# EMISSIONS TEST REPORT

EMISSION TESTING PROGRAM FOR COMPLIANCE WITH THE ELECTRIC UTILITY MACT PHASE III EPA SECTION 114 INFORMATION COLLECTION REQUEST FOR THE
AES / IPL Eagle Valley Units 1, 2, and 6

Prepared for:
Indianapolis Power and Light Eagle Valley Generating Station Martinsville, Indiana

Prepared by:

URS Corpor ation 1600 Perimeter Park Drive

Morrisville, NC 27560

July 2010

## TABLE OF CONTENTS

Section 1 Introduction ................................................................................................................1-1
1.1 Summary of Test Program....................................................................... 1-1 Section 2 Facility Description ..................................................................................................2-1
2.1 Eagle Valley Units 1 and 2 ...................................................................... 2-1 2.1.1 Process Description...................................................................... 2-1 2.1.2 Sampling Location....................................................................... 2-1 2.1.3 Process Operating Data................................................................ 2-2 2.2 Unit 6 ....................................................................................................... 2-4 2.2.1 Process Description...................................................................... 2-4 2.2.2 Sampling Location....................................................................... 2-4 2.2.3 Process Operating Data................................................................ 2-5 2.3 Fuel Analysis Data................................................................................... 2-6

Section 3 Test Results ................................................................................................................3-1

3.1 Units 1 and 2 ............................................................................................ 3-1 3.2 Unit 6 ....................................................................................................... 3-6

Section 4 Test Methods ..............................................................................................................4-1

4.1 EPA Methods 1-4..................................................................................... 4-1 4.2 EPA Methods OTM-027 and OTM-028.................................................. 4-1 4.3 EPA Methods 5 and OTM-028................................................................ 4-2 4.4 EPA Method 6C....................................................................................... 4-3 4.5 EPA Method 7E ....................................................................................... 4-3 4.6 EPA Method 10........................................................................................ 4-4 4.7 EPA Method 18........................................................................................ 4-4 4.8 EPA Method 23........................................................................................ 4-4 4.9 EPA Method 25A..................................................................................... 4-6 4.10 EPA Method 26A..................................................................................... 4-6 4.11 EPA Methods 5 and 29 ............................................................................ 4-7 4.12 EPA Method 30B..................................................................................... 4-7 4.13 EPA Conditional Test Method 33............................................................ 4-8 4.14 SW846-0010 ............................................................................................ 4-9 4.15 SW846-0031 .......................................................................................... 4-10 4.16 Process Data........................................................................................... 4-10 Section 5 Quality Assurance/Quality Control ..................................................................5-1
5.1 Sampling QA/QC..................................................................................... 5-1 5.2 Other QA/QC........................................................................................... 5-1

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## TABLE OF CONTENTS

APPENDICES Appendix A Sampling Data A-1 Eagle Valley Units 1 and 2 A-1-1 Preliminary Test Data A-1-2 Emission Test Data for PM, PM 2.5, and Metals A-1-3 Emission Test Data for Acid Gases A-1-4 Emissions Test Data for Non-Dioxin/Furan Organics A-1-5 Emissions Test Data for Dioxin Organics
A-2 Eagle Valley Unit 6 A-2-1 Preliminary Test Data A-2-2 Emission Test Data for PM, PM 2.5, and Metals

Appendix B Analytical Data B-1 Enthalpy Analytical Labs – EPA Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 B-2 Analytical Perspectives Labs – M23 Analysis B-3 Test America – Met hod 29 SW846-0031 Analysis B-4 URS – Gravimetric Analysis B-5 Columbia Analytical Fuel Analysis
Appendix C Hourly Process Operating Data
Appendix D QA/QC Data
Appendix E 30-Day Process Data
Appendix F EPA ERT Files and Spreadsheets

Appendix G Test Plans and Correspondence

iii Eagle Valley Test Report - Final SV 31827132

## TABLE OF CONTENTS

iv Eagle Valley Test Report - Final SV 31827132 LIST OF TABLES Page 1-1 Summary of Eagle Valley Station Testing Requirem ents .......................................... 1-1 1-2 Eagle Valley Station Testing Dates ............................................................................ 1-1 1-3 Summary of Test Re sults for Eagle Valley ................................................................. 1-2 2-1 Summary of Boiler Operating Parameters for Units 1 & 2 ........................................ 2-3 2-2 Summary of Boiler Operating Parameters for Unit 6 ................................................. 2-6 2-3 Summary of Fuel Anal ysis for Units 1, 2, and 6 ........................................................ 2-6 3-1 Units 1 and 2 Test Schedule ........................................................................................ 3-1 3-2 Units 1 and 2 Summar y f or Particulate Matter ........................................................... 3-2 3-3 Units 1 and 2 Summary for Metals ............................................................................. 3-2 3-4 Units 1 and 2 Summary for Non-Dioxin Organic HAP .............................................. 3-2 3-5 Units 1 and 2 Summary for Dioxins/Furans and PCB ................................................ 3-3 3-6 Units 1 and 2 Summary for Semi-Volatile PAHs ....................................................... 3-3 3-7 Units 1 and 2 Summary for Acid Gases ...................................................................... 3-4 3-8 Units 1 and 2 Summary for Sp eciated Volatile Organic Compounds ........................ 3-4 3-9 Unit 6 Test Schedule ................................................................................................... 3-6 3-10 Unit 6 Summary for Particulate Matter ...................................................................... 3-6 3-11 Unit 6 Summary for Metals ........................................................................................ 3-7

LIST OF FIGURES
2-1 Process Flow Diagram for Units 1 and 2 .................................................................... 2-1 2-2 Sampling Locations for Units 1 and 2 ........................................................................ 2-2 2-3 Process Flow Diagram for Unit 6 ............................................................................... 2-4 2-4 Sampling Location for Unit 6 ..................................................................................... 2-5

## SECTION 

# ONE Introduction

1. Section 1 ONE Introduction 

### 1.1 SUMMARY OF TEST PROGRAM On November 10, 2009, USEPA published a noti ce in the Federal Register (Vol. 75, No. 216, pages 58012-58013) pursuant to Section 114 of the federa l Clean Air Act regarding an Information Collection Request (ICR) for Ne w and Existing Coal and Oil-fired Electric Utility Steam Electric Units. The objective of the ICR was to obtain information related to hazardous air pollutant (HAP) emissions from th e coal- and oil-fired boilers used to produce electricity. In late December of 2009, the U.S. EPA sent ICR letters to affected facility owners defining unit-specific test ing requirements and schedules. IP&L’s Eagle Valley Station received such a le tter on January 4, 2010. Included in the letter was the requirement to conduct the emissi ons testing summarized in Table 1-1. Table 1-1. Summary of Eagle Vall ey Station Testing Requirements

Unit ID Acid Gas HAP Dioxin HAP Non-Dioxin HAP Metallic HAP Eagle Valley 1 X X X X Eagle Valley 2 X X X X Eagle Valley 6 X
URS Corporation (URS) was contracted to conduct the emissions te sting required by the ICR. The actual test dates for each boiler are summarized in Table 1-2. Table 1-2. Eagle Valley Station Testing Dates

Unit ID Testing Dates Eagle Valley 1 & 2 May 4-7, 2010 Eagle Valley 6 May 11-12, 2010

Table 1-3 is a summary of the compounds tested and the test re sults for each of the units tested, based on the average of all three valid test runs for each parameter.

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## SECTION 

# ONE Introduction

Table 1-3. Summary of Test Results for Eagle Valley

Test Results Test Parameter EV 1&2 EV 6 Units Filterable PM b 2.30E-03 8.42E-03 lb/mmBtu PM 2.5 4.12E-03 3.92E-02 lb/mmBtu Aqueous CPM 1.39E-03 2.78E-02 lb/mmBtu Organic CPM 1.29E-03 3.72E-03 lb/mmBtu Total PM c 5.81E-03 4.21E-02 lb/mmBtu Antimony 7.19E-08 6.26E-07 lb/mmBtu Arsenic [<6.18E-07] 6.88E-06 lb/mmBtu Beryllium [<2.48E-08] [<1.86E-07] lb/mmBtu Cadmium 4.94E-08 9.15E-08 lb/mmBtu Chromium 8.05E-07 1.96E-06 lb/mmBtu Cobalt 8.55E-08 4.47E-07 lb/mmBtu Lead 5.84E-06 6.26E-06 lb/mmBtu Manganese 1.26E-06 1.01E-06 lb/mmBtu Mercury 1.36E-07 3.81E-06 lb/mmBtu Nickel 9.30E-07 2.70E-06 lb/mmBtu Selenium [<3.51E-07] 7.42E-05 lb/mmBtu [<1.98E-10] -- lb/mmBtu PCDD/F [<0.23] -- ng/dscm@7% O 2 [<8.62E-10] -- lb/mmBtu PCB [<1.00] -- ng/dscm@7% O 2 HCl [<9.38E-05] -- lb/mmBtu HF [<9.62E-05] -- lb/mmBtu HCN [<2.58E-05 ] -- lb/mmBtu 1.16E-01 -- lb/mmBtu NO X 70.4 -- ppmvd@7% O 2 2.18E-02 -- lb/mmBtu SO 2 9.5 -- ppmvd@7% O 2 8.41E-04 -- lb/mmBtu CO 0.8 -- ppmvd@7% O 2 [<4.73E-06] -- lb/mmBtu HCHO [<4.39E-03] -- ppmvd@7% O 2 2.57E-04 -- lb/mmBtu THC 0.2 -- ppmvd@7% O 2 6.70E-04 -- lb/mmBtu CH 4 1.2 -- ppmvd@7% O 2 [<2.40E-04] -- lb/mmBtu Volatile Organic HAP d [<278] -- ug/dscm@7% O 2 [<1.91E-06] -- lb/mmBtu Semi-Volatile Organic HAP e [<2.22] -- ug/dscm@7% O 2

a Results containing non-detect valu es are indicated with [<] and are

reported at the full detection limit. b Based on RM 5/29 data

c Based on OTM-027/028 data d Excludes acetone, methylene chloride , and toluene used for Method 0010

recovery that was in field blanks.

e Sum of 19 targeted PAH compounds.

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## SECTION 

# ONE Introduction

1-3 Eagle Valley Test Report - Final SV 31827132 During the stack test periods, the normal load wa s maintained during the test periods. For oilfired Units 1 and 2, normal load was approximate ly 40% of full load. For coal-fired Unit 6, normal load was approximately 82% of full load. The emission testing program was conducted in a ccordance with the requirements of EPA’s Section 114 ICR and the guidance posted on th e RTI Utility MACT We bsite. There were no deviations to the standard test methods utili zed for this test program. Results for total Speciated Volatile Organic HAP do not include values for acetone, methylene chloride, toluene, or the four compounds used as spik e compounds. Acetone, me thylene chloride, and toluene were present at the test location and were detected in the field blanks. Reported values for these compounds are assumed to be due to contamination. Reported values for the four compounds used as surrogates are due to spike recoveries being >100%. Section 2 of this report describes each of th e units tested, including sampling locations and operating conditions. Section 3 is a detailed summary of test results. Section 4 describes the test methods used for this program, and Sec tion 5 describes quality assurance parameters. Raw data and calculation summaries are contained in the Appendices.

## SECTION 

# TWO Facility Description

2. Section 2 TWO Facility Description Section 2 describes each of th e tested units, the sampling locations, and the unit operating data during the testing.



### 2.1 EAGLE VALLEY UNITS 1 AND 2

2.1.1 Process Description
Units 1 and 2 are identical units. Each is ra ted at 42 MW (summer, gross) oil fired and combusts No. 2 distillate fuel oil. There are no add-on emission controls. Figure 2-1 is a process flow diagram for each unit.

ConcentricFired Boiler S t

a
c k Oil

Air

Figure 2-1. Process Flow Diagram for Units 1 and 2



### 2.1.2 Sampling Location As approved by the EPA, testing for Units 1 and 2 was conducted on the common stack servicing both units while both units were in operation. Sampli ng was conducted at the stack sampling ports as shown on Figure 2-2. Sampling was conducted in each of four test ports situated in 90 degree increments in orientation.

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## SECTION 

# TWO Facility Description

>360”

>1440”

Breaching duct Ports 180 "

Figure 2-2. Sampling Locations for Units 1 and 2



### 2.1.3 Process Operating Data Testing was conducted under normal opera ting conditions on May 4-7, 2010 on the combined stack for Units 1 and 2. Table 2- 1 summarizes the boiler operating parameters during the test program. A copy of the operating data compiled during each of the test runs is provided in Appendix C. As part of the ICR, the facility was required to track operating parameters for a 30-day period that includes the emissions testing period. Howe ver, because Units 1 and 2 are peaking units that are infrequently operated, the only time peri od that the boiler opera ted during this 30-day period was during the ICR-required stack testi ng. These operating data are presented in the EPA supplied Excel spreadsheets in Appendix F.

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# TWO Facility Description

Table 2-1. Summary of Boiler Operating Parameters for Units 1 & 2

Run Boiler O 2 (%) Heat Input (MMBtu/hr) Oil Flow (gallons/hr) Gross Output (MW) Net Output (MW) Methods 5/29, and OTM-027/028

PM/Met Run 1 9.3 418.0 3
, 033 32.0 29.9 PM/Met Run 2 9.2 415.9 3
, 018 31.9 29.7 PM/Met Run 3 9.0 419.4 3
, 042 32.1 29.9 Avera g e 9.2 417.8 3 , 031 32.0 29.8 Methods 18, 23, 25A, 30B, and 316

Or g Run 1 9.3 401.8 2
, 914 30.3 28.1 Or g Run 2 9.3 400.3 2
, 903 30.1 27.9 Or g Run 3 9.0 407.6 2
, 956 30.5 28.3 Avera g e 9.2 403.2 2 , 924 30.3 28.1 Method 30B

H g Run 3 9.3 399.6 2
, 898 30.0 27.8 H g Run 4 9.4 383.5 2
, 781 28.2 26.0 H g Run 5 9.4 391.3 2
, 838 28.9 26.7 Avera g e 9.4 391.4 2 , 839 29.0 26.8
Method 26 CTM 033

AG Run 1 9.0 406.6 2
, 949 30.7 28.6 AG Run 2 9.2 395.5 2
, 868 29.8 27.6 AG Run 3 9.3 389.1 2
, 822 29.0 26.8 Avera g e 9.2 397.1 2 , 880 29.8 27.7
Method SW846-0031 and SW846-0010

Vol/Svol Run 1 8.7 415.3 3
, 012 31.8 29.6 Vol/Svol Run 2 8.9 409.9 2
, 973 31.0 28.9 Vol/Svol Run 3 8.7 412.8 2
, 994 31.1 29.0 Avera g e 8.8 412.7 2 , 993 31.3 29.2 Values in this table for heat input, oil flow , and boiler output are a combined total for both boilers 1 and 2. Boiler O 2 is an average of the results for both boilers.

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# TWO Facility Description

2.2 UNIT 6

2.2.1 Process Description Unit 6 is rated at 105 MW (summer, gross). Th e unit combusts bituminous coal and consists of a tangentially fired combustor equipped with low NO X burners and over-fire air (LNB/OFA) and an electrostatic precipitator (ESP) to reduce ai r emissions. Figure 2-3 is a process flow diagram for Unit 6.

ESP S t

a
c k T-Fired Boiler with LNB/OF A Coal

Air

Flyash

Figure 2-3. Process Flow Diagram for Unit 6



### 2.2.2 Sampling Location Flue gas samples were collected through test ports located in stac k. Port locations relative to the inlet breaching duct and stack outlet ar e illustrated in Figure 2-4. Sampling was conducted in each of four test ports.

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## SECTION 

# TWO Facility Description

>434”

>1736”

Breaching duct Ports 217 "

Figure 2-4. Sampling Lo cation for Unit 6



### 2.2.3 Process Operating Data Testing was conducted under normal operati ng conditions on May 6 and May 11-12, 2010. Table 2-2 summarizes the boiler operating paramete rs during the test prog ram. A copy of the operating data compiled during each of the test runs is provided in Appendix C. As part of the ICR, the facility was required to track operating parameters for a 30-day period that includes the emissions testing period. The 30-day operating data are presented in the EPA-supplied Excel spreadsheet in Appendix F.

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## SECTION 

# TWO Facility Description

Table 2-2. Summary of Boiler Operating Parameters for Unit 6

Run Heat Input (MMBtu/hr) Steam Load (Klbs/hr) Net Output (MW) Boiler O 2 (%) Methods 5/29, and 5/OTM-028

PM/Met Run 1 613.5 570.7 82.6 2.9 PM/Me t Run 2 630.8 569.9 82.1 2.9 PM/Met Run 3 582.5 539.2 78.2 3.0 Avera g e 608.9 559.9 81.0 2.9 Method 30B

H g Run 1 813.5 570.3 82.7 2.9 H g Run 2 828.5 570.8 82.6 2.8 H g Run 3 813.3 570.1 82.1 2.8 Avera g e 818.4 570.4 82.5 2.8



### 2.3 FUEL ANALYSIS DATA The average fuel analysis values based on the fuel samples collected during the testing are summarized in Table 2-3. The analytical data associated with each test run are in Appendix B-5. Table 2-3. Summary of Fuel Analysis for Units 1, 2, and 6

Parameter Units 1&2 Unit 6 Units HHV, as received 19,509 10,635 Btu/lb Moisture NA 17.6 % Ash 0.04 8.74 % HHV, dry NA 12,898 Btu/lb

Sulfur 1.59E-02 2.36 lb/MMBtu as SO 2 Chlorine 8.14E-03 8.14E-03 lb/MMBtu Fluorine ND NA lb/MMBtu Arsenic 6.31E-04 6.31E-04 lb/MMBtu Beryllium 2.48E-04 2.48E-04 lb/MMBtu Cadmium ND ND lb/MMBtu Chromium 7.83E-04 7.83E-04 lb/MMBtu

Cobalt 5.69E-04 5.69E-04 lb/MMBtu Lead 1.16E-03 1.16E-03 lb/MMBtu Manganese 1.63E-03 1.63E-03 lb/MMBtu

Mercury 8.14E-06 8.14E-06 lb/MMBtu

Nickel 2.51E-03 2.51E-03 lb/MMBtu Selenium ND ND lb/MMBtu

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## SECTION 

# THREE Test Results

3. Section 3 THREE Test Results 

### 3.1 UNITS 1 AND 2 The test schedule and run times for Eagle Vall ey Units 1 & 2 are shown in Table 3-1.
Table 3-1. Units 1 and 2 Test Schedule

Date Run Times a Test Methods Run # 5/7/10 0325-0649 Acid Gases-1 5/7/10 0740-1045 Acid Gases-2 5/7/10 1105-1420 EPA Methods 1-4, 3A, 26A and CTM-033 Acid Gases-3 5/4/10 0940-1622 PM/Metals-1 5/4/10 1725-2352 PM/Metals-2 5/5/10 0130-0838 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 5/6/10 0010-0827 Organic HAPs-1 5/6/10 0900-1715 Organic HAPs-2 5/6-7/10 1740-0210 EPA Methods 1-4, 3A, 18, 23, 25A, and 316 Organic HAPs-3

5/6/10 1350-1550 Hg-3 5/7/10 1510-1710 Hg-4 5/7/10 1715-1915 EPA Method 30B Hg-5 5/5/10 1100-1315 V/Svol Run 1 5/5/10 1400-1615 V/Svol Run 2 5/5/10 1650-1905 SW846 Methods 0010 and 0031 V/Svol Run 3

a Run times are based on Eastern Daylight-Savings Time (EDST) The test team arrived on site on May 3, comple ted safety training, powered up the trailer, and began setting up the test equipment. Test runs on Units 1 and 2 were completed on May 4-7, as outlined in Table 3-1. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR. Tables 3-2 through 3-8 summari ze the results from the test program on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report.

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## SECTION 

# THREE Test Results

Table 3-2. Units 1 and 2 Summary for Particulate Matter

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-027/028 a

Run Filterable PM b (lb/MMBtu) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 2.33E-03 3.15E-03 3.21E-04 1.83E-03 3.85E-03 2 2.68E-03 5.19E-03 2.39E-03 1.23E-03 7.90E-03 3 1.90E-03 4.02E-03 1.46E-03 8.16E-04 5.68E-03 Avg. 2.30E-03 4.12E-03 1.39E-03 1.29E-03 5.81E-03

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit); b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA OTM-027/028 sampling train.

Table 3-3. Units 1 and 2 Summary for Metals Reference Method Test Results for EPA Methods 29 and 30B (lb/MMBtu) a Run 1 2 3 Average Antimony 5.30E-08 4.94E-08 1.13E-07 7.19E-08
Arsenic [<3.00E-07] [<3.01E-07] [<1.25E-06] [<6.18E-07] Beryllium [<1.25E-08] [<1.96E-08] [<4.22E-08] [<2.48E-08]
Cadmium 6.11E-08 6.51E-08 2.19E-08 4.94E-08
Chromium 1.04E-06 8.87E-07 4.85E-07 8.05E-07
Cobalt 6.61E-08 7.54E-08 1.15E-07 8.55E-08
Lead 7.07E-06 6.95E-06 3.51E-06 5.84E-06 Manganese 1.62E-06 1.58E-06 5.95E-07 1.26E-06 Mercury b 5.96E-08 1.41E-07 2.08E-07 1.36E-07
Nickel 1.04E-06 1.07E-06 6.79E-07 9.30E-07
Selenium [<2.19E-07] [<1.38E-07] 6.97E-07 [<3.51E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

b Mercury Results based on Runs 1, 4 and 5. For Runs 2 and 3, the analytical data were rejected because of incorrect recording of pre- test spike concentrations.

Table 3-4. Units 1 and 2 Summary for Non-Dioxin Organic HAP Reference Method Test Results for EPA Methods 1-4, 18, 23, 25A, and 316 a

Run CO (lb/MMBtu) HCHO (lb/MMBtu) THC (lb/MMBtu) CH 4 (lb/MMBtu) 1 9.78E-04 [<5.55E-06] 2.03E-04 7.11E-04 2 1.26E-03 [<4.33E-06] 2.25E-04 6.65E-04 3 2.88E-04 [<4.30E-06] 3.44E-04 6.35E-04 Avg. 8.41E-04 [ < 4.73E-06] 2.57E-04 6.70E-04

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

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# THREE Test Results

Table 3-5. Units 1 and 2 Summary for Dioxins/Furans and PCB Reference Method Test Results for EPA Method 23 (lb/MMBtu) a Run 1 2 3 Average Total Dioxins & Furans [<3.36E-10] [<3.99E-11] [<2.19E-10] [<1.98E-10] Total PCBs [<9.19E-10] [<1.18E-09] [<4.88E-10] [<8.62E-10]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Table 3-6. Units 1 and 2 Summary for Semi-Volatile PAHs
Reference Method Test Results for EPA SW846 Methods 0010 (lb/MMBtu) a Analyte 1 2 3 Average Naphthalene [<3.25E-07] [<2.00E-07] [<2.05E-07] [<2.43E-07] 2-Methylnaphthalene [<1.76E-07] [<1.32E-07] [<1.17E-07] [<1.41E-07] Acenaphthylene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Acenaphthene (CCC) [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Fluorene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Phenanthrene [<2.42E-07] [<2.00E-07] [<1.40E-07] [<1.93E-07] Anthracene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Fluoranthene (CCC) [<1.53E-07] [<1.63E-07] [<8.78E-08] [<1.34E-07] Pyrene [<1.37E-07] [<1.62E-07] [<8.45E-08] [<1.27E-07] Benzo(a)anthracene [<7.69E-08] [<7. 71E-08] [<7.27E-08] [<7.55E-08] Chrysene [<8.45E-08] [<7.71E-08] [<7.27E-08] [<7.80E-08] Benzo(b)fluoranthene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Benzo(k)fluoranthene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Benzo(e)pyrene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Benzo(a)pyrene (CCC) [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Perylene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Indeno(1,2,3-cd)pyrene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Dibenz(a,h)anthracene [<7.69E-08] [<7.71E-08] [<7.27E-08] [<7.55E-08] Benzo(g,h,i)perylene [<8.97E-08] [<1.06E-07] [<7.27E-08] [<8.92E-08]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

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# THREE Test Results

Table 3-7. Units 1 and 2 Summary for Acid Gases Reference Method Test Results for EPA Methods 1-4, 26A, & CTM-33 a

Run SO 2 (lb/MMBtu) NO X (lb/MMBtu) HCl (lb/MMBtu) HF (lb/MMBtu) HCN (lb/MMBtu) 1 2.53E-02 1.17E-01 [<8.78E-05] [<9.03E-05] [<2.67E-05] 2 2.10E-02 1.17E-01 [<9.57E-05] [<9.81E-05] [<2.65E-05] 3 1.93E-02 1.15E-01 [<9.77E-05] [<1.00E-04] [<2.43E-05] Avg. 2.18E-02 1.16E-01 [<9.38E-05] [<9.62E-05] [<2.58E-05]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.
Table 3-8. Units 1 and 2 Summary for Speciated Volatile Organic Compounds

Reference Method Test Results for EPA SW846 Methods 0031 ( lb/MMBtu ) a Analyte 1 2 3 Average trans-1,3-Dichloropropene [<1.85E-07] [<1.86E-07] [<1.87E-07] [<1.86E-07]
Acetone 5.84E-04 8.18E-04 5.71E-04 6.57E-04 Ethylbenzene [<4.13E-07] [<3.47E-07] [<3.51E-07] [<3.70E-07]
Trichlorofluoromethane [<1.56E-06] [<2.07E-06] [<1.28E-06] [<1.63E-06]
Hexachlorobutadiene [<4.32E-07] [<4.34E-07] [<4.36E-07] [<4.34E-07]
2-Hexanone [<3.01E-06] [<3.82E-06] [<3.33E-06] [<3.39E-06] Isopropylbenzene [<1.74E-07] [<1.55E-07] [<1.68E-07] [<1.66E-07] p-Isopropyltoluene [<1.59E-07] [<1.71E-07] [<1.99E-07] [<1.76E-07] Methylene chloride 1.95E-04 1.06E-04 8.01E-05 1.27E-04 4-Methyl-2-pentanone [<1.33E-05] [<1.34E-05] [<1.35E-05] [<1.34E-05] Naphthalene [<1.40E-06] [<1.43E-06] [<1.50E-06] [<1.44E-06]
Benzene 1.43E-04 1.83E-04 [<1.80E-04] [<1.69E-04] n-Propylbenzene [<2.20E-07] [<1.98E-07] [<2.54E-07] [<2.24E-07] Styrene [<2.87E-06] [<2.26E-06] [<1.97E-06] [<2.37E-06] 1,1,1,2-Tetrachloroethane [<1.71E-07] [<1.72E-07] [<1.73E-07] [<1.72E-07] 1,1,2,2-Tetrachloroethane [<4.14E-07] [<4.16E-07] [<4.19E-07] [<4.16E-07]
Tetrachloroethene [<1.70E-07] [<1.70E-07] [<1.71E-07] [<1.70E-07]
Toluene 2.57E-06 2.07E-06 2.11E-06 2.25E-06 1,2,3-Trichlorobenzene [<2.13E-07] [<2.14E-07] [<2.62E-07] [<2.30E-07] 1,2,4-Trichlorobenzene [<2.63E-07] [<2.64E-07] [<2.78E-07] [<2.68E-07] 1,1,1-Trichloroethane [<1.69E-07] [<1.70E-07] [<1.71E-07] [<1.70E-07] 1,1,2-Trichloroethane [<1.30E-06] [<1.31E-06] [<1.31E-06] [<1.31E-06]
Trichloroethene [<3.09E-07] [<3.11E-07] [<3.12E-07] [<3.11E-07] 1,2,3-Trichloropropane [<3.24E-06] [<3.26E-06] [<3.28E-06] [<3.26E-06] 1,2,4-Trimethylbenzene [<3.54E-07] [<3.60E-07] [<4.10E-07] [<3.75E-07] 1,3,5-Trimethylbenzene [<2.36E-07] [<2.37E-07] [<2.45E-07] [<2.39E-07] Vinyl chloride [<3.18E-07] [<3.19E-07] [<3.21E-07] [<3.19E-07] o-Xylene [<3.52E-07] [<3.13E-07] [<3.44E-07] [<3.36E-07]

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Table 3-8 Cont. Units 1 and 2 Summary for Speciated Volatile Organic Compounds

Reference Method Test Results for EPA SW846 Methods 0010 ( lb/MMBtu ) a

Analyte 1 2 3 Average m-Xylene & p-Xylene [<1.01E-06] [<8.07E-07] [<8.08E-07] [<8.76E-07]
Bromobenzene [<2.82E-07] [<2.83E-07] [<2.85E-07] [<2.84E-07]
Bromochloromethane [<4.11E-07] [<4.13E-07] [<4.15E-07] [<4.13E-07]
Bromodichloromethane [<2.03E-07] [<2.04E-07] [<2.05E-07] [<2.04E-07]
Bromoform [<1.56E-06] [<1.57E-06] [<1.58E-06] [<1.57E-06]
Bromomethane [<8.76E-07] [<8.49E-07] [<9.33E-07] [<8.86E-07]
2-Butanone [<1.33E-05] [<1.34E-05] [<1.35E-05] [<1.34E-05] n-Butylbenzene [<1.88E-07] [<2.11E-07] [<2.67E-07] [<2.22E-07] sec-Butylbenzene [<1.46E-07] [<1.47E-07] [<1.62E-07] [<1.52E-07] tert-Butylbenzene [<1.59E-07] [<1.60E-07] [<1.71E-07] [<1.64E-07]
Carbon disulfide [<2.72E-07] [<5.37E-07] [<5.82E-07] [<4.64E-07]
Carbon tetrachloride [<4.65E-07] [<4.72E-07] [<4.45E-07] [<4.61E-07]
Chlorobenzene [<4.37E-07] [<4.03E-07] [<5.00E-07] [<4.47E-07]
Chlorodibromomethane [<3.19E-07] [<3.21E-07] [<3.22E-07] [<3.21E-07] 1,2-Dibromo-3-chloropropane [<1.83E-06] [<1.84E-06] [<1.85E-06] [<1.84E-06]
Chloroethane [<8.57E-07] [<8.61E-07] [<8.66E-07] [<8.61E-07]
Chloroform [<1.82E-07] [<1.78E-07] [<1.73E-07] [<1.78E-07]
Chloromethane [<1.13E-05] [<8.96E-06] [<1.32E-05] [<1.11E-05]
2-Chlorotoluene [<1.81E-07] [<1.82E-07] [<2.01E-07] [<1.88E-07]
4-Chlorotoluene [<2.06E-07] [<2.07E-07] [<2.09E-07] [<2.07E-07] 1,2-Dibromoethane [<2.34E-07] [<2.35E-07] [<2.36E-07] [<2.35E-07]
Dibromomethane [<3.23E-07] [<3.25E-07] [<3.27E-07] [<3.25E-07] 1,2-Dichlorobenzene [<2.47E-07] [<2.48E-07] [<2.50E-07] [<2.48E-07] 1,3-Dichlorobenzene [<2.02E-07] [<2.03E-07] [<2.04E-07] [<2.03E-07] 1,4-Dichlorobenzene [<2.18E-07] [<2.19E-07] [<2.21E-07] [<2.19E-07]
Dichlorodifluoromethane [<2.06E-06] [<1.85E-06] [<2.13E-06] [<2.01E-06] 1,1-Dichloroethane [<1.46E-07] [<1.47E-07] [<1.48E-07] [<1.47E-07] 1,2-Dichloroethane [<2.41E-07] [<2.43E-07] [<2.44E-07] [<2.43E-07] 1,1-Dichloroethene [<2.29E-07] [<2.30E-07] [<2.31E-07] [<2.30E-07] cis-1,2-Dichloroethene [<1.59E-07] [<1.60E-07] [<1.61E-07] [<1.60E-07] trans-1,2-Dichloroethene [<2.73E-07] [<2.74E-07] [<2.76E-07] [<2.74E-07] 1,2-Dichloropropane [<2.43E-07] [<2.44E-07] [<2.45E-07] [<2.44E-07] 1,3-Dichloropropane [<2.10E-07] [<2.11E-07] [<2.12E-07] [<2.11E-07] 2,2-Dichloropropane [<1.58E-07] [<1.59E-07] [<1.60E-07] [<1.59E-07] 1,1-Dichloropropene [<1.57E-07] [<1.58E-07] [<1.59E-07] [<1.58E-07] cis-1,3-Dichloropropene [<2.50E-07] [<2.51E-07] [<2.52E-07] [<2.51E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Some compounds that were found above the detec tion limit were all present in similar levels in the field blanks. The four spike surrogates were reported at levels above the detection limits in both the blank and test run samples due to spike recoveries being above 100%.

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Those four compounds have been excluded from table 3.8. Acetone, methylene chloride, and toluene were present as solvents in near pr oximity to the VOST sampling train due their use for the Method 0010 and M23 recovery and were also present in the field blanks. Further details of the emissions for each compound are provided in Appendix A.



### 3.2 UNIT 6 The test schedule and run times for Eagle Valley Unit 6 are shown in Table 3-9.
Table 3-9. Unit 6 Test Schedule

Date Run Times a Test Methods Run # 5/11/10 0940-1555 PM/Metals-1 5/11/10 1635-2250 PM/Metals-2 5/12/10 0745-1610 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 5/11/10 1200-1400 Hg-1 5/11/10 1415-1615 Hg-2 5/11/10 1730-1930 EPA Method 30B Hg-3

a Run times are based on Eastern Daylight -Savings Time Standard Time (EDST) Test runs were completed as outlined in Table 3-17 above. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR. Tables 3-10 and 3-11 summarize th e results from the test program on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report. Table 3-10. Unit 6 Summary for Particulate Matter Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28

Run Filterable PM b (lb/MMBtu ) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 6.75E-03 3.27E-02 2.54E-02 1.57E-03 3.57E-02 2 9.98E-03 5.83E-02 4.59E-02 4.68E-03 6.09E-02 3 8.55E-03 2.65E-02 1.21E-02 4.89E-03 2.97E-02 Avg. 8.42E-03 3.92E-02 2.78E-02 3.72E-03 4.21E-02

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit); b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA OTM-027/028 sampling train.

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3-7 Eagle Valley Test Report - Final SV 31827132 Table 3-11. Unit 6 Summary for Metals
Reference Method Test Results for EPA Methods 29 and 30B (lb/MMBtu) a Run 1 2 3 Average Antimony 5.59E-07 8.28E-07 4.91E-07 6.26E-07 Arsenic 7.10E-06 9.74E-06 3.80E-06 6.88E-06 Beryllium [<1.71E-07] [<2.63E-07] [<1.23E-07] [<1.86E-07] Cadmium 8.92E-08 1.25E-07 6.04E-08 9.15E-08 Chromium 1.97E-06 3.47E-06 4.54E-07 1.96E-06 Cobalt 4.37E-07 6.08E-07 2.96E-07 4.47E-07 Lead 6.60E-06 8.51E-06 3.66E-06 6.26E-06 Manganese 1.01E-06 1.40E-06 6.24E-07 1.01E-06 Mercury 4.26E-06 3.42E-06 3.77E-06 3.81E-06 Nickel 2.56E-06 4.15E-06 1.40E-06 2.70E-06 Selenium 8.39E-05 9.08E-05 4.79E-05 7.42E-05

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Further details of the emissions for each compound are provided in Appendix A.

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4. Section 4 FOUR Test Methods The following sections present information on th e test methods used for the test program.



### 4.1 EPA METHODS 1-4 EPA Reference Methods 1, 2, 3, and 4 were used to determine the sample traverse point locations, volumetric flow, flue gas molecular we ight, and the gas moisture content. Vent gas velocity and moisture content were measured at the stack locati on in conjunction with isokinetic sampling trains. Flue gas molecular weight was cal culated using EPA Method 3A to determine concentrations of O 2 and CO 2 in the stack gas.



### 4.2 EPA METHODS OTM-027 AND OTM-028
The PM-2.5 concentration was determined using EPA Other Test Method 027 and 028. A measured volume of stack gas was drawn from the stack pseudo-isoki netically through an Apex Instruments PM 2.5 cyclone and in-stack 63 mm glass filter. Sampling was conducted at a fixed sampling rate using the calculations from the test method to determine dwell time at each sample point. The remaining sample ga s passed through a heated probe and transfer line followed by a vertical water-jacketed condensing coil before entering the impinger train. The front half of the impinger train consisted of an oversized short stem impinger followed by a standard modified impinger. The two parts of the impinger train were connected with an in-train Teflon membrane filter. The sample gas passing through the filter was monitored and maintained at just below 85 O F by controlling the temperature of the front half water bath surrounding the impingers. The back half of the imp inger train consisted of two standard size modified Greenberg-Smith impingers, the firs t of which contained 100 ml of organic free water with the final impinger c ontaining silica gel. The back ha lf of the sampling train was immersed in an ice bath to mainta in the exit temperature to below 68 O F. After exiting the impinger train, the dry gas was measured using a dry gas metering console. Particulate matter trapped in the fractions of the cyclone was r ecovered by brushing and rinsing each fraction individuall y with acetone into separately labeled sample. Front half rinse samples were dried, desiccated for 24 hour s, and analyzed gravimetrically at the URS Laboratory in Morrisville, NC. Th e glass fiber filter was also de siccated, and the weight gain was added to the rinse weight. The back half of the sampling train (after the 63 mm in-stack filter) including the heated sample probe, transfer line, and condenser coil were rinsed with high purity organic free water, high purity acetone, and high purity MeCl to recover any condensable matter that may have accumulated during the test run. The impi nger train was sealed and transported to the mobile laboratory where it was purged with nitrogen at 20 lp m for one hour before being recovered and extracted with high purity or ganic free water, high purity acetone, and high purity MeCl to remove and preserve the c ondensable particulate for evaporation and gravimetric analysis at the laboratory. Rinses were kept separate from the condensed moisture fraction until combined by the laboratory. Moisture in the gas streams was determined using EPA Method 4. In this method, the weight gain in the chilled impingers is used to calculate the percentage of moisture in the stack gas sample.

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Molecular weight, carbon dioxide, and oxygen content of the gas samples were determined using either EPA Method 3A or 3B. Stack gas velocity and volumetric flow rate were determined using EPA Method 2. In this method, a Type S pitot is used to traverse the duct using traverse points determined by EPA Method 1. The pitot pressures and temperature data collected during each sampling traverse are used to calcul ate the stack gas velocity. Samples were all given a unique identification nu mber and logged into a table as they were collected and recovered. Identification number s were included on all sample containers during the analytical process. All EPA Met hod OTM-027 samples were analyzed at the URS RTP Field Laboratory. Enthalpy Analytical of Durham, North Carolina performed the EPA Method OTM-028 analysis. Appendix B contains the analytical data sheets and laboratory report from Enthalpy Analytical.



### 4.3 EPA METHODS 5 AND OTM-028
Because the stack characteristics are such that the presences of entrained water droplets exist, the PM-2.5 concentration was determined us ing EPA Method 5 and Other Test Method 028. A measured volume of stack gas was drawn fr om the stack isokinet ically through a button hook style glass nozzle followed by a heated quar tz filter. The remaining sample gas passed through a heated transfer line followed by a vert ical water-jacketed c ondensing coil before entering the impinger train. The front half of the impinger train consisted of an oversized short stem impinger followed by a standard modified impinger. The two parts of the impinger train were connected with an in-tra in Teflon membrane filter. The sample gas passing through the filter was monitored and maintained at just below 85 O F by controlling the temperature of the front half water bath surrounding the impingers. The back half of the impinger train consisted of two standard size modified Greenberg-Smith impingers, the first of which contained 100 ml of organic free water with the final impinger containing silica gel. The back half of the sampling train was immers ed in an ice bath to maintain the exit temperature to below 68 O F. After exiting the impinger train, the dry gas was measured using a dry gas metering console. Particulate matter trapped in the heated probe and filter assembly was recovered by brushing and rinsing each fraction individually with acetone into separately labeled sample. Front half rinse samples were dried, desiccated for 24 hour s, and analyzed gravimetrically at the URS Laboratory in Morrisville, NC. The quartz fiber filter was also desiccated, and the weight gain was added to the rinse weight. The back half of the sampling train, including the heated transfer line and condensing coil, was rinsed with high purity organic free wate r, high purity acetone, a nd high purity MeCl to recover any condensable matter that may have accumulated during the test run. The impinger train was sealed and transported to the mobile laboratory where it was purged with nitrogen at 20 lpm for one hour before being recovered and extracted with hi gh purity organic free water, high purity acetone, and high purity MeCl to remove and preserve the condensable particulate for evaporation and gravimetric anal ysis at the laboratory. Rinses were kept separate from the condensed moisture fraction until combined by the laboratory.

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Moisture in the gas streams was determined using EPA Method 4. In this method, the weight gain in the chilled impingers is used to calculate the percentage of moisture in the stack gas sample. Molecular weight, carbon dioxide, and oxygen content of the gas samples were determined using EPA Method 3A or 3B. Stack gas velocity and volumetric flow rate were determined using EPA Method 2. In this method, a Type S pitot is used to traverse the duct using traverse points determined by EPA Method 1. The pitot pressures and temperature data collected during each sampling traverse are used to calcul ate the stack gas velocity. Samples were all given a unique identification nu mber and logged into a table as they were collected and recovered. Identification number s were included on all sample containers during the analytical process. All EPA Method 5 samples were analyzed at the URS RTP Field Laboratory. Enthalpy Analytical of Durham, North Carolina performed the EPA Method OTM-028 analysis. Appendix B contains the analytical data sheets and laboratory report from Enthalpy Analytical.



### 4.4 EPA METHOD 6C
Emissions of sulfur dioxide were determin ed using the procedures provided in EPA Method 6C using the facility’s cer tified CEMS instrumentation. The SO 2 analyzer works off the ultraviolet (UV) absorption principle. The sample stream pa sses through a sample chamber within the analyzer at a constant pr essure which has a UV li ght source present at one end. The SO 2 molecules in the sample stream abso rb a portion of the energy from the UV lamp which excites the particle causing it to d ecay to a lower energy state. As the particle decays, it gives of ultraviolet light at a diffe rent wavelength. The emission of that light is measured by a photomultiplier tube located pe rpendicular to the UV light source further down the sample path. The intensity of the li ght detected by the photomultiplier tube is proportional in relation to the concentration of SO 2 in the sample stream. The light intensity measured by the analyzer corresponds to a si gnal that was transf erred to the DAS and recorded in by the historian.



### 4.5 EPA METHOD 7E
EPA Method 7E was used to determine concentra tions of oxides of nitrogen in the flue gas using the facility’s certified CEMS instrumentation. The NO x analyzer operates off the chemiluminescent principle and is equipped with a catalytic thermal converter to convert NO 2 to NO. The sample gas is passed through th e converter and heated to break one of the oxygen bonds in the NO 2 molecule. After the conversion, th e oxides all exist as NO in the sample stream. The gas is then blended with ozone in a reaction chamber that is held under constant vacuum. The resulting chem ical reaction between the NO and O 3 produces a photon of light for each molecule. The chemilumine scent photons are measured by a photomultiplier tube at the end of the reaction chamber to pr oduce a signal that is linear in relation to concentration.

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4.6 EPA METHOD 10
EPA Method 10 was used to determine concentr ations of carbon monoxide in the flue gas using the facility’s certified CEMS instrumenta tion as well as by the test crew on site. The concentration of carbon monoxide in the stack exhaust was se lectively measured by a gas filter correlation analyzer. The analyzer’s op eration is based on the principle that carbon monoxide absorbs infrared light at a speci fic wavelength. The instrument produces an infrared light signal which pa sses through a spinning correlati on wheel. The light signal is modulated by alternating back and forth betw een two chambers on the wheel, one of which contains nitrogen (measurement cell) and the ot her contains carbon monoxide (the reference cell). The nitrogen cell is transparent to the infr ared light and allows the entire light signal to pass though while the carbon monoxide cell abso rbs all of the light at the effected wavelengths providing a baseline. After the lig ht source is chopped it passes through the sample chamber where the continuous stream of sample gas is maintained at a constant temperature and pressure. The chamber contains multiple mirrors to extend the path length during which the signal is in contact with the sample gas before being measured by the detector. The amplitude of the difference betw een the modulations in the signal is a nonlinear correlation that repres ents the concentration of car bon monoxide in the sample. The signal is linearized by the intern al software of the instrument resulting in a voltage output that is recorded by a data acquisition system. The gas filter correlation analyzer was calibrated using EPA Protocol 1 ga ses with the resultant test data being corrected for bias and drift.



### 4.7 EPA METHOD 18 EPA Method 18 was performed to determine con centration of methane in the flue gas. A sample of the stack gas was extracted from th e test location through an in-stack filter and transported to the test traile r through a heated sample line an d heated head pump. A slip stream of the sample gas was injected directly to the GC/FID heated manifold. The column separates the constituents in the gas str eam by molecular size, allowing the smaller compounds to pass through first. Once the hydr ocarbon constituents have passed through the column they are introduced to a flame ioniza tion detector (FID). The ionizer heats the compounds to break the carbon bonds. As each ca rbon bond breaks the intensity of the flame as well as the chamber conductivity increase, which is measured by the detector to provide a response. Because the compounds have been sp eciated by passing them through the column, the resultant intensity of the response is attribut ed to a specific or ganic compound based on the time it takes the response to be detected after being injected into the column and the level of response. The GC/FID is calibrated using EPA Protocol 1 gases at th ree concentrations to develop a linear regression curve. Each test r un consisted of at least five injects to the GC/FID followed by a 3 replicate calibration ch eck. Results for each test run were averaged and compared against the calibration curve to determine concentrations.



### 4.8 EPA METHOD 23 The procedures from EPA Method 23 were employed to determine emissions of polychlorinated dibenzo-p-dioxins, polych lorinated dibenzofurans (PCDD/F), and

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polychlorinated biphynals in the stack gas. A sample of the gas stream was extracted isokinetically from the source through a glass nozzle and heated probe and filter assembly. The gas stream was then filtered through a pretre ated glass filter before passing into a waterjacketed condenser followed by a module cont aining XAD-2 resin to remove the remaining PCDD/F and PCB constituents. The exhaust of the condenser was monitored to remain at or below 68 O F during the test. The flue gas then passed through an ice bath impinger train containing HPLC grade water and silica gel to remove any remain ing moisture prior to being measured by a dry gas metering console. After the final leak check ha d been performed the sample train was partially disassembled and transported to the mobile laboratory for recovery. The front half of the train was rinsed with acetone a nd toluene as prescribed in the ICR. Rinses of the back half connecting glassw are and condenser were added to the front half rinses in the mobile laboratory. All three solv ent rinses were kept separate until received by the analytical laboratory. During the recovery process, the XAD-2 Resin was reweighed for the moisture determination, the thermocouple was removed, and the ends were properly sealed with Teflon tape and al uminum foil. The module was then covered with aluminum foil to prevent excess exposure, labeled and kept co ol in a sample refrigerator until the test program was completed. Prior to the sampling event all of the glassw are was washed with Alconox and deionized water and baked at 300 O C for 4 hours. A final rinse of the glassware with MeCl was performed prior to being packaged for transpor t to the facility. XAD-2 Resin traps and glass filters were prepared by the laboratory prior to the sampling program. Filters were baked to remove any contaminants. XAD modules were cleaned and baked according to the procedures above before being packed w ith XAD-2 Resin. The XAD modules were then spiked with know concentrations of PCDD/F prior to shipment to the URS Laboratory. Sample traps were maintained on ice or in a sample refrigerator prior to and following the sampling event until they arrived back at the laboratory for analysis. Analysis of the EPA Method 23 samples was performed by Analytical Perspectives in Wilmington, North Carolina. Analytical Perspectives calculated detection limits using the equation: DL = ( 2.5 × H N × Q IS ) / ( H IS × W × RRF)
Where:

 DL is the estimated detection limit for homologous 2,3,7,8-substituted PCDD/PCDFs

 HN is the height of the noise (using 20-30 data points to determine s, with 4s used as the value)

 QIS is the amount (in pg) of extraction standard added to the sample before extraction

 HIS is the peak height of the extraction standard

 W is the weight of the sample (for met hod 23 samples this value is always 1)

 RRF is the calculated relative re sponse factor for the analyte

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4.9 EPA METHOD 25A
EPA Method 25A was used to determine concen tration of total hydrocarbons (THC) in the gas stream. A sample of the stack gas was extract ed from the test location through an in-stack filter and heated line and transported to the m obile laboratory with the aid of a heated head pump. A slip stream of the hot gas is directed to the flame ionization analyzer. The ionizer heats the gas to break the carbon bonds of the organic compounds. As each carbon bond breaks, the intensity of the flame as well as the chamber conductivity increase, which is measured by the detector to provide a res ponse. Because the organic compounds have not been speciated, the detector only documents the number of carbon bonds broken on the basis of the calibration gas used. Fo r this program, the calibration basis was methane so the resultant response is on an as methane basi s. The instrument was calibrated using EPA Protocol 1 gases with the resultan t data being corrected for drift.



### 4.10 EPA METHOD 26A EPA Method 26A was used to determine emissions of HCl, Cl 2 , and HF in the gas stream. A sample of the stack gas was extracted from th e test location through a glass nozzle, heated probe, and filter assembly prior to entering th e sample train. The sample was filtered through a Teflon coated quartz filter maintained at greater than 248 O F meeting the specifications for particle retention of 99.95 % for 0.3um as prescr ibed in the test method. The sample then passed thorough an oversized knockout Greenbe rg-Smith impinger containing 50 ml of 0.1 N H 2 SO 4 followed by two standard size Greenberg-S mith impingers also containing 0.1N H 2 SO 4 . The sample then passed through two standard size modified Greenberg-Smith impingers containing 0.1N NaOH followed by a silica gel impinger before being measured by a dry gas meter. Hydrogenated halogen comp ounds were captured in the acidic impinger solutions while the remaining elemental ha logens are captured in the basic impinger solutions. After completion of the test run, a leak check was performed and the sampling system was partially disassembled and transpor ted to the mobile laboratory for recovery. Sampling trains were weighed gravimetrically for moisture calculations, and recovered into appropriately labeled sample jars with DI H 2 O. Sodium thiosulfate was added to the basic impinger solutions by the labor atory prior to analysis. Enthalpy Analytical in Durham, North Carolina performed the analysis for these samples by ion chromatography. Gravimetric analysis of the front-half samples was performed by URS Corporation in Morrisville, North Carolina. Even though the ICR did not request that analysis of Cl 2 be conducted along with this sampling train it was performed, and the results are included in the appendices of this test report. Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria, a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.

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# FOUR Test Methods

4.11 EPA METHODS 5 AND 29 Emissions of filterable particulate matter and sp ecific metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese , mercury, nickel, and selenium) were determined using the procedures prescribed in EPA Methods 5 and 29. A sample of the stack gas was withdrawn isokinetically from the sour ce through a glass nozzle, heated probe, and heater filter prior to entering the impinger trai n. The impinger train was maintained in an ice bath with an exit temperature of less than 68 O F prior to being measured by a dry gas metering console. The impinger train consisted of an oversized impinger and two standard size impingers (the second being a Greenberg -Smith with the other two being modified Greenberg-Smith). The second and third im pingers contained a solution of 5% HNO 3 and 10% H 2 O 2 in water. The fourth impinger was an empty modified Greenberg-Smith impinger. Impingers 5 and 6 were both modified Greenbe rg-Smith Impingers containing a solution of 4% KMnO 4 and 10% H 2 SO 4 in water. The final impinger contained silica gel. At the completion of each test run, following the final leak check, the sampling train was partially disassembled and transported to the mobile laboratory for sa mple recovery. The probe and nozzle was first rinsed and brushe d with acetone followed by 0.1 N HNO 3 into separate jars. In the laboratory, the train was weighed gravim etrically for moisture determinations and recovered as prescribed in the test method. Once the samples were transported back to the URS Laboratory in Morrisville, North Carolina, the acetone rinses were dried down at ambient temperatures and desiccated along with the filters. Following gravimetric analys is of the samples, the acetone rinses were reconstituted with 0.1N HNO 3 and added to the front half nitric rinses. Samples were then shipped to the Test America Laboratory in Sacramento, California for analysis by ICP-MS and CVAAS. Test America calculated a MDL using the method of 7 replicate samples spiked at greater than 3 times the estimated MDL. The complete details and formulae used are in the SOP attached as an addendum to the analytical report. Regent blanks showed no significant levels of contamination except for nickel. The filter blank resulted in a contamination level of 3.6 ug. Analytical results we re corrected for this blank value only.



### 4.12 EPA METHOD 30B
EPA Reference Method 30B “Determination of Total Vapor Phase Mercury Emissions From Coal-Fired Combustion Sources Using Carbon Traps” was used to determine vaporous mercury concentration in each With Method 30B, flue gas is extracted from a stack or duct using paired, two-section sorbent media traps at a constant flow rate. The use of in-stack sorbent traps minimizes potential loss of me rcury during transport through a probe/sample line. For each test run, paired train sampling is used to determine measurement precision and verify acceptability of the measured emissions data. This test consisted of collecting an integrated sample (3 point short- line) using Method 30B at sampling points 0.4, 1.2, and 2.0 meters from the stack wall. A single port was used to collect the samples.

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A dual console Apex Instruments Model XC 260 sorbent tube sampling system was used to sample flue gas at both the stack. The sorbent traps were procured from Ohio Lumex. For the field recovery test the front section of one t ube in each pair was spiked by URS with a known concentration of elemental mercury prior to sampling. QA/QC procedures required by Method 30B were adhered to throughout the program. The sorbent traps were analyzed on-site by URS using an Ohio Lumex 915+ thermal analyzer with M324 attachment. A Field Recovery Test based on recovery of an elemental Hg spike was used to assess measurement bias and to verify data acceptability. In accordance with Method 30B section 8.2.3.1.1, an Hg o analytical bias test was performed to confirm that the analytical system results we re within ±10% of the target value. Table 4-3 shows the results of the Hg o analytical bias test. All sample s at three different spike levels passed the ±10% spike recovery criteria for the test program. All samples were analyzed by the URS laboratory in Morrisville, NC. In accordance with Method 30B section 8.2.3.1.2, an Hg +2 analytical bias test was performed prior to field deployment to confirm that the an alytical system results were within ±10% of the target value. Table 4-4 shows the results of the Hg +2 analytical bias tests. All samples at three different spike levels passed th e ±10% spike recovery criteria. As previously approved by the EPA, sources including oil and coke fired units where the presence of mercury is not anticipated, test runs were conducted usi ng tubes spiked at 50 ng of mercury with two hour samples being co llected at a nominal 2-hours. Using these procedures, if the QA/QC criteri a for paired trap agreement of spike concentration with respect to sample concentration are not met, the test runs will still be considered as valid.



### 4.13 EPA CONDITIONAL TEST METHOD 33 Emissions of hydrogen cyanide were measured using the procedures prescribed in EPA Conditional Test Method 316. A sa mple of the stack gas was ex tracted isokinetically through a glass nozzle and heated probe assembly. The sample passed through a heated filter assembly to remove particulate followed by a fi ve-impinger train before being measured by a dry gas metering console. The impinger train was ma intained in an ice bath to control the exit impinger temperature to at or below 68 O F. The configuration of th e train included a primary impinger containing lead acetate, a knock-out impinger, two impi ngers containing 100 ml of 4N NaOH each, and a final silica gel impinger. The purpose of the lead acetate was to remove SO 2 from the sample stream in order to maintain the pH of the NaOH above 12. As recommended by the test method Alizarin Yellow was utilized in the NaOH impingers as an indicator of pH. At the completion of each test run, the sample train was partially disassembled and transported to the mobile laboratory for recovery. The probe nozzle and connection glassware were brushe d and recovered into a glass sa mple jar with acetone to be archived for PM analysis. In the mobile laboratory, the impinge r train was weighed gravimetrically for moisture determination. The impinger contents were recovered into sample jars followed by rinses of lead acetat e for the first and second impingers and high purity water for the NaOH impingers. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. A field blank was collected and

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analyzed once per facility. . As prescribed in the test method, a field spike was prepared once for each facility and analyzed along with the samples. Enthalpy Analytical in Durham, North Carolina conducted the analysis of the samples. Lead acetate was prepared by Enthalpy and used with in the 10-day holding time provided in the test method. Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria, a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.



### 4.14 SW846-0010 Emissions of speciated semi-volatile or ganic compounds were measured using the procedures prescribed in Solid Waste Asso ciation 846 Method 0010. A sample of the stack gas was extracted isokinetically through a glass nozzle and heat ed probe assembly. The gas then passed through a glass filter to remove filterable constituents followed by a horizontal condenser and XAD-2 Resin trap before entering the impinger train. The temperature of the sample gas was monitored through a thermo well at the entrance of the re sin trap to ensure the temperature was below 68 O F. After exiting the resin tr ap, the sample stream passed through an impinger train containi ng organic free water to rem ove any residual semi-volatile compounds and residual moisture before bei ng measured by a dry gas meter. The impinger train was maintained in an ice bath to control the exit impinger temperature to at or below 68 O F. The impinger train consisted two standard size impingers with containing 100 ml of organic free water each followed by an third empty impinger. The fourth and final impinger contained silica gel. At the completion of each test run, the sample train was partially disassembled and transported to the mobile laboratory for recovery. The probe nozzle and connection glassware were brushe d and recovered into a glass sa mple jar with acetone first followed by MeCl as prescribed in the ICR. In the mobile laboratory, the impinger train was weighed gravimetrically for moisture determ ination. The first impinger contents were recovered into sample jars followed by rinses of acetone and MeCl with all rinses and samples being recovered into their separate sample jars. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. A field blank was collected and analyzed once per facility. Enthalpy Analytical in Durham, North Carolina prepared the filters and XAD-2 Resin traps for the sampling event. Resin traps were us ed within the 30-day hold time after being prepared. Enthalpy Analytical provided the analysis for these samples. Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria,

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4-10 Eagle Valley Test Report - Final SV 31827132 a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.



### 4.15 SW846-0031 Emissions of speciated volatile organic com pounds were measured using the procedures prescribed in Solid Waste Association 846 Method 0031. A sample of the stack gas was extracted glass lined heated probe assembly maintained at 130 + 5 O C containing an organic free glass wool plug to filter out particulat e matter. The gas was then passed through a condenser maintained at below 20 O C, two Tenax sorbent traps, a condensate trap, and an Anasorb trap to collect the volatile compounds. The gas pass es through a final silica gel reservoir before being measured by a dry gas me ter. The system was operated as to collect a nominal 1 liter per minute of gas for 20 minutes pe r tube set. A test run as described in the ICR consisted of four sets of traps with one condensate sample. A field blank was performed for each test run to document any contamination issues that may have been present. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. Additional QA/QC samples includi ng one pre-test train blank per source, one trip blank per cooler, and a reagent bla nk were collected for each facility. TestAmerica located in Knoxville, Tennessee prep ared the traps and performed the analysis. Analytes for this test method were not specifi cally requested by the ICR therefore a list of 64 typical compounds of interest for this test method were reported in the test results. Test America calculated a MDL using the method of 7 replicate samples spiked at greater than 3 times the estimated MDL. The complete details and formulae used are in the SOP attached as an addendum to the analytical report.



### 4.16 PROCESS DATA
Process data from each of the units was record ed by the facility DAS and PI system. Process indicators that were monitored included boile r steaming rate (Klbs/hr), fuel firing rates (mmBtu/hr calculated heat i nput), and scrubber operation (q uench flow and differential pressure of the scrubber as compliance indicat ors for PM, pH, and recirculation rates of scrubber liquid are also included as requested). Copies of the process operating data records are included in Appendix C. Copies of the 30- day monitoring data are provided in Appendix E.

## SECTION 

# FIVE Quality Assurance/Quality Control

5. Section 5 FIVE Quality Assurance/Quality Control Specific quality assurance and quality control ( QA/QC) procedures were used during the test program to cover field sampling, recovery, sample analysis, data reduc tion, and interpretation of results. QA/QC procedures were strictly foll owed to ensure the production of useful and valid data. This section will describe these procedures and will report the test program QA parameters, which indicate data quality.



### 5.1 SAMPLING QA/QC Prior to and immediately following each test run, leak checks of all manual method sampling trains were performed to verify no sample dilution of the sampled stack gas was occurring during the test. All leak checks were recorded properly and met the leak criterion. Where any leak check failed, the test run was aborted a nd repeated. Prior to and following the test program, pitot leak checks were performed on th e pressure differential measuring systems. CEM analyzers were calibrated according to the relevant test method with bias and drift checks being performed as require d. Analyzers were calibrated using EPA Protocol 1 gases. Copies of the cylinder certificatio ns are included in the appendices. Prior to beginning the test program a leak check was performed on the CEMS sampling system to verify the absence of leaks by cappi ng the tip of the sample probe and pulling a vacuum. Flow rate was monitored until the ab sence of flow was detection using in-line rotometers on the flow control manifold. A stratification check was performed on the stack prior to beginning the first test run for all reference method CEMS instrumentation. The results of that traverse showed the absence of any significant stratification. Results of that QC check are provided in Appendix D. Sampling media and glassware were prepared using the prescribed procedures for the applicable test method. Where glassware wa s used on multiple units, the glassware was blanked between them to verify cleanliness between units. On-site analysis of Method 30B sorbent traps fo r Runs 2 and3 during testing of Units 1 and 2 determined that the labeled spike concentratio ns on the tube sheets we re incorrect, resulting in the spike criteria requiremen ts not being met. Runs 4 and 5 were conducted to remedy this situation. The data for all five runs are in the appendices.



### 5.2 OTHER QA/QC The sampling and recovery procedures sp ecified in EPA Methods 5, 18, 23, 25A, 26A, 29, OTM027/OTM028, CTM 033, SW846-0010, SW846-0061, and SW846-0031. The following QA/QC procedures were satisfied for the purpose of ensuring valid results:

 All sampling equipment passed a thorough vi sual and operation check prior to and after transport to ensure clean and operab le parts. Equipment that failed to pass this check was not used in the field.

 Manometers were leveled and zeroed before measuring the differential pressure across the S-type pitot tubes.

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5-2 Eagle Valley Test Report - Final SV 31827132  The temperature measurement system was capable of measuring the ambient temperature prior to each traverse to within  2  C of the average measured ambient temperature.

 The field personnel reviewed sampling da ta forms daily on-site during testing.

 Ice was maintained in the impinger baths at all times; exit temperatures were maintained at less than 20  C (<68  F) except for the front half of the OTM028 impinger train which was maintained at less than 29 o C (<85 o F).

 Each leg of the S-type pitot tube achieved the prescribed leak criterion described in EPA Method 2.

 Readings of the dry gas meter, stack gas velocity head (  P), sample line orifice meter pressure differential (  H), temperature, and vacuum pump were made during sampling at each traverse point at a minimum of one every five minutes.

 Dry gas meters were calibrated before the test program and the calibration was rechecked after the test was completed using the ALT-009 Gamma QA procedure.

 Methods 23, 316, CTM-033, SW846-0010, and SW846-0031 samples were kept on ice until analyzed.

 A field spike and field blank were perf ormed as part of the CTM-033 sampling portion of the test program. Results for the field spike are provided in the Enthalpy Analytical Report in Append ix B-1 and met the method criteria.

 Field blanks were conducted and analyzed for each manual test method performed on-site. Reagent blanks were collected a nd archived in case of further need for analysis.

### APPENDIX A Sampling Data

APPENDIX A-1 EAGLE VALLEY UNITS 1 AND 2 Appendix A-1-1 Preliminary Test Data Appendix A-1-2 Emission Test Data for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3A
Appendix A-1-3 Emission T est Data for Acid Gases EPA Methods 3A, 6C, and 7E EPA Method 26A EPA CTM-033
Appendix A-1-4 Emissions Test Data for Non-Dioxin/Furan Organics EPA Methods 3A, 10, and 25A EPA Method 18 EPA Method 316 SW846-0010 SW846-0031
Appendix A-1-5 Emissions Test Da ta for PCDD/F and Coplanar PCBs EPA Method 23 EPA Method 3A

APPENDIX A-2 EAGLE VALLEY UNIT 6 Appendix A-2-1 Preliminary Test Data Appendix A-2-2 Emission Test Data for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3BAPP ENDIX A-1 EAGLE VALLEY UNITS 1 AND 2

Appendix A-1-1 Preliminary Test Data Appendix A-1-2 Emission Test Data for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3A
Appendix A-1-3 Emission T est Data for Acid Gases EPA Methods 3A, 6C, and 7E EPA Method 26A EPA CTM-033
Appendix A-1-4 Emissions Test Data for Non-Dioxin/Furan Organics EPA Methods 3A, 10, and 25A EPA Method 18 EPA Method 316 SW846-0010 SW846-0031
Appendix A-1-5 Emissions Test Da ta for PCDD/F and Coplanar PCBs EPA Method 23 EPA Method 3AAppendix A-1-1 Preliminary Test Dat aAppendix A-1-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods OTM-027/028EPA Method 30BEPA Method 3AAppendix A-1-3 Emission Test Data for Acid GasesEPA Method 3A, 6C, and 7EEPA Method 26AEPA CTM- 033Appendix A-1-4 Emissions Test Data for Non-Dioxin/Furan OrganicsEPA Methods 3A, 10, and 25A
(See Appendix A-1-2 also)EPA Method 18EPA Method 316SW846-0010SW846-0031Appendix A-1-5 Emissions Test Data for PCDD/F and Cop lanar PCBsEPA Method 23EPA Method 3A
(See Appendix A-1-2)APPENDIX A-2 EAGLE VALLEY UNIT 6

Appendix A-2-1 Preliminary Test Data Appendix A-2-2 Emission Test Data for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3BAppendix A-2-1 Preliminary Test Dat aAppendix A-2-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods OTM-027/028EPA Method 30BEPA Method 3B

### APPENDIX B Analytical Data

Appendix B-1 Enthalpy Analytical Labs Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 Appendix B-2 Analytical Persp ectives Labs – M23 Analysis Appendix B-3 Test America – Methods 29 and SW846-0031 Appendix B-4 URS Gravimetric Analysis Appendix B-5 Columbia Analytical Fuel AnalysisAppendix B-1 Enthalp y Analytical Labs Methods 26A, 316, CTM-033, OTM-028, and SW846-0010Appendix B-2
Anal ytical Perspectives M23 AnalysisAppendix B-3 Test America Method 29 and SW846-0031Appendix B-4 URS Gravimetric Anal ysisAppendix B-5 Columbia Analy tical Fuel Analysis

### APPENDIX C Hourly Process Operating Data

Appendix C-1 Eagle Valley Units 1 and 2 Appendix C-2 Eagle Valley Unit 6Appendix C-1 Eagle Valley Units 1 and 2Appendix C-2 Eagle Valley Unit 6

### APPENDIX D

QA/QC Data

### APPENDIX E 30-Day Process Data

Appendix E-1 Eagle Valley Units 1 and 2 Appendix E-2 Eagle Valley Unit 6Appendix E-1 Eagle Valley Units 1 and 2Appendix E-2 Eagle Valley Unit 6

### APPENDIX F EPA ERT Files and Spreadsheets

### APPENDIX G Test Plans and Correspondence