 of the 12 RCA data points fell within a 25% tolerance interval of the initial correlation relation (Procedure 2 requires that 9 of the 12 data points fall within a ± 25% tolerance interval). The 12 RCA data points were then used to develop a new correlation relation for all three PM-CEMS. These new correlations were within the draft PS-11 correlation criteria for the F904K beta gauge but were just outside the confidence interval and tolerance interval criteria for the ESC P5B and DR 300-40 light scatter monitors.MRI-OPPT\\R4703-02-07 Revised.wpd 

### ES-3

Because the results from the first RCA, as discussed above, did not meet the draft Procedure 2 criteria, the second RCA/ACA test objective was revised to include investigation of possible reasons for the differences between the initial correlation and the first RCA. The test plan was revised accordingly, and the test was carried out in mid-November 1999. The revised plan included use of one traversing train and one single point train in each run. The traversing train was intended to provide data like that obtained in the previous tests, while the single point train would provide data to assess possible stratification of particulate, and variability in that stratification, at the test location. Also included were tests at reduced boiler load in order to obtain lower duct velocity and determine any effects on particulate stratification. Results from the second RCA test (RCA #2) showed that 5 of the 6 data points obtained at full boiler load fell within the ± 25% tolerance interval of the first RCA correlation relation. These 5 runs had a nearly constant particulate stratification ratio, ranging from 0.57 to 0.63 (see **N OTE**  

### ). The remaining run had a higher stratification ratio of 1.09 and fell within the tolerance interval of the initial correlation relation. This finding offers a plausible explanation for why the RCA #1 data did not fall within a 25% tolerance interval of the initial correlation relation (i.e., the stratification ratio may have been different in the two sets of tests). Sufficient data are not available to confirm this explanation, but the difference may be related to the location of the perturbing device and its possible effect on the particulate stratifications and/or particle size distribution, as discussed below.
**N OTE** 



### — Particulate stratification ratio is the particulate concentration measured by a single point sampling train divided by the concentration measured by a simultaneous multipoint traversing train.
The second RCA test also included 6 runs at reduced boiler load, and 5 of these 6 runs did not match any of the previous test results (i.e., did not fall within a ± 25% tolerance interval of either the initial correlation or the RCA #1 correlation) even though the stratification ratio wasMRI-OPPT\\R4703-02-07 Revised.wpd 

### ES-4

essentially the same as in 5 of the 6 full load tests. Thus, the reduced boiler load test results provided an indication of changes in particulate characteristics and consequently the response of the three specific PM-CEMS used in this test program, as explained further in this report. Results from the second RCA certainly showed that the particulate concentration is stratified when the perturbing device is open in order to increase the particulate concentration (as was done for the initial correlation relation testing and the RCA tests). Close proximity of the perturbing device and baghouse compartment outlet ducts to the PM-CEMS was undoubtedly the cause of the stratification. As far as the primary objective of this project is concerned, the test results have shown that the three PM-CEMS did meet the draft PS-11 initial correlation criteria, but did not meet the draft Procedure 2 criteria for either of the two RCA tests. One peer reviewer of this report believed that close proximity of the PM-CEMS to the baghouse outlet and perturbing device (i.e., stratification) was the cause of the non-agreement of the two RCA test results with the initial correlation. Conversely, a second reviewer stated that he was not convinced by the information presented in the report that stratification was responsible for the non-agreement. A third reviewer stated that the initial correlation and RCA data suggest that several different correlations exist. These comments illustrate the fact that no definite conclusion can be made as to the cause of the non-agreement of the results. It should be noted that one of the objectives of the project was to determine whether the PM-CEMS satisfy all the requirements of draft PS-11 and draft Procedure 2, or determine if changes are needed in those requirements. As a consequence of the non-agreement discussed above, and related uncertainty about the effects of the perturbing device on the test results, one of the changes that has been recommended in PS-11 is to allow correlation data to be collected over the normal range of a facility’s emissions (without using a perturbing device), even if thatMRI-OPPT\\R4703-02-07 Revised.wpd 

### ES-5

range is very narrow (e.g., a baghouse outlet). However, extrapolation of the resulting correlation relation is limited to 125% of the highest PM-CEMS response, above which additional data must be collected. It is believed that this recommended change in draft PS-11 will help avoid problems that may be associated with artificially increasing PM emissions (for correlation test purposes).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-1



# Section 1. Introduction 1.1 Summary of Test Program

1.1.1 Overall Purpose of the Program EPA’s Office of Air Quality Planning and Standards (QAQPS) is considering the possible use of particulate matter continuous emission monitoring systems (PM-CEMS) in future standards. Also, states may require them for State Implementation Plans (SIP) and Economic Incentive Program (EIP) monitoring, and industry sources may use PM-CEMS for Title V monitoring. EPA therefore desired evaluation of PM-CEMS technology on a long-term, continuous basis. The purpose of this demonstration program was to assess the performance of PM-CEMS over an extended time (i.e., 6 months). The objectives of this EPA-sponsored PM-CEMS demonstration were to:

• Demonstrate whether the PM-CEMS can provide reliable and accurate information over an extended period of time

• Evaluate the PM-CEMS for durability, data availability, and setup/maintenance requirements1

### PS-11, Performance Specification 11—Specifications and Test Procedures for

Particulate Matter Continuous Emission Monitoring Systems in Stationary Sources (draft Revision 4, November 1998). 2

### Procedure 2—Quality Assurance Requirements for Particulate Matter Continuous Emission Monitoring Systems (40 CFR 60, App. F, draft Revision 2, November 1998).
MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-2 • Determine whether the PM-CEMS satisfy all the requirements of draft PS-11 1

### and QA criteria specified in draft Procedure 2,2

### or determine if changes are needed in the requirements of PS-11 and/or Procedure 2 Other related objectives of the project were to:

• Determine if the PM-CEMS exhibit at least 80% data availability

• Document PM-CEMS maintenance requirements and operating and maintenance (O & M) costs

• Determine if the PM-CEMS correlation remains true for a long period of time after initial correlation, per draft Procedure 2

• Determine reliability and accuracy of the moisture CEMS This report presents all the results of the project with emphasis on the results of the initial correlation testing and comparison with results from the first and second RCA/ACA. The report also contains daily results for the PM-CEMS during the entire period from July 20, 1999, to February 16, 2000, and data availability during that period (excluding the period of September 15-October 7, 1999, when no data were available due to Hurricane Floyd and associated plant shutdown).3

### 40 CFR 60, Appendix A, Method 17—Determination of Particulate Emissions from Stationary Sources (In-Stack Filtration Method).
MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-3 All of the initial correlation testing and RCA testing involved manual reference method determination of particulate concentration, which was carried out in accordance with EPA Method 17 (M17). 3



### 1.1.2 Test Site The test site was Cogentrix of Rocky Mount, Inc., located in Battleboro, NC. Cogentrix is an electric utility cogeneration plant consisting of four identical boilers powering two electric generating units. Each generating unit is rated at approximately 55-60 megawatts, for a total plant electrical capacity of 115 megawatts. Each of the generating units is powered by a pair of Combustion Engineering stoker-grate power boilers designated as Boilers A and B. Figure 1-1 is a simplified schematic of the generating unit effluent flow. Each of the four boilers fires bituminous coal and is rated for 375 million BTU/hr heat input and 250,000 lb stream/hr output. The combustion flue gas from each boiler passes through a mechanical dust collector and a Joy Technologies, Inc. dry SO2 

### absorber (scrubber) before entering the Joy Technologies pulse-jet fabric filter (baghouse) for particulate control. The effluent from each pair of boilers is combined downstream of the baghouses, exhausting through a common stack. Testing was carried out on Unit 2-A boiler/baghouse.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-4 **Figure 1-1. Unit 1 Effluent Schematic (Units 1 and 2 are identical)**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-5

1.1.3 Summary of CEMS Evaluated For this PM-CEMS demonstration project, EPA purchased a total of three PM-CEMS from two vendors. The following criteria were used by EPA to choose the PM-CEMS:
1. EPA wanted to demonstrate the viability of both a light scattering type and beta gauge type PM-CEM and wanted at least one duplicate technology. 2. EPA wanted instruments that had been previously demonstrated on another test. 3. EPA wanted instruments capable of doing an automatic daily zero and upscale calibration drift check. 4. EPA wanted instruments that were commercially available (i.e., no prototypes). EPA decided to use the following PM-CEMS:

• Environmental Systems Corporation (ESC) model P5B light-scattering type PM-CEM,

• Durag model DR 300-40 light scattering type PM CEM,

• Durag model F904K beta gauge type PM CEM. Descriptions of the PM CEMS are provided below. In addition to the three PM CEMS, one additional CEMS, for monitoring stack gas moisture, was used (Vaisala HMP 235 moisture CEMS).

1.1.3.1 ESC P5B PM CEM The Environmental Systems Corporation model P5B light-scattering type PM-CEMS detects particulate matter in the stack by reading the back-scattered light (175 E

### ) from a collimated, near-infrared light emitting diode (LED). Since this instrument measures in the nearMRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-6

infrared, it is less sensitive to changes in particle size, and it has a roughly constant response to particles in the 0.1 to 10 μm range. The P5B does have an interference from condensed water droplets in the gas stream. This instrument’s measuring range is 0.5 mg/m 3

### up to 20,000 mg/m 3 

### , and it has dual range capability; however, the dual range feature was not used for this demonstration. The measuring volume is located 4.75 inches from the physical end of the probe that contains both the transmitting and receiving optics. The P5B is inserted into the flow through a four-inch port and flange with a bolt hole at the 12 o’clock position. The probe is purged with air to keep the optics clean and cool. The P5B does automatic zero and upscale drift checks tomeet daily QC check requirements. This instrument was evaluated by EPA/OSW at the longterm field test at the DuPont Experimental Field Station incinerator. The prototype to this instrument was evaluated at a secondary lead smelter by the University of Windsor in 1976- 1977. ESC has sold over 100 of these instruments worldwide.

1.1.3.2 Durag DR 300-40 PM CEM The Durag model DR 300-40 light scattering type PM-CEMS detects particulate matter in the stack by reading the light scattered by the particulate at 120 E

### . The light beam is generated by halogen lamp (400-700 nm) modulated at 1.2 kHz. The Durag DR 300-40 is sensitive to changes in particle characteristics (e.g., size, shape, and color) and presence of condensed water droplets in the gas stream. This instrument’s measuring ranges are dependent on the size of aperture installed, and are approximately from 0 to 1 mg/m 3

### up to 0 to 100 mg/m 3 

### . Within a measuring range, the Durag DR 300-40 has three sensitivity levels and automatically moves from one level to the next, where each level is 3 times less sensitive than the previous level. The data acquisition system calculates a “range adjusted” mA value that allows for a continuum in the output as the instrument changes levels. The equations that are used to calculate the range adjusted milliamps are shown below, along with the actual milliamp range and corresponding range adjusted milliamps.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-7 Equation Actual mA range Range adjusted

values Level 1 As read 4.00-20 4-20 Level 2 Range adjusted mA = 3(mA-4) +4 9.33-20 20-52 Level 3 Range adjusted mA = 9 (mA-4) +4 9.33-20 52-148 The sample volume for the DR 300-40 is located in an area 3 to 11 inches (centered at 6 inches) from the face of the instrument . Both the light source and the detector are located in a single unit, thus requiring only one point of access (i.e., a 5-inch by 12-inch rectangular flange is welded to the duct wall). The DR 300-40 does automatic zero and upscale drift checks to meet daily QC check requirements and provides automatic compensation for dirt on the optics (although the optics are protected by an air purge system). This instrument was approved by the German TÜV for all source categories, and it was evaluated by EPA/OSW at the long-term field test at the DuPont Experimental Field Station incinerator. Durag has sold over 500 of these instruments worldwide.

1.1.3.3 Durag F904K PM-CEM The Durag F904K beta gauge type monitor extracts a heated sample from the stack, transports the sample to the instrument, and deposits particulate on a filter tape during user defined sampling periods (e.g., 4 to 8 minutes). Sample is extracted from the stack at a single point under isokinetic conditions at the normal process operating rate (i.e., isokinetic sampling is not maintained as stack flow changes). The probe is inserted into the stack through a 6-inch port and standard flange. The F904K introduces dilution air after the sampling nozzle to (1) minimize particulate loss in the sampling system, (2) handle high dust loadings (> 200 mg/dscm), and (3) sample wet or saturated stack gas. The measuring range is determined by the length of the sampling period and the amount of dilution air introduced in the probe, but the instrument canMRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-8

accommodate a range of up to 6 to 8 mg of particulate deposited on the filter tape during each sampling period. Before and after each sampling period, the filter tape is moved between a carbon 14 ( 14

### C) beta particle source and Geiger-Mueller detector. The amount (in units of mg) of PM on the filter is determined by the reduction in transmission of beta particles between the dirty tape (after sampling) and the clean tape (before sampling). The attenuation of the beta particles is believed to be minimally sensitive to the composition of the particulate. The sampled gas is dried and the flow rate measured, thus allowing reporting of PM concentration on a dry basis. Further, the temperature of the dry sample gas is measured and the sample gas volume is corrected to standard temperature (20 E

### C). The F904K does automatic zero and upscale drift checks to meet daily QC requirements. The zero check is performed by measuring the same location on the filter tape twice in succession with tape transport between measurements, without collecting a sample. The upscale check is done by simulating beta attenuation at an upscale check value (i.e., 50% transmission). The simulation of beta attenuation is done by counting beta particles for 240 seconds and comparing that count to the count from the first 120 second zero measurement of the zero drift check. A typical sampling cycle requires 120 seconds for zero measurement, 19 seconds of tape transport, sampling period (300 seconds to 570 seconds), 19 seconds of tape transport, 120 seconds for sample measurement, 38 seconds for tape transport and print on tape. The cycle then starts over with a new tape zero measurement. The F904 version was approved by the German TÜV for all sources. The F904 version was evaluated by EPA/OSW at the long-term field test at the DuPont Experimental Field Station incinerator and by Eli Lilly (only during phase II) at a liquid waste incinerator.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-9

1.1.3.4 Vaisala HMP 235 Moisture CEM The Vaisala HMP 235 moisture monitor measures the relative humidity (RH) and temperature of the stack gas and calculates the absolute humidity in units of grams per cubic meter (g/m

3

### ). The two outputs from the instrument are absolute humidity ( 0 to 600 g/m 3

### ) scaled from 0 to 10 Vdc and temperature (–20 E

### C to 180 E

### C) scaled from 0 to 10 Vdc. RH is detected with a HUMICAP® H-sensor, and temperature is measured with a Pt 100 RTD. The HUMICAP® sensor operates on the principal of changes in capacitance between its thin polymer films as they absorb water molecules. The HMP 235's moisture readings were correlated to the Method 17 moisture results from the initial correlation tests and compared with results from the two RCA tests. Those results are presented in Section 5 of this report. Note: Vaisala does not market the HMP 235 as a stack gas moisture monitor. Themonitor’s application is in less harsh environments (e.g., food production processes) than coalfired boiler exhausts. Therefore, Vaisala would not guarantee the HMP 235's performance for monitoring stack gas moisture. Vaisala indicated that the corrosive nature of stack gas environments might destroy the thin polymer films that detect the amount of water molecules in the air. A Vaisala technical representative estimated that the HUMICAP® sensor would last for two to three months in a 50 ppm SO2

### and 50 ppm NOx

### stack gas. At that point, the approximately $250 sensor would have to be replaced. Noting the potential use of this instrument as an accurate and economical stack gas moisture monitor, EPA decided to examine the HMP 235 as a stack gas moisture monitor during this test program. During this test program, the same HUMICAP® H-sensor was used for the entire period.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-10

1.1.4 Emissions Measured Emissions measured in these tests were particulate and moisture. Particulate emissions determined by the M17 tests were calculated in mg/dscm and then converted to units corresponding to those measured by each of the PM-CEMS (mg/acm for the light scatter CEMS and mg/dscm for the extractive beta gauge PM-CEM). Moisture measured by the dual M17 trains, in percent by volume, was used directly for correlation with the moisture CEM.

1.1.5 Dates of Tests This report covers operation of the CEMS during the 6-month endurance test (July 20, 1999-February 16, 2000). It also covers the initial correlation tests and the two RCA/ACA tests. Nine preliminary runs were carried out over the period of July 9-14 which were used only for assessing the range of emissions and setting the measurement range on the PM-CEMS. Thereafter, a total of 15 runs (Runs 10-24) were carried out during the period of July 15-19 for the initial correlation tests. The first RCA/ACA test (12 runs) was carried out on August 26-31, 1999. The second RCA test (12 runs) was done on November 16-20, 1999. Results presented later in this report are from each of these three sets of tests and refer to the run numbers within each test. The numbering of runs was as follows:MRI-OPPT\\R4703-02-07 Revised.wpd 

### 1-11 Initial Correlation Tests Runs 13-24 (See Note) First RCA Runs 1-12 Second RCA Runs 31-42
**N OTE** 



### — Runs 10, 11, and 12 were originally excluded from the initial correlation results, as explained later in this report.



# 1.2 Key Personnel
The key personnel who planned and coordinated the test program are:

• Dan Bivins EPA Work Assignment Manager (919) 541-5244

• Paul Gorman Work Assignment Leader for

Contractor (MRI) (816) 753-7600 x1281

• Craig Clapsaddle CEM Task Leader for Contractor (MRI) (919) 851-8181 x5342

• Tracy Patterson Air Quality Manager—Cogentrix (804) 541-4246

• Steve Carter Plant Manager—Cogentrix (252) 442-0708

• Mike Chaffin I&C Supervisor—Cogentrix (252) 442-0708MRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-1



# Section 2. Sampling Location 2.1 Flue Gas Sampling Location The PM-CEMS and manual particulate sampling (EPA Method 17) locations are in the flue gas duct exiting the fabric filter as shown in Figure 2-1, where it can be seen that the PM-CEMS were located only about 2 diameters downstream from the 90 E 

### bend in the baghouse outlet duct. This rectangular duct has inside dimensions of 5 N 

### 6 O 

### x 4 N 

### 9 O 

### with the CEMS (and M17 ports) located on the 4 N



### 9 O 

### wall, as shown in Figure 2-2 and Figure 2-3. In this rectangular duct, the gas flows downward toward the inlet to the induced draft fan. The duct is under high negative pressure (–20"H 2

### O). For the second RCA/ACA test, Cogentrix installed one additional M17 sampling port (port F), which was used only for the single point M17 sampling train as shown in Figure 2-3. A schematic diagram of the baghouse outlet duct, showing the location of the perturbing device, is given in Figure 2-4. The ESC P5B probe extends 10" inside the duct, with the “sample volume” 5" further into the duct. It is 10" from the right side wall and 159" downstream from the 90E 

### duct bend. The Durag DR 300-40 is mounted on the stack wall, extending 2" outside the wall. The “sample volume” covers 3" to 11" from the instrument; thus, the “sample volume” is 1" to 9" inside the wall. It is 13" from the left side wall and 132" downstream from the 90E 

### duct bend. The Durag F904K probe extends 24" inside the duct wall, and the probe is fitted with a 5- mm nozzle that provides near isokinetic sampling at the duct velocity of 90 ft/sec. However, the sampling rate is not adjusted to maintain isokinetic sampling as velocity in the duct changes. It is 15" from the right side wall and 128" downstream from the 90E

### duct bend.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-2 82 

### "

1 28 

### "

1 59 

### "

69 

### " 5 

### ′ 6

### ′′ B ag h o u se O ut l et D u c t

M 1 7 S am p l i n g P o r

t s 1 2 

### " U p p e r Pl a t f o rm

D u r ag Bet a G a u g e Pr o be ( 1 28 ”) D u r ag Li g ht Sc atte r C E M ( 1 3 2”)

L owe r Pl atf o rm

T o I D Fa n E S C Li g h t S catte r C E M M o i st u re M o n i t o r P ro b e

2 00 0

. 52 1 -1 G as F lo wMRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-3 **Figure 2-1. Location of CEMS and M17 Test Ports (Elevation Side View)**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-4 200 0

. 5 2 1 - 2

B eam 4′9 " I D

1 2 " M 1 7 S am p l i n g Po r t s
U p pe r g r at e i n g
5 -1 1 /1 6" 1 7- 1 /

8 " 28- 1 /

2 " 39 - 7 / 8" 5 1 - 5

/ 1 6" 9 " F90 4K Du rag B e

ta G u ag e P M
- C EM S P rob e
1 5 "

36 "

1 0 "

P 5 B E S C l i gh t s catte r P M
- CE M S L o w er be am V

a i s a l a H M P 2 35 H 2O mo n i to r D R 30 0-40 Du r a g Li gh t Scatte r PM
- C EM S 1 3" 1 3 2" 1 59 " 1 28 " 8 2" B otto m of B ag h o u s e O ut l et D u c

t

A B C D E F S i n g l e P o i nt M 1 7

S am p l i n g P o r

t G as F l owMRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-5 N ote: V a l u es i n pa ren t he s i s a r

e t he a ve rag e sta c k ve l o c it

y at e a c h p o i nt , i n m/m i n . , as me as u red du r i ng t he i n it i al co rre l a t i o n te sts . 

# X d e pi cts th e “sa m p l i n g l o cati on ” of t he C E MS i n t he d uct
. d e pi cts t he sam p li ng po i n t fo r t h e s i n g l e p o i nt M 1 7 t r a i n . de p i ct s t h e sa m p l i n g p o i nts for t he M 1 7 t ravers i n g t r a i n . 

## B

2 0 00

. 5 2 1 - 3 

### 4 ′9 " Sam pl i n g po r ts (4 " p i pe n i p p les )



### 2 8

. 5 "

1 7
. 1 "

5
. 7 " 5 ′ 6" 1 3

. 2" 1 3

. 2 " 6

. 6" 

## E

D

C

A 

# X F 90 4 K 

# XX

E SC
- P5 B ( 2 1 3 3) ( 22 1 1 ) ( 2 2 1 1 ) ( 1 78 9 ) ( 63 6 )

( 20 9 3) ( 20 9 3) ( 1 69 2 ) ( 1 23 1 ) ( 45 0 )

( 1 8 3 6) ( 20 5 2) ( 1 92 5 ) ( 1 1 6 1 ) ( 26 0 )

( 20 5 2) ( 1 9 6 9) ( 1 83 1 ) ( 1 22 1 ) ( 36 7 )

( 2 1 7 2) ( 2 1 3 3) ( 1 96 9 ) ( 1 53 6 ) ( 68 7 ) 

# X H M P2 3 5



# XXXX D R3 0 0- 4 0 

## F Samp l i n g po r t fo r si n g le po int tra i n 

### 2 0" 

### Figure 2-2. Location of CEMS and M17 Test Ports (Elevation Front View)

**Figure 2-3. M17 Sampling Points and CEMS Locations**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-6 2 00 0

. 5 1 2 T o I D Fan G as Fl ow

B ag h o u se O ut let D u ct

Bag h o u se I nl et D u ct Out l ets fr om eac h of 6 bag h o u se co m p

a rtm e nts (3 o n each si d e of o ut let d u ct)

I n l ets to each of 6 bag h o u se c o mpa r t me nts (3 o n eac h si d e of in l et d u c t )
Gas F lo w 6 " Ø I n s ul at ed B y pass Pe r

t u rb i n g Devi ce 30 F t
.



### Figure 2-4. Schematic Elevation Side View of Baghouse Inlet/Outlet Ducts and Perturbing DeviceMRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-7

The moisture CEM is equipped with a 48" long probe which extends 26" inside the duct wall.Based on the expectation that the particulate concentration at the sampling location exiting the fabric filter would be quite low, a “perturbing device” was installed by the facility for this project. This perturbing device consisted of an insulated 6" diameter pipe and butterfly valve that allowed a portion of the gas to be diverted from the inlet of the fabric filter to the outlet, thus raising the dust concentration in the outlet duct. This allowed adjustment (increase) of the outlet PM concentration to cover a range of particulate emissions for this project. The 6-inch insulated pipe was installed approximately 30 ft upstream of the 90 E

### bend in the outlet duct (See Figures 2- 1 and 2-4). It was discovered during the project that this distance may not have been sufficient to allow complete mixing of the PM from the perturbing device with the baghouse outlet flow prior to the PM-CEMS.



# 2.2 Sampling and Analytical Procedures The sampling/analytical procedures used for the initial correlation tests and RCA tests were determination of particulate and moisture concentration per EPA Method 17 (40 CFR 60, Appendix A) and associated requirements of draft PS-11 and Procedure 2. Two EPA Method 17 sampling trains were used in each run. Each train consisted of the following, along with an S-type pitot tube and thermocouple:

• Quartz nozzle

• 47 mm in-stack filter holder with quartz fiber filter

• Teflon ball cone check valve

• 10 ft. stainless steel probe

• 20 ft of thick wall latex tubing

• Impinger boxMRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-8

• Umbilical cord

• Sampling console (dry gas meter and pump) The two M17 sampling trains were operated simultaneously (except for a 2-minute offset) but were in different ports (i.e., simultaneous traverses were conducted). There were a total of 5 ports (shown in Figure 2-3) with 5 sampling points in each port, for a total of 25 traverse points. There was also a sixth port (port F in Figure 2-3) that was used for a single point sampling train. However, in the second RCA/ACA tests, one of the two M17 sampling trains was used to sample at a single point (see Figure 2-3) rather than traversing to sample all 25 points. All the M17 tests included determination of particulate and moisture concentration per EPA Method 17 (40 CFR 60, Appendix A) and associated requirements of drafts PS-11 and draft Procedure 2 (with the exception that precision was determined in only one run during the second RCA test because one train was used for single point sampling in all other runs). Analytical procedures for the M17 samples are shown in Figure 2-5.



# 2.3 Process Sampling Locations No process samples were collected for this test program, but the facility did provide a computer printout of selected process operating data once every 15 min during each M17 test period.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 2-9 P l a c e i n d e s s i c a t o r C o n t a i n e r N o . 1 : F i l t e r

W e i g h f i l t e r t o n e a r e s t 0

. 1 m g
. C l e a n o f f d u s t f r o m e x t e r n a l s u r f a c e o f p r o b e n o z z l e a n d f i l t e r h o l d e r . R i n s e a n d b r u s h t h e n o z z l e a n d i n s i d e o f f i l t e r h o l d e r 3 t i m e s w i t h a c e t o n e i n t o g l a s s c o n t a i n e r .

E m p t y c o n t e n t s i n t o 2 5 0 m l b e a k e r w i t h t a r e d t e f l o n l i n e r . E v a p o r a t e t o d r y n e s s a t r o o m t e m p e r a t u r e . D e s s i c a t e f o r 2 4 h o u r s . W e i g h t o c o n s t a n t w e i g h t
. C o n t a i n e r N o . 2 : A c e t o n e R i n s e o f n o z z l e a n d f i l t e r h o l d e r W i p e o f f o u t s i d e o f e a c h i m p i n g e r , t h e n w e i g h o n f i e l d b a l a n c e t o d e t e r m i n e w e i g h t o f m o i s t u r e c o l l e c t e d

. I m p i n g e r s a n d S i l i c a G e l

N o t e : B l a n k f i l t e r s a n d a c e t o n e b l a n k a r e a n a l y z e d t h e s a m e a s s h o w n f o r s a m p l e s . 

### Figure 2-5. Analytical Scheme for M17 Train ComponentsMRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-1



# Section 3. Installation and Start-up of the CEMS
For the purchase of the three PM-CEMS, a technical specification was written by MRI and sent to the vendors. The vendors responded to the specification with their proposals, and MRIissued purchase orders for the ESC P5B light-scattering PM-CEM, the Durag DR 300-40 lightscattering PM-CEM, and the Durag F904K beta gauge PM-CEM on May 20, 1998. As noted earlier, these PM-CEMS were selected for the following reasons:
1. Each successfully worked on another demonstration test 2. Each does an automatic daily zero and upscale calibration drift check 3. All are commercially available In addition to the three PM-CEMS, a Vaisala HMP 235 moisture monitor was purchased. The purchase prices for the CEMS and the data acquisition system are listed in the following table, which includes labor costs for programming the computerized data acquisition system as discussed in Section 3.2.

CEM model Base price Additional items ESC P5B $12,750 $925 for non-standard 6 foot probe Durag DR 300-40 $15,500 None Durag F904K $36,515 $550 for stainless steel sample line $120/ft for flexible sample line $915 for temperature controller for flexible line $2,375 for reinforced cabinet $4,200 for cabinet air conditioner $1,765 for filter tape printer Vaisala HMP 235 $2,345 $10 for 6 foot power cord Fluke Wireless Data Logger 2625 A/WL $6,100 $500 for two UPS unitsMRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-2 Programming of data acquisition system $12,000


# 3.1 CEMS Delivery In the PM-CEM vendor’s proposals, they provided their lead time for delivery of the instruments. Based on each vendor’s delivery schedule, MRI requested the following delivery dates:

PM-CEM model Delivery date P5B June 21, 1998 DR 300-40 June 05, 1998 F904K July 16, 1998 

### Since the selection of the test site was delayed, the vendors were not strictly required to meet the delivery dates. The P5B was complete and ready for shipping to MRI by mid- June, 1998, but the vendor requested and was given extra time to complete upgrades to the instrument. The P5B was received by MRI on August 19, 1998. The DR 300-40 was received by MRI on July 14, 1998. The F904K arrived in the Durag, USA, office from Germany on July 22, 1998, and Durag personnel completed work on the instrument and finalized the operating manual. The F904K was scheduled for delivery to MRI on October 27, 1998; however, circumstances unrelated to the instrument delayed delivery until December 2, 1998.



# 3.2 Functional Acceptability Testing After receiving the instruments at MRI’s facility, and before shipping them to the test site, MRI conducted functional acceptability testing (FAT) on each CEM. The FAT consisted of the following:MRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-3

1. Unpacking and starting up each CEM according to the manufacturer’s instructions 2. Wiring the signal and alarm status outputs to the datalogger 3. Logging instrument output by the data acquisition system (DAS) 4. Initiating and recording zero and upscale calibration drift checks 5. Initiating and recording alarms 6. Conducting a 7 day drift test on the PM-CEMS 7. Checking the calibration of the HMP 235 moisture monitor against EPA Method 4 8. Developing a sample volume audit procedure for the F904K At the conclusion of the FAT, the instruments were repackaged for shipment to the test site. Conducting the FAT led to a much smoother installation and start-up of the PM-CEMS in the field. The FAT of each PM-CEM required approximately the following man-hours to complete:

PM-CEM FAT Man-hours P5B 14 DR 300-40 16 F904K 24


### The PM-CEMS were connected to the data acquisition system and computer during the FAT period at MRI, and a program was written to provide all the necessary data logging capabilities. They included the following:

• Converting all CEM signals (mA) to computed values (e.g., mg/acm)

• Computing average 1 min values for readings taken every 15 sec

• Logging all 1 min avg values and daily calibration drift values

• Storing all 1 min readings every 24 hrsMRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-4

• Handling error signals from the PM-CEMS and flagging all associated data

• Providing on-line graphing of PM-CEM readings for any selected time interval, including historic data (i.e., date for days prior to the current day)

• Loading the commercially available program titled “Remotely Possible” so that data could by viewed and/or downloaded from other MRI offices (the test site office trailer containing the computerized data acquisition system was unattended during most of the 6 month test period). The programming effort involved many details requiring several person-days of effort, at a cost of $12,000. This allowed debugging of the system at MRI, which considerably shortened the start-up time for the system when it was installed on site.



# 3.3 Installation at the Test Site The CEMS were shipped via common carrier from MRI in Kansas City, Missouri, to the test site in North Carolina. The boxes were stored at the test site until MRI’s installation team arrived. Test site personnel (Cogentrix) made the following site modifications in preparation for the CEMS installation and initial correlation testing:
1. Installed five new ports for the Method 17 testing 2. Installed a new port for the DR 300-40 3. Installed a new port for the F904K 4. Installed an extension to an existing port for the P5B 5. Installed approximately 25 feet of 6-inch pipe and a multi-position butterfly valve to bypass particulate from the inlet duct (dirty-side) to the outlet duct (clean-side) of the baghouseMRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-5

6. Installed a transformer and 60 amps of electrical power for the CEMS, Method 17 testing, and an office trailer Preparation effort by the test site personnel required approximately the following man-hours to complete:
Activity Preparation Man-hours Install five new ports for the Method 17 testing 12 Install a new port for the DR 300-40 6 Install a new port for the F904K 3 Install an extension to an existing port 2 Install approximately 25 feet of 6-inch pipe and a butterfly valve 10 Install a transformer and 60 amps of electrical power 20



### For the installation effort, a crane was used to hoist four large boxes onto a platform about 50 feet above grade. The CEMS and supporting materials (e.g., tools, datalogger, computer, etc.) were unpacked and placed in their installation areas. Approximately 10 man-hours were needed to get the CEMS and supporting materials in place and ready for installation. The CEMS and DAS were installed and started up according to the manufacturer’s instructions. The installation and start-up effort required approximately the following man-hours to complete:

PM-CEM Installation Man-hours P5B 6 DR 300-40 8 F904K 24 1 HMP 235 2
1 Estimate of hours under normal circumstances. See discussion below about start-up issues.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-6

Connecting all of the data communication and alarm wires and starting the datalogger and DAS required an additional 6 man-hours.



# 3.4 Start-up Issues Startup of the P5B, DR 300-40, HMP 235, and datalogger/DAS proceeded without incident. As noted above, conducting the FAT before shipping the PM-CEMS to the test siteexpedited the start-up effort. The following two major problems were experienced during startup of the F904K:
1. Water passed through the conditioning system and flooded downstream components
2. Sample gas could not be extracted from the extremely negative pressure duct (about –23 inches W.C.) when using dilution air MRI and Durag personnel expended about 48 man-hours trying to rectify the problems. Eventually, Durag personnel removed the instrument and transported it back to their office to redesign the sampling system and repair the problems. The problems were corrected by:
1. Replacing the leaking moisture condenser 2. Replacing the carbon vane pump that was damaged by the water 3. Moving the dilution air control valve from the exhaust side to the dilution side 4. Replacing the old electronic control system (motherboard with EPROMs programmed in a cryptic language) with a state-of-the-art programmable logic controller (PLC) system The upgraded instrument was delivered to the test site and reinstalled by Durag personnel. Start-up of the redesigned instrument proceeded without incident and the instrument operated properly. The reinstallation and start-up required about 12 man-hours of effort.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 3-7

A few other problems with the PM-CEMS and moisture CEM did occur during the subsequent 6-month endurance test period, which are described in the next section.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-1



# Section 4. Durability, Availability, and Maintenance Requirements for CEMS Data availability and maintenance requirements have been recorded throughout the 6-month endurance test period of July 20, 1999, to February 16, 2000. During the subject period, operation of the CEMS was interrupted by Hurricane Floyd, which flooded the transformer where Cogentrix ties into the electrical grid system. Therefore, the plant was off-line from September 16 to about October 3, 1999. The CEMS were restarted on October 7, 1999. After the system restart, several CEMS problems occurred. The maintenance and data unavailability for each monitor during the 6-month period are listed below, excluding the hurricane period. Also excluded are the short periods each day (approximately 5-10 min) for the automatic zero and upscale drift checks, and three short periods of data unavailability (30-60 min) when MRI performed an ACA on the ESC-P5B and Durag DR 300-40. (The Durag F904K did not include any reference standards for performing an ACA.)



# 4.1 ESC-P5B

• Data were unavailable for approximately 30 min on August 23, 1999, while the drift problem was corrected.

• The instrument experienced some upscale drift problems during the 6-month period. The number of daily upscale drift checks that exceeded 2 percent are presented in Table 4-1 and the corrective actions are discussed below.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-2 **Table 4-1. Levels of Upscale Calibration Drift for the ESC P5B** Upscale drift exceeded Number of days

2% 101 days 3% 65 days 4% 24 days 5% 6 days 6% 1 day



### • On October 13 and 14, the upscale calibration drift was 6.17% and 5.50%, respectively. Therefore, on October 15, the lenses and purge air filter were cleaned. The reference calibration was reset, and the upscale calibration drift was reduced to 0.75%. During this procedure, 30 min of data were lost.

• Since the filter for the purge air is located inside the instrument’s protective housing, ambient air that is used for purge air is drawn into the housing. In the power plant environment, fine particulate in the ambient air collects on all of the instrument’s components inside the protective housing. MRI recommends locating the purge air filter separate from the rest of the instrument.

• On October 20, the purge air filter was replaced. No data were lost during this procedure.

• On November 9 and 10, the upscale calibration drift was 5.08% and 4.08%, respectively. Therefore, on November 11, the lenses were cleaned again, and the upscale calibration drift was reduced to 0.92%. During this procedure, 15 min of data were lost.

• On November 20, the lenses and purge air filter were cleaned, resulting in 12 min of lost data.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-3

• On December 1 and 2 a malfunction error occurred because of low battery voltage. The lenses were cleaned and a battery was replaced (39 hr of data were lost). However, it is estimated that no more than 24 hr of data would have been lost if plant personnel were responsible for such instrument problems. The replacement battery was not a spare part and was shipped overnight from ESC.

• December 10 and 30 the lenses were cleaned to correct drift problems. During each cleaning procedure, 14 min and 12 min of data were lost, respectively.

• January 11 and 19 the lenses were cleaned to correct drift problem. During each cleaning procedure, 14 min and 13 min of data were lost, respectively.

• During the period of January 30 through February 6 the upscale daily drift exceeded 4% and thus was out of control for 2 days. As a consequence, 2 days of data were lost.However, this lost time would not have occurred at a permanent installation of the PMCEMS where plant personnel were responsible for correcting such problems.



# 4.2 Durag DR 300-40

• Data were unavailable for approximately 60 min on August 26, 1999, while the shutter mechanism was repaired.

• During the calibration drift check, conducted on Saturday, October 16, 1999, the contamination rate value (i.e., dirty window check) exceeded a preset internal limit. This error caused the instrument to actuate the data flag “OFF,” and the data were considered suspect. MRI personnel traveled to the site and corrected the error by cleaning the protective lenses and initiating the calibration cycle on Wednesday, October 20. About 4MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-4 days of data were lost. By contrast, we estimate that no more than 4 hours of data would have been lost if plant personnel had the responsibility of responding to instrument errors.

• During the February 9 calibration drift check a “dirty window” error occurred. On February 10 the reference filter was cleaned to correct the problem, which took about 1.5 hr. The flag was active for about 29 hr before the reference filter could be cleaned. However, the data were still valid.



# 4.3 Durag F904K

• The cabinet air conditioner unit was not working when the system was restarted on October 7 (after the hurricane). The air conditioner was removed and sent back to the manufacturer. The problem was the compressor, and repairs, including shipping, cost about $300. Removing and replacing the air conditioner required about 4 man-hours. The air conditioner was out of service for 14 days, but the monitor continued to function without the air conditioner.

• When the system was restarted on October 7, a high pressure air hose inside the cabinet had become disconnected. The hose was reattached using the original hose clamp.

• On October 11, the roll of filter tape was expended, and a new roll was installed on October 12. Approximately 15 hours of data were lost; however, we estimate that no more than 4 hours of data would have been lost if the plant’s personnel were responding to instrument errors.

• On October 12, about 9 hours after the filter tape was replaced, the high pressure air hose became disconnected again. This problem caused a vacuum error, and the instrument automatically shut down. MRI responded to this error on October 15 andMRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-5 reconnected the hose. Approximately 3 days of data were lost due to this problem; however, we estimate that at most 4 hours of data would have been lost if the plant’s personnel were responding to instrument errors.

• On October 15, about 8 hours after reconnecting the high pressure air hose, it became disconnected again, causing the instrument to shut down. MRI responded to this error on October 20 and installed a second hose clamp along with the original. About 4.5 days of data were lost due to this problem. We estimate that no more than 8 hours of data would have been lost if the plant’s personnel were responding to errors. (This estimate is longer than others because the error occurred late at night, just after 2300 hours.)

• On October 22 and 24 and November 8 the boiler went off-line and was then restarted. When the boiler is refired, the baghouse is bypassed, and the PM-CEMS experiences high concentrations of particulate in the duct. Each time the boiler was refired, the F904K would shut down due to high vacuum errors. This type of error occurred on October 22 causing about 3 days of lost data, on October 29 causing about 5 days of lost data, and on November 8 causing about 3 days of lost data. If plant personnel were responding to each of these errors, we estimate that no more than 2 hours of data would have been lost for each occurrence. (To help control the amount of lost data, MRI recommends that Durag design an automatic restart to activate one hour after a vacuum error shutdown.)

• Beginning on November 2, the F904K began to experience filter tear errors. Filter tears occurred on November 2, 9, and 12. Upon close inspection of the filter adapter, it was found that the left side of the adapter was not opening as far as the right side. When the filter tape was moved backward after a zero measurement, sometimes it would become pinched between the top and bottom of the filter adapter and tear down the middle. We found that the mechanism which pulls down the bottom half of the filter adapter had a worn part on the left side which was not allowing the mechanism to move downward asMRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-6 far as required. MRI had a new part made to replace the worn part, and we received a new mechanism as a spare. Troubleshooting and repair of this problem caused 3 days of lost data. (Since wear on part of the mechanism that opens the filter adapter caused the instrument to malfunction after about 6 months of continuous operation, MRI recommends that Durag redesign the mechanism.)

• During the November 11 maintenance visit, MRI discovered that the automatic and manual blowback of the sample line and probe was not working. During the second RCA, the blowback seemed to work intermittently but not as expected. This problem did not cause any loss of data but has not been solved.

• The F904K’s response to particulate concentrations during the first two days of the second RCA test program was not in agreement with the other two PM-CEMS or any of the previous test results. During investigation on November 17, MRI found that the resistance-heated stainless steel tube at the sample line/probe union had melted, and ambient air was leaking into the sample gas. Troubleshooting and repairing this problem required about 8 man-hours. At least 2 days of data were invalid because of this problem, and F904K data from the first four test runs of the second RCA test program were invalid. (Note that this problem would not have been discovered without comparing actual measured PM concentrations to the monitor’s results. This finding suggests that some amount of manual field sampling to verify the PM-CEMS values [e.g., 3 test runs done at 6- or 12-month intervals] should be done between full RCAs.)

• A new roll of filter tape was installed on August 31, after the first RCA, and the sample interval was increased from 8 to 9.5 min in order to use less filter tape and still complete a sample and reporting cycle every 15 min. Only 16 operating days had elapsed when the instrument was shut down because of the hurricane-caused flood. The instrument ran for 4 days after restart before the filter tape was depleted (i.e., 20 days of run-time on theMRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-7 roll of filter tape). A new roll of filter tape was installed on October 11, and that roll lasted until November 21.

• The roll of filter tape was replaced again on December 10 and 30, January 19, and February 7.



# 4.4 HMP 235 Moisture CEMS The moisture monitor experienced several maintenance issues and was unavailable for an extended period of time while it was sent back to the manufacturer for repair and recalibration. Details are presented below.

• On Friday, September 10, the moisture monitor values were erratic. MRI investigated this on Monday, September 13, and, through communication with the manufacturer, determined the problem was a cold solder junction on the RTD temperature probe. Thejunction was resoldered, and the monitor returned to proper operation. About 3 manhours were required to troubleshoot and repair the monitor. About 3 days of data were lost; however, we estimate that no more than 6 hours of data would have been lost if the plant’s personnel were responding to instrument errors.

• On Saturday, October 9, the moisture monitor began reporting -440% moisture. MRI responded on Tuesday, October 12, and, with the manufacturer, determined that the best course of action was to send the instrument back for repairs. About 4 man-hours were required to troubleshoot, remove, and ship the monitor. On November 11, the moisture monitor was reinstalled. The manufacturer (Vaisala) could not explain why the monitor did not work properly because it worked fine when they turned it on. The service technician suggested simply disconnecting the electrical power from the unit the next timeMRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-8 the problem occurred. Reinstallation effort was about 2 man-hours, and approximately one month of moisture data was lost.

• On November 15, the moisture monitor’s temperature values appeared incorrect. The probe was removed and the RTD was repaired. This effort required about 1 man-hour. The following day, the monitor’s moisture values were much lower than the moisture values from the Method 17 sampling runs (i.e., about 6% compared to 12%). The probe was removed, and the RTD junction was resoldered. This repair seemed to fix the problem, and the monitor’s moisture values returned to normal (12% H 2

### 0). This repair effort was about 1 man-hour. In total, approximately 33 hours of moisture data were lost due to these problems.

• Late on November 20 and into November 21, the moisture values gradually increased from 12% to about 36%. The probe was removed, and the relative humidity sensor was examined. A new sensor was installed, but it produced the same readings. The old sensor was reinstalled, and the probe was inserted back into the stack. The moisture values were normal. About 18 hours of moisture data were lost due to this problem.

• Two other periods of obviously erroneous readings occurred on December 7 and December 17, with about 14 hr of data lost.

• More erroneous readings started on December 25 and continued through December 28, 1999. A total of 94 hr of data were lost until a field repair could be made. However, it is estimated that only about 8 hr of data would have been lost if site personnel were responsible for correcting such problems.

• Erroneous readings again occurred on January 3 through January 11 and 192 hr of data were lost. Corrective action on January 11 included bracing the probe to help reduceMRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-9 vibration, which may have been the cause of all the erroneous reading problems. No further problems occurred thereafter (January 11 through February 16).


# 4.5 Summary A summary of each monitor’s data unavailability is presented in Table 4-2 (not including the period of the hurricane outage or the short periods of daily drift checks or performing the ACAs). Table 4-2 shows actual data unavailability and the estimated data unavailability. The estimated data unavailability is considered more realistic, in that it reflects what would be expected if on-site facility personnel were responsible for responding to problems and/or performing maintenance on the CEMS. The periods of estimated data unavailability shown in Table 4-2 were used to calculate the percentage of time that data were available for each CEMS, as shown in Table 4-3, for the entire period of July 20, 1999, to February 16, 2000. The total amount of time for that period is 212 days, but when the hurricane period is excluded (21 days), a period of 100% availability would be 191 days (4,584 hr). As shown in Table 4-3, all three PM-CEMS and the H 2

### O CEM exhibited data availability of over 80%. The two light scatter type PM-CEMS had on availability of over 99%, and the beta gauge type PM-CEMS had an availability of over 96%. The moisture monitor (HMP-235) had an availability of only 82% primarily because 30 days were lost when it had to be sent back to the manufacturer for repair as discussed in Section 4.4.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-10 **Table 4-2. CEMS Data Unavailability** Event Actual data unavailability Estimated data

unavailabilitya ESC P5B Aug 23—Clean lenses to correct drift problem 0.5 hr 0.5 hr Oct 15—Lenses and purge air filter cleaned

and reference calibration reset 0.5 hr 0.5 hr
Nov 11—Lenses cleaned 0.25 hr 0.25 hr Nov 20—Lenses and purge air filter cleaned 0.20 hr 0.20 hr Dec 1 to 2—Malfunction error; cleaned

lenses and replaced battery 39 hr 24 hr
Dec 10—Cleaned lenses to correct drift 0.25 hr 0.25 hr Dec 30—Cleaned lenses to correct drift 0.25 hr 0.25 hr Jan 11—Cleaned lenses to correct drift and replaced purge air filter 0.25 hr 0.25 hr
Jan 19—Cleaned lenses to correct drift 0.25 hr 0.25 hr Feb 7—Cleaned lenses to correct drift (drift out of control for 2 days, February 5 and 6, but this would not have occurred if site personnel were available to correct the problem) 48 hr 0.25 hr

TOTAL = 26.70 hr

Durag DR 300-40 Aug 26—Repaired shutter 1 hr 1 hr Oct 17—Contamination rate value over limit about 4 days 4 hr Feb 9 to 10—“Dirty Window” error. Cleaned

the reference filter 1.5 hr 1.5 hr
TOTAL = 6.5 hr

### Table 4-2 (Continued)

Event Actual data unavailability Estimated data

unavailabilitya

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-11 Durag F904K Oct 11—Filter tape replaced 15 hours 4 hr Oct 12—Vacuum error—high pressure air

hose off about 3 days 4 hr Oct 15—Vacuum error—high pressure air

hose off about 4.5 days 8 hr Oct 22—Vacuum error—boiler start-up,

high PM about 3 days 2 hr Oct 29—Vacuum error—boiler start-up,

high PM about 5 days 2 hr Nov 8—Vacuum error—boiler start-up,

high PM about 3 days 2 hr Nov 2, 9, 12—Filter tear error—repaired filter

adapter about 3 days 72 hr Nov 17—Low response—broken sample line at least 2 days 48 hr Nov 21—Changed tape 0.25 hr 0.25 hr Dec 10—Changed tape 0.25 hr 0.25 hr Dec 30—Changed tape 0.25 hr 0.25 hr Jan 19—Changed tape 0.25 hr 0.25 hr Feb 7—Changed tape 0.25 hr 0.25 hr TOTAL = 143.25 hr

### Table 4-2 (Continued)

Event Actual data unavailability Estimated data

unavailabilitya

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-12 HMP 235 Sept 10—Erratic moisture values—cold

solder junction problem about 3 days 6 hr

Oct 9—Erroneous moisture values (–440%)—sent back to manufacturer for repair about 30 days 720 hr

Nov 15—Erroneous temperatures 33 hr 33 hr Nov 20—High moisture values 18 hr 18 hr Dec 7—Erroneous readings* 7 hr 7 hr Dec 17—Erroneous readings* 7 hr 7 hr Dec 25—Erroneous readings* 94 hr 8 hr January 3 to 11—Erroneous readings* 192 hr 8 hr TOTAL = 807 hr * Erroneous readings were likely due to vibration of duct at probe location. Corrective measures were taken (on January 11, 2000) to reduce the vibration by bracing the probe. No erroneous readings occurred thereafter.

a Assumes on-site facility personnel would be available to respond to problems.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 4-13 **Table 4-3. Data Availability for Each CEMS**

CEMS Total estimated time of

data unavailability, from Table 4-2 (hours) Total time for period of July 20, 1999, to February 16, 2000, excluding hurricane (hours) Data availability (%) ESC P5B 26.70 4,584 99.4 Durag DR300-40 6.5 4,584 99.9 Durag F904K 143.25 4,584 96.9 Vaisala HMP-235 807 4,584 82.4MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-1



# Section 5. Presentation and Discussion of Results 5.1 Objectives and Test Matrix As was noted in Section 1, the primary objectives of this project were to:

• Demonstrate whether the PM-CEMS can provide reliable and accurate information over an extended period of time

• Evaluate the PM-CEMS for durability, data availability, and setup/maintenance requirements

• Determine whether the PM-CEMS satisfy all the requirements of draft PS-11 and QA criteria specified in draft Procedure 2, or determine if changes are needed in the requirements of PS-11 and/or Procedure 2 Other related objectives of the project were to:

• Determine if PM-CEMS exhibit at least 80% data availability (based on number of hours of usable valid results for each month)

• Document PM-CEMS maintenance requirements and operating and maintenance costs

• Evaluate a technique for perturbing (increasing) baghouse PM emissions.

• Determine if PM-CEMS correlation remains true for a long period of time after the initial correlation, per PS-11

• Determine reliability and accuracy of the moisture CEMSMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-2

As discussed later, the first RCA tests did not meet all of the criteria in Procedure 2 for any of the three PM-CEMS. It was determined that further testing was necessary to investigate the reason for the difference between the initial correlation test results and the results from the first RCA tests. Thus, the second RCA tests were carried out with two important differences from the first RCA/ACA tests. In the second RCA tests, two M17 sampling trains were again used in each run, but only one was a traversing train, while the other sampled at a single point. [However, one run (Run 33) was carried out with both trains traversing in order to check precision between the two trains.] The purpose of this was to determine if the concentration measured by the single point train was substantially different from that measured by the traversing train (i.e., particulate stratification) and, if so, determine whether the ratio of the concentrations was constant. If the ratio was not constant, it would indicate that the concentrations at the location of the PM-CEMS (which measure at a single point or small area) would not necessarily be represented by the concentration measured by an M17 traversing train. If the ratio was constant, the stratification would automatically be accounted for in the correlation. A variable ratio of single point M17 measurements to M17 traversing measurements would provide a plausible explanation for why the results of the first RCA did not meet Procedure 2 criteria for agreement with the initial correlation. A variable ratio would indicate that particulate from the perturbing device (high concentration) is not well mixed with the particulate from the baghouse compartments (low concentration) prior to the location of the PM-CEMS, and the extent of mixing is variable (i.e., shifting stratification). The initial correlation tests and first RCA tests were carried out with all runs being at or near full boiler load. Full boiler load conditions had a steam flow rate between 268-291 K lb/hr. In the second RCA, some runs were purposely done at reduced boiler load in order to obtain data at lower gas flow rates, which could affect particulate stratification. The reduced boiler loadMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-3

conditions (i.e., low load-LL) had steam flow rates of near 205 K lb/hr. This reduction in boiler load resulted in about an 18% decrease in the average fine gas volumetric flow rate.


# 5.2 Field Test Changes and Problems Some field test changes were made to correct problems before and during the initial correlation tests and the RCA tests, as discussed below.

5.2.1 Initial Correlation Test Changes and Issues There were four field test changes and/or problems in the initial correlation tests as described below.

5.2.1.1 Durag Beta Gauge Changes Prior to any testing, problems with one of the PM-CEMS (Durag F904K beta gauge) necessitated major changes and repairs by the vendor as discussed previously in Section 4.

5.2.1.2 Re-ranging of PM-CEMSAn issue identified during the initial testing (Runs 1-9) was that the initial ranges of the PMCEMS were too wide; measuring up to four times the boiler’s emission limit of near 17.0 mg/acm. This meant that the PM-CEMS response at the emission limits was only about 6 mA. Therefore, it was necessary to decrease the ranges on the PM-CEMS (i.e., increase sensitivity) in order to expand the response to near 12 mA at the emission limit, but attempting to avoid exceeding the maximum response (20 mA) during momentary spikes in particulate concentration.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-4

The range for the ESC P5B was decreased to 0-20 mg. The range for the Durag DR 300-40 was decreased as much as possible by use of the maximum possible aperture (45 mm). The range for the Durag F904K was decreased to 0-20 mg/dm 3

### at standard temperature (20 E

### C). After completing this re-ranging, the initial correlation testing (Runs 10-24) was carried out.

5.2.1.3 Moisture Differences in M17 Results
Differences noted in H 2

### O content determined between the simultaneous dual M17 trains resulted in procedural changes that were implemented to help minimize the difference, as discussed in more detail later in this section.

5.2.1.4 Exclusion of Data for 3 Runs Preliminary graphing of the PM-CEM initial correlation test results was done in the field as data became available. But, only after results for the last 6 runs (Runs 19-24) were available did it become fairly obvious that there was something different about results for Run 10, 11, and 12. That is, these 3 runs did not appear to correlate well with the other 12 runs (Runs 13-24). Subsequent inquiries with plant personnel revealed that the facility was burning a different coal during runs 10, 11, and 12, which they referred to as “met coal.” This coal caused ash removal problems for the facility in operation of the boilers, but MRI was unaware of these problems at the time. Facility personnel indicated that receipt of “met coal” has occurred less than three times in the past 9 years, and they were considering refusing receipt of coal deliveries that included “met coal.” Because operation of the facility was atypical during these three runs it was decided to delete data for Runs 10, 11, and 12 from the PM-CEMS correlations. (However, the results from the subsequent RCA tests indicate that those data probably should not have been deleted, and they have been included in subsequent discussion of results in this report.)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-5

5.2.2 First RCA Test Changes and/or Problems There were no changes or problems of note. However, discrepancies were found between the initial correlation test results and the first RCA results, as discussed in detail in Section 5.3.

5.2.3 Second RCA Test Changes and/or Problems There were two changes made in the second RCA tests as described previously in Section 5.1 (i.e., use of a single point train and conducting some runs at reduced boiler load.) In addition, there were two other minor changes. The first was that the sampling period for the single point train (Train B) was changed slightly after Run 34 so that it sampled continuously, including short periods when the traversing train (Train A) was shut down for port changes. The second change was that the first run (Run 30) was an experimental run. Data from that run were not valid for use in any evaluation of the data from the second RCA tests. A total of 12 valid runs were carried out (Run 31-42) as planned. The only other problems were a few mechanical difficulties with the CEMS, as discussed previously in Sections 3 and 4.



# 5.3 Presentation of Results This section presents and discusses results from the initial correlation tests, the first RCA test, and the second RCA test, arranged as follows:MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-6

5.3.1 Process Data 5.3.2 M17 Test Results and H 2

### 0 CEM Results 5.3.3 PM-CEMS Daily Drift Test Data and ACA results 5.3.4 Initial Correlation and RCA Test Results 5.3.5 Investigation of Reasons for Non-agreement of RCA Results

5.3.1 Process Data Selected process data were printed out by facility personnel every 15 min during each test run. A summary of that data is given in Table 5-1A, B, and C, with more detailed data given in the Appendices. As shown in Table 5-1C, Runs 31-36 of the second RCA tests were carried out at near full boiler load (269-277 K lb/hr steam flow), whereas Runs 37-42 were at reduced boiler load (average steam flow of 199-217 K lb/hr). The reduced boiler load was sometimes steady (Runs 37, 38, 39) with steam flows of 200-210 K lb/hr, and sometimes variable (Runs 40, 41, 42) with increasing or decreasing steam flow during the test runs. (See Volume 4, Appendix A.)

5.3.2 M17 Test Results and H 2 

### O CEMS Results
5.3.2.1 M17 Sampling and Particulate Test Results Results for the two M17 trains (Train A and Train B) are summarized in Tables 5-2 A, B, C1, and C2 and in Tables 5-3 A, B, C1 and C2. (Tables C1 and C2 for the 2nd RCA tests contain results for the traversing train and single-point train.) Computer printouts of all results are given in Appendix B, and copies of field sampling data sheets are contained in Appendices C and D. Copies of post-test calibrations of the M17 sampling equipment are provided in Appendix E. (See Appendices Volumes 2, 3, and 4 of this report).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-7

It should be noted that the last two columns in Tables 5-3A, B, C1, and C2 are the M17 particulate concentration results that have been converted to units that are consistent with the PM-CEMS measurements, as stipulated in PS-11. It is these particulateMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-8 **Table 5-1A. Summary of Process Data for Each Run of the Initial Correlation Tests** * Date: July 15, 1999 July 16, 1999 July 17, 1999 July 18, 1999 July 19, 1999 Run no. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Steam Flow (klb/hr) 275.2 274.3 282.2 271.0 281.3 283.3 281.7 279.9 284.0 281.4 280.7 281.0 284.6 268.2 280.7 Steam Temp (deg F) 951 942 957 955 952 951 950 953 951 952 952 950 950 950 950 Coal Flow (lb/hr) 27755 25747 27998 27916 28695 25850 29892 26862 28527 28255 27524 27228 27765 25809 24219 Boiler 02(Avg) 3.5 4.1 3.2 3.5 2.9 2.7 3.2 3.6 3.7 3.1 4.2 3.3 3.2 3.5 3.0 East Undergate Air Flow (lb/hr) 128676 130096 130733 128824 132511 134389 134629 134781 133996 134853 133999 133560 136925 128456 129941 West Undergate Air Flow (lb/hr) 130777 130218 130834 128754 131928 133130 134112 133363 133820 134659 134057 133113 136150 128523 130108 Baghouse Inlet Temp (deg F) 186.8 185.2 191.7 185.1 183.9 184.7 183.1 186.1 183.2 185.2 185 183.7 184.8 189.6 186.1 Baghouse Outlet Temp (deg F) 187.8 184.6 184 180.9 186.9 180.9 179.8 180 180.6 179.7 180.2 180.2 179.3 179.6 179.8 Baghouse DP (in H 2 O) 6.9 6.8 8.1 7.4 6.6 6.9 6.7 7.2 7.4 6.3 6.9 6.7 6.8 6.3 7.1 ID Fan Suct. Press. (in H 2 O) –22.5 –23.2 –24.1 –22.9 –22.4 –23.9 –24 –23.4 –23.3 –23 –23.5 –23.8 –23.8 –21.6 –23.4 Stack Opacity 4.79 4.56 5.55 3.72 4.51 5.27 3.71 3.54 3.92 4.01 4.22 4.14 4.25 4.11 5.39 *Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-9 **Table 5-1B. Summary of Process Data for Each Run of First RCA Tests** * Date 8/26/99 8/27/99 8/28/99 8/29/99 8/30/99 Run No. 1 2 3 4 5 6 7 8 9 10 11 12 Steam Flow (klb/hr) 284.9 286.6 286.7 291.2 279.7 285.5 285.3 279.9 267.6 281.3 271.7 278.6 Steam Temp (deg F) 951 949 949 951 949 952 951 951 952 950 952 949 Coal Flow (lb/hr) NA NA NA 30,461 28,493 29,366 28,402 27,208 26,364 27,524 25,803 26,585 Boiler 02(Avg) 3.0 3.4 2.6 2.5 3.1 2.3 2.5 3.0 3.0 2.0 3.9 3.7 East Undergrate Air Flow (lb/hr) 133,132 132,958 131,609 133,930 125,199 127,597 128,255 130,913 124,918 132,169 136,230 139,502 West Undergrate Air Flow (lb/hr) 132,370 131,757 131,202 133,690 127,846 128,703 128,918 131,460 126,814 132,122 135,646 139,180 Baghouse Inlet Temp (deg F) 185.0 186.5 186.8 187.7 185.6 186 188.1 184.7 184.4 185.1 185.1 184.9 Baghouse Outlet Temp (deg F) 179.1 179.4 182.5 180.4 179.5 182.7 190.6 180 181.9 180.2 180.7 177.1 Baghouse DP (in H 2 O) 8.2 7.4 8.1 8.6 7.7 8.2 9.1 8 7.4 6.9 7.6 7.3 ID Fan Suct. Press. (in H 2 O) –23.6 –23.1 –23.8 –24.2 –22.4 –22.2 –23.5 –23.2 –21.1 –23.9 –23.8 –24 Stack Opacity 7.26 5.31 4.89 5.09 5.02 6.23 4.75 4.05 5.01 5.82 3.81 3.80 NA—Not available. Monitor not operational. *Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-10 **Table 5-1C. Summary of Process Data for Each Run of Second RCA Tests** * Date 11/16/99 11/17/99 11/18/99 11/19/99 11/20/99 Run no. 31 32 33 34 35 36 37 38 39 40 41 42 Steam Flow (klb/hr) 269.1 274.6 277.4 276.4 275.4 272.7 205.0 204.3 205.9 199.4 217.9 217.0 Steam Temp (deg F) 945 951 955 954 951 951 951 950 951 953 949 946 Coal Flow (lb/hr) 27,621 28,096 29,286 28,460 28,819 28,028 19,642 19,641 20,261 21,742 21,921 22,029 Boiler O2(Avg) 3.0 4.0 2.7 3.4 3.4 3.5 5.0 4.9 5.0 5.5 4.7 4.6 East Undergrate Air Flow (lb/hr) 129,895 125,586 123,375 121,533 119,891 119,534 100,875 100,759 101,711 101,675 101,686 102,958 West Undergrate Air Flow (lb/hr) 130,976 127,925 124,288 120,292 120,611 120,671 99,163 98,441 100,332 99,141 100,244 102,405 Baghouse Inlet Temp (deg F) 185 185 185 185 185 185 185 186 185 185 183 185 Baghouse Outlet Temp (deg F) 174 174 174 175 176 175 173 174 173 176 176 178 Baghouse DP (in H 2 O) 10.2 11.5 10.7 10.7 10.9 12.1 6.3 5.5 5.7 5.8 6.8 7.8 ID Fan Suct. Press. (in H 2 O) –25.5 –26.3 –23.1 –25.9 –25.4 –25.7 –16.6 –15.2 –16.4 –-16.0 –17.7 –16.8 2A SDA Outlet Temp (deg F) 188.9 185.0 184.8 184.7 185.1 184.2 184.4 185.6 186.5 186.1 184.8 187.3 2A Atomizer KW (KW) 64.0 66.0 69.5 68.8 63.8 67.0 49.6 49.8 49.2 47.8 55.3 54.6 U2 % Solids (%) 35.0 34.4 34.9 35.4 34.7 34.3 34.8 34.8 34.5 35.0 35.3 35.2 2A Lime Flow (gpm) 4.5 3.8 4.3 5.5 5.6 5.5 5.6 4.8 5.2 6.8 4.6 5.2 Stack Opacity 8.67 9.53 9.74 9.38 8.52 10.49 9.65 7.84 7.76 Opacity data not available *Based on average of readings taken once every 15 minutes (except opacity which was taken from six-minute averages during each run).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-11 **Table 5-2A. Summary of M17 Sampling Data for Initial Correlation Tests**

Run Sampling

time (min) Sample gas

volume (dscm) Orsat analysis Water (%) Average stack

temperature Isokinetic

(%) Stack velocity (m/min) Stack gas

flow rate (dscm/min) Oxygen Carbon

dioxide (%) (%) ( F) 10 A 100 1.678 5.0 14.6 12.8 194 100.7 1,430 2,306 10 B 100 1.653 5.0 14.6 13.2 195 101.0 1,445 2,316 11 A 100 1.619 5.0 14.5 12.7 191 100.9 1,405 2,271 11 B 100 1.686 5.0 14.5 13.0 191 101.3 1,447 2,330 12 A 100 1.668 4.5 14.8 14.1 190 102.1 1,423 2,261 12 B 100 1.621 4.5 14.8 14.8 190 102.5 1,421 2,238 13 A 100 1.632 5.8 13.6 11.9 186 99.7 1,413 2,315 13 B 100 1.637 5.8 13.6 11.9 187 99.4 1,409 2,306 14 A 100 1.655 4.7 14.6 13.1 192 100.7 1,415 2,275 14 B 100 1.633 4.7 14.6 13..4 193 100.9 1,431 2,289 15 A 100 1.653 4.7 14.6 13.0 186 100.6 1,437 2,325 15 B 100 1.687 4.7 14.6 13.2 187 100.9 1,451 2,340 16 A 100 1.887 5.1 14.6 13.3 185 100.8 1,444 2,334 16 B 100 1.910 5.1 14.6 13.4 186 101.1 1,460 2,354 17 A 100 1.841 5.0 14.6 12.2 185 99.8 1,444 2,371 17 B 100 1.800 5.0 14.6 14.2 186 101.6 1,420 2,277 18 A 100 1.834 5.1 14.5 12.7 186 99.9 1,413 2,289 18 B 100 1.856 5.1 14.5 14.0 186 101.1 1,435 2,289 19 A 100 1.627 5.2 14.6 13.1 185 99.9 1,419 2,306 19 B 100 1.640 5.2 14.6 13.2 185 100.0 1,416 2,295 20 A 100 1.685 5.2 14.6 15.0 185 101.5 1,445 2,299 20 B 100 1.655 5.2 14.6 15.5 186 102.0 1,452 2,296 21 A 100 1.626 5.4 14.1 13.9 185 100.7 1,428 2,284 21 B 100 1.686 5.4 14.1 14.2 186 101.1 1,467 2,336 22 A 100 1.655 5.0 14.7 13.5 184 99.8 1,428 2,297 22 B 100 1.647 5.0 14.7 13.7 185 99.9 1,455 2,333 23 A 100 1.597 5.0 14.8 12.9 185 99.8 1,390 2,264 23 B 100 1.587 5.0 14.8 13.5 185 100.2 1,372 2,217MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-12

24 A 100 1.608 5.0 14.8 13.9 185 100.1 1,392 2,225 24 B 100 1.607 5.0 14.8 14.2 185 100.3 1,422 2,266



### Table 5-2B. Summary of M17 Sampling Data for First RCA Tests

Run Sampling

time (min) Sample gas

volume (dscm) Orsat analysis Water (%) Average stack temperature Isokinetic

(%) Stack velocity (m/min) Stack gas

flow rate (dscm/min) Oxygen Carbon

dioxide (%) (%) ( F) 1 A 100 1.610 4.2 15.0 14.3 184 101.2 1,405 2,225 1 B 100 1.634 4.2 15.0 14.3 185 104.1 1,405 2,222 2 A 100 1.773 4.2 15.0 14.1 185 101.3 1,434 2,274 2 B 100 1.802 4.2 15.0 14.2 185 101.4 1,443 2,285 3 A 100 1.812 4.2 15.0 14.3 188 101.5 1,411 2,227 3 B 100 1.820 4.2 15.0 14.8 189 102 1,421 2,225 4 A 100 1.746 4.2 15.1 14.3 185 101.6 1,415 2,233 4 B 100 1.790 4.2 15.1 14.8 186 102.1 1,437 2,255 5 A 100 1.538 4.2 15.0 14.1 185 99.5 1,348 2,163 5 B 100 1.551 4.2 15.0 13.7 186 99.2 1,374 2,212 6 A 100 1.550 4.1 15.2 13.8 188 99.7 1,351 2,152 6 B 100 1.549 4.1 15.2 13.9 188 99.8 1,381 2,195 7 A 100 1.544 4.2 15.0 13.7 195 99.5 1,376 2,172 7 B 100 1.560 4.2 15.0 14.0 197 99.8 1,411 2,212 8 A 100 1.593 4.0 15.2 13.8 185 99.9 1,383 2,209 8 B 100 1.581 4.0 15.2 13.7 186 99.8 1,404 2,242 9 A 100 1.539 4.2 15.0 13.9 186 99.7 1,355 2,161 9 B 100 1.490 4.2 15.0 13.7 187 99.6 1,324 2,116 10 A 100 1.598 4.0 15.2 14.2 185 100.4 1,393 2,204 10 B 100 1.552 4.0 15.2 14.7 186 100.8 1,386 2,177 11 A 100 1.622 4.8 14.0 11.9 186 97.9 1,430 2,318 11 B 100 1.575 4.8 14.0 12.1 186 98.1 1,406 2,272 12 A 100 1.653 5.1 14.3 12.6 182 98.7 1,432 2,319MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-13

12 B 100 1.629 5.1 14.3 12.3 183 98.4 1,444 2,341MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-14 **Table 5-2C1. Summary of M17 Sampling Data for Traversing Train A (Second RCA Test)** 

Run Sampling

time (min) Sample gas

volume (dscm) Orsat analysis Water (%) Average stack temperature ( F) Isokinetic

(%) Stack velocity (m/min) Stack gas

flow rate (dscm/min) Oxygen (%) Carbon dioxide (%) 31 A 75 0.776 4.5 14.6 12.2 177 101.5 1,402 2,291 32 A 75 0.748 4.8 14.7 11.3 177 100.0 1,343 2,242 33 Aa 100 0.987 3.3 15.4 12.3 178 101.4 1,325 2,187 33 B a 100 1.001 3.3 15.4 11.6 180 100.5 1,350 2,237 34 A 75 0.757 4.2 14.6 13.0 179 101.7 1,368 2,230 35 A 75 0.729 3.8 15.0 12.0 179 100.7 1,299 2,170 36 A 75 0.703 3.8 14.9 11.6 179 100.3 1,255 2,101 37 Ab 75 0.638 6.1 13.5 10.5 177 99.7 1,100 1,917 38 Ab 75 0.640 5.7 13.0 11.4 177 101.6 1,096 1,890 39 Ab 75 0.629 5.3 13.3 10.4 177 100.3 1,075 1,878 40 Ab 75 0.611 6.3 12.5 12.4 179 99.4 1,089 1,843 41 Ab 75 0.642 5.9 13.3 12.4 180 99.9 1,144 1,927 42 Ab 75 0.625 5.1 14.1 12.4 181 99.6 1,120 1,880
a Run 33 was a test for precision of the Method 17 sampling. b Runs 37-42 were reduced load tests.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-15 **Table 5-2C2. Summary of M17 Sampling Data (Train B—Single Point) (Second RCA Test)** 

Run Sampling

time (min) Sample gas

volume (dscm) Orsat analysis Water (%) Average stack temperature ( F) Isokinetic

(%) Stack velocity (m/min) Stack gas

flow rate (dscm/min) Oxygen (%) Carbon dioxide (%) 31 B 75 0.794 4.5 14.6 11.0 180 100.8 1,430 2,359 32 B 80 0.812 4.8 14.7 11.9 180 100.7 1,372 2,265 33 B No single point train used in Run 33 (precision run). 34 B 85 0.818 4.2 14.6 12.5 182 101.4 1,307 2,134 35 B 80 0.786 3.8 15.0 11.4 181 100.3 1,312 2,201 36 B 80 0.758 3.8 14.9 12.5 182 101.2 1,274 2,104 37 B a 80 0.652 6.1 13.5 9.8 179 100.6 1,041 1,821 38 B a 80 0.662 5.7 13.0 10.1 180 100.4 1,062 1,852 39 B a 80 0.668 5.3 13.3 10.3 179 100.0 1,076 1,876 40 B a 80 0.607 6.3 12.5 12.4 181 99.3 1,018 1,716 41 B a 80 0.681 5.9 13.3 12.4 182 99.4 1,146 1,924 42 B a 80 0.641 5.1 14.1 11.2 184 98.9 1,076 1,821

a Runs 37-42 were reduced load tests.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-16 **Table 5-3A. M17 Particulate Test Results for Initial Correlation Tests** M17 Particulate concentration converted to units corresponding

to PM CEMs

Run Amount found in probe rinse (mg) Amount

found on filter (mg) Total

particulate weight (mg) Gas volume

sampled (dscm) Particulate

concentration (mg/dscm) ESC and Durag

light scatter (mg/acm) Durag beta

gauge (mg/dscm) 10A 7.7 57.1 64.8 1.678 38.6 25.6 38.6 10B 12.4 54.3 66.7 1.653 40.4 26.6 40.4 11A 13.9 54.8 68.7 1.619 42.4 28.2 42.4 11 B 13.0 56.4 69.4 1.686 41.2 27.3 41.2 12 A 11.9 69.1 81.0 1.668 48.6 31.8 48.6 12 B 8.9 73.0 81.9 1.621 50.5 32.8 50.5 13 A 4.8 23.6 28.4 1.632 17.4 11.7 17.4 13 B 4.0 23.9 27.9 1.637 17 11.5 17 14 A 4.3 29.4 33.7 1.655 20.4 13.5 20.4 14 B 4.7 30.9 35.6 1.633 21.8 14.4 21.8 15 A 7.4 29.5 36.9 1.653 22.3 14.9 22.3 15 B 3.4 32.3 35.7 1.687 21.2 14.1 21.2 16 A 2.4 6.2 8.6 1.887 4.6 3.0 4.6 16 B 1.8 6.9 8.7 1.91 4.6 3.0 4.6 17 A 1.4 6.0 7.4 1.841 4.0 2.7 4.0 17 B 1.6 5.6 7.2 1.8 4.0 2.6 4.0 18 A 2.3 6.7 9.0 1.834 4.9 3.3 4.9 18 B 1.7 7.1 8.8 1.856 4.7 3.1 4.7 19 A 5.2 35.2 40.4 1.627 24.8 16.6 24.8 19 B 4.6 34.8 39.4 1.64 24.0 16.1 24.0 20 A 3.9 22.4 26.3 1.685 15.6 10.2 15.6 20 B 3.6 23.9 27.5 1.655 16.6 10.8 16.6 21 A 4.0 19.8 23.8 1.626 14.6 9.7 14.6 21 B 3.6 20.0 23.6 1.686 14.0 9.2 14.0 22 A 4.7 33 37.7 1.655 22.8 15.1 22.8 22 B 3.1 36.0 39.1 1.647 23.7 15.7 23.7 23 A 2.3 18.7 21 1.597 13.1 8.8 13.1 23 B 2.4 18.3 20.7 1.587 13.0 8.7 13.0 24 A 5.3 40.7 46.0 1.608 28.6 18.8 28.6MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-17

24 B 4.5 40.7 45.2 1.607 28.1 18.5 28.1MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-18 **Table 5-3B. M17 Particulate Test Results for First RCA Test** M17 Particulate concentration converted to units corresponding

to PM CEMS
Run Amount found in probe rinse (mg) Amount

found on filter (mg) Total

particulate weight (mg) Gas volume

sampled (dscm) Particulate

concentration (mg/dscm) ESC and Durag

light scatter (mg/acm) Durag beta

gauge (mg/dscm) 1 A 12.4 59.9 72.3 1.610 44.9 29.3 44.9 1 B 12.5 54.9 67.4 1.634 41.2 26.9 41.2 2 A 1.1 4.1 5.2 1.773 2.9 1.9 2.9 2 B 0.4 4.8 5.2 1.802 2.9 1.9 2.9 3 A 0.2 6.7 6.9 1.812 3.8 2.5 3.8 3 B 1.3 6.1 7.4 1.820 4.1 2.6 4.1 4 A 0.8 6.1 6.9 1.746 4.0 2.6 4.0 4 B 0.5 6.7 7.2 1.790 4.0 2.6 4.0 5 A 4.0 18.4 22.4 1.538 14.6 9.6 14.6 5 B 2.6 20.6 23.2 1.551 15.0 9.9 15.0 6 A 1.0 18.5 19.5 1.550 12.6 8.2 12.6 6 B 2.7 17.0 19.7 1.549 12.7 8.3 12.7 7 A 5.3 21.9 27.2 1.544 17.6 11.5 17.6 7 B 6.8 20.1 26.9 1.560 17.2 11.1 17.2 8 A 10.6 42.9 53.5 1.593 33.6 22.1 33.6 8 B 9.4 43.8 53.2 1.581 33.7 22.1 33.7 9 A 14.9 41.7 56.6 1.539 36.8 24.2 36.8 9 B 12.0 42.2 54.2 1.490 36.4 23.9 36.4 10 A 2.1 61.5 63.6 1.598 39.8 25.9 39.8 10 B 9.2 56.3 65.5 1.552 42.2 27.3 42.2 11 A 5.6 24.8 30.4 1.622 18.7 12.5 18.7 11 B 5.6 26.2 31.8 1.575 20.2 13.4 20.2 12 A 11.5 35.4 46.9 1.653 28.4 18.9 28.4 12 B 10.9 36.1 47.0 1.629 28.9 19.3 28.9MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-19 **Table 5-3C1. M17 Particulate Test Results—Traversing Train**

**(Second RCA Test)** M17 Particulate concentration converted to units corresponding

to PM-CEMS
Run Amount found in probe rinse (mg) Amount

found on filter (mg) Total

particulate weight (mg) Gas volume

sampled (dscm) Particulate

concentration (mg/dscm) ESC and Durag

light scatter (mg/acm) Durag beta

gauge (mg/dscm) 31 A 2.8 26.4 29.3 0.776 37.8 25.4 37.8 32 A 2.1 18.7 20.8 0.748 27.8 19.1 27.8 33A a 2.4 25.5 27.9 0.987 28.3 19.2 28.3 33B a 0.7 25.3 26.0 1.001 26.0 17.7 26.0 34 A 2.8 8.8 11.6 0.757 15.3 10.3 15.3 35 A 1.0 13.4 14.4 0.729 19.7 13.6 19.7 36 A 1.6 25.5 27.1 0.703 38.5 26.6 38.5 37 A 4.4 46.8 51.2 0.638 80.2 57.6 80.2 38 A 4.0 29.1 33.1 0.640 51.7 36.7 51.7 39 A 3.8 27.3 31.1 0.629 49.5 35.6 49.5 40 A 1.0 9.7 10.7 0.611 17.5 12.2 17.5 41 A 2.4 19.9 22.3 0.642 34.7 24.1 34.7 42 A 5.2 29.4 34.6 0.625 55.4 38.3 55.4
a Run 33 was a test for precision of the Method 17 sampling.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-20 **Table 5-3C2. M17 Particulate Test Results (Train B—Single Point) (Second RCA Test)**  M17 Particulate concentration converted to units corresponding

to PM-CEMS

Run Amount found in

probe rinse (mg) Amount

found on filter (mg) Total

particulate weight (mg) Gas volume

sampled (dscm) Particulate

concentration (mg/dscm) ESC and Durag

light scatter (mg/acm) Durag beta

gauge (mg/dscm) 31 B 0.7 18.1 18.8 0.794 23.7 16.1 23.7 32 B 0.8 13.4 14.2 0.812 17.5 11.9 17.5 33 B No single point train used in Run 33 (precision run). 34 B 0.3 13.4 13.7 0.818 16.7 11.3 16.7 35 B 0.0 8.8 8.8 0.786 11.2 7.7 11.2 36 B 0.0 17.1 17.1 0.758 22.6 15.3 22.6 37 B 1.3 32.0 33.3 0.652 51.1 36.8 51.1 38 B 2.3 19.9 22.2 0.662 33.5 24.1 33.5 39 B 2.0 20.8 22.8 0.668 34.1 24.5 34.1 40 B 2.1 6.8 8.9 0.607 14.7 10.2 14.7 41 B 0.5 13.1 13.6 0.681 20.0 13.8 20.0 42 B 1.0 20.0 21.0 0.641 32.8 22.8 32.8MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-21

concentration values, and the associated PM-CEMS response, that were used to develop the initial correlation relations and to evaluate results from RCA # 1 and # 2 as discussed later in Section 5.3.4. During each test run of the initial correlation tests and the first RCA tests, dual M17 trains were operated simultaneously. Each train sampled 4 minutes at each of the 25 traverse points for an elapsed test run time of approximately 110 minutes (100 minutes of actual sample time). To facilitate moving the sampling trains from point to point, Train A was started 2 minutes before Train B. During each test run of the second RCA tests, two M17 trains were again operated essentially simultaneously. But, one train (Train A) was used to traverse the stack, sampling for 3 min at each of 25 points for a total of 75 min. The other train (Train B) was used to sample at a single point for a total of 80 min. In Run 33, both Train A and Train B were traversing trains, sampling for 4 min at each point to recheck precision of the measurements. Except for Run 33,only the results from Train A were used in evaluating the results relative to correlation with PMCEMS response discussed later in this report. The dual train particulate results were used to determine the precision of each test run’s M17 data and screen the M17 data for outliers. The precision of the dual trains is presented in Table 5-4 A and B and shows that precision criteria were met in all 15 runs of the initial correlation tests and in all 12 runs of the first RCA test. The precision criteria were also met for the one run (Run 33) in the second RCA test. In addition to the precision criteria, the dual trains were checked for systematic data bias, according to the equation presented in Section 10.1.2 of draft Procedure 2. If no bias exists, a plot of Train B versus Train A would generate a straight line correlation, passing through the origin, with a slope of 1.0. The criteria in draft Procedure 2 stipulate that the slope calculated in the regression analysis must fall between 0.93 and 1.07. The plots of Train B particulateMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-22

concentration versus Train A particulate concentration for the initial correlation tests and first RCA test are presented in Figures 5-1A and B. The calculated

**Table 5-4A. Precision of Method 17 Dual Trains for Initial Correlation Tests** Run no. Train A

(mg/dscm) Train B

(mg/dscm) RSD

(%) Criteria

(See note) Pass/Fail 10 38.6 40.4 2.28 RSD < 10% Pass 11 42.4 41.2 1.44 RSD < 10% Pass 12 48.6 50.5 1.92 RSD < 10% Pass 13 17.4 17.0 1.16 RSD < 10% Pass 14 20.4 21.8 3.32 RSD < 10% Pass 15 22.3 21.2 2.53 RSD < 10% Pass 16 4.6 4.6 0.00 RSD < 19% Pass 17 4.0 4.0 0.00 RSD < 20% Pass 18 4.9 4.7 2.08 RSD < 18.7% Pass 19 20.8 20.0 1.96 RSD < 10% Pass 20 15.6 16.6 3.11 RSD < 10% Pass 21 14.6 14.0 2.10 RSD < 10% Pass 22 13.5 13.7 0.74 RSD < 10% Pass 23 13.1 13.0 0.38 RSD < 10% Pass 24 28.6 28.1 0.88 RSD < 10% Pass Note:Acceptance limit for precision of paired trains is: RSD < 10% if conc is > 10 mg/dscm RSD < 25% if conc is < 1 mg/dscm. At between 1 and 10 mg/dscm, the allowable RSD decrease linearly from 25% to 10%. % RSD is defined as 100 x (CA - CB)/(CA + C B).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-23MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-24 **Table 5-4B. Precision of Method 17 Dual Trains for First RCA Tests** Run no. Train A

(mg/dscm) Train B

(mg/dscm) Avg.

(mg/dscm) RSD

(%) Criteria

(See note) Pass/Fail 1 44.9 41.2 43.05 4.30 RSD < 10% Pass 2 2.9 2.9 2.9 0.00 RSD < 21.8% Pass 3 3.8 4.1 3.95 3.80 RSD < 20.0% Pass 4 4 4 4 0.00 RSD < 20.0% Pass 5 14.6 15 14.8 1.35 RSD < 10% Pass 6 12.6 12.7 12.65 0.40 RSD < 10% Pass 7 17.6 17.2 17.4 1.15 RSD < 10% Pass 8 33.6 33.7 33.65 0.15 RSD < 10% Pass 9 36.8 36.4 36.6 0.55 RSD < 10% Pass 10 39.8 42.2 41 2.93 RSD < 10% Pass 11 18.7 20.2 19.45 3.86 RSD < 10% Pass 12 28.4 28.9 28.65 0.87 RSD < 10% Pass Note: Acceptance limit for precision of paired trains is: RSD < 10% if conc is > 10 mg/dscm RSD < 25% if conc is < 1 mg/dscm At between 1 and 10 mg/dscm, the allowable RSD decrease linearly from 25% to 10%. % RSD is defined as 100 x (CA - CB)/(CA + C B).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-25 **Figure 5-1A. Bias of Train A versus Train B in Initial Correlation Tests**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-26 **Figure 5-1B. Bias of Train A versus Train B in First RCA Tests**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-27

slope of 1.02 and 0.977 falls within the Procedure 2 criteria; therefore, the M17 sampling results met the criteria in both sets of tests.

5.3.2.2 M17 H 2 

### O Results Moisture results for the M17 trains (shown previously in Tables 5-2 A, B, and C) have been retabulated in Table 5-5A, B, and C. Moisture results for the M17 trains in the initial correlation tests, given in Table 5-5A, show that results for Train B were higher than Train A in almost all runs, with the largest absolute difference occurring in Runs 17 and 18 (2.0 and 1.3% H 2

### O, respectively). After corrective actions (discussed in Section 6) were implemented for Runs 19-24, the difference ranged from 0.1% H

2

### O to 0.6% H

2

### O. The absolute differences in the first RCA tests (Table 5-5B) had a similar range, from 0 to 0.5% H 2

### O. The absolute differences in the second RCA test (Table 5- 5C) had a somewhat higher range of 0 to 1.3% H 2

### O. In this second RCA test, the trains were not identical (i.e., Train A traversing, Train B single point), but it was expected that the gas sampled by both trains would have the same moisture content. Thus, the reason for the differences is not known.

5.3.2.3 H 2 

### O CEM Results EPA included testing of the Vaisala HMP 235 moisture CEM in this project to determine if it may be applicable to moisture monitoring in some types of facilities such as the Cogentrix coal fired power plant (with low SO2

### emissions).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-28

**Table 5-5A. Comparison of M17 Moisture Results for Initial Correlation Tests**

Run no. Train A

(traversing) (% H2O) Train B

(traversing) (% H2O) Average

(% H2O) Differences A-B

(% H2O) 10 12.8 13.2 13.00 –0.4 11 12.7 13.0 12.85 –0.3 12 14.1 14.8 14.45 –0.7 13 11.9 11.9 11.90 0 14 13.1 13.4 13.25 –0.3 15 13.0 13.2 13.10 –0.2 16 13.3 13.4 13.35 –0.1 17 12.2 14.2 13.20 –2.0 18 12.7 14.0 13.35 –1.3 19 13.1 13.2 13.15 –0.1 20 15.0 15.5 15.25 –0.5 21 13.9 14.2 14.05 –0.3 22 13.5 13.7 13.60 –0.2 23 12.9 13.5 13.20 –0.6 24 13.9 14.2 14.05 –0.3MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-29 **Table 5-5B. Comparison of M17 Moisture Results for First RCA Test**

Run no. Train A

(traversing) (% H2O) Train B

(traversing) (% H2O) Average

(% H2O) Differences A-B

(% H2O) 1 14.3 14.3 14.30 0 2 14.1 14.2 14.15 –0.1 3 14.3 14.8 14.55 –0.5 4 14.3 14.8 14.55 –0.5 5 14.1 13.7 13.90 +0.4 6 13.8 13.9 13.85 –0.1 7 13.7 14.0 13.85 –0.3 8 13.8 13.7 13.75 +0.1 9 13.9 13.7 13.80 +0.2 10 14.2 14.7 14.45 –0.5 11 11.9 12.1 12.00 –0.2 12 12.6 12.3 12.45 +0.3MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-30 **Table 5-5C. Comparison of M17 Moisture Results for Second RCA Test**

Run no. Train A (traversing) (% H2O) Train B (single point)* (% H2O) Differences A-B (% H2O) 31 12.2 11.0 +1.2 32 11.3 11.9 –0.6 33 12.3 11.6* +0.7 34 13.0 12.5 +0.5 35 12.0 11.4 +0.6 36 11.6 12.5 –0.9 37 10.5 9.8 +0.7 38 11.4 10.1 +1.3 39 10.4 10.3 +0.1 40 12.4 12.4 0 41 12.4 12.4 0 42 12.4 11.2 +1.2 * Train B was a traversing train in Run 33.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-31

The Vaisala H

2

### O CEM outputs a 0-10 Vdc signal that is proportional to the moisture content of the gas in terms of absolute humidity (0-600 g/acm). In order to convert the CEM response to %H2

### O by volume, the following equation was used:
%H2

### O = (0.029)(Vdc)(t + 273) where t = stack temperature in E

### C.
N OTE

### : This equation is based on the assumption of a constant stack pressure of 13.7 psia (i.e., –24" H 2

### O). Since the stack gas environment at this specific facility might have an effect on the accuracy of the H

2

### O CEM, the readings taken during each run of the initial correlation tests were compared with the corresponding average M17 H 2

### O results. That comparison was used to develop a correction factor that was incorporated into the above equation, as discussed below. Thereafter, the H 2

### O CEM and average M17 H 2

### O results obtained for each run in the first and second RCA were used to assess the accuracy of the H 2

### O CEM.
The data in Table 5-6A show the H 2

### O results from the initial correlation tests which were used to calculate a correction factor for the moisture monitor as follows:
H2 

### O Correction Factor ' % H2 

### O by M17 % H2 

### O reported by CEM ' 13
. 45 11
. 38 ' 1
. 180

This correction factor was applied to the original equation shown above that is used to convert the H

2

### O CEM response (Vdc) to % H 2

### O, as follows:
%H2

### O = (1.182) (0.029) (Vdc)(t + 273) = (0.034)(Vdc)(t + 273)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-32 **Table 5-6A. Summary of Moisture Results for Initial Correlation Tests**

**(CEM vs M17, and Calculated Correction Factor** ) Run no. H 2O CEM (% by vol) M17 (% by vol)* 10 10.95 13.00 11 10.96 12.85 12 11.15 14.45 13 11.10 11.90 14 10.92 13.25 15 11.35 13.10 16 11.72 13.35 17 11.36 13.20 18 11.33 13.35 19 11.71 13.15 20 11.78 15.25 21 11.88 14.05 22 11.56 13.60 23 11.29 13.20 24 11.57 14.05

Avg 11.38 Avg. 13.45 Calculated Correction Factor = 13.45/11.38 = 1.182


### . *Average results for Train A and B.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-33

Using this equation, the H 2

### O CEM results were recalculated and plotted as shown in Figure 5-2. This figure still shows considerable spread in the data, with differences as wide as 1.3% H

2

### O. However, an error of 1% H 2

### O, at a 10% moisture level, (e.g., 10% as 11%) would result in an error of only about 1% in conversion of particulate concentration in mg/dscm to mg/acm. Since the range of H 2

### O content measured in these tests had a narrow range of only 11.90% to 15.25%, it was not possible to evaluate accuracy of the H 2

### O CEM at higher moisture levels (e.g., 30-40%).
The reason for the difference between the H 2

### O CEM results and the M17 results is not known, but may reflect the fact that the range of the instrument is 600 g/acm, or near 100% H 2

### O by volume, corresponding to an output signal of 10 Vdc. Thus, a difference of 1% H 2

### O is a difference of only 0.1 Vdc. It should also be noted that the difference between dual M17 trains may be as much as 1% H 2

### O, as discussed previously

. Regardless of the reason for the difference in the H 2

### O CEM and M17 results, the equation shown above, with the correction factor, was incorporated into the data acquisition system computer program in order to convert the H 2

### O CEM output to % H 2

### O. Those values were used in the RCA tests to determine accuracy of the H 2

### O CEM, by comparison with the M17 H 2

### O results.
Results for the H 2

### O CEM in the first RCA tests are tabulated in Table 5-6 B, and show that the CEM met the criteria in the QAPP, with a difference of less than 1% H 2

### O, and relative accuracy (RA) better than 10%. A comparison of the M17 H 2

### O (Train A) test results for the second RCA with the H 2

### O CEMS data is provided in Table 5-6C and shows that the H 2

### O CEMS always read lower than the M17 result. The average difference was 2.0% H 2

### O and an RA of 23%, which did not meetMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-34

the criteria specified in the QAPP of ±1% H 2

### O or RA #

### 10%. Also, Section 3 and 4 discussed the fact that there were some operational problems with the H 2

### O CEMS atMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-35

**Fig ur**  **e 5-2. Comparison of Adjusted Moisture Monitor Readings with M17 Results, from Initial Correlation Tests**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-36 **Table 5-6B. Summary of Moisture Results from the first RCA Test (CEM versus M17)** 
Run no. H 2O CEM

(% by vol) M17

(% by vol) Difference

(% H2O by vol) 1 14.69 14.30 –0.39 2 14.28 14.15 –0.14 3 14.24 14.55 + 0.30 4 14.69 14.55 –0.15 5 14.00 13.90 –0.10 6 13.85 13.85 0 7 13.45 13.85 + 0.40 8 14.23 13.75 –0.48 9 14.01 13.80 –0.21 10 14.18 14.45 + 0.27 11 12.17 12.00 –0.17 12 12.50 12.45 –0.05 Note: Relative accuracy of the H2O CEM was 0.83% and the average difference was < 0.1% H2O.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-37 **Table 5-6C. Summary of Moisture Results for the Second RCA Tests**

**(CEMS versus Method 17)** Run no. H 2O CEM

(% by vol) M17 Train A

(% by vol) Difference

(% by vol) 31 NA* 12.2*

– 32 10.6 11.3 0.7 33 10.7 12.0 1.3 34 10.7 13.0 2.3 35 10.7 12.0 1.3 36 10.5 11.6 1.1 37 9.1 10.5 1.4 38 8.9 11.4 2.5 39 9.0 10.4 1.4 40 9.3 12.4 3.1 41 9.1 12.4 3.3 42 8.5 12.4 3.9 * Moisture CEMS was malfunctioning and was repaired. Note: Relative accuracy of the H2O CEM was 23% and the average difference was 2.0% H2O.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-38

about the time of the second RCA. These problems may have been caused by the constant vibration of the H 2

### O CEM probe, which may have put severe stresses on the sensor in the CEMS probe. Even so, the H 2

### O CEMS data were very useful on a day-to-day basis since thisdata often provided a good indication of plant operational problems or shutdowns. (The PMCEMS readings were normally quite low and did not show significantly different readings during most plant operational problems or shutdowns.) The Vaisala HMP 235 moisture CEM also includes a temperature sensor that is used to monitor stack temperature and is also used in the calculation of percent H 2

### O by volume as discussed in the previous section. The HMP 235 temperature is output as a 0-10 Vdc signal, with a temperature range of –20 E 

### to + 180 E

### C signal. Thus, the equation used to calculate temperature was: Temp in E

### C = 20 (Vdc) – 20 In order to evaluate the accuracy of the HMP 235 temperature readings, they were compared with the average M17 stack thermocouple data for each run of the initial correlation tests, as given in Table 5-7A. These results show that the HMP 235 temperatures were an average of 2.0 E

### C lower than the M17 data. Although this met the QA criteria of ±2 E

### C, the equation above was changed slightly in order to improve the accuracy of the temperature readings, as shown in the equation below. Temp in E

### C = 20 (Vdc) – 18 The temperature results from the first RCA (which used the modified equation above) are presented in Table 5-7B and show that the CEM met the accuracy criteria of ±2 E

### C. The same comparison for the second RCA tests in Table 5-7C showed that the H 2

### O CEM reading was always higher than the M17 temperature measurement but did meet the QA criteria of ±2 E

### C.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-39 **Table 5-7A. Stack Temperature Comparison for Initial Correlation Tests (M17 Versus H** **2**

### O CEM)

Stack temperature E C Run no. M17 H 2O CEM Difference 10 90 87.8 –2.2 11 88 85.7 –2.3 12 88 85.5 –2.5 13 85.5 84.1 –1.4 14 89 87.1 –1.9 15 86 83.8 –2.2 16 85 83.0 –2.0 17 85 83.5 –1.5 18 86 83.8 –2.2 19 85 83.1 –1.9 20 85.5 83.7 –1.8 21 85 83.5 –1.5 22 85 82.7 –2.3 23 85 82.9 –2.1 24 85 83.4 –1.6 Average 86.2 84.2 –2.0MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-40 **Table 5-7B. Stack Temperature Comparison for the First RCA Tests**

**(M17 Versus H 2** 

### O CEM)

Run no. Stack temperature E C

M17 H 2O CEM Difference 1 84.7 84.7 0 2 85.0 84.8 –0.2 3 86.9 86.7 –0.2 4 85.3 85.4 +0.1 5 85.3 85.2 –0.1 6 86.7 87.0 +0.3 7 91.1 90.8 –0.3 8 85.3 85.7 +0.4 9 85.8 86.2 +0.4 10 85.3 85.7 +0.4 11 85.6 85.7 +0.1 12 83.6 84.0 +0.4 Average 85.9 86.0 +0.1MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-41 **Table 5-7C. Stack Temperature Comparison for Second RCA Test**

**(CEMS versus Method 17)**

Stack temperature (E C) Run no. Method 17 H 2O CEM Difference 31 80.6 NA

– 32 80.6 82.2 +1.6 33 81.7 83.1 +1.4 34 81.7 83.8 +2.1 35 81.6 84.0 +2.4 36 81.6 83.4 +1.8 37 80.6 82.1 +1.5 38 80.6 82.1 +1.5 39 80.6 82.0 +1.4 40 81.7 83.4 +1.7 41 82.2 83.4 +1.2 42 82.8 84.2 +1.4 Average 81.4 83.1 +1.6MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-42

5.3.3 PM-CEMS Drift Test Data and ACA Results The three PM-CEMS operated since the beginning of the 6-month evaluation period (July 20, 1999) through the end of the 6-month test period (February 16, 2000) except for the downtime of September 15 to October 7 due to Hurricane Floyd. During this period, an initial 7-day drift test was performed, and thereafter the four PM-CEMS have performed automatic daily zero and upscale drift checks. Also, four ACAs were carried out for the two light scatter PM-CEMS as well as sample volume audits (SVA) on the beta gauge CEMS. Results for these tests are presented in the sections below.

5.3.3.1 7-day Zero and Upscale Drift Test Results Calibration drift data for the 7-day drift test were collected, as prescribed in Section 8.5 of PS-11, beginning after the shakedown period and before the initial correlation test. Calibration drift data for the ESC P5B and Durag DR 300-40 were taken during the period July 1 through July 7, but the Durag F904K had been removed and was at Durag’s office undergoing repairs and upgrades. The 7-day drift test results for the Durag F904K were collected starting July 10, 1999, after the instrument was reinstalled on July 9, 1999. Drift test results are discussed below and are presented in Table 5-8.

• ESC P5B. The zero reference value for the ESC P5B was 4.05 mA, and the upscale reference value was 12 mA. The largest zero drift was 0.25% of the upscale reference value. The largest upscale drift was 1.33% of the upscale reference value. These results show that the ESC P5B met the 7-day zero and upscale drift criteria of #

### 2% of the upscale reference value.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-43 **Table 5-8. 7-Day Calibration Drift Results for the Three PM-CEMS**

**ESC P5B 7-Day Calibration Drift Test Results** Date Zero

reading (mA) Zero drift (%) Upscale reading (mA) Upscale drift (%) 7/1/99 4.02 0.25 11.90 0.83 7/2/99 4.02 0.25 11.85 1.25 7/3/99 4.02 0.25 11.91 0.75 7/4/99 4.02 0.25 11.93 0.58 7/5/99 4.02 0.25 11.93 0.58 7/6/99 4.02 0.25 11.89 0.92 7/7/99 4.02 0.25 11.84 1.33



### Durag DR 300-40 7-Day Calibration Drift Test Results Date Zero

reading (mA) Zero drift (%) Upscale reading (mA) Upscale drift (%) 7/1/99 4.03 0.20 15.06 0.40 7/2/99 4.03 0.20 15.06 0.40 7/3/99 4.03 0.20 15.07 0.47 7/4/99 4.03 0.20 15.06 0.40 7/5/99 4.03 0.20 15.13 0.87 7/6/99 4.03 0.20 15.07 0.47 7/7/99 4.03 0.20 15.06 0.47



### Durag F904K 7-Day Calibration Drift Test Results Date Zero

reading (mA) Zero drift (%) Upscale reading (mA) Upscale drift (%) 7/10/99 4.10 0.69 14.48 0.55 7/11/99 4.17 1.17 14.40 1.10 7/12/99 4.10 0.69 14.56 0.00 7/13/99 4.02 0.14 14.56 0.00 7/14/99 4.02 0.14 14.48 0.55 7/15/99 4.17 1.17 14.40 1.10MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-44 7/16/99 4.10 0.69 14.48 0.55


### • Durag DR 300-40. The zero reference value for the Durag DR 300-40 was 4.0 mA, and the upscale reference value was 15 mA. The largest zero drift was 0.20% of the upscale reference value. The largest upscale drift was 0.87% of the upscale reference value. These results show that the DR 300-40 met the 7-day zero and upscale drift criteria of #

### 2% of the upscale reference value.

• Durag F904K. The zero reference value for the Durag F904K was 4.0 mA, and the upscale reference value was 14.56 mA. The largest zero drift was 1.17% of the upscale reference value. The largest upscale drift was 1.10% of the upscale reference value. These results show that the F904K met the 7-day zero and upscale drift criteria of #

### 2% of the upscale reference value.

5.3.3.2 Daily Zero and Upscale Drift Test Results Daily zero and upscale drift checks, as prescribed in draft Procedure 2, were carried out automatically by all three PM-CEMS. Daily calibration drift data for the 6-month endurance test period was collected in segments corresponding with the RCA tests, as follows:

July 20, 1999, to August 31, 1999 (See Table 5-9A) September 1, 1999, to November 20, 1999 (See Table 5-9B) November 21, 1999, to February 16, 2000 (See Table 5-9C) Daily drift data for the period of July 20 to August 31, 1999, show that all three PM-CEM were within the out-of-control limits. (The drift test criteria in draft Procedure 2 specify that a CEM must be adjusted if the drift exceeds 4% of the upscale value, and that the CEM is out of control if the drift exceeds 4% for five consecutive days or exceeds 8% in any one day.) It was noted that for the ESC-P5B, the upscale drift was progressively increasing and exceeded 4% for three consecutive days (August 21 to August 23, 1999). Therefore, on August 24, 1999, theMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-45

manufacturer’s procedures were used to re-adjust the instrument, which decreased the subsequent upscale drift values.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-46 **Table 5-9A. Daily Drift Results (July 20 to August 31, 1999)** ESC PM CEM Zero = 4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value =14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) 7/20/99 4.02 0.25 11.83 1.42 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 7/21/99 4.02 0.25 11.82 1.50 4.02 0.13 15.06 0.40 4.18 1.24 14.48 0.55 7/22/99 4.02 0.25 11.82 1.50 4.02 0.13 15.07 0.47 4.02 0.14 14.48 0.55 7/23/99 4.02 0.25 11.83 1.42 4.03 0.20 15.06 0.40 4.1 0.69 14.48 0.55 7/24/99 4.02 0.25 11.78 1.83 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 7/25/99 4.02 0.25 11.8 1.67 4.03 0.20 15.08 0.53 4.02 0.14 14.48 0.55 7/26/99 4.02 0.25 11.77 1.92 4.02 0.13 15.06 0.40 4.02 0.14 14.63 0.48 7/27/99 4.02 0.25 11.75 2.08 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 7/28/99 4.02 0.25 11.76 2.00 4.02 0.13 15.08 0.53 4.18 1.24 14.56 0.00 7/29/99 4.02 0.25 11.7 2.50 4.03 0.20 15.07 0.47 4.02 0.14 14.56 0.00 7/30/99 4.02 0.25 11.7 2.50 4.03 0.20 15.07 0.47 4.1 0.69 14.48 0.55 7/31/99 4.02 0.25 11.73 2.25 4.03 0.20 15.08 0.53 4.18 1.24 14.41 1.03 8/1/99 4.02 0.25 11.71 2.42 4.03 0.20 15.08 0.53 4.18 1.24 14.48 0.55 8/2/99 4.02 0.25 11.68 2.67 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 8/3/99 4.02 0.25 11.6 3.33 4.02 0.13 15.06 0.40 4.1 0.69 14.48 0.55 8/4/99 4.02 0.25 11.59 3.42 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 8/5/99 4.02 0.25 11.57 3.58 4.02 0.13 15.06 0.40 4.1 0.69 14.56 0.00 8/6/99 4.02 0.25 11.63 3.08 4.03 0.20 15.06 0.40 4.02 0.14 14.56 0.00 8/7/99 4.02 0.25 11.57 3.58 4.03 0.20 15.06 0.40 4.02 0.14 14.56 0.00 8/8/99 4.02 0.25 11.59 3.42 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 8/9/99 4.02 0.25 11.55 3.75 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 8/10/99 4.02 0.25 11.56 3.67 4.02 0.13 15.05 0.33 4.1 0.69 14.48 0.55 8/11/99 4.02 0.25 11.54 3.83 4.02 0.13 15.05 0.33 4.02 0.14 14.48 0.55 8/12/99 4.02 0.25 11.58 3.50 4.03 0.20 15.07 0.47 4.02 0.14 14.56 0.00 8/13/99 4.02 0.25 11.61 3.25 4.02 0.13 14.99 0.07 4.02 0.14 14.48 0.55 8/14/99 4.02 0.25 11.58 3.50 4.03 0.20 15.07 0.47 4.18 1.24 14.72 1.10 8/15/99 4.02 0.25 11.53 3.92 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 8/16/99 4.02 0.25 11.57 3.58 4.02 0.13 15.06 0.40 4.1 0.69 14.48 0.55

### Table 5-9A (Continued)

ESC PM CEM Zero = 4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value =14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-47 8/17/99 4.02 0.25 11.56 3.67 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 8/18/99 4.02 0.25 11.55 3.75 4.02 0.13 15.06 0.40 4.1 0.69 14.56 0.00 8/19/99 4.02 0.25 11.54 3.83 4.03 0.20 15.06 0.40 4.1 0.69 14.56 0.00 8/20/99 4.02 0.25 11.53 3.92 4.02 0.13 15.06 0.40 4.1 0.69 14.56 0.00 8/21/99 4.02 0.25 11.46 4.50 4.02 0.13 15.07 0.47 4.1 0.69 14.48 0.55 8/22/99 4.02 0.25 11.41 4.92 4.02 0.13 15.06 0.40 4.02 0.14 14.48 0.55 8/23/99 4.02 0.25 11.47 4.42 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 8/24/99 4.03 0.17 11.94 0.50 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 8/25/99 4.02 0.25 11.92 0.67 4.03 0.20 15.07 0.47 4.02 0.14 14.48 0.55 8/26/99 4.02 0.25 11.82 1.50 4.02 0.13 15.05 0.33 4.02 0.14 14.48 0.55 8/27/99 4.03 0.17 11.92 0.67 4.02 0.13 15.05 0.33 4.1 0.69 14.48 0.55 8/28/99 4.03 0.17 11.94 0.50 4.03 0.20 15.06 0.40 4.02 0.14 14.56 0.00 8/29/99 4.05 0.00 11.89 0.92 4.03 0.20 15.06 0.40 4.02 0.14 14.64 0.55 8/30/99 4.09 0.33 11.83 1.42 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 8/31/99 4.02 0.25 11.75 2.08 4.02 0.13 15.05 0.33 4.02 0.14 14.48 0.55MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-48 **Table 5-9B. Daily Drift Results (September 1 to November 20, 1999)** ESC PM CEM Zero =4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM-CEM Ref. Value =15 mA Durag F904K PM-CEM Ref. Value =14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) 9/1/99 4.02 0.25 11.76 2.00 4.02 0.13 15.05 0.33 4.1 0.69 14.56 0.00 9/2/99 4.02 0.25 11.76 2.00 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 9/3/99 4.02 0.25 11.82 1.50 4.02 0.13 15.02 0.13 4.18 1.24 14.48 0.55 9/4/99 4.02 0.25 12 0.00 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 9/5/99 4.02 0.25 11.87 1.08 4.02 0.13 15.05 0.33 4.02 0.14 14.48 0.55 9/6/99 4.02 0.25 11.93 0.58 4.03 0.20 15.07 0.47 4.18 1.24 14.64 0.55 9/7/99 4.02 0.25 11.88 1.00 4.02 0.13 15.06 0.40 4.1 0.69 14.41 1.03 9/8/99 4.02 0.25 11.9 0.83 4.02 0.13 15.05 0.33 4.02 0.14 14.64 0.55 9/9/99 4.02 0.25 11.87 1.08 4.02 0.13 15.06 0.40 4.02 0.14 14.56 0.00 9/10/99 4.02 0.25 11.84 1.33 4.03 0.20 15.06 0.40 4.17 1.17 14.56 0.00 9/11/99 4.02 0.25 11.75 2.08 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00 9/12/99 4.02 0.25 11.73 2.25 4.02 0.13 15.06 0.40 4.1 0.69 14.56 0.00 9/13/99 4.02 0.25 11.7 2.50 4.02 0.13 15.05 0.33 4.1 0.69 14.56 0.00 9/14/99 4.02 0.25 11.75 2.08 4.02 0.13 15.06 0.40 4.18 1.24 14.56 0.00 9/15/99 4.02 0.25 11.81 1.58 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 System off-line due to Hurricane Floyd 10/7/99 4.02 0.25 11.91 0.75 4.02 0.13 15.04 0.27 4.02 0.14 14.64 0.55 10/8/99 4.02 0.25 11.62 3.17 4.02 0.13 15.06 0.40 4.03 0.21 14.49 0.48 10/9/99 4.02 0.25 11.46 4.50 4.02 0.13 15.04 0.27 4.1 0.69 14.48 0.55 10/10/99 4.02 0.25 11.56 3.67 4.02 0.13 15.06 0.40 4.02 0.14 14.49 0.48 10/11/99 4.02 0.25 11.61 3.25 4.02 0.13 15.04 0.27 4.02 0.14 14.49 0.48 10/12/99 4.02 0.25 11.5 4.17 4.02 0.13 15.04 0.27 4.1 0.69 14.64 0.55 10/13/99 4.02 0.25 11.26 6.17 4.02 0.13 15.05 0.33 F904K is out-of-service; air conditioner broken; 10/14/99 4.01 0.33 11.34 5.50 4.02 0.13 15.04 0.27 Pressurized air line came disconnected 10/15/99 4.02 0.25 11.97 0.25 4.02 0.13 15.04 0.27 4.1 0.69 14.41 1.03 10/16/99 4.02 0.25 11.87 1.08 4.02 0.13 15.06 0.40 F904K is out-of-service; pressurized air line off 10/17/99 4.01 0.33 11.98 0.17 DR 300-40 is out-of-service, dirty window check too high " 10/18/99 4.01 0.33 11.95 0.42 " 10/19/99 4.02 0.25 11.84 1.33 " 10/20/99 4.01 0.33 11.92 0.67 4.1 0.69 14.48 0.55 10/21/99 4.01 0.33 11.89 0.92 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 10/22/99 4.01 0.33 11.84 1.33 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 10/23/99 4.02 0.25 11.65 2.92 4.02 0.13 15.05 0.33 F904K is out-of-service; 3 vacuum errors on 10/22/99 10/24/99 4.02 0.25 11.58 3.50 4.01 0.07 15.04 0.27 "

### Table 5-9B (Continued)

ESC PM CEM Zero =4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM-CEM Ref. Value =15 mA Durag F904K PM-CEM Ref. Value =14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-49 10/25/99 4.01 0.33 11.62 3.17 4.01 0.07 15.03 0.20 " 10/26/99 4.01 0.33 11.68 2.67 4.02 0.13 15.02 0.13 4.18 1.24 14.41 1.03 10/27/99 4.02 0.25 11.65 2.92 4.02 0.13 15.22 1.47 4.1 0.69 14.56 0.00 10/28/99 4.02 0.25 11.57 3.58 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 10/29/99 4.01 0.33 11.73 2.25 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00 10/30/99 4.02 0.25 11.61 3.25 4.02 0.13 15.03 0.20 F904K is out-of-service; 3 vacuum errors on 10/29/99 10/31/99 4.01 0.33 11.66 2.83 4.02 0.13 15.06 0.40 " 11/1/99 4.01 0.33 11.66 2.83 4.02 0.13 15.05 0.33 " 11/2/99 4.01 0.33 11.68 2.67 4.02 0.13 15.06 0.40 F904K is out-of-service; filter tear. 11/3/99 Data logger off line 11/3 a.m. Data logger off line 11/3 a.m. 4.02 0.14 14.64 0.55 11/4/99 4.01 0.33 11.43 4.75 4.01 0.07 15.03 0.20 4.1 0.69 14.56 0.00 11/5/99 4.01 0.33 11.34 5.50 4.01 0.07 15.04 0.27 4.02 0.14 14.56 0.00 11/6/99 4.01 0.33 11.45 4.58 4.02 0.13 15.03 0.20 4.02 0.14 14.48 0.55 11/7/99 4.01 0.33 11.51 4.08 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00 11/8/99 4.01 0.33 11.61 3.25 4.01 0.07 15.05 0.33 4.02 0.14 14.56 0.00 11/9/99 4.01 0.33 11.39 5.08 4.02 0.13 15.04 0.27 F904K is out-of-service; 3 vacuum errors on 11/8/99 11/10/99 4.01 0.33 11.51 4.08 4.02 0.13 15.04 0.27 F904K is out-of-service; filter tear. 11/11/99 4.01 0.33 12.11 0.92 4.02 0.13 15.05 0.33 F904K repaired but no drift check 11/12/99 4.02 0.25 12.03 0.25 4.02 0.13 15.04 0.27 4.02 0.14 14.49 0.48 11/13/99 4.02 0.25 11.97 0.25 4.02 0.13 15.04 0.27 F904K is out-of-service; filter tear. 11/14/99 4.01 0.33 12.08 0.67 4.02 0.13 15.03 0.20 " 11/15/99 4.02 0.25 12.04 0.33 4.02 0.13 15.05 0.33 " 11/16/99 4.01 0.33 12.06 0.50 4.01 0.07 15.03 0.20 F904K back in service, no calibration 11/17/99 4.02 0.25 12.03 0.25 4.01 0.07 15.05 0.33 4.1 0.69 14.49 0.48 11/18/99 4.01 0.33 11.88 1.00 4.01 0.07 15.04 0.27 4.1 0.69 14.56 0.00 11/19/99 4.01 0.33 11.8 1.67 4.01 0.07 15.04 0.27 4.1 0.69 14.56 0.00 11/20/99 4.02 0.25 11.89 0.92 4.02 0.13 15.03 0.20 4.1 0.69 14.49 0.48 

### Table 5-9C. Daily Cal Drift Data (November 21 to February 16) ESC PM CEM Zero=4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value = 14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) 11/21/99 4.02 0.25 11.8 1.67 4.02 0.13 15.04 0.27 4.02 0.14 14.41 1.03 11/22/99 4.02 0.25 11.8 1.67 4.02 0.13 15.04 0.27 4.18 1.24 14.64 0.55 11/23/99 4.02 0.25 11.62 3.17 4.02 0.13 15.05 0.33 4.02 0.14 14.57 0.07 11/24/99 4.02 0.25 11.64 3.00 4.02 0.13 15.05 0.33 4.18 1.24 14.64 0.55 11/25/99 4.02 0.25 11.64 3.00 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00

### Table 5-9C (Continued)

ESC PM CEM Zero=4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value = 14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-50 11/26/99 4.02 0.25 11.66 2.83 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 11/27/99 4.02 0.25 11.6 3.33 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 11/28/99 4.02 0.25 11.61 3.25 4.02 0.13 15.05 0.33 4.02 0.14 14.49 0.48 11/29/99 4.01 0.33 11.57 3.58 4.01 0.07 15.03 0.20 4.02 0.14 14.64 0.55 11/30/99 4.02 0.25 11.49 4.25 4.01 0.07 15.02 0.13 4.1 0.69 14.49 0.48 12/1/99 4.01 0.33 11.41 4.92 4.01 0.07 15.05 0.33 4.1 0.69 14.56 0.00 12/2/99 4.01 0.33 12.09 0.75 4.01 0.07 15.02 0.13 4.1 0.69 14.56 0.00 12/3/99 4.01 0.33 12.24 2.00 4.02 0.13 15.03 0.20 4.02 0.14 14.56 0.00 12/4/99 4.02 0.25 11.73 2.25 4.02 0.13 15.04 0.27 4.02 0.14 14.48 0.55 12/5/99 4.02 0.25 12.03 0.25 4.02 0.13 15.03 0.20 4.1 0.69 14.48 0.55 12/6/99 4.02 0.25 11.78 1.83 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 12/7/99 4.01 0.33 11.67 2.75 4.01 0.07 15.02 0.13 4.02 0.14 14.56 0.00 12/8/99 4.02 0.25 11.62 3.17 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 12/9/99 4.01 0.33 11.62 3.17 4.01 0.07 15.02 0.13 4.1 0.69 14.4 1.10 12/10/99 4.02 0.25 11.76 2.00 4.02 0.13 15.04 0.27 4.1 0.69 14.64 0.55 12/11/99 4.01 0.33 11.99 0.08 4.02 0.13 15.04 0.27 4.02 0.14 14.49 0.48 12/12/99 4.02 0.25 11.83 1.42 4.01 0.07 15.03 0.20 4.1 0.69 14.64 0.55 12/13/99 4.01 0.33 11.97 0.25 4.02 0.13 15.04 0.27 4.1 0.69 14.64 0.55 12/14/99 4.02 0.25 11.96 0.33 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 12/15/99 4.02 0.25 11.85 1.25 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 12/16/99 4.01 0.33 11.85 1.25 4.02 0.13 15.04 0.27 4.02 0.14 14.64 0.55 12/17/99 4.02 0.25 11.72 2.33 4.01 0.07 15.02 0.13 4.02 0.14 14.56 0.00 12/18/99 4.02 0.25 11.7 2.50 4.02 0.13 15.05 0.33 4.02 0.14 14.56 0.00 12/19/99 4.02 0.25 11.7 2.50 4.02 0.13 15.03 0.20 4.02 0.14 14.48 0.55 12/20/99 4.02 0.25 11.81 1.58 4.02 0.13 15.04 0.27 4.02 0.14 14.48 0.55 12/21/99 4.02 0.25 11.76 2.00 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 12/22/99 4.02 0.25 11.73 2.25 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 12/23/99 4.01 0.33 11.68 2.67 4.01 0.07 15.04 0.27 4.02 0.14 14.49 0.48 12/24/99 4.01 0.33 11.67 2.75 4.01 0.07 15.04 0.27 4.02 0.14 14.56 0.00 12/25/99 4.01 0.33 11.56 3.67 4.01 0.07 15.03 0.20 4.1 0.69 14.49 0.48 12/26/99 4.01 0.33 11.49 4.25 4.01 0.07 15.02 0.13 4.1 0.69 14.56 0.00 12/27/99 4.01 0.33 11.57 3.58 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 12/28/99 4.01 0.33 11.55 3.75 4.02 0.13 15.03 0.20 4.1 0.69 14.56 0.00

### Table 5-9C (Continued)

ESC PM CEM Zero=4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value = 14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-51 12/29/99 4.02 0.25 11.52 4.00 4.01 0.07 15.04 0.27 4.1 0.69 14.56 0.00 12/30/99 4.02 0.25 11.52 4.00 4.02 0.13 15.03 0.20 4.02 0.14 14.56 0.00 12/31/99 4.02 0.25 11.9 0.83 4.02 0.13 15.03 0.20 4.02 0.14 14.49 0.48 1/1/00 4.02 0.25 11.78 1.83 4.02 0.13 15.04 0.27 4.18 1.24 14.33 1.58 1/2/00 4.02 0.25 11.82 1.50 4.02 0.13 15.03 0.20 4.1 0.69 14.49 0.48 1/3/00 4.02 0.25 11.88 1.00 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 1/4/00 4.02 0.25 11.91 0.75 4.02 0.13 15.05 0.33 4.1 0.69 14.4 1.10 1/5/00 4.02 0.25 11.75 2.08 4.02 0.13 15.03 0.20 4.1 0.69 14.49 0.48 1/6/00 4.02 0.25 11.65 2.92 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 1/7/00 4.02 0.25 11.65 2.92 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00 1/8/00 4.02 0.25 11.59 3.42 4.01 0.07 15.02 0.13 4.1 0.69 14.64 0.55 1/9/00 4.02 0.25 11.61 3.25 4.02 0.13 15.04 0.27 4.1 0.69 14.56 0.00 1/10/00 Computer problem; no drift data taken 1/11/00 4.02 0.25 11.65 2.92 4.01 0.07 15.03 0.20 4.02 0.14 14.56 0.00 1/12/00 4.02 0.25 12.01 0.08 4.02 0.13 15.03 0.20 4.1 0.69 14.56 0.00 1/13/00 4.02 0.25 12 0.00 4.02 0.13 15.04 0.27 4.02 0.14 14.56 0.00 1/14/00 4.02 0.25 11.95 0.42 4.01 0.07 15.04 0.27 4.02 0.14 14.56 0.00 1/15/00 4.02 0.25 11.89 0.92 4.02 0.13 15.03 0.20 4.1 0.69 14.57 0.07 1/16/00 4.01 0.33 11.87 1.08 4.01 0.07 15.03 0.20 4.1 0.69 14.56 0.00 1/17/00 4.01 0.33 11.91 0.75 4.02 0.13 15.03 0.20 4.1 0.69 14.49 0.48 1/18/00 4.02 0.25 11.84 1.33 4.01 0.07 15.03 0.20 4.1 0.69 14.49 0.48 1/19/00 4.01 0.33 11.81 1.58 4.01 0.07 15.03 0.20 4.01 0.07 14.56 0.00 1/20/00 4.02 0.25 11.93 0.58 4.01 0.07 15.04 0.27 4.02 0.14 14.56 0.00 1/21/00 4.01 0.33 11.93 0.58 4 0.00 15.03 0.20 4.02 0.14 14.49 0.48 1/22/00 4.01 0.33 11.92 0.67 4.01 0.07 15.02 0.13 4.09 0.62 14.56 0.00 1/23/00 4.01 0.33 11.9 0.83 4.01 0.07 15.02 0.13 4.01 0.07 14.56 0.00 1/24/00 4.01 0.33 11.86 1.17 4.01 0.07 15.03 0.20 4.01 0.07 14.49 0.48 1/25/00 4.01 0.33 11.69 2.58 4 0.00 15.02 0.13 4.01 0.07 14.56 0.00 1/26/00 4.01 0.33 11.7 2.50 4.01 0.07 15.03 0.20 4.09 0.62 14.64 0.55 1/27/00 4.01 0.33 11.66 2.83 4 0.00 15.02 0.13 4.01 0.07 14.48 0.55 1/28/00 4.01 0.33 11.59 3.42 4 0.00 15.02 0.13 4.01 0.07 14.56 0.00 1/29/00 4.01 0.33 11.56 3.67 4.01 0.07 15.03 0.20 4.09 0.62 14.48 0.55 1/30/00 4.01 0.33 11.41 4.92 4.01 0.07 15.03 0.20 4.01 0.07 14.56 0.00

### Table 5-9C (Continued)

ESC PM CEM Zero=4.05 mA Ref. Value = 12 mA Durag DR 300-40 PM CEM Ref. Value = 15 mA Durag F904K PM CEM Ref. Value = 14.56 mA Date Zero

reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift Zero reading Zero drift Upscale reading Upscale drift (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%) (mA) (%)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-52 1/31/00 4.01 0.33 11.42 4.83 4.01 0.07 15.03 0.20 4.09 0.62 14.56 0.00 2/1/00 4.01 0.33 11.44 4.67 4.01 0.07 15.01 0.07 4.01 0.07 14.56 0.00 2/2/00 4.01 0.33 11.44 4.67 4.01 0.07 15.03 0.20 4.01 0.07 14.56 0.00 2/3/00 4.01 0.33 11.39 5.08 4.01 0.07 15.02 0.13 4.02 0.14 14.56 0.00 2/4/00 4.02 0.25 11.43 4.75 4.01 0.07 15.03 0.20 4.09 0.62 14.41 1.03 2/5/00 4.01 0.33 11.42 4.83 4.01 0.07 15.04 0.27 4.09 0.62 14.48 0.55 2/6/00 4.01 0.33 11.39 5.08 4.01 0.07 15.03 0.20 4.01 0.07 14.56 0.00 2/7/00 4.02 0.25 12.02 0.17 4.01 0.07 15.05 0.33 4.09 0.62 14.48 0.55 2/8/00 4.02 0.25 12.02 0.17 4.01 0.07 15.04 0.27 4.17 1.17 14.48 0.55 2/9/00 4.01 0.33 11.86 1.17 4.01 0.07 15.03 0.20 4.09 0.62 14.56 0.00 2/10/00 No data due to maintenance 4.02 0.13 15.05 0.33 4.09 0.62 14.56 0.00 2/11/00 Operator error caused no calibration drift data to be available for any of the PM CEMSs 2/12/00 4.02 0.25 11.92 0.67 4.01 0.07 15.04 0.27 4.01 0.07 14.49 0.48 2/13/00 4.01 0.33 11.89 0.92 4.01 0.07 15.03 0.20 4.09 0.62 14.48 0.55 2/14/00 4.01 0.33 12.08 0.67 4.01 0.07 15.04 0.27 4.09 0.62 14.64 0.55 2/15/00 4.02 0.25 11.92 0.67 4.01 0.07 15.04 0.27 4.02 0.14 14.48 0.55 2/16/00 4.02 0.25 11.9 0.83 4.01 0.07 15.04 0.27 4.02 0.14 14.56 0.00MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-53

Daily drift results for the period of September 1 to November 20, 1999, are given in Table 5-9B. These data show that none of the three PM-CEMS exceeded the out-of-control limits given above. It was noted that for the ESC P5B, the upscale drift was progressively increasing and exceeded 4% for three consecutive days (October 12-14). Therefore, on October 15, 1999, the manufacturer’s procedures were used to clean the lenses and to change the purge air filter, which decreased the subsequent upscale drift values. The upscale drift again exceeded 4% on November 9 and 10, and the above corrective procedure was used on November 11, 1999. Daily drift results for the period of November 21, 1999, to February 16, 2000, are given in Table 5-9C. These also show that the three PM-CEMS did not exceed the out-of-control limits discussed above, except as noted below. That is, it was necessary to perform corrective action on the ESC-P5B six times during the period, to correct the upscale drift problem as noted previously in Section 4.1. The upscale drift exceeded 4% for 7 consecutive days and therefore was out of control for 2 days (February 5 and 6, 2000). However, this out-of-control period would not have occurred if on-site personnel were responsible for responding to such problems.

5.3.3.3 Absolute Correlation Audit Results Absolute correlation audits (ACA) were conducted on the ESC-P5B and Durag DR 300- 40 according to procedures given in draft Procedure 2. Audit standards (i.e., reference materials) for the ACAs were provided by the two PM-CEM manufacturers. No such reference materials were available from Durag for the F904K beta gauge, so the ACAs for this PM-CEM were limited to performing sample volume audits (SVA). For the ESC-P5B, the manufacturer provided three “reference tubes” with assigned reference values of 34.6 mg, 57.8 mg, and 105.2 mg. To conduct the ACAs on the ESC P5B, the sensor was removed from the probe and each reference tube was alternately attached to theMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-54

sensor until each tube had been applied three times. The readings (in mg) were read directly from the instrument display. For the Durag DR 300-40, the manufacturer used a combination of light filters in a “filter box” to establish the reference standards. The manufacturer initially established the reference values in the field on June 6, 1999. The first ACA was carried out on July 8, 1999, using thoseinitial reference values. However, it later became necessary to change the range on the PMCEMS (as discussed previously in Section 5.2.1.2), which affected the reference values. Therefore, on July 14, 1999, MRI re-established the reference values, as given below, which were used in all the subsequent ACAs. Since the DR300-40 has three operating ranges (i.e., levels) the reference values are range adjusted milliamps, as was explained in Section 1.1.3.2.

Reference values in Range adjusted milliamps Initial values established June 6, 1999 Later values after range change

established July 14, 1999 Range 16.39 mA 14.53 Range 1 32.83 mA 28.60 Range 2 67.81 mA 61.42 Range 3 144.76 mA 133.78 Range 3 For each ACA of the Durag DR 300-40, the instrument was removed from the duct and placed on the filter box. Each reference filter was alternately applied to the instrument according to the manufacturer’s instructions until each reference was applied three times. The readings, in range adjusted mA, were obtained from the 1 min averages generated by the DAS, which were compared with the reference values.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-55

A total of four ACAs were performed on the ESC-P5B and DR 300-40, as follows: June 30 and July 8, 1999 Initial ACA Prior to start of 6-month endurance test period on July 20, 1999 August 26, 1999 2nd ACA Prior to first RCA on August 27, 1999 November 15, 1999 3rd ACA Prior to second RCA on November 17, 1999 February 7, 2000 4th ACA Prior to end of 6-month endurance test on February 16, 2000Results for all four ACAs are given in Table 5-10A, B, C, and D and show that the ESCP5B and DR 300-40 met the draft Procedure 2 criteria in all four ACAs.

5.3.3.4 Sample Volume Audit Results The Durag F904K beta gauge is an extractive PM-CEM, as was explained in Section 1.1.3.3. Particulate matter is collected on a paper tape during each sample cycle. The amount (mg) of particulate matter on the filter is determined by the reduction in transmission of beta particles, before and after sampling. During each sampling period the F904K measures the volumetric flowrate of sample gas in order to determine the total volume of gas sampled during the sampling cycle. Thus, the output signal from the monitor (mA) is proportional to the mass of particulate per unit volume of gas (i.e., mg/dscm). Since the measurement of the gas volume is a critical parameter in the results, EPA draft Procedure 2 (dated November 1998) specifies that a Sample Volume Audit (SVA) be performed every quarter, and that the PM-CEM be considered out of control if results exceed ±5% of the average sample volume audit value.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-56

The procedure used for the SVAs was to connect the sample gas exhaust from the F904K to the inlet of the dry gas meter (DGM) on one of the calibrated sampling consolesMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-57 **Table 5-10A. Results for Initial ACA**
**ESC P5B ACA Result**

Test date June 30, 1999 Audit points Low (mg) Mid (mg) High (mg) Challenge 1 35.1 57.2 104.9 Challenge 2 35.0 57.4 105.2 Challenge 3 35.0 57.3 104.4

Average 35.0 57.3 104.8 Reference value (by manf.) 34.6 57.8 105.2
ACA% 1.16 0.87 0.35 Pass/Fail 15% Criteria Pass Pass Pass


### Durag DR 300-40 ACA Result

Test date July 8, 1999 Audit points (See note) Range 1 A (ra mA) Range 2

B (ra mA) Range 3

C (ra mA) Range 3

D (ra mA) Challenge 1 15.42 30.67 63.64 137.86 Challenge 2 15.72 31.25 64.15 138.79 Challenge 3 15.76 31.33 64.57 139.45

Average 15.63 31.08 64.12 138.70 Reference value (by manf. in field) 16.39 32.83 67.81 144.76
ACA% 4.64 5.32 5.44 4.19 Pass/Fail 15% Criteria Pass Pass Pass Pass Note: Units shown in columns (ra mA) are range adjusted milliamps.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-58 **Table 5-10B. Results for 2nd ACA**
**ESC P5B ACA Result**

Test date August 26, 1999 Audit points Low (mg) Mid (mg) High (mg) Challenge 1 35.1 56.9 104.0 Challenge 2 35.3 56.9 105.1 Challenge 3 34.8 56.4 104.2

Average 35.7 56.7 104.4 Reference value (by manf.) 34.6 57.8 105.2
ACA% 1.35 1.85 0.73 Pass/Fail 15% Criteria Pass Pass Pass


### Durag DR 300-40 ACA Result

Test date August 26, 1999 Audit points (See note) Range 1 A (ra mA) Range 2

B (ra mA) Range 3

C (ra mA) Range 3

D (ra mA) Challenge 1 14.64 28.57 61.82 132.90 Challenge 2 14.60 28.66 61.74 133.40 Challenge 3 14.64 28.78 61.93 133.70

Average 14.63 28.67 61.83 133.33 Reference value (by MRI on July 14, 1999) 14.53 28.6 61.42 133.78
ACA% 0.67 0.24 0.67 0.33 Pass/Fail 15% Criteria Pass Pass Pass Pass Note: Units shown in columns (ra mA) are ranged adjusted milliamps.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-59 **Table 5-10C. Results for 3rd ACA**
**ESC P5B ACA Result**

Test date November 15, 1999 Audit points Low (mg) Mid (mg) High (mg) Challenge 1 35.4 57.9 105.8 Challenge 2 34.9 57.4 104.8 Challenge 3 35.2 57.1 105.1

Average 35.17 57.47 105.23 Reference value (by manf.) 34.6 57.8 105.2
ACA% 1.64 0.58 0.03 Pass/Fail 15% Criteria Pass Pass Pass


### Durag DR 300-40 ACA Result

Test date November 15, 1999 Audit points (See note) Range 1 A (ra mA) Range 2

B (ra mA) Range 3

C (ra mA) Range 3

D (ra mA) Challenge 1 15.14 29.95 64.57 140.94 Challenge 2 15.16 29.98 64.66 141.07 Challenge 3 15.15 29.98 64.66 141.16

Average 15.15 29.97 64.63 141.06 Reference value (by MRI on July 14, 1999) 14.53 28.6 61.42 133.78
ACA% 4.27 4.79 5.23 5.44 Pass/Fail 15% Criteria Pass Pass Pass Pass Note: Units shown in columns (ra mA) is ranged adjusted milliamps.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-60 **Table 5-10D. Results for 4th ACA**
**ESC P5B ACA Result**

Test date February 7, 2000 Audit points Low (mg) Mid (mg) High (mg) Challenge 1 35.0 57.3 103.2 Challenge 2 34.7 57.2 104.0 Challenge 3 34.6 56.8 103.7

Average 34.77 57.10 103.63 Reference value (by manf.) 34.6 57.8 105.2
ACA% 0.48 1.21 1.49 Pass/Fail 15% Criteria Pass Pass Pass


### Durag DR 300-40 ACA Result

Test date February 7, 2000 Audit points (See note) Range 1 A (ra mA) Range 2

B (ra mA) Range 3

C (ra mA) Range 3

D (ra mA) Challenge 1 14.74 25.39 62.23 135.50 Challenge 2 14.72 28.99 62.18 135.10 Challenge 3 14.77 29.00 62.14 136.00

Average 14.74 27.79 62.18 135.53 Reference value (by MRI on July 14, 1999) 14.53 28.6 61.42 133.78
ACA% 1.47 2.82 1.24 1.31 Pass/Fail 15% Criteria Pass Pass Pass Pass Note: Units shown in columns (ra mA) are ranged adjusted milliamps.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-61

used in the M17 tests in order to determine the volume of gas exhausted over a sampling cycle. This assumed that the exhaust volume was equal to the sampled volume, which is true as long as there are no leaks in the dilution air line or sample line upstream of the sample pump. The volume measured by the DGM was then compared with the volume reported by the F904K. (The F904K only reported volume to the nearest liter.) For this project a total of four SVAs were carried out. Each audit consisted of three sampling cycles, but several three-cycle audits were done during some of the SVAs since draft Procedure 2 does not specify how many should be done. The four SVAs were carried out on the following dates:

Initial SVA July 12 to 18, 1999 During the initial correlation testing Second SVA August 26 to 31, 1999 During first RCA Third SVA November 16 to 20, 1999 During second RCA Fourth SVA February 7, 2000 Prior to end of 6-month endurance test period Results for the four SVA are presented in Table 5-11A, B, C, and D, and show that the F904K met the criteria (5%) in all the SVAs.

5.3.4 Initial Correlation and RCA Test Results Probably the most important objective of this project was to carry out the initial correlation tests to determine if the data met the draft PS-11 criteria, and later to carry out RCA tests to determine if those data met the draft Procedure 2 criteria, which is that 75% of the data points must fall within a ± 25% tolerance interval of the initial correlation relation.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-62MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-63 **Table 5-11A. Initial SVA Results**

**Durag F904K**

Date Run no. Reference F904K volume (N liters) F904K volume (N liters) Difference

(N liters) Percent of

reference (%) Criteria 5%

Pass/Fail 7/12/99 1 95.3 95 0.3 0.3

2 94.9 95 –0.1 –0.1 3 95.4 95 0.4 0.4 Average 0.2 Pass 7/13/99 1 93.8 95 –1.2 –1.3

2 93.5 95 –1.5 –1.6 3 93.6 95 –1.4 –1.5 Average –1.5 Pass 7/14/99 1 94.8 95 –.02 –0.2

2 93.6 94 –0.4 –0.4 3 92.8 94 –1.2 –1.3 Average –0.6 Pass 7/15/99 1 95.8 95 –0.8 0.8

2 92.2 93 –0.8 –0.9 3 93.0 94 –1.0 –1.1 Average –0.4 Pass 7/16/99 1 93.2 94 –0.8 –0.9

2 94.4 95 –0.6 –0.6 3 92.3 96 –3.7 –4.0 Average –1.8 Pass 7/17/99 1 93.9 94 –0.1 –0.1

2 94.4 95 –0.6 –0.6 3 93.6 94 –0.4 –0.4 Average –0.4 Pass 7/18/99 1 94.4 95 –0.6 –0.6

2 92.9 93 –0.1 –0.1 3 94.7 96 –1.3 –1.4 Average –0.7 PassMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-64

N liters refers to Normal liters (i.e., standard conditions of 20 E C and 760 mm Hg). 

### Table 5-11B. Second SVA Results

**Durag F904K**

Date Run no. Reference F904K volume (N liters) F904K volume (N liters) Difference

(N liters) Percent of

reference (%) Criteria 5%

Pass/Fail 8/26/99 1 96.4 94 2.4 2.5

2 96.6 94 2.6 2.7 3 95.4 93 2.4 2.5 Average 2.6 Pass 8/27/99 1 96.5 95 1.5 1.6

2 97.2 95 2.2 2.3 3 96.8 94 2.8 2.9 Average 2.2 Pass 8/28/99 1 96.3 93 3.3 3.4

2 96 93 3 3.1 3 96.5 95 1.5 1.6 Average 2.7 Pass 8/29/99 1 99.1 96 3.1 3.1

2 99.1 96 3 3.0 3 96.9 95 1.9 2.0 Average 2.7 Pass 8/30/99 1 98.1 94 4.1 4.2

2 98.1 95 3.1 3.2 3 96.3 94 2.3 2.4 Average 3.2 Pass 8/31/99 1 95.6 93 2.6 2.7

2 97.7 94 3.7 3.8 3 98.5 95 3.5 3.6 Average 3.4 Pass N liters refers to Normal liters (i.e., standard conditions of 20 E C and 760 mm Hg).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-65MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-66 **Table 5-11C. Third SVA Results**

**Durag F904K**

Date Test no. Reference F904K volume (N liters) F904K volume (N liters) Difference

(N liters) Percent of

reference (%) Criteria 5%

Pass/Fail 11/16/99 1 96.7 93 3.7 3.8

2 96.7 94 2.7 2.8 3 97 93 4 4.1 Average 3.6 Pass 11/17/99 1 99.1 94 5.1 5.1

2 94.7 92 2.7 2.9 3 95.5 94 1.5 1.6 Average 3.2 Pass 11/18/99 1 94.2 93 1.2 1.3

2 95.1 94 1.1 1.2 3 92.8 92 0.8 0.9 Average 1.1 Pass 11/19/99 1 94.2 93 1.2 1.3

2 93.8 92 1.8 1.9 3 93.8 93 0.8 0.9 Average 1.3 Pass 11/20/99 1 94.1 91 3.1 3.3

2 96.6 95 1.6 1.7 3 96.8 94 2.8 2.9 Average 2.6 Pass N liters refers to Normal liters (i.e., standard conditions of 20 E C and 760 mm Hg).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-67 **Table 5-11D. Fourth SVA Results**

**Durag F904K**

Date Test no. Reference F904K volume (N liters) F904K volume (N liters) Difference

(N liters) Percent of

reference (%) Criteria 5%

Pass/Fail 2/7/00 1 113.9 112 1.9 1.7

2 112.6 112 0.6 0.5 3 114.2 113 1.2 1.1 Average 1.1 Pass N liters refers to Normal liters (i.e., standard conditions of 20 E C and 760 mm Hg).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-68

The initial correlation tests were carried out on July 15-19, 1999, just prior to the start of the 6-month endurance test period on July 20, 1999. The first RCA was carried out August 27 to August 30, 1999. The second RCA was carried out on November 17 to 20, 1999. Results for each of these tests are described in the following three sections:

5.3.4.1 Initial Correlation Test Results and Correlation Relations 5.3.4.2 First RCA Test Results and Comparison with Initial Correlation

Relations 5.3.4.3 Second RCA Test Results and Comparison with Initial

Correlation Relations

5.3.4.1 Initial Correlation Test Results and Correlation Relations The initial correlation tests consisted of 15 runs, but only 12 runs were used for determining the initial correlation relations because 3 of the runs (Run 10, 11 and 12) appeared to be outliers. It was discovered that the facility was burning a very unusual coal (“met coal”) during these 3 runs, as was explained in Section 5.2.1.4. These runs were therefore not included in the statistical calculations specified in draft PS-11. (However, the later results from the RCA tests indicated that these three data points probably should not have been excluded, and they have been included in the later discussion of the results and graphs from the first and second RCA.) The start of each test run was coordinated with the beginning of a sampling period for the F904K. Since the time required for M17 port changes was short (2-3 min), port change times were not removed from the PM CEMS test run averages. The average of the PM-CEM readings was computed after each run for comparison with the average of M17 results for each run. Those data are shown in Table 5-12 and were used to develop the correlation relations, as prescribed in draft PS-11, Section 12.3.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-69MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-70 **Table 5-12. Tabulation of Data from Initial Correlation Tests Tabulation of Data for ESC P5B and Durag 300-40**  Run no. Concentration*

(mg/acm) ESC P5B

response (ma) DR300-400 response

(Range Adj: ma) 10 26.13 11.40 20.06 

# } Not included in initial correlation relations 11 27.75 11.76 21.62 12 32.28 13.88 27.83 13 11.61 9.60 15.45 14 13.92 10.01 17.22 15 14.46 10.54 19.36 16 3.03 5.87 6.42 17 2.68 5.78 6.44 18 3.20 6.00 7.28 19 16.33 12.00 20.93 20 10.52 9.45 15.80 21 9.42 8.97 14.32 22 15.38 13.16 24.54 23 8.75 9.57 15.68 24 18.65 14.50 30.88 *Average particulate concentration measured by M17, converted to units consistent with PM-CEMS (See Table 5-3A)

### Table 5-12 (Continued)

MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-71 **Tabulation of Data for Durag F904K**

Run no. Concentration*

(mg/dscm) F904K Response (ma) 10 39.5 11.74 

# } Not included in initial correlation relations 11 41.8 11.71 12 49.5 14.49 13 17.2 8.58 14 21.1 9.24 15 21.8 9.98 16 4.6 5.04 17 4.0 5.09 18 4.8 5.21 19 24.4 10.48 20 16.1 8.07 21 14.3 8.05 22 23.3 10.95 23 13.1 8.08 24 28.4 12.27 *Average particulate concentration measured by M17, converted to units consistent with PM-CEMS (See Table 5-3A)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-72

Polynomial and linear correlation equations were generated for each PM-CEM. The correlation for each PM-CEM was done in units consistent with the results of the PM-CEM’s measurements. The ESC P5B and Durag DR 300-40 correlations were done in units of mg/acm, while the Durag F904K correlation was done in units of mg/dscm. The regression equations and corresponding correlation coefficients (r) are listed below. The graphs for the linear correlations are shown in Figures 5-3A, B, and C. (All the CEM data for each run are tabulated in Volume 2, Appendix F, and statistical results are shown in Volume 2, Appendix G.) Emission limits for the facility are shown on the Figures 5-3A, B, and C, in units consistent with those measured by the PM-CEMS, as a horizontal dashed line (i.e., 17 mg/acm or 25.5 mg/dscm).
ESC P5B : Polynomial Equation (r = 0.970) mg/acm = ! 

### 0.098 * mA 2

### + mA ! 

### 16.06 Linear Equation (r = 0.964) mg/acm = 1.89 * mA ! 

### 7.50 (See Figure 5-3A) Durag DR 300-40 : Polynomial Equation (r = 0.972) mg/acm = –0.018 * mA 2

### + 1.33 * mA – 5.29 Linear Equation (r = 0.955) mg/acm = 0.71 * mA – 0.82 (See Figure 5-3B) Durag F904K: Polynomial Equation (r = 0.988) mg/dscm = –0.11 * mA 2

### + 5.12 * mA –19.13 Linear Equation (r = 0.988)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-73 mg/dscm = 3.37 * mA – 12.38 (See Figure 5-3C)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-74 **Figure 5-3A. Linear Regression for ESC Light Scatter—P5B**



## ESC P5B - Linear

0 5 10 15 20 25

4 6 8 10 12 14 16 mAmg/acm Initial Corr. ylin CI low CI high TI low TI high 

## y=1.89x-7.50

Emission Limit = 17 mg/acmMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-75MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-76 **Figure 5-3B. Linear Regression for Durag Light Scatter—DR 300-40**



## Durag DR 300-40 - Linear

0 5 10 15 20 25 30

4 8 12 16 20 24 28 32 Range adjusted mAmg/acm Initial Corr. ylin CI low CI high TI low TI high 

## y=0.71x-0.82

Emission Limit = 17 mg/acmMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-77MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-78 **Figure 5-3C. Linear Regression for Durag Beta Gauge—F904K**

Durag F904K - Linear

0 5 10 15 20 25 30 35

4 6 8 10 12 14 mAmg/dscm Initial Corr. ylin CI low CI high TI low TI high 

### y = 3.37x - 12.38

Emission Limit = 25.5 mg/dscmMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-79MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-80

The test (specified in Section 18.2.3 of draft PS-11) to determine the best correlation fit at the 95% confidence level revealed: (1) for the ESC P5B the linear regression gave the best fit, (2) for the Durag DR 300-40 the polynomial regression gave the best fit, and (3) for the Durag F904K the linear regression gave the best fit. (Details of these calculations are presented in Appendix G.) Since the polynomial equation gave the best fit for the DR 300-40, a check to determine the location of the maxima was done. This check was carried out by taking the derivative of the equation, setting it equal to zero, and solving for mA. The maxima check showed that the maxima occurred at a range adjusted mA value of 36.9. Although the highest average mA reading obtained during the initial correlation test was only 31, 1-min average readings of greater than 36.9 did occur during the testing. Therefore, the polynomial equation for the DR 300-40 was not appropriate, so the linear regression equation was used. The PS-11 performance criteria for the selected correlation equations are presented in Table 5-13 and show that (1) the ESC P5B met all three correlation test performance specifications, (2) the Durag DR 300-40 met two of the three correlation test performance specifications, and (3) the Durag F904K met all three correlation test performance specifications. The Durag DR 300-40 PM-CEM had a confidence interval at the emission limit (10.4%) that was just outside the performance specification (10%). However, if the polynomial equation had been used, which gave the better fit but contained a maxima, the DR 300-40 would also have met all three performance specifications. Therefore, all three PM-CEMS were considered to have met all three performance specifications. Although the initial correlation data met the criteria for confidence interval (CI) percentage (< 10%) and tolerance interval (TI) percentage (< 25%), the same was not true for the first RCA data, as discussed in the next section. It is important to point out that these percentages are calculated using the emission limit; therefore a facility’s emission limit has a direct impact on the TI % and CI % and, thus, a direct impact on whether or not the criteria are met.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-81

**Table 5-13. Selected Correlation Equation Values Versus Performance Criteria**

Criterion ESC P5B Durag DR 300-40 Durag F904K Criteria limit Correlation Coefficient (r) 0.964 0.955 0.988 > 0.85 Confidence Interval (CI) at Emission Limit (See note) 9.20% 10.42% 5.37% < 10%

Tolerance Interval (TI) at Emission Limit 17.94% 20.20% 10.73% < 25%
Note: This facility’s emission limit is 0.02 lb/10 6 BTU. This limit was converted to concentration units of 17.0 mg/acm and 25.5 mg/dscm in order to determine the confidence interval and tolerance interval at the emission limit. However, the conversion to concentration units is not exact since the calculation is dependent on percent O 2 and percent H2O, as well as temperature and pressure, which are variable.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-82

5.3.4.2 First RCA Test Results and Comparison with Initial Correlations The primary purpose of the first RCA/ACA test was to compare the RCA test results with the initial correlations discussed above. That is, the initial correlation tests were used to develop graphs (and confidence/tolerance intervals) which relate instrument response (e.g., ma) to particulate concentration (e.g., mg/acm). For the RCA tests, the instrument response and the measured particulate concentration can be plotted on the initial correlation graphs. Ideally, all of the RCA data would fall within the tolerance interval of the initial correlation graph. However, EPA’s draft Procedure 2 specifies that at least 75% of the RCA data (i.e., 9 of 12 runs) must fall within a tolerance interval of ± 25% of the emission limit value, drawn as two lines parallel with the initial correlation line. The data from the first RCA test are presented in Table 5-14, and these data have been plotted on the graphs developed from the initial correlation tests as shown in Figures 5-4A, B, and C (the 12 RCA runs are shown as triangles). Examination of Figures 5-4A, B, and C clearly shows that for each of the three PM-CEMS, no more than 7 of the 12 RCA tests fell within the ± 25% tolerance interval. These results were unexpected, especially since it occurred for all three PM-CEMS. Preliminary review of all the procedures and data did not provide an explanation for these results and the failure to meet the RCA criteria in draft Procedure 2. Draft Procedure 2 does provide procedures to follow if a PM-CEMS correlation fails to meet the RCA criteria. The first step is to combine the RCA data with the initial correlation data, and the combined data are then used to perform the mathematical calculations defined in PS-11 for development of a new PM-CEMS correlation, including examination of alternate forms of the correlation relation (e.g., polynomial). If results for the combined data meet the PS-11 criteria, the revised correlation is to be used. This combining of the data was investigated for this project, with results for the best-fit equation shown in Table 5-15.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-83MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-84 **Table 5-14. Tabulation of Data from First RCA Test Tabulation of First RCA Data for ESC P5B and Durag 300-40** 

Run no. Concentration (mg/acm) ESC P5B

response (ma) DR300-40 response (Range Adj: ma) 1 28.09 14.66 28.77 2 1.90 6.38 6.11 3 2.54 6.41 6.59 4 2.59 6.40 6.75 5 9.77 8.51 11.72 6 8.29 8.35 11.92 7 11.30 7.70 10.80 8 22.12 10.34 16.22 9 24.05 11.23 18.60 10 26.62 11.92 21.53 11 12.97 9.07 12.62 12 19.10 10.17 14.59


### Tabulation of First RCA Data for Durag F904K

Run no. Concentration

(mg/dscm) F904K response (ma) 1 43.05 14.20 2 2.90 5.04 3 3.95 5.07 4 4.00 4.99 5 14.80 7.30 6 12.65 6.99 7 17.40 6.88 8 33.65 9.71 9 36.60 10.71 10 41.00 11.65MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-85 11 19.45 7.57 12 28.65 8.42MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-86 

## ESC P5B - Linear

-5 0 5 10 15 20 25 30 35

4 6 8 10 12 14 16

mAmg/acm Init. Corr. RCA#1 3 MET coal runs Correlation Line - 25% TI + 25% TI 

## y = 1.89x - 7.50

Emission limit = 17 mg/acm



### Figur **e 5-4A. Comparison of Initial Correlation Equation with the First RCA Test Data for ESC-P5B**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-87MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-88 

## Durag DR 300-40 - Linear

-5 0 5 10 15 20 25 30 35

4 8 12 16 20 24 28 32
Range Adjusted mAmg/acm Init. Corr. RCA#1 3 MET coal runs Correlation Line - 25% TI + 25% TI 

## y = 0.71x - 0.82

Emission limit = 17 mg/acm



### Figure 5-4B. Comparison of Initial Correlation Equation with First RCA Test Data for DR300-40MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-89 

## Durag F904K - Linear

-10 0 10 20 30 40 50 60

4 6 8 10 12 14 16

mAmg/dscm Init. Corr. RCA#1 3 MET coal runs Correlation Line - 25% TI + 25% TI 

## y = 3.37x - 12.38

Emission limit = 25.5 mg/dscm



### Fig **ure 5-4C. Comparison of Initial Correlation Equation with First RCA Test Data for F904K**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-90MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-91

**Table 5-15. Correlation Equation Results Using Combined Data from Initial Correlation**

**Tests and First RCA Tests (24 Total Data Points)**
Criterion ESC

P5B Durag

DR 300-40 Durag

F904K Criteria limit Correlation Coefficient (r) (Linear) 0.87 (Polynomial)

0.85 (Linear)

0.92 > 0.85 Confidence Interval (CI) at Emission Limit (See note) 12.0% 14.8% 9.6% < 10%

Tolerance Interval (TI) at Emission Limit 36.9% 39.8% 30.5% < 25%
Note: This facility’s emission limit is 0.02 lb/10 6 BTU. This limit was converted to concentration units of 17.0 mg/acm and 25.5 mg/dscm in order to determine the confidence interval and tolerance interval at the emission limit. However, the conversion to concentration units is not exact since the calculation is dependent on percent O 2 and percent H2O, as well as temperature and pressure, all of which are variable.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-92

None of the three PM-CEMS met all of the draft PS-11 criteria for the combined data. Although all three PM-CEMS met the correlation coefficient criterion (> 0.85), only one met the confidence interval criterion (< 10%), and none met the tolerance interval criterion (< 25%). (More details on these calculations and associated graphs are given in Volume 2, Appendix G-2.) In circumstances where combined data, as discussed above, do not meet the PS-11 criteria, Procedure 2 specifies that a new PM-CEM correlation must be developed based on revised data, which may include the RCA test results but not include the original correlation data. Therefore, the first RCA test data were evaluated per the calculation procedures in PS-11. The results for the best-fit equations (polynomial) are given in Table 5-16, which shows that only the Durag beta gauge (F904K) met all three criteria. The other two PM-CEMS met the correlation coefficient criterion but did not meet the confidence interval and tolerance interval criteria. (More details on these calculations and associated graphs for the first RCA are given in Volume 3, Appendix G-3). Again, it should be noted that meeting these criteria is a function of the facility’s emission limit. As mentioned earlier, the fact that the results from the first RCA were considerably different from the initial correlation data and did not meet the draft Procedure 2 criteria, was unexpected and caused considerable concern, especially in view of the fact that the initial correlation relation met all the draft PS-11 criteria and all three PM-CEMS had been maintained in proper working order (e.g., the two light scatter PM-CEMS passed ACA criteria and the beta gauge passed the sample volume audits). Therefore, the test scenario for the planned second RCA was modified in an effort to obtain additional data that might explain the reason(s) for the non-agreement between the initial correlation and the first RCA, as described in the next section.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-93

**Table 5-16. Correlation Equation Results Using First RCA Test Data Only (12 Data Points)** 
Criterion ESC

P5B Durag

DR 300-40 Durag

F904K Criteria limit Correlation Coefficient (r) (Polynomial) 0.97 (Polynomial)

0.97 (Polynomial)

0.98 > 0.85
Confidence Interval (CI) at Emission Limit 11.6% 11.5% 9.3% < 10%

Tolerance Interval (TI) at Emission Limit 26.5% 26.6% 21.2% < 25%

Note: This facility’s emission limit is 0.02 lb/10 6 BTU. This limit was converted to concentration units of 17.0 mg/acm and 25.5 mg/dscm in order to determine the confidence interval and tolerance interval at the emission limit. However, the conversion to concentration units is not exact since the calculation is dependent on percent O 2 and percent H2O as well as temperature and pressure, all of which are variable.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-94

5.3.4.3 Second RCA Test Results and Comparison with Initial Correlations and First RCA Test Results The primary goal of the second RCA was to obtain data for direct comparison with the initial correlations and the first RCA test results. However, it was decided to replace one of thedual traversing trains (previously used in the initial correlation and first RCA tests) with a singlepoint train. Only the traversing train data (referred to as Train A) were used for comparison with the initial correlation relations and first RCA test results. A second change in the test plan for the second RCA was that some runs would purposely be carried out at reduced boiler load. All the runs in the initial correlation tests and first RCA tests had been done at near full boiler load with a steam production rate of 268-291 K lb/hr. In RCA #2, the low load (LL) runs had steam production rates of 200-210 K lb/hr. Some runs were done at variable load (VL) where steam production was increasing or decreasing between the low load and full load steam rates. As stated above, the primary purposes of the second RCA test was to compare the test results with the initial correlations developed previously from the initial correlation testing and with the first RCA test results. Results from the second RCA test (traversing Train A) are tabulated in Table 5-17 and have been plotted (red dots) on the graphs of the initial correlation results (black diamonds) along with results from the first RCA (blue triangles), as shown in Figure 5-5 A, B, and C and discussed below. (Detailed data for the second RCA test are contained in Volume 4, Appendices F and G.) Figures 5-5A, B, and C show the initial correlation data (black diamonds) and the best fit equation (linear) along with a ± 25% tolerance interval, and also show the data points from both the first and second RCA. The initial correlation data met all the draft PS-11 criteria as discussed previously. However, data for three runs of the initial correlation were excluded sinceMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-95

those runs appeared to be outliers, as was discussed in Section 5.3.4.1. Those 3 data points are included in Figures 5-5A, B, and C (green diamonds).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-96 **Table 5-17. Tabulation of Data from Second RCA Test Tabulation of Second RCA Data for ESC P5B and Durag 300-40** 

Run no. Concentration (mg/acm) ESC P5B

response (ma) DR300-40 response

(Range Adj: ma) 31 25.4 11.69 22.41 32 19.1 10.06 18.64 33 18.4 9.60 17.77 34 10.3 9.42 17.32 35 13.6 7.95 13.31 36 26.6 11.00 22.72 37 57.6 13.44 23.69 38 36.7 10.53 16.92 39 35.6 11.08 17.76 40 12.2 7.54 11.07 41 24.1 8.87 14.90 42 38.3 12.74 

### 28.30

* Concentration measured by M17 Traversing Train (Train A) except Run 33 used average for the two traversing trains.



### Tabulation of Second RCA Data for Durag F904K
Run no. Concentration*

(mg/dscm) F904K Response (ma) 31 37.8 NA-probe broken 32 27.8 NA-probe broken 33 27.2 NA-probe broken 34 15.3 NA-probe broken 35 19.7 7.14 36 38.5 10.28 37 80.2 14.80 38 51.7 11.15 39 49.5 11.34 40 17.5 6.35 41 34.7 7.86 42 55.4 10.92MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-97 * Concentration measured by M17 Traversing Train (Train A) except Run 33 used average for the two traversing trains. 

### Figures 5-5A, B, and C include the results from the first RCA tests (blue triangles) and show that no more than 7 of the 12 runs in the first RCA test fell within the ± 25% tolerance interval of the initial correlation (EPA draft Procedure 2 specifies that 9 of 12 runs (75%) must fall within a ± 25% tolerance interval of the initial correlation). Only 1 of the 12 runs in the second RCA test fell within this ± 25% tolerance interval. Therefore, the results from the second RCA were compared with results from the first RCA alone. That is, the first RCA data had been used for development of separate new correlations as discussed previously in Section 5.3.4.2. Even though these correlations did not meet the confidence interval and tolerance interval criteria for two of the PM-CEMS, they were used to evaluate the data from the second RCA. As shown in Figures 5-6A, B, and C, no more than 6 of the 12 runs from the second RCA fell within a ± 25% tolerance interval of the first RCA correlation relation. The next section of this report presents an investigation of possible reasons for the non-agreement of the results from both the first and the second RCA.

5.3.5 Investigation of Reason(s) for Non-agreement of RCA Results It was originally recognized that the location of the PM-CEMS very near the outlet of thebaghouse compartments was not the most desirable location since it only minimally met the PS11 guidance (i.e., only two duct diameters downstream of a 90 E 

### bend). However, it was the only possible location at this facility to install three PM-CEMS and a moisture monitor. The location had a potential for particulate stratification, but this was not thought to be a serious problem since much of the large particulate would have been removed from the flue gas by the mechanical dust collector and dry SO2

### absorber upstream of the baghouse. It was also thought that if particulate stratification existed it would be constant.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-98MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-99 

## ESC P5B - Linear

-10 0 10 20 30 40 50 60

4 6 8 10 12 14 16

mAmg/acm Init. Corr. RCA#1 3 MET coal runs RCA#2 Correlation Line - 25% TI + 25% TI 

## y = 1.89x - 7.50

VL LL VL

Emission limit = 17 mg/acm LL VL = Variable Load LL = Low Load



### Figure **5-5A. ESC-P5B Initial Correlation and all RCA Data**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-100MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-101 

## Durag DR 300-40 - Linear

-10 0 10 20 30 40 50 60

4 8 12 16 20 24 28 32

Range adjusted mAmg/acm Init. Corr. RCA#1 3 MET coal runs RCA#2 Correlation Line - 25% TI + 25% TI 

## y = 0.71x - 0.82

VL LL VL

Emission limit = 17 mg/acm VL LL VL = Variable Load LL = Low Load



### Figure **5-5B. DR300-40 Initial Correlation and all RCA Data**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-102MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-103 

## Durag F904K - Linear

-10 0 10 20 30 40 50 60 70 80 90

4 6 8 10 12 14 16

mAmg/dscm Init. Corr. RCA#1 3 MET coal runs RCA#2 Correlation Line - 25% TI + 25% TI 

## y = 3.37x - 12.38

VL VL LL

Emission Limit = 25.5 mg/dscm VL LL VL = Variable Load LL = Low Load



### Figure 5-5C. F904K Initial Correlation and all RCA DataMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-104MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-105 

## ESC P5B - Polynomial

-10 0 10 20 30 40 50 60

4 6 8 10 12 14 16

mAmg/acm RCA #1 RCA #2 Correlation Curve - 25% TI + 25% TI 

## y = -46.95 + 9.46x - 0.29x^2

LL VL

VL Emission limit = 17 mg/acm LL VL = Variable Load LL = Low LoadMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-106 **Figure 5-6A. ESC-P5B Correlation for First RCA and Comparison with Data from Second RCA**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-107MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-108 

## Durag DR 300-40 - Polynomial

-10 0 10 20 30 40 50 60

4 8 12 16 20 24 28 32

Range Adjusted mAmg/acm RCA #1 RCA #2 Correlation Curve - 25% TI + 25% TI 

## y = -16.11 + 3.04x - 0.051x^2
LL VL

VL Emission limit = 17 mg/acm LL VL = Variable Load LL = Low Load



### Figure 5-6B. DR300-40 Correlation for First RCA, and Comparison with Data from Second RCAMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-109MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-110 

## Durag F904K - Polynomial

-10 0 10 20 30 40 50 60 70 80 90

4 6 8 10 12 14 16
mAmg/dscm RCA #1 RCA #2 Correlation Curve - 25% TI + 25% TI 

## y = -48.00 + 11.99x - 0.39x^2

LL

VL VL

Emission limit = 25.5 mg/dscm LL

VL VL = Variable Load LL = Low Load



### Figure 5-6C. F904K Correlation for First RCA, and Comparison with Data from Second RCAMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-111MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-112

That is, stratification would not be a problem if the ratio of the particulate concentration at any single point in the duct was constant, relative to the average concentration in the duct. If this ratio was constant, the concentration that existed at any single point (i.e., PM-CEMS location) would be proportional to the average concentration as measured by a traversing train. Investigation of possible reasons for why the RCA results did not meet the draft Procedure 2 criteria relative to the initial correlation test results is discussed in the following subsections and included the investigation of:

• Differences in velocity distribution

• Spikes in PM-CEMS response and causal relation between baghouse cleaning cycle and operation/location of perturbing device

• Particulate concentration ratio for single point train versus traversing trainIt should be noted that the results from each RCA showed similar patterns for all three PMCEMS (i.e., higher emissions relative to PM-CEMS response). This indicated that changes inparticulate characteristics (e.g., size distribution, etc.) probably were not the cause of nonagreement of RCA results, since beta-gauges are not believed to be affected by such changes.

5.3.5.1 Velocity Distribution The initial correlation test data showed that the velocity distribution across the duct was highly skewed, with the highest velocity toward the duct wall opposite the M17 test ports and the PM-CEMS (see Figure 2-1). An example of this skewed velocity distribution is shown in Figure 5-7. Velocity measurements (made through the middle sampling port C) show that the velocity ranges from nearly 1800 meters/minutes (m/min) down to only 200-300 m/min nearest the M17 sampling ports (i.e., Point C1).MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-113

**Figure 5-7. Velocity at Traverse Points through Port C—ICAL vs. First RCA**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-114

Data like those in Figure 5-7 also show that at the points of highest velocity (C5-C3) the velocity measured during the initial correlation tests was somewhat higher than that measured during the first RCA. This led to a suspicion that the lower velocity in the first RCA test might also be associated with a change in particulate stratification. If so, this might be the reason why the results from the first RCA did not fall within the tolerance interval of the initial correlation data. This was investigated further in the second RCA test, where particulate stratification was measured with a single point and traversing trains, at different velocities (i.e., different loads) as discussed in Section 5.3.5.4.

5.3.5.2 Spikes in PM-CEMS Response It had been observed during all of the tests that there were spikes in the response of the two light scatter PM-CEMS (ESC-P5B and Durag DR300-40). It was also observed that the spikes were much larger when the perturbing device was open in order to obtain higher concentrations. Moreover, the spikes occurred every 24 minutes with a 4 minute offset between the spike for the ESC-P5B and the DR-300-40. This phenomenon is shown in Figures 5-8A and 5-8B. Figure 5-8A for November 15 shows the response for the two PM-CEMS over time, when the perturbing device was closed so particulate concentration was low (about 2 mg/acm). The peaks from both monitors occur at the same time and represent relatively small changes in particulate concentration (approx. 0.20 mg/acm). These peaks are likely caused by the brief puff of particulate when a cleaned compartment is first opened. Figure 5-8B for November 17 shows the response of the two PM-CEMS when the perturbing device was open so particulate concentration was high (about 12 mg/acm). The peaks are much greater (about 4-6 mg/acm) and occur every 24 minutes, with the peak for the ESC-P5B occurring 4 minutes after the peak for the DR300-40.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-115 **Figure 5-8A. November 15, 1999: Perturbing Device Closed**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-116 **Figure 5-8B. November 17, 1999: Perturbing Device Open PM-CEM Response** **Converted to (mg/acm)**MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-117

The normal behavior of a baghouse is that there is a PM spike from a freshly cleaned compartment for a brief time until the dust cake on the compartment bags is re-established. However, this is not consistent with what is shown in Figure 5-8B. Moreover, the spike is too large to be attributed to the brief spike that occurs after a compartment cleaning. Rather, the phenomena is caused by the baghouse cleaning cycle and its effect on the particulate from the perturbing device, as explained below.

5.3.5.3 Effect of Baghouse Cleaning Cycle on Spikes in PM-CEMS Response In order to understand the cause of the peaks in the response of the two light-scatter type PM-CEMS, it is necessary to understand the baghouse geometry, the cleaning cycle, and the location of the perturbing device. Figure 5-9 is a schematic top view of the baghouse outlet duct and outlet ducts from each baghouse compartment. There are six baghouse compartments, and the outlet from each is connected to the common outlet duct. The ducts from each compartment contain a damper (valve) that closes whenever that compartment undergoes a cleaning cycle. Each compartment is cleaned for 4 minutes, so the cycle for all six compartments is 24 minutes. Figure 5-9 also shows the location of the perturbing device, a 6-in. diameter pipe which is connected into the bottom of the baghouse outlet duct. The other end of this pipe is connected to the inlet duct to the baghouse. There is a butterfly valve in the 6-in. diameter pipe which provides a means of regulating the amount of particulate that bypasses the baghouse, flowing directly from the inlet duct to the outlet duct. The purpose of this bypass was to increase the PM concentration, simulating a broken bag. However, as mentioned in Section 2.1, the location of the perturbing device may not have been sufficient to allow complete mixing with the baghouse effluent prior to the location of the PM-CEMS.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-118MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-119 C o m pa rt m e nt N o . 6 C o m pa rt m e nt N o . 4 C o m pa rt m e nt N o . 2

C o m pa rt m e nt N o . 5 C o m pa rt m e nt N o . 3 C o m pa rt m e nt N o . 1 9 0 o e l bow w h e r e f low t u r n s d ow nwa rd 6” pe rt u r b i n g d evi c e ( at bott o m of bag h o u s e ex h a u s t d u ct)

2000

. 52 1 -4 P M C E M S S a m p l i n g Po rts l ocat ed o n t h is wa l l , be l ow o u t let d u ct



### Figure 5-9. Top View of Baghouse Outlet DuctMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-120

“Dirty” gas passing through the perturbing device has a very high particulate concentration, probably 100 to 1,000 times the concentration in the baghouse outlet ducts. The intent is for this dirty gas to mix thoroughly with the clean gas in the baghouse outlet duct prior to the location of the PM-CEMS. This is most difficult to achieve when compartment 5 or 6 undergoes cleaning. When the compartment 5 damper closes at the beginning of its cleaning cycle, the clean gas from the open compartment 6 pushes the higher particulate gas in the common outlet duct toward the compartment that is closed (No. 5), causing a sudden rise in response of the Durag DR 300-40 located in the same side of the duct until the air flow pattern becomes stable. Four minutes later, the No. 5 damper reopens and the opposite damper (No. 6) closes, pushing the higher particulate gas in the opposite direction, toward compartment 6, and causing a peak in the response of the ESC P5B located on the other side of the duct until the air flow pattern becomes stable again. This phenomenon was observed during all the tests when the bypass was open and helped to explain the peaks in the PM-CEMS response and the offset between those peaks. This analysis shows that the location of the PM-CEMS relative to the location of the perturbing device is just as important as their location relative to the outlet of the control device. That is, if a perturbing device is used to bypass gas around a control device in order to increase outlet particulate concentration, then the PM-CEMS must be located far enough downstream of the point where the low and high concentration gases come together for them to become well mixed before the gas reaches the PM-CEMS (and the M17 sampling points). Also, devices which can introduce dilution air or otherwise disturb the air flow pattern must be well upstream of the PM-CEMS sampling location.

5.3.5.4 Particulate Concentration Ratio for Single Point Train versus Traversing TrainMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-121

Data for the single point train (B) and traversing train (A) used in the second RCA tests are presented in Table 5-18, including the calculated ratio for the two trains in each **Table 5-18. Tabulation of Data for Single Point Train Versus Traversing Train**

Run no. Load B-Single point (mg/dscm) A-Traversing

(mg/dscm) Ratio (B/A) 31 High 23.7 37.8 0.627 32 High 17.5 27.8 0.630 33 Precision run NA NA

— 34 High 16.7 15.3 1.092 35 High 11.2 19.7 0.569 36 High 22.6 38.5 0.587 37 Low 51.1 80.2 0.637 38 Low 33.5 51.7 0.648 39 Low 34.1 49.5 0.689 40 Variable 14.7 17.5 0.840 41 Low—High 20.0 34.7 0.576 42 Variable 32.8 55.4 0.592MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-122

run. These data are also presented graphically in Figure 5-10, and show that the ratio was essentially constant, covering a narrow range of ratios from 0.569 to 0.689 over a wide range of particulate concentration, except for 2 of the 11 runs (Runs 34 and 40). It can be concluded from these results that the particulate is stratified (i.e., single point values are different from the traversing train values), but that the stratification was essentially constant except in 2 runs (Runs 34 and 40) (i.e., the ratio varies over a narrow range in most runs, even for a wide range in particulate concentration). This indicates that a change in boiler load did not have much effect on particulate stratification. All of the initial correlation tests and first RCA tests were done at full load (steam flowrates of 268-291 K lb/hr). In the second RCA, six of the tests were done at full load while the other six were done at reduced or variable load (see Volume 4, Appendix A). Results for five of the six full load tests done in RCA #2 fell within the ± 25% tolerance interval of the RCA #1 correlation relation, with stratification ratios varying over a narrow range of 0.57 to 0.63. The other high load test (Run 34) had a higher ratio of 1.09, and the results for that run fell within the ± 25% tolerance interval of the initial correlation relation. Thus, a change in the stratification ratio may be a possible explanation for why the RCA #1 correlation was different than the initial correlation.
Five of the six reduced load tests had stratification ratios about the same as the full load tests, but fell outside (above) the ± 25% tolerance interval of both the initial correlation relation and RCA #1 correlation relation. This suggests that the two light scatter monitors responded differently to the particulate at reduced load as compared to high load. If this was due to changes in the light scatter characteristics of the particulate (e.g., different particle size distribution), then light scatter type PM-CEMS may not be appropriate for sources that change load or otherwise make changes that affect light scatter characteristics of the particulate.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-123

The above represents a possible explanation for why the data for the light scatter monitors at the five reduced load tests did not match either of the two tolerance intervals, but it does not explain why the results for the F904K beta gauge also did not fall withinMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-124 **Figure 5-10. Particulate Ratio vs. Concentration** 

# Ratio vs. Concentration

3 1 3 6 4 1 3 2 3 8 3 9 4 2 3 7 3 4

4 0

3 5



# 0 0.2 0.4 0.6 0.8 1 1.2

0 20 40 60 80 100 mg/dscm Particulate Concentration (Traversing Train)Particulate Concentration Ratio(Single Point Train VersusTraversing Train)MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-125

either tolerance interval since beta-gauges are not supposed to be susceptible to changes in particle characteristics. However, the reduced load tests did involve lower duct velocities, which affect the isokinetic sampling rate of the beta gauge. The beta gauge samples at a constant rate and was installed to sample near isokinetically at full load (i.e., the normal operating condition). Therefore, at reduced load it samples at a rate higher than isokinetic, which could produce a low bias in the concentration of particulate sampled by the beta gauge, and thus a lower than expected response. It should be noted that a difference in the particle size distribution between the full load and low load tests may have been caused by the perturbing device rather than an actual change in the process. That is, the gas in the baghouse inlet duct must make a 90 E 

### change in direction in order to enter the perturbing device (6" pipe). At full load (high duct velocity), it is more difficult for larger particles to make this change in direction; but at low load (lower duct velocity), more of the larger particles could enter the perturbing device (i.e., the particulate size distribution at low load would shift to more large particles). This is consistent with the discussion in the above two paragraphs, but no particle size measurements were done in any of the tests.

5.3.5.5 Summary Results from the second RCA confirmed that the velocity distribution is highly skewed, and that the particulate concentration was stratified but was relatively constant over 9 of 11 runs done in RCA #2. Investigation of spikes in the response of the two light-scatter PM-CEMS certainly indicated that there is short-term variability in the particulate stratification, but such variability is apparently dampened out over the M17 sampling periods of 75 to 100 min. This dampening of short-term variability is evidenced by the narrow range of stratification ratios measured during 9 of the 11 runs in RCA #2 and by the fact that the dual M17 trains used in the initial correlation tests and RCA #1 tests met all of the precision and bias criteria per draft Procedure 2.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-126

The primary purpose of the RCA #2 tests was to obtain data on particulate stratification at full load and reduced load in order to try to determine why the RCA #1 results did not meet the draft Procedure 2 criteria relative to the initial correlation relation. The discussion in Section 5.3.5.4 provides a possible explanation for that finding, but it does not change the fact that the RCA #1 and RCA #2 test results did not meet the draft Procedure 2 criteria. It is clear that the location of the PM-CEMS was less than ideal, but the location selected was the only suitable location available at this facility. This location minimally met the guidance in draft PS-11. Thus, the inability to meet the draft Procedure 2 criteria in the two RCA tests may have been due, at least in part, to the location of the PM-CEMS rather than the PM-CEMS themselves. The low load tests done in RCA #2 do indicate possible limitations in the PM-CEMS. That is, if changes in process operating conditions cause changes in particle size distribution, the light scatter PM-CEMS may respond differently to the same particulate concentration. Further, ifchanges in process operating conditions cause changes in flue gas flowrate, then extractive PMCEMS, that do not maintain isokinetic sampling, may also respond differently to the same particulate concentration. One peer reviewer of the report commented that the data suggest that several different correlations exist, but except for the 3 “met coal” runs, there was no indication of changes in the coal or process operating conditions between the 3 sets of tests that would produce different correlations. One peer reviewer seemed convinced that the non-agreement of the two RCA results with the initial correlation was entirely due to the location of the PM-CEMS relative to the baghouse outlet and perturbing device (i.e., stratification). But, conversely, another reviewer stated that he did not think, based on the information shown, that stratification at the PM-CEMS location could be the cause of the non-agreement. These peer review comments and the discussion presentedMRI-OPPT\\R4703-02-07 Revised.wpd 

### 5-127

above demonstrate that no definite conclusion can be made as to the cause of the non-agreement of the results from the RCA tests with the initial correlation, and thus, inability to demonstrate long-term stability of the initial correlation. But, this finding and many other results from the project have been very useful in enabling recommendations for several changes in draft PS-11 and draft Procedure 2, which should be published as a supplementary proposal in the Federal Register in the near future.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 6-1



# Section 6. Internal QA/QC Activities 6.1 QA/QC Issues The QA/QC issues are discussed below for the initial correlation tests, first RCA, second RCA, and final ACA.

6.1.1 Initial Correlation Test Two QA/QC issues occurred during the initial correlation testing as described below:

6.1.1.1 Re-ranging of PM-CEMS After the first 9 runs it was clear that the range on the three PM-CEMS was too broad, considering the facility’s particulate emission limit (~ 17 mg/acm). It was therefore necessary to change (decrease) the range on the CEMS. This necessitated performing the entire set of 15 runs after the range on the PM-CEMS had been changed.

6.1.1.2 Difference in M17 Moisture Contents
It was observed that the moisture content determined in the dual M17 trains sometimes differed by as much as 2.0% H 2

### O (e.g., 12.2% vs. 14.2% in Run 17). This might have been caused by using an H 2

### O squirt bottle to identify sources of leaks in an impinger train that did not pass initial leak check. However, even when that had not been done, the difference in some runs was higher than expected.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 6-2

Investigation of the problem revealed that additional water flowed into the first impinger if the latex transfer line was elevated to help draw water out of the line, while maintaining flow of air through the sampling system using the sampling console pump. (This was done after the end of a run and after completing all leak checks.) This procedure was used in all runs after Run 18, and in the later RCA tests, as well as eliminating the use of water in troubleshooting any leak check problems. It should be noted that investigation of two sets of similar multiple train data from other stack tests revealed that moisture differences of at least 1% H 2

### O have occurred for a moisture level of 10-15%, and differences of at least 2% for a moisture level of ~ 50%. In both sets of data the filter/impinger box was directly connected to the probe, or a heated Teflon transfer line was used to connect the probe to the filter/impinger box. In many emission tests, the moisture content is of minimal importance when particulate emissions are in terms of mg/dscm. However, moisture content does affect conversion to other units (e.g. mg/acm). An error of 1% H 2

### O causes a similar error (1%) in converting mg/dscm to mg/acm, for a moisture level of 10% in the gas. However, an error of 1% H 2

### O causes an error of about 2% in the conversion to mg/acm, for a moisture level of 50% in the gas. Moreover, examination of other test data indicated that in high moisture stack gas, the difference in H 2

### O measured by dual trains can exceed 1% H 2

### O (up to as much as 2.3% H 2

### O).

6.1.2 First RCA Test No QA/QC problems or issues occurred during the first RCA tests.MRI-OPPT\\R4703-02-07 Revised.wpd 

### 6-3

6.1.3 Second RCA Test There were some operational and maintenance problems with the CEMS during the second RCA, primarily the H 2

### O CEMS and the F904K PM-CEMS, as discussed earlier in this report. No other QA/QC problems occurred during the second RCA/ACA testing.

6.1.4 Final ACA After the second RCA (November 16 to November 20, 1999) the logging of data from all the PM-CEMS continued to the end of the 6-month endurance test period (February 16, 2000). Near the end of that period (February 7, 2000) a final ACA and SVA was carried out. Although there was some maintenance performed to correct operational problems on some of the CEMS during this period (as discussed previously), there were no QA/QC problems.



# 6.2 QA Audits Absolute correlation audits of the two light scatter PM-CEMS were performed four times during the 6-month endurance test, as discussed previously in Section 5, using audit materials supplied by the vendors (no audit materials were available for the Durag F904K). In addition, all three PM-CEMS automatically perform a daily calibration drift check. The ESC P5B was the only one that sometimes exceeded the drift criteria of #

### 4% of the upscale value, but corrective action prevented it from exceeding the 4% criteria for 5 consecutive days (i.e. the out-of-control criteria). Also, four sets of sample volume audits were performed on the Durag F904K, which met the criteria of ±5% of the audit value (i.e., volume measured by the calibrated dry gas meter). For all the M17 sampling, the crew chief reviewed all of the raw data sheets, and these were also spot checked by the WAL. Post-test calibration checks of the sampling meter boxes wereMRI-OPPT\\R4703-02-07 Revised.wpd 

### 6-4

performed using calibrated critical orifices after the initial correlation and the two RCA tests. Results for both meter boxes were within the acceptable range of 5% after each set of tests. These QA checks, as well as those for thermocouples, barometer, and pitot tubes are contained in Appendix E. An audit of the initial correlation relationship was also carried out. This consisted of an independent calculation of all statistical results for one PM-CEMS by an MRI statistician. That is, the M17 results and the average response for the Durag beta gauge, for all 12 runs, were used to carry out all the statistical calculations per PS-11. These independently determined results were then compared with those computed for the initial correlation relations. Some minor discrepancies were identified and corrected, including any that affected results for the other two PM-CEMS.