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 Corporation 

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 – Method 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 

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LIST OF TABLES 

Page 

1-1 Summary of Eagle Valley Station Testing Requirements .......................................... 1-1 

1-2 Eagle Valley Station Testing Dates............................................................................ 1-1 

1-3 Summary of Test Results 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 Analysis for Units 1, 2, and 6 ........................................................ 2-6 

3-1 Units 1 and 2 Test Schedule........................................................................................ 3-1 

3-2 Units 1 and 2 Summary for 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 Speciated 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 
SECTIONONE Introduction 

1. Section 1 ONE Introduction 

1.1 SUMMARY OF TEST PROGRAM 

On November 10, 2009, USEPA published a notice in the Federal Register (Vol. 75, 

No. 216, pages 58012-58013) pursuant to Section 114 of the federal Clean Air Act regarding 

an Information Collection Request (ICR) for New 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 the 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 testing requirements and schedules. 

IP&L’s Eagle Valley Station received such a letter on January 4, 2010. Included in the letter 

was the requirement to conduct the emissions testing summarized in Table 1-1. 

Table 1-1. Summary of Eagle Valley 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 testing 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 results for each of the units 

tested, based on the average of all three valid test runs for each parameter. 

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SECTIONONE Introduction 

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

Test Results 

Test Parameter EV 1&2 EV 6 Units 

Filterable PMb 2.30E-03 8.42E-03 lb/mmBtu 

PM2.5 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 PMc 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% O2

[<8.62E-10] -- lb/mmBtu PCB [<1.00] -- ng/dscm@7% O2

HCl [<9.38E-05] -- lb/mmBtu 

HF [<9.62E-05] -- lb/mmBtu 

HCN [<2.58E-05] -- lb/mmBtu 

1.16E-01 -- lb/mmBtu NOX 70.4 -- ppmvd@7% O2

2.18E-02 -- lb/mmBtu SO2 9.5 -- ppmvd@7% O2

8.41E-04 -- lb/mmBtu CO 0.8 -- ppmvd@7% O2

[<4.73E-06] -- lb/mmBtu HCHO [<4.39E-03] -- ppmvd@7% O2

2.57E-04 -- lb/mmBtu THC 0.2 -- ppmvd@7% O2

6.70E-04 -- lb/mmBtu CH4 1.2 -- ppmvd@7% O2

Volatile Organic [<2.40E-04] -- lb/mmBtu 

HAPd [<278] -- ug/dscm@7% O2

Semi-Volatile [<1.91E-06] -- lb/mmBtu 

Organic HAPe [<2.22] -- ug/dscm@7% O2

a

 Results containing non-detect values 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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SECTIONONE Introduction 

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During the stack test periods, the normal load was maintained during the test periods. For oilfired Units 1 and 2, normal load was approximately 40% of full load. For coal-fired Unit 6, 

normal load was approximately 82% of full load. 

The emission testing program was conducted in accordance with the requirements of EPA’s 

Section 114 ICR and the guidance posted on the RTI Utility MACT Website. There were no 

deviations to the standard test methods utilized 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 spike compounds. Acetone, methylene 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 the 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 Section 5 describes quality assurance parameters. 

Raw data and calculation summaries are contained in the Appendices. 
SECTIONTWO Facility Description 

2. Section 2 TWO Facility Description 

Section 2 describes each of the 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 rated 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. Sampling 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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SECTIONTWO 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 operating 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. However, because Units 1 and 2 are peaking units 

that are infrequently operated, the only time period that the boiler operated during this 30-day 

period was during the ICR-required stack testing. These operating data are presented in the 

EPA supplied Excel spreadsheets in Appendix F. 

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SECTIONTWO Facility Description 

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

Run 

Boiler O2

(%) 

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

Average 9.2 417.8 3,031 32.0 29.8

Methods 18, 23, 25A, 30B, and 316 

Org Run 1 9.3 401.8 2,914 30.3 28.1

Org Run 2 9.3 400.3 2,903 30.1 27.9

Org Run 3 9.0 407.6 2,956 30.5 28.3

Average 9.2 403.2 2,924 30.3 28.1

Method 30B

Hg Run 3 9.3 399.6 2,898 30.0 27.8

Hg Run 4 9.4 383.5 2,781 28.2 26.0

Hg Run 5 9.4 391.3 2,838 28.9 26.7

Average 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

Average 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

Average 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 O2 is an average of the results for both boilers. 

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SECTIONTWO Facility Description 

2.2 UNIT 6 

2.2.1 Process Description 

Unit 6 is rated at 105 MW (summer, gross). The unit combusts bituminous coal and consists 

of a tangentially fired combustor equipped with low NOX burners and over-fire air 

(LNB/OFA) and an electrostatic precipitator (ESP) to reduce air emissions. Figure 2-3 is a 

process flow diagram for Unit 6. 

ESP 

S

t

a

c

k 

T-Fired 

Boiler with 

LNB/OFA 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 stack. Port locations relative to 

the inlet breaching duct and stack outlet are illustrated in Figure 2-4. Sampling was 

conducted in each of four test ports. 

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SECTIONTWO Facility Description 

>434” 

>1736” 

Breaching 

duct 

Ports 

217 " 

Figure 2-4. Sampling Location for Unit 6 

2.2.3 Process Operating Data 

Testing was conducted under normal operating conditions on May 6 and May 11-12, 2010. 

Table 2-2 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. The 30-day operating data are presented in the 

EPA-supplied Excel spreadsheet in Appendix F. 

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SECTIONTWO 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 O2

(%) 

Methods 5/29, and 5/OTM-028

PM/Met Run 1 613.5 570.7 82.6 2.9 

PM/Met Run 2 630.8 569.9 82.1 2.9 

PM/Met Run 3 582.5 539.2 78.2 3.0 

Average 608.9 559.9 81.0 2.9 

Method 30B

Hg Run 1 813.5 570.3 82.7 2.9 

Hg Run 2 828.5 570.8 82.6 2.8 

Hg Run 3 813.3 570.1 82.1 2.8 

Average 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 SO2

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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SECTIONTHREE Test Results 

3. Section 3 THREE Test Results 

3.1 UNITS 1 AND 2 

The test schedule and run times for Eagle Valley Units 1 & 2 are shown in Table 3-1. 

Table 3-1. Units 1 and 2 Test Schedule 

Date Run Timesa 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, completed 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 summarize 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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SECTIONTHREE 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-027/028a

Run 

Filterable PMb

(lb/MMBtu) 

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu) 

Total PMc

(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 with [<] 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 

Mercuryb 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 with [<] 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 316a

Run 

CO 

(lb/MMBtu) 

HCHO 

(lb/MMBtu) 

THC 

(lb/MMBtu) 

CH4

(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 with [<] and are reported at the full detection limit. 

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SECTIONTHREE 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 with [<] 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 with [<] and are reported at the full detection limit. 

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SECTIONTHREE Test Results 

Table 3-7. Units 1 and 2 Summary for Acid Gases 

Reference Method Test Results for EPA Methods 1-4, 26A, & CTM-33a

Run 

SO2

(lb/MMBtu)

NOX

(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 with [<] 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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SECTIONTHREE Test Results 

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 with [<] and are reported at the full detection limit. 

Some compounds that were found above the detection 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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SECTIONTHREE Test Results 

Those four compounds have been excluded from table 3.8. Acetone, methylene chloride, and 

toluene were present as solvents in near proximity 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 Timesa 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 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. 

Table 3-10. Unit 6 Summary for Particulate Matter 

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28 

Run 

Filterable 

PMb 

(lb/MMBtu)

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu)

Total PMc

(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 with [<] 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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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 with [<] and are reported at the full detection limit. 

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

4. Section 4 FOUR Test Methods 

The following sections present information on the 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 weight, and the gas moisture content. Vent gas 

velocity and moisture content were measured at the stack location in conjunction with 

isokinetic sampling trains. Flue gas molecular weight was calculated using EPA Method 3A 

to determine concentrations of O2 and CO2 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-isokinetically 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 gas 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 OF 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 

immersed in an ice bath to maintain the exit temperature to below 68 OF. 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 recovered by brushing and 

rinsing each fraction individually with acetone into separately labeled sample. Front half 

rinse samples were dried, desiccated for 24 hours, and analyzed gravimetrically at the URS 

Laboratory in Morrisville, NC. The glass fiber filter was also desiccated, 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 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 high purity organic free water, high purity acetone, and high 

purity MeCl to remove and preserve the condensable 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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SECTIONFOUR Test Methods 

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 calculate the stack gas velocity. 

Samples were all given a unique identification number and logged into a table as they were 

collected and recovered. Identification numbers were included on all sample containers 

during the analytical process. All EPA Method 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 using EPA Method 5 and Other Test Method 028. 

A measured volume of stack gas was drawn from the stack isokinetically through a button 

hook style glass nozzle followed by a heated quartz filter. The remaining sample gas passed 

through a heated 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 OF 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 immersed in an ice bath to maintain the exit 

temperature to below 68 OF. 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 hours, 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 water, high purity acetone, and 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 high purity organic free 

water, high purity acetone, and high purity MeCl to remove and preserve the condensable 

particulate for evaporation and gravimetric analysis at the laboratory. Rinses were kept 

separate from the condensed moisture fraction until combined by the laboratory. 

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SECTIONFOUR Test Methods 

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 calculate the stack gas velocity. 

Samples were all given a unique identification number and logged into a table as they were 

collected and recovered. Identification numbers 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 determined using the procedures provided in EPA 

Method 6C using the facility’s certified CEMS instrumentation. The SO2 analyzer works off 

the ultraviolet (UV) absorption principle. The sample stream passes through a sample 

chamber within the analyzer at a constant pressure which has a UV light source present at 

one end. The SO2 molecules in the sample stream absorb a portion of the energy from the UV 

lamp which excites the particle causing it to decay to a lower energy state. As the particle 

decays, it gives of ultraviolet light at a different wavelength. The emission of that light is 

measured by a photomultiplier tube located perpendicular to the UV light source further 

down the sample path. The intensity of the light detected by the photomultiplier tube is 

proportional in relation to the concentration of SO2 in the sample stream. The light intensity 

measured by the analyzer corresponds to a signal that was transferred to the DAS and 

recorded in by the historian. 

4.5 EPA METHOD 7E 

EPA Method 7E was used to determine concentrations of oxides of nitrogen in the flue gas 

using the facility’s certified CEMS instrumentation. The NOx analyzer operates off the 

chemiluminescent principle and is equipped with a catalytic thermal converter to convert 

NO2 to NO. The sample gas is passed through the converter and heated to break one of the 

oxygen bonds in the NO2 molecule. After the conversion, the 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 chemical reaction between the NO and O3 produces a photon 

of light for each molecule. The chemiluminescent photons are measured by a photomultiplier 

tube at the end of the reaction chamber to produce a signal that is linear in relation to 

concentration. 

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SECTIONFOUR Test Methods 

4.6 EPA METHOD 10 

EPA Method 10 was used to determine concentrations of carbon monoxide in the flue gas 

using the facility’s certified CEMS instrumentation as well as by the test crew on site. The 

concentration of carbon monoxide in the stack exhaust was selectively measured by a gas 

filter correlation analyzer. The analyzer’s operation is based on the principle that carbon 

monoxide absorbs infrared light at a specific wavelength. The instrument produces an 

infrared light signal which passes through a spinning correlation wheel. The light signal is 

modulated by alternating back and forth between two chambers on the wheel, one of which 

contains nitrogen (measurement cell) and the other contains carbon monoxide (the reference 

cell). The nitrogen cell is transparent to the infrared light and allows the entire light signal to 

pass though while the carbon monoxide cell absorbs all of the light at the effected 

wavelengths providing a baseline. After the light 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 between the modulations in the signal is a nonlinear correlation that represents the concentration of carbon monoxide in the sample. The 

signal is linearized by the internal 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 gases with the resultant test data being corrected for bias and 

drift. 

4.7 EPA METHOD 18 

EPA Method 18 was performed to determine concentration of methane in the flue gas. A 

sample of the stack gas was extracted from the test location through an in-stack filter and 

transported to the test trailer through a heated sample line and 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 stream by molecular size, allowing the smaller 

compounds to pass through first. Once the hydrocarbon constituents have passed through the 

column they are introduced to a flame ionization detector (FID). The ionizer heats the 

compounds to break the carbon bonds. 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 

response. Because the compounds have been speciated by passing them through the column, 

the resultant intensity of the response is attributed to a specific organic 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 three concentrations to 

develop a linear regression curve. Each test run consisted of at least five injects to the 

GC/FID followed by a 3 replicate calibration check. 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, polychlorinated dibenzofurans (PCDD/F), and 

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SECTIONFOUR Test Methods 

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 pretreated glass filter before passing into a waterjacketed condenser followed by a module containing 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 OF during the test. The flue gas then passed through an ice bath impinger train 

containing HPLC grade water and silica gel to remove any remaining moisture prior to being 

measured by a dry gas metering console. After the final leak check had 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 and toluene as prescribed in the 

ICR. Rinses of the back half connecting glassware and condenser were added to the front half 

rinses in the mobile laboratory. All three solvent 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 aluminum foil. The module was then covered with aluminum foil 

to prevent excess exposure, labeled and kept cool in a sample refrigerator until the test 

program was completed. 

Prior to the sampling event all of the glassware was washed with Alconox and deionized 

water and baked at 300 OC for 4 hours. A final rinse of the glassware with MeCl was 

performed prior to being packaged for transport 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 with 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 × HN × QIS) / ( HIS × 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 method 23 samples this value is always 1) 

 RRF is the calculated relative response factor for the analyte 

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SECTIONFOUR Test Methods 

4.9 EPA METHOD 25A 

EPA Method 25A was used to determine concentration of total hydrocarbons (THC) in the 

gas stream. A sample of the stack gas was extracted from the test location through an in-stack 

filter and heated line and transported to the mobile 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 response. 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. For this program, the calibration basis was methane so the 

resultant response is on an as methane basis. The instrument was calibrated using EPA 

Protocol 1 gases with the resultant data being corrected for drift. 

4.10 EPA METHOD 26A 

EPA Method 26A was used to determine emissions of HCl, Cl2, and HF in the gas stream. A 

sample of the stack gas was extracted from the test location through a glass nozzle, heated 

probe, and filter assembly prior to entering the sample train. The sample was filtered through 

a Teflon coated quartz filter maintained at greater than 248 OF meeting the specifications for 

particle retention of 99.95 % for 0.3um as prescribed in the test method. The sample then 

passed thorough an oversized knockout Greenberg-Smith impinger containing 50 ml of 0.1 N 

H2SO4 followed by two standard size Greenberg-Smith impingers also containing 0.1N 

H2SO4. 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 compounds were captured in the acidic impinger 

solutions while the remaining elemental halogens 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 transported to the mobile laboratory for recovery. 

Sampling trains were weighed gravimetrically for moisture calculations, and recovered into 

appropriately labeled sample jars with DI H2O. Sodium thiosulfate was added to the basic 

impinger solutions by the laboratory 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 Cl2 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 determine 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 replicates 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 concentration of the standard used to produce 

the MDL value. 

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4.11 EPA METHODS 5 AND 29 

Emissions of filterable particulate matter and specific 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 source through a glass nozzle, heated probe, and 

heater filter prior to entering the impinger train. The impinger train was maintained in an ice 

bath with an exit temperature of less than 68 OF 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 impingers contained a solution of 5% HNO3 and 

10% H2O2 in water. The fourth impinger was an empty modified Greenberg-Smith impinger. 

Impingers 5 and 6 were both modified Greenberg-Smith Impingers containing a solution of 

4% KMnO4 and 10% H2SO4 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 sample recovery. The probe and 

nozzle was first rinsed and brushed with acetone followed by 0.1 N HNO3 into separate jars. 

In the laboratory, the train was weighed gravimetrically 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 analysis of the samples, the acetone rinses were 

reconstituted with 0.1N HNO3 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 were 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 mercury 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 tube 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 Hgo

 analytical bias test was performed 

to confirm that the analytical system results were within ±10% of the target value. Table 4-3 

shows the results of the Hgo

 analytical bias test. All samples 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 analytical 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 the ±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 using tubes spiked at 50 ng 

of mercury with two hour samples being collected at a nominal 2-hours. Using these 

procedures, if the QA/QC criteria 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 sample of the stack gas was extracted isokinetically through 

a glass nozzle and heated probe assembly. The sample passed through a heated filter 

assembly to remove particulate followed by a five-impinger train before being measured by a 

dry gas metering console. The impinger train was maintained in an ice bath to control the exit 

impinger temperature to at or below 68 OF. The configuration of the train included a primary 

impinger containing lead acetate, a knock-out impinger, two impingers containing 100 ml of 

4N NaOH each, and a final silica gel impinger. The purpose of the lead acetate was to 

remove SO2 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 brushed and recovered into a glass sample jar with acetone to be 

archived for PM analysis. In the mobile laboratory, the impinger train was weighed 

gravimetrically for moisture determination. The impinger contents were recovered into 

sample jars followed by rinses of lead acetate 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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SECTIONFOUR Test Methods 

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 within 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 determine 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 replicates 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 concentration of the standard used to produce 

the MDL value. 

4.14 SW846-0010 

Emissions of speciated semi-volatile organic compounds were measured using the 

procedures prescribed in Solid Waste Association 846 Method 0010. A sample of the stack 

gas was extracted isokinetically through a glass nozzle and heated 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 resin trap to ensure 

the temperature was below 68 OF. After exiting the resin trap, the sample stream passed 

through an impinger train containing organic free water to remove any residual semi-volatile 

compounds and residual moisture before being 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 

OF. 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 brushed and recovered into a glass sample jar with acetone first 

followed by MeCl as prescribed in the ICR. In the mobile laboratory, the impinger train was 

weighed gravimetrically for moisture determination. 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 used 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 determine 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 replicates 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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a default MDL value was used of 1/10 of the concentration of the standard used to produce 

the MDL value. 

4.15 SW846-0031 

Emissions of speciated volatile organic compounds 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 OC containing an organic 

free glass wool plug to filter out particulate matter. The gas was then passed through a 

condenser maintained at below 20 OC, two Tenax sorbent traps, a condensate trap, and an 

Anasorb trap to collect the volatile compounds. The gas passes through a final silica gel 

reservoir before being measured by a dry gas meter. The system was operated as to collect a 

nominal 1 liter per minute of gas for 20 minutes per 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 including one pre-test train blank per source, one 

trip blank per cooler, and a reagent blank were collected for each facility. 

TestAmerica located in Knoxville, Tennessee prepared the traps and performed the analysis. 

Analytes for this test method were not specifically 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 recorded by the facility DAS and PI system. Process 

indicators that were monitored included boiler steaming rate (Klbs/hr), fuel firing rates 

(mmBtu/hr calculated heat input), and scrubber operation (quench flow and differential 

pressure of the scrubber as compliance indicators 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. 
SECTIONFIVE 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 reduction, and interpretation 

of results. QA/QC procedures were strictly followed 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 and repeated. Prior to and following the test 

program, pitot leak checks were performed on the pressure differential measuring systems. 

CEM analyzers were calibrated according to the relevant test method with bias and drift 

checks being performed as required. Analyzers were calibrated using EPA Protocol 1 gases. 

Copies of the cylinder certifications 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 capping the tip of the sample probe and pulling a 

vacuum. Flow rate was monitored until the absence 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 was used on multiple units, the glassware was 

blanked between them to verify cleanliness between units. 

On-site analysis of Method 30B sorbent traps for Runs 2 and3 during testing of Units 1 and 2 

determined that the labeled spike concentrations on the tube sheets were incorrect, resulting 

in the spike criteria requirements 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 specified 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 visual and operation check prior to and 

after transport to ensure clean and operable 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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 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 data 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 29oC (<85oF). 

 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 performed 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 Appendix 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 and 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 Test 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 Data 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 3B 
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 Test 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 Data for PCDD/F and Coplanar PCBs

 EPA Method 23 

 EPA Method 3A 
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 Test Data for Acid Gases 
EPA Method 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 

(See Appendix A-1-2 also) 
EPA Method 18 
EPA Method 316 
SW846-0010 
SW846-0031 
Appendix A-1-5 

Emissions Test Data for PCDD/F and Coplanar PCBs 
EPA Method 23 
EPA 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 3B 
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 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 Perspectives 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 Analysis 
Appendix B-1 

Enthalpy Analytical Labs 

Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 
Appendix B-2 

Analytical Perspectives 

M23 Analysis 
Appendix B-3 

Test America 

Method 29 and SW846-0031 
Appendix B-4 

URS 

Gravimetric Analysis 
Appendix B-5 

Columbia Analytical Fuel Analysis 
APPENDIX C 

Hourly Process Operating Data 

Appendix C-1 Eagle Valley Units 1 and 2 

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

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

Eagle Valley Units 1 and 2 
Appendix E-2 

Eagle Valley Unit 6 
APPENDIX F 

EPA ERT Files and Spreadsheets 
APPENDIX G 

Test Plans and Correspondence