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Work Order No. 12251.014.400 

Georgia Power Company 

Plant Wansley, Units 1 and 2 

Carrollton, Georgia 

EGU ICR Test Program for 

Acid Gases HAPs 

Southern Company 

22 April 2010 

Prepared For

SOUTHERN COMPANY SERVICES 

600 North 18th Street 

Birmingham, Alabama 35203 

Jon Howard Natalie Vaught 

ICR Program Manager Report Coordinator 

Approved for Transmittal Approved for Transmittal

Prepared By

WESTON SOLUTIONS, INC. 

1625 Pumphrey Ave.

Auburn, Alabama 36832-4303 

Phone: (334) 466-5600 Fax: (334) 466-5660 

2 July 2010 
 

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WESTON SOLUTIONS, INC. (WESTON®) 

EMISSION TESTING PRACTICE – AUBURN OPERATIONS

ACCREDITATION STIPULATION

Laboratory: Weston Solutions, Inc. 

Accreditor(s): Louisiana Environmental Laboratory Accreditation 

Program (LELAP) – Laboratory and Emission Testing Practice 

Accreditation ID: LELAP – 03024 

Scope: Hydrogen Chloride Sampling and Analysis 

Hydrogen Fluoride Sampling and Analysis 

Hydrogen Cyanide Sampling and Analysis 

Effective: LELAP – 21 December 2001 

Expires: LELAP – 30 June 2010 

Note: These accreditation stipulations conform to the requirements of Georgia Rule 391-3-26-01. 
 

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Data Qualifiers 

The following are general reporting notes that are applicable to all WESTON reports, unless 

otherwise noted. 

• NL denotes data that was not from a LELAP accredited method. 

• LNL denotes lab results that are not from an accredited LELAP laboratory. 

• NN denotes data that was not from a NELAP accredited method. 

• NNL denotes lab results that are not from an accredited NELAP laboratory. 

• ED denotes data that is not to be used for compliance purposes and may deviate from 

approved procedures. 

• Q denotes data whose QA/QC check did not fall within the specified range. This data is still 

considered valid. 

• A denotes data that is anomalously high with no explanation for the outlier. 

• BDL denotes values that were below the limit of detection of the analyzer and 2% of the 

span gas was used to calculate an emission rate. 

• DF denotes a dilution factor.

• NAP denotes emission testing performed by personnel from a non-NELAC accredited 

laboratory.

• S denotes analysis that has been subcontracted. 
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 TABLE OF CONTENTS

SECTION 1 INTRODUCTION.................................................................................................... 6

SECTION 2 RESULTS AND DISCUSSION .............................................................................. 8

2.1 Emission Testing Results ................................................................................. 8

SECTION 3 PROCESS DESCRIPTION .................................................................................. 11

3.1 Source Descriptions and Test Locations ........................................................ 11

3.2 Pollution Control Equipment ......................................................................... 11

3.3 Sootblowing ................................................................................................... 11

3.4 Process Parameters ......................................................................................... 12

SECTION 4 QUALITY CONTROL .......................................................................................... 14

4.1 Data Collection and Reduction ...................................................................... 14

4.2 Chain-of-Custody ........................................................................................... 14

4.3 Performance Data for Volumetric Flow Measurements ................................ 14

4.4 Unit 1 Performance Data for Isokinetic Sampling Methods Acid Gases 

Measurements ................................................................................................. 15

4.5 Unit 2 Performance Data for Isokinetic Sampling Methods Acid Gases 

Measurements ................................................................................................. 16

SECTION 5 SOURCE TESTING METHODOLOGY ............................................................ 17 

APPENDIX A EXAMPLE CALCULATIONS

APPENDIX B TEST METHODOLOGY

APPENDIX C FIELD DATA – PLANT WANSLEY, UNITS 1 AND 2

APPENDIX D LABORATORY DATA

APPENDIX E QUALITY CONTROL DATA

APPENDIX F PROCESS OPERATING/PRODUCTION DATA
 TABLE OF CONTENTS

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LIST OF TABLES

Table 1-1 Scope of Work Georgia Power Company, Plant Wansley, Units 1 and 2 ...................... 6

Table 1-2 WESTON Project Team .................................................................................................. 7

Table 2-1 Plant Wansley, Unit 1 Summary of Acid Gases Emission Results ................................. 9

Table 2-2 Plant Wansley, Unit 2 Summary of Acid Gases Emission Results ............................... 10

Table 3-1 Plant Wansley, Unit 1 Process Parameters .................................................................... 12

Table 3-2 Plant Wansley, Unit 2 Process Parameters .................................................................... 12

Table 4-1 Unit 1 Summary of Method 26A Performance Criteria and Achieved Results ............ 15

Table 4-2 Unit 2 Summary of Method 26A Performance Criteria and Achieved Results ............ 16

Table 5-1 Source Testing Methodology ........................................................................................ 17
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SECTION 1 

INTRODUCTION

The U.S. Environmental Protection Agency (EPA), under the authority of Section 114 of the Clean 

Air Act, issued an information collection request (ICR) to Southern Company Services (Southern 

Company) for the Georgia Power Plant Company, Plant Wansley, Units 1 and 2 located near 

Carrollton, Georgia. The ICR set forth fuel sampling, emission testing, and process and pollution 

control data collection requirements. To comply with this ICR, Southern Company retained Weston 

Solutions, Inc. (WESTON®) to conduct hazardous air pollutants (HAPs) emission testing. EPA will 

use the data collected during this program to develop maximum achievable control technology 

(MACT) standards for coal- and oil-fired electric utility steam generating units. 

The scope of work for Units 1 and 2 ICR is summarized in Table 1-1. Parameters within each 

grouping were measured simultaneously, where applicable. 

TABLE 1-1 

SCOPE OF WORK

GEORGIA POWER COMPANY, PLANT WANSLEY, UNITS 1 AND 2

Group A Parameters 

HCl, HF, and HCN (M26A) 

O2/CO2 (M3A Modified) 

Group A Sampling Notes – All parameters were sampled concurrently and meet the minimum 

requirements of the EPA’s ICR. 
 INTRODUCTION

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WESTON performed the emission testing during 22 April 2010. The project team included the 

individuals identified in Table 1-2. 

TABLE 1-2 

WESTON PROJECT TEAM

Name Project Role QSTI Credential 

Jon Howard Program Manager QSTI 1, 2, and 4 Qualified Individual 

Gregory Sims Technical Director QSTI 1, 2, and 3 Qualified Individual 

QSTI 4 Certified 

Matt Dallesasse Test Team Member ---- 

Billy Routhier Test Team Member QSTI 3 Qualified Individual 

Kevin Rass Test Team Member ---- 

Steve Daughtry Test Team Member ---- 

Melanie Wright Quality Assurance Manager QSTI 1 Qualified Individual 

Natalie Vaught Report Coordinator QSTI 3 Qualified Individual 

Ms. Christie Garrett of Georgia Power Company (GPC) coordinated the testing with plant 

operations. Mr. Wim Marchant and Mr. Gary Blackmon of SCS provided technical assistance and 

oversight for the test program. A representative of the Georgia Department of Environmental 

Protection (GEPD) was not present during testing 

The Louisiana Environmental Laboratory Accreditation Program (LELAP) accredits WESTON’s 

emission testing laboratory. The stipulation associated with this accrediting authority precedes the 

table of contents of this report. 
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SECTION 2 

RESULTS AND DISCUSSION

2.1 EMISSION TESTING RESULTS

Tables 2-1 and 2-2 provide detailed summaries of the emission results. Any differences between 

the calculated results presented in the appendices and the results reported in the summary tables are 

due to rounding for presentation. 

Following is a description of the procedures and methods used to determine the minimum analytical 

detection limits for each test parameter. 

Derivation of Analytical Detection Limits and Their Use in Calculating Source Emission 

Concentrations and Rates. 

Method Detection Limit (MDL)

EPA defines the Method Detection Limit (MDL) as: 

The minimum concentration of a substance that can be measured and reported with 99% 

confidence that the analyte concentration is greater than zero and is determined from 

analysis of a sample in a given matrix type containing the analyte. 

WESTON conducts a method detection limit study each year to support EPA Methods 26A and 

CTM 033 analytical work in accordance with the procedures set forth in Appendix B to 40 CFR 

Part 136. 

In summary, this approach involves multiple analyses of prepared samples at or near the expected 

lower range of the analytical method. While the MDL has value from a theoretical perspective, it 

has limited use for practical applications because analytes of interest are almost always present in a 

matrix that differs significantly from that of the prepared samples used to conduct the MDL study. 

Limit of Quantitation (LOQ) for Methods 26/26A (HCl, HF, and HCN)

EPA defines the Limit of Quantitation (LOQ) as: 

The lowest concentration of a chemical that can be accurately and reproducibly quantitated 

(Risk Assessment Guidance for Superfund: Volume I -- Human Health Evaluation Manual 

(Part A). Interim Final. U.S. Environmental Protection Agency. Office of Emergency and 

Remedial Response. EPA/540/1-89/002, Types and Definitions of Detection Limits and 

Quantitation Limits) 
 RESULTS AND DISCUSSION

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The LOQ is the concentration or mass that the laboratory has established as the lowest defensible 

level that can be reported and still be considered accurate. The LOQ must be greater than or equal 

to the results of the MDL. 

The WESTON lab has established LOQ values of 3X the MDL for HCl, HF, and HCN. 

For these three compounds WESTON calculates emission test results using the reported LOQ for 

ND samples and reports them as less than (<) values. 

TABLE 2-1 

PLANT WANSLEY, UNIT 1 

SUMMARY OF ACID GASES EMISSION RESULTS

Parameter Run 1 Run 2 Run 3 Average 

Test Time 

 Date 4/22/10 4/22/10 4/22/10 --- 

 Start Time 0728 0859 1014 --- 

 End Time 0838 1007 1127 --- 

Isokinetic Sampling Rate 112a

 111a 107 110 

Stack Gas Characteristics 

 Temperature, oF 123 124 124 124 

 Oxygen, % 8.4 6.9 6.4 7.2 

 Carbon Dioxide, % 12.3 12.2 12.1 12.2 

 Moisture, % 13 13 13 13 

 Velocity, ft/sec 50 49 49 49 

Volumetric Flow Rate 

 Actual, acfm 2.70 E+06 2.67 E+06 2.67 E+06 2.68 E+06 

 Wet Standard, wscfm 2.37 E+06 2.33 E+06 2.33 E+06 2.34 E+06 

 Dry Standard, dscfm 2.06 E+06 2.02 E+06 2.02 E+06 2.03 E+06 

ACID GASES 

Hydrogen Chloride 

 Emission Rate, O2 F-Factor, lb/MMBtu 2.29 E-04 4.37 E-04 2.24 E-04 2.97 E-04 

Hydrogen Fluoride 

 Emission Rate, O2 F-Factor, lb/MMBtu 7.79 E-05 1.01 E-04 8.38 E-05 8.76 E-05 

Hydrogen Cyanide 

 Emission Rate, O2 F-Factor, lb/MMBtu [<3.40 E-04] [<3.10 E-04] [<3.33 E-04] [<3.27 E-04] 

a

The isokinetic sampling rate for Run 1 and Run 2 exceeded the allowable percentage after the results were corrected 

for carbon dioxide (CO2) loss. 

Note 1: Sample volumes were corrected to account for CO2 loss from the gas stream due to the use of concentrated 

sodium hydroxide. 

Note. 2: Sample results indicating measured mass below the LOQ were indicated by brackets around the < LOQ value. 
 RESULTS AND DISCUSSION

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TABLE 2-2 

PLANT WANSLEY, UNIT 2 

SUMMARY OF ACID GASES EMISSION RESULTS

Parameter Run 1 Run 2 Run 3 Average 

Test Time 

 Date 4/22/10 4/22/10 4/22/10 --- 

 Start Time 1138 1258 1422 --- 

 End Time 1248 1409 1528 --- 

Isokinetic Sampling Rate 108 110 106 108 

Stack Gas Characteristics 

 Temperature, oF 123 124 124 124 

 Oxygen, % 6.2 6.4 7.9 6.9 

 Carbon Dioxide, % 12.1 12.1 11.9 12.1 

 Moisture, % 13 13 13 13 

 Velocity, ft/sec 48 48 49 48 

Volumetric Flow Rate 

 Actual, acfm 2.61 E+06 2.64 E+06 2.65 E+06 2.63 E+06 

 Wet Standard, wscfm 2.28 E+06 2.30 E+06 2.32 E+06 2.30 E+06 

 Dry Standard, dscfm 1.98 E+06 2.00 E+06 2.01 E+06 2.00 E+06 

ACID GASES 

Hydrogen Chloride 

 Emission Rate, O2 F-Factor, lb/MMBtu 2.29 E-04 2.00 E-04 2.06 E-04 2.12 E-04 

Hydrogen Fluoride 

 Emission Rate, O2 F-Factor, lb/MMBtu 8.49 E-05 5.77 E-05 [<5.00 E-05] <6.42 E-05 

Hydrogen Cyanide 

 Emission Rate, O2 F-Factor, lb/MMBtu [<2.93 E-04] [<3.17 E-04] [<3.34 E-04] [<3.14 E-04] 

Samples results indicating measured masses above the LOQ for one or more runs (but not all runs) have been presented 

as < and shade. 

Note 1: Sample volumes were corrected to account for CO2 loss from the gas stream due to the use of concentrated 

sodium hydroxide. 

Note. 2: Sample results indicating measured mass below the LOQ were indicated by brackets around the < LOQ value. 
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SECTION 3 

PROCESS DESCRIPTION

3.1 SOURCE DESCRIPTIONS AND TEST LOCATIONS

Unit 1 at Plant Wansley is an 865 MW generating unit which started commercial operation in 1976. 

The Combustion Engineering tangential fired unit is equipped with an SCR for NOX control. 

Unit 2 at Plant Wansley is an 865 MW generating unit which started commercial operation in 1978. 

The Combustion Engineering tangential fired unit is equipped with an SCR for NOX control. 

3.2 POLLUTION CONTROL EQUIPMENT

Primary particulate control is by a Cold-Side, Res-Cott/SEI RDE electrostatic precipitator. Sulfur 

dioxide removal and additional PM control is performed by a Chiyoda Jet Bubbling Reactor 

commissioned in 2008. 

Primary particulate control is by a Cold-Side, Res.-Cott. Weighted Wire electrostatic precipitator. 

Sulfur dioxide removal and additional PM control is performed by a Chiyoda Jet Bubbling Reactor 

commissioned in 2009. 

At the time of the ICR test program, no additional exhaust gas controls were in operation. 

3.3 SOOTBLOWING

No sootblowing activities were conducted during any test run events. 
 QUALITY CONTROL

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3.4 PROCESS PARAMETERS

Table 3-1 presents the process information collected during the ICR testing. 

TABLE 3-1 

PLANT WANSLEY, UNIT 1 

PROCESS PARAMETERS

Parameter Run 1 Run 2 Run 3 Mean 

 Date 4/22/10 4/22/10 4/22/10 --- 

 Time Began 0728 0859 1014 --- 

 Time Ended 0838 1007 1127 --- 

NOx, ppmvd 30.567 31.629 31.329 31.175 

SO2, ppmvd 25.882 28.022 25.100 26.335 

Gross Electric Output, MW 919.788 919.790 920.675 920.084 

Station Service, MW 47.116 46.470 46.411 46.666 

Net Load, MW 872.672 873.320 874.264 873.419 

ESP, Total KW 1,026.096 1,029.107 1,014.257 1,023.153 

Main Steam Flow, Klb/hr 6,378.936 6,378.293 6,384.410 6,380.546 

Total Fuel Flow, Klb/hr 476.310 477.140 472.347 475.265 

Coal Heat Value, Btu/lb 12,119.000 12,119.000 12,119.000 12,119.000 

Total Heat Input (from Coal Feed), MMBtu/hr 5,772.395 5,782.456 5,724.375 5,759.742 

Total Heat Input (from Flow/CO2), MMBtu/hra 7,883.918 7,742.852 7,648.245 7,758.338 

Scrubber Parameters 

Slurry pH 5.238 5.176 5.276 5.230 

Submergence Level, in 8.245 8.201 8.262 8.236 

Differential Pressure, in H2O 14.646 14.582 14.556 14.595 

a

The Total Heat Input calculations show a significant discrepancy. The Heat Input calculated from the flow rate and 

carbon dioxide is correct, the reported Heat Input from the Coal Feed Rate is low due to a signal scaling issue. For 

emission rate calculation, the appropriate F-Factor is used to calculate the emission rates. 
 QUALITY CONTROL

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TABLE 3-2 

PLANT WANSLEY, UNIT 2 

PROCESS PARAMETERS

Parameter Run 1 Run 2 Run 3 Mean 

 Date 4/22/10 4/22/10 4/22/10 --- 

 Time Began 1138 1258 1422 --- 

 Time Ended 1248 1409 1528 --- 

NOx, ppmvd 31.741 32.067 32.499 32.102 

SO2, ppmvd 23.992 18.122 16.856 19.657 

Gross Electric Output, MW 922.427 922.540 926.880 923.949 

Station Service, MW 46.591 46.182 46.132 46.302 

Net Load, MW 875.836 876.359 880.747 877.648 

ESP, Total KW 798.388 779.336 784.439 787.387 

Main Steam Flow, Klb/hr 6,397.166 6,397.205 6,426.286 6,406.886 

Total Fuel Flow, Klb/hr 471.066 466.257 465.620 467.648 

Coal Heat Value, Btu/lb 12,106.000 12,106.000 12,106.000 12,106.000 

Total Heat Input (from Coal Feed), MMBtu/hr 5,702.731 5,644.505 5,636.790 5,661.342 

Total Heat Input (from Flow/CO2), MMBtu/hra 7,947.562 7,914.061 7,871.586 7,911.070 

Scrubber Parameters 

Slurry pH 5.561 5.577 5.618 5.586 

Submergence Level, in 8.067 8.176 8.044 8.095 

Differential Pressure, in H2O 14.048 14.314 14.126 14.163 

a

The Total Heat Input calculations show a significant discrepancy. The Heat Input calculated from the flow rate and 

carbon dioxide is correct, the reported Heat Input from the Coal Feed Rate is low due to a signal scaling issue. For 

emission rate calculation, the appropriate F-Factor is used to calculate the emission rates. 
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SECTION 4 

QUALITY CONTROL

This section provides detailed information regarding the QA/QC activities associated with stack 

sampling. 

4.1 DATA COLLECTION AND REDUCTION

Data were collected on pre-printed data sheets or electronically using validated data acquisition 

instrumentation and software. Collected data were reduced using pre-programmed calculators and 

validated spreadsheets. Data transfers were independently verified. 

Copies of field data sheets are provided in the Appendices. 

4.2 CHAIN-OF-CUSTODY

Sample chain-of-custody was maintained from sample train recovery through analysis at the 

laboratory. Chain-of-custody forms accompany the analytical results provided in Appendix D. 

4.3 PERFORMANCE DATA FOR VOLUMETRIC FLOW MEASUREMENTS

Volumetric flow data were obtained using certified pitot tubes and temperature measurement 

equipment. Equipment used during the test program met the requirements of EPA Method 2. 

Copies of calibration data are provided in Appendix E. 
 QUALITY CONTROL

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4.4 UNIT 1 PERFORMANCE DATA FOR ISOKINETIC SAMPLING 

METHODS ACID GASES MEASUREMENTS

Acid gases were measured using isokinetic sampling procedures. Table 4-1 summarizes the method 

performance criteria and achieved results for the method. Additionally, Appendix E provides 

copies of stack test equipment calibration data. 

TABLE 4-1 

UNIT 1 

SUMMARY OF METHOD 26A/CTM033 

PERFORMANCE CRITERIA AND ACHIEVED RESULTS

Method 26A Performance Data 

QA Specification 

Performance 

Run 1 Run 2 Run 3 Acceptance Criteria 

Isokinetic Sampling Rate, %a 112 111 107 90%-110% 

Minimum Sampling Time 60 min 60 min 60 min 60 minutes 

Minimum Sample Volume, M3 0.90 0.96 0.94 ---- 

pH (CTM033) 13.7 13.7 13.8 >12 

Duplicate Analysis (26A) <5% <5% <5% <5% difference 

a

The isokinetic sampling rate for Run 1 and Run 2 exceeded the allowable percentage after the results were corrected 

for carbon dioxide (CO2) loss. 
 QUALITY CONTROL

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4.5 UNIT 2 PERFORMANCE DATA FOR ISOKINETIC SAMPLING 

METHODS ACID GASES MEASUREMENTS

Acid gases were measured using isokinetic sampling procedures. Table 4-2 summarizes the method 

performance criteria and achieved results for the method. Additionally, Appendix E provides 

copies of stack test equipment calibration data. 

TABLE 4-2 

UNIT 2 

SUMMARY OF METHOD 26A 

PERFORMANCE CRITERIA AND ACHIEVED RESULTS

Method 26A Performance Data 

QA Specification 

Performance 

Run 1 Run 2 Run 3 Acceptance Criteria 

Isokinetic Sampling Rate, % 108 110 106 90%-110% 

Minimum Sampling Time 60 min 60 min 60 min 60 minutes 

Minimum Sample Volume, M3 0.93 0.95 0.92 ---- 

pH (CTM033) 13.7 13.7 13.7 >12 

Duplicate Analysis (26A) <5% <5% <5% <5% difference 
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SECTION 5 

SOURCE TESTING METHODOLOGY

The emission testing program was conducted in accordance with the U.S. EPA Reference Methods 

summarized in Table 5-1. Method descriptions and quality assurance data are provided in the 

referenced appendices. 

TABLE 5-1 

SOURCE TESTING METHODOLOGY

Parameter 

Method 

Number 

Appendix Reference 

Comments

Data 

Qualifiers 

Method 

Description 

Quality 

Control 

Data 

Volumetric Flow Rate 1,2,4 B.1 E See Note 1 

Gas Composition 3A B.2 E See Note 2 

HCl, HF, and HCN 26A/CTM033 B.3 E See Note 3 

These results meet all requirements of NELAC unless otherwise specified. 

The results within this report relate only to the samples listed in the body of this report. 

Notes: 

1. The source was oversaturated. Moisture was calculated from the saturation tables at the source 

temperature and pressure. 

2. Modified analysis of integrated bag samples. 

3. The method was modified by using 6N sodium hydroxide to maintain a pH above 12. The 

sample volumes are corrected for the CO2 concentration; due to the use of the strong caustic, 

CO2 is removed from the gas stream. 
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APPENDIX A 

EXAMPLE CALCULATIONS
 APPENDIX A 

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EXAMPLE CALCULATIONS

Meter Pressure (Pm), in. Hg 

13.6 in.H O/in.Hg

H Pm = Pb+

2

∆

 where, Pb = barometric pressure, in. Hg 

 ∆H = Pressure differential of orifice in. H2O 

Absolute Stack Gas Pressure (Ps), in. Hg 

13.6 in.H O/in.Hg

Pg Ps = Pb+

2

 where, Pb = barometric pressure, in. Hg 

 Pg = Static Pressure, in. H2O 

Standard Meter Volume (Vmstd), dscf 

Tm

17.64 R/in. Hg x Y x Vm x Pm Vmstd ° =

 where, Y = meter correction factor 

 Vm = meter volume, cf or L

 Pm = meter pressure, in. Hg 

 Tm = meter temperature, o

R 

CO2 Volume Correction 

 corrected Vmstd

100 - actual % CO

100 - measured % CO Vmstd x 

2

2 = ⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

Standard Wet Volume (Vwstd), scf

Vwstd 0.04707 ft /mL x Vlc 3 =

 where, Vlc = volume of H2O collected, mL 

Standard Wet Volume (Vwstd), L

Vwstd = 1.333 L/mL x Vlc

 where, Vlc = volume of H2O collected, mL 
 APPENDIX A 

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Moisture Fraction (Measured), (Bws) 

 (Vwstd +Vmstd)

Vwstd Bws = 

 where, Vwstd = standard wet volume, scf or L 

 Vmstd = standard meter volume, dscf or L 

Moisture Fraction (at saturation), (Bws) 

 Ps

Vp Bws = 

 where, Vp = vapor pressure of H2O at stack gas temp., in. Hg 

 Ps = absolute stack gas pressure, in. Hg 

Moisture, % (M%) 

M% = Bws x 100 

 where, Bws = moisture fraction, measured or at saturation, whichever is lowest 

Molecular Weight (DRY) (Md), lb/lb-mole 

Md = (0.44 x % CO )+(0.32 x % O )+(0.28 (100 -% CO -% O )) 2 2 2 2

Molecular Weight (WET) (Ms), lb/lb-mole 

Ms = Md (1- Bws) +18 (Bws) where, Md = molecular weight (DRY), lb/lb-mole 

 Bws = moisture fraction, dimensionless 

Average Velocity (Vs), ft/sec 

Ps x Ms

Ts x Cp x Delta P avg. x ( R)(in.H O)(lb/lb - mole)(in.Hg)

sec

ft Vs=85.49

2 °

 where, Cp = pitot tube coefficient 

 Delta P = velocity head of stack gas, in. H2O 

 Ts = absolute stack temperature, o

R 

 Ps = absolute stack gas pressure, in. Hg 

 Ms = molecular weight of stack gas, lb/lb-mole 

Average Stack Gas Flow at Stack Conditions (Qa), acfm 

Qa = 60 sec/min x Vs x As where, Vs = stack gas velocity, ft/sec 

 As = cross-sectional area of stack, ft2
 APPENDIX A 

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Average Stack Gas Flow at Standard Conditions (Qs), dscfm 

Ts

Ps x Qa x (1- Bws) x in. HgR Qs 17.64 ° =

 where, Qa = average stack gas flow at stack conditions, ft3

/min 

 Bws = moisture content (dimensionless) 

 Ps = absolute stack gas pressure, in. Hg 

 Ts = absolute stack temperature, o

R 

Percent Isokinetic Sampling Rate (%I) 

Ps x Vs x An x x (1- Bws)

0.0945 (in.Hg)(min)/( R)(sec) x Ts x Vmstd % I = Θ

°

 where, Ts = avg. stack temperature, o

R 

 Vmstd = standard meter volume, dscf 

 Ps = absolute stack gas pressure, in. Hg 

 Vs = stack gas velocity, ft/sec 

 An = cross-sectional area of nozzle, ft2

 Θ = total sampling time, min 

 Bws = moisture content (dimensionless) 

HCl Concentration (conc.), ppm (μL/L) 

 x sample vol.(L)

g - mole

g mol. wt

g - mole

L mass g x 24.04

conc. = 

μ

μ

μ

μ μ

Emission Rate (EMR), lb/MMBtu (O2 F-Factor) 

% O2 20.9 -

20.9 x MMBtu

dscf

x MW x F factor,

ppm

lb/scfM EMR = conc. dry x 2.59 E -09

 where, HCl conc. dry = measured HCl conc., dry ppm 

 F factor = defined by client or CFR, scf/MMBtu 

 Bws = moisture fraction, dimensionless 

 M = molecular weight of HCl (36.47 lb/lb-mole) 
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APPENDIX B 

TEST METHODOLOGY

B.1 VOLUMETRIC FLOW RATE

B.2 GAS COMPOSITION

B.3 HCl, HF, AND HCN (M26A/CTM033) 
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B.1 VOLUMETRIC FLOW RATE

Mass emission rates are calculated by multiplying measured target analyte concentrations by 

calculated volumetric flow rates. Volumetric flow rates are calculated using measurement data 

obtained by EPA Reference Methods 1-4. 

The ductwork is measured at the sample location to the nearest 0.25 inch using a steel tape measure. 

Traverse points are selected in accordance with EPA Reference Method 1 on the basis of ductwork 

dimensions, geometry, and upstream and downstream disturbances. When a sample location does 

not meet EPA Reference Method 1 criteria, the maximum recommended number of traverse points 

is used. 

Gas Velocity

The velocity of the gas stream is measured in accordance with EPA Reference Method 2 by reading 

the instantaneous velocity pressure with an inclined manometer at each traverse point using an “S” 

type pitot tube. The stack pressure was calculated from the measured static pressure of the stack 

and the ambient barometric pressure. The static pressure was measured by using the static side of 

the pitot tube, and the barometric pressure was measured using a calibrated aneroid barometer. An 

inclined manometer with a scale of 0 to 10 inches of water was used for velocity pressure 

measurements. 

Moisture Content

The moisture content of the gas stream is determined using one of the following procedures: 

• For sources requiring testing by EPA Reference or Test Methods 5, 8, 12, 13, 17, 23, 26A, 

29, 0010, or 0011, moisture is determined by EPA Reference Method 4. At the conclusion 

of each run the volume of condensed moisture in the impingers of the sampling train is 

measured and used to calculate the moisture content of the gas stream. 

• For sources with temperatures greater than 212 °F, the approximation technique described 

in EPA Reference Method 4 may be used with midget impingers to condense moisture 

before dry gas volume measurement. 

• For sources with a temperature of less than 212 °F, wet bulb/dry bulb temperature 

measurements may be made, and the moisture content calculated using vapor pressure 

tables. 

When multiple methods are used for moisture determinations, the lowest moisture value is used for 

volumetric flow calculations. 
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The molecular weight of the gas stream is calculated using the measured moisture, oxygen, and 

carbon dioxide concentrations. The balance of the gas stream is assumed to be nitrogen. The 

volumetric flow is then calculated at stack and standard conditions using the calculated molecular 

weight, the measured stack temperature, and measured velocity, stack and barometric pressures. 

Standard conditions are 68 °F and 29.92 inches of mercury and 0% moisture. 

Data Acquisition and Reporting

Data are recorded at the time of collection on preprinted data sheets. Calculations are performed 

(where possible) with preprogrammed calculators or spreadsheet software. 

Quality Control

Quality control procedures for volumetric flow measurements involve leak checks of pitot tubes, 

pitot tube lines and manometers and periodic calibration checks of thermocouples and pyrometers. 

Data transfers are minimized. Data sheets are checked for completeness and accuracy. 

Calculations are verified by a second person. 
 APPENDIX B 

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B.2 GAS COMPOSITION (INSTRUMENTAL) 

Oxygen (O2) and carbon dioxide (CO2) were collected in integrated bags and analyzed in 

accordance with EPA Reference Method 3A. 

Sampling Equipment and Procedures

Figure B-1 illustrates the sampling system. The sample is withdrawn continuously from the source 

through a heated probe, filter, and sample line to a sample conditioner which removes moisture from 

the gas stream. The sample is then transported to an O2 analyzer and a CO2 analyzer. 

Sample Analysis

The O2 analyzer uses an electrochemical cell or paramagnetic detector and the CO2 analyzer uses a 

non-dispersive infra-red (NDIR) detector to produce an electrical signal which is linearly proportional 

to the O2 and CO2 concentration, respectively. 

Data Acquisition and Reduction

Data is acquired electronically using a computer and software designed by WESTON for EPA 

Reference Method 3A analysis. This system generates a calibration curve, converts electronic signals 

into concentrations, and provides one-minute averages during the sample run and an average 

concentration over the duration of the sample run. 

Quality Control

At the time of analysis, O2 and CO2 in nitrogen calibration gases certified according to EPA Protocol-1, 

are used to calibrate the analyzer and to determine a bias correction factor for the entire system bias in 

accordance with EPA Reference Method 3A. The calibration gases are introduced directly to the 

analyzer to generate the calibration curve. A zero gas and an upscale calibration gas is introduced at 

the probe and recovered through the sampling and analytical system. A bias correction factor is 

calculated using the ratio of the concentration measured from the sampling system and concentration 

measured directly at the analyzer. Sample run averages are corrected for system bias results. 
 APPENDIX B 

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Figure B-1 Continuous Emission Monitoring System 
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B.3 EPA METHOD 26A/CTM-033 SAMPLING TRAIN (HCl, HF, HCN) 

Hydrogen Fluoride (HF), hydrogen chloride (HCl) and hydrogen cyanide emissions testing was 

performed isokinetically utilizing a sampling train that combines EPA Reference Method 26A and 

EPA Conditional Test Method 033 (CTM-033 Modified). 

A borosilicate glass nozzle was attached directly to a heated borosilicate glass probe of appropriate 

length. The probe was connected to a heated borosilicate glass filter holder with a Teflon filter support 

containing a 9-cm quartz fiber filter. The filter holder was connected to the first of seven impingers. 

During the effort the first impinger contained 50 mL of 0.1N sulfuric acid (H2SO4). The second and 

third impingers each contained 100 mL of 0.1N H2SO4. The fourth, fifth and sixth impingers each 

contained 100 mL of 6N NaOH. The seventh impinger contained 300 grams of dry pre-weighed silica 

gel. The second and third impingers were standard Greenburg-Smith impingers. All other impingers 

were modified design. All impingers were maintained in a crushed ice bath. A gas measuring control 

console with a leak-free vacuum pump, a calibrated dry gas meter, a calibrated orifice, and inclined 

manometers was connected to the final impinger, probe, heated filter holder, and pitot tube via an 

umbilical cord to complete the train. Figure B-2 presents a schematic of the sampling train. 

Flue gas velocity was measured with a calibrated S-type pitot tube fastened alongside the sampling 

nozzle. Flue gas temperatures were monitored with a calibrated direct readout digital thermometer 

equipped with a chromel-alumel (Type K) thermocouple positioned near the sampling nozzle. The 

probe, filter box, and impinger exit gas temperatures were monitored with a calibrated direct readout 

digital thermometer equipped with type K thermocouples positioned in the probe, heated filter box and 

in the gas stream after the last impinger. 
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6

Figure B-2 EPA Reference Method 26A/CTM-033 HCl, HF, and HCN Sampling Train