ATALYST

Am Management, Inc.

SALT RIVER PROJECT

NAVAJO GENERATING STATION

UNITS 1,2

ACID MIST EMISSIONS TEST REPORT

CATALYST AIR MANAGEMENT, INC.

REPORT NUMBER 264-001

DECEMBER 31,2009

Test Date: November 16-17, 2009

Prepared for

Mr. L. Dee Shakespear

Salt River Project

Navajo Generating Station

State Highway 98

Page, AZ 86040
ATALYST

Am Management, Inc.

STATEMENT OF VALIDITY

Salt River Project Navajo Generating Station

Catalyst Report 264-001

December 31,2009

To the extent practical, information and data provided in this test report has been verified as true

and correct.

Michae^WTTaylor

President Catalyst Air Management, Inc.

2505 Byington-Solway Road

Knoxville, TN 37931

(865)531-0075
^•""N TABLE OF CONTENTS

LETTER OF TRANSMITTAL

TITLE PAGE

STATEMENT OF VALIDITY

TABLE OF CONTENTS

PROJECT FACT SHEET

1-4

5-6

9-24

25-40

41-56

57

57-63

64-70

71-77

78

78-86

87-92

93-95

96

98-101

102-104

105-110

111-114

Introduction

Summary of Test Results

Results of Testing

Description of Combustion Unit

Sampling Program Procedures

Operating Conditions

Quality Assurance

Discussion

APPENDICES

Reference Method Test Results

Unitl

Unit

Unit

Plant Data

Unitl

Unit

Unit

Laboratory Analysis

Acid Mist Barium Chloride Titration

Aid Mist Ion Chromatography

Coal

Reference Method Quality Assurance

Isokinetic Sampling Equipment

Calibration Gas Specification Sheets

Sample Calculations

Figures
NAME OF SOURCE OWNER:

SOURCE IDENTIFICATION:

LOCATION OF SOURCE:

TYPE OF OPERATION:

TYPES OF TESTS PERFORMED:

TEST COMPANY:

LABORATORY ANALYSIS:

SITE SUPERVISOR:

TEST PERSONNEL:

TEST DATES:

OWNER'S REPRESENTATIVE:

TEST OBSERVER:

PROJECT FACT SHEET

Salt River Project

Navajo Generating Station

Units 1,2

Highway 98

Page, AZ 86040

Coal Fired Steam Generating Unit

Sample Traverse-EPA Method

Volumetric Flow Rate-EPA Method

Oxygen/Carbon Dioxide-EPA Method

Moisture Content-EPA Method

Sulfuric Acid Mist-NCASI Method 8A

Catalyst Air Management, Inc.

2505 Byington-Solway Road

Knoxville, TN 37931

Maxxam Analytics, Inc.

5555 North Service Road

Burlington, Ontario L7L 5H7

Mike Challis Project Manager

Rick Derrera Lead Technician

William Sapp Scientist

Frank Mo Chemist

November 16-17,2009

L. Dee Shakespear

111
1-0 Introduction

Catalyst Air Management, Inc. (Catalyst) was contracted by the Salt River Project (SRP) to

perform source emission testing at Navajo Generating Station Units 1, 2 and 3 to

determine the sulfuric acid mist emissions from the units.

The sampling program was conducted November 16 and 17, 2009. The testing was

performed by Messrs. Rick Derrera and William Sapp of Catalyst and Mr. Frank Mo of

Maxxam, with the assistance of personnel assigned by SRP. Mr. L. Dee Shakespear of SRP

coordinated plant operation during the testing.

2.0 Summary of Test Results

summary of test results developed by this source-sampling program is presented in Tables

through 4. The summary tables are presented as follows:

Table

3.0 Results of Testing

Description

Summary of Acid Mist Emissions

Acid Mist Sampling Summary - Unit

Acid Mist Sampling Summary Unit

Acid Mist Sampling Summary Unit

The individual test run results are shown in Tables through and tabulated in Appendices

through 3.

TABLE

Summary of Acid Mist Emissions

Unit Concentration

(gr/dscf)

4.22E-05

7.71E-05

8.10E-06

Emission Rate

Gb/mmBtu)

9.43E-05

1.64E-04

1.75E-05

Emission Rate

(lb/hr)

0.51

1.31

0.13

The results were calculated using the Ion Chromatography laboratory values. The Barium

Chloride titration values that were performed on site were not used because the values were

less than the reportable detection limit (RDL) for the analytical method. The titration

method analysis are shown in the lab analysis appendix.
TABLE

ACID MIST SAMPLING SUMMARY

Client: Salt River Project

Plant: Navajo Unit

Location: Stack

Run Number:

Date:

Load (MW):

Run Time: Start

End

Pbar Barometric Pressure:

TT Sampling Time:

VM Meter Volume:

TM Avg. Meter Temp (F):

PM Avg. Delta (in. of H2O):

Meter Calibration Factor:

VMSTD Std. Gas Volume (SCF):

Vic Volume Water Collected:

%M Percent Moisture:

Bws Mole Fraction, Dry:

%CO2 Carbon Dioxide, Dry:

%O2 Oxygen, Dry:

MD Dry Molecular Weight:

MS Wet Molecular Weight:

PS Static Press, (in. of Hg):

TS Stack Temp. (F):

CP Pitot Coefficient:

VS Stack Gas Velocity (AFPS):

QS Stack Gas Volume (DSCFM):

QA Stack Gas Volume (ACFM):

SO3

ppm Emission Concentration:

gr/dscf Emission Concentration:

Ib/mmbtu Emission Rate:

Ib/hr Emission Rate:

EPA Method 8A

11/16/09

599

13:22

14:22

25.40

60.0

32.041

50

0.75

0.99

27.933

104

14.92

0.149

11.4

7.9

30.14

28.33

25.44

120

0.84

39.7

1,488,714

2,261,834

0.03

3.87E-05

8.69E-05

0.49

11/16/09

500

15:08

16:08

25.40

60.0

32.721

53

0.75

0.99

28.382

101

14.35

0.144

11.5

7.8

30.15

28.41

25.44

120

0.84

35.6

1,342,170

2,025,736

0.03

4.57E-05

1.02E-04

0.53

11/16/09

499

16:35

17:35

25.40

60.0

33.024

57

0.75

0.99

28.418

100

14.22

0.142

11.5

7.8

30.15

28.42

25.44

120

0.84

35.2

1,330,192

2,004,439

0.03

3.80E-05

8.47E-05

0.43

Average ppm 0.03

Average gr/dscf 4.22E-05

Average lb/mmBtu 9.43E-05

Average lb/hr 0.51
TABLE

ACID MIST SAMPLING SUMMARY

Client: Salt River Project

Plant: Navajo Unit

Location: Stack

Run Number:

Date:

Load (MW):

Run Time: Start

End

Pbar Barometric Pressure:

TT Sampling Time:

VM Meter Volume:

TM Avg. Meter Temp (F):

PM Avg. Delta (in. of H2O):

Meter Calibration Factor:

VMSTD Std. Gas Volume (SCF):

Vic Volume Water Collected:

%M Percent Moisture:

Bws Mole Fraction, Dry:

%CO2 Carbon Dioxide, Dry:

%O2 Oxygen, Dry:

MD Dry Molecular Weight:

MS Wet Molecular Weight:

PS Static Press, (in. of Hg):

TS Stack Temp. (F):

CP Pitot Coefficient:

VS Stack Gas Velocity (AFPS):

QS Stack Gas Volume (DSCFM):

QA Stack Gas Volume (ACFM):

SO3

ppm Emission Concentration:

gr/dscf Emission Concentration:

lb/mmbtu Emission Rate:

lb/hr Emission Rate:

EPA Method 8A

11/17/09

731

8:09

9:09

25.51

60.0

40.989

55

1.30

0.99

35.579

99

11.59

0.116

12.2

7.1

30.24

28.82

25.62

120

0.84

50.8

1,989,956

2,888,601

0.07

1.08E-04

2.29E-04

1.85

11/17/09

735

9:45

10:45

25.51

60.0

42.527

53

1.30

0.99

37.051

122

13.43

0.134

11.8

7.4

30.18

28.55

25.62

120

0.84

50.8

1,950,928

2,893,044

0.03

4.58E-05

9.91E-05

0.77

11/17/09

743

11:12

12:12

25.51

60.0

41.993

55

1.30

0.99

36.497

117

13.12

0.131

12.0

7.2

30.21

28.61

25.62

121

0.84

51.3

1,973,459

2,920,469

0.03

4.23E-05

9.01E-05

0.72

Average ppm 0.05

Average gr/dscf 7.71E-05

Average ib/mmBtu 1.64E-04

Average lb/hr 1.31
TABLE

ACID MIST SAMPLING SUMMARY

EPA Method 8A

Client: Salt River Proj ect

Plant: Navajo Unit

Location: Stack

Run Number:

Date:

Load (MW):

Run Time: Start

End

Pbar Barometric Pressure:

TT Sampling Time:

VM Meter Volume:

TM Avg. Meter Temp (F):

PM Avg. Delta (in. of H2O):

Meter Calibration Factor:

VMSTD Std. Gas Volume (SCF):

Vic Volume Water Collected:

%M Percent Moisture:

Bws Mole Fraction, Dry:

%CO2 Carbon Dioxide, Dry:

%O2 Oxygen, Dry:

MD Dry Molecular Weight:

MS Wet Molecular Weight:

PS Static Press, (in. of Hg):

TS Stack Temp. (F):

CP Pitot Coefficient:

VS Stack Gas Velocity (AFPS):

QS Stack Gas Volume (DSCFM):

QA Stack Gas Volume (ACFM):

SO3

ppm Emission Concentration:

gr/dscf Emission Concentration:

lb/mmbtu Emission Rate:

lb/hr Emission Rate:

11/17/09

725

14:08

15:08

25.51

60.0

42.481

54

1.30

0.99

36.939

125

13.75

0.137

11.9

7.4

30.20

28.52

25.63

121

0.84

50.3

1,921,794

2,862,082

0.01

8.77E-06

1.90E-05

0.14

11/17/09

723

15:37

16:37

25.51

60.0

43.090

56

1.30

0.99

37.366

120

13.14

0.131

11.8

7.4

30.18

28.58

25.63

120

0.84

50.8

1,958,286

2,893,505

0.01

7.43E-06

1.61E-05

0.12

11/17/09

718

16:57

17:57

25.51

60.0

43.046

53

1.30

0.99

37.552

124

13.46

0.135

11.9

7.3

30.20

28.55

25.63

120

0.84

50.5

1,937,727

2,871,881

0.01

7.40E-06

1.59E-05

0.12

Average ppm 0.01

Average gr/dscf 8.10E-06

Average lb/mmBtu 1.75E-05

Average lb/hr 0.13
4-° Description of Comhustion Units

Navajo Generating Station (NGS) is located on the Navajo Reservation, miles east of

Page, Arizona, off U.S. Highway 98. NGS has three 750 MW (net) coal fired units with hot side electrostatic precipitators and wet limestone scrubbers.

5.0 Sampling Program Procedures

The following test methods were utilized during the test program:

EPA Method Sample and Velocity Traverse for Stationary Sources

EPA Method Determination of Stack Gas Velocity and Volumetric Flow Rate

EPA Method 3A Gas Analysis for CO2, O2, Excess Air and Dry Molecular Weight

(Instrumental Analyzer Method)

EPA Method Determination of Moisture Content in Stack Gas

NCASI Method 8A Determination of Sulfuric Acid Vapor or Mist and Sulfur Dioxide

Emissions from Stationary Sources from Kraft Recovery Furnaces

The sampling was conducted in vertical section at the 50(T level of each 775^ stack

The Hastelloy lined, 34.75^ diameter stacks are enclosed in concrete shell with an 8:

annular space. There are four (4), six inch test ports orientated 90 degrees apart in the

same horizontal plane. Test runs were conducted in triplicate for all parameters with

each bemg minimum of 60 minutes in duration. The sampling procedures quality

assurance, analysis and calculations utilized for the program were performed in

accordance with the test protocol submitted and approved and the Code of Federal

Regulations, Title 40, Part 60, Appendix A.

The flow traverses were performed at three (3) traverse points for each port, 12 total

pomts. The acid mist sampling was performed single point for 90 minutes.

5.1 Sulfuric Acid Mist NCASI Method 8A

Acid Mist emissions were determined in accordance with EPA Method 8A procedures

gas sample was extracted at constant flow rate from the flue gas and the sulfuric acid

mist, including SO3> was separated and measured by barium-thorin titration. The sulfuric

acid mist fraction of the train was the only portion analyzed. The probe and filter were

maintained at 500 °F. The condenser coil was maintained between 167 and 185 °F. The

sampling train consists of the following equipment connected in series:

Quartz nozzle and heated quartz lined probe

Heated quartz filter holder with quartz filter

modified Grahm condenser with Type glass frit and 200 cm of 5-mm ID glass

Greenburg-Smith impinger containing 100 ml of 3% hydrogen peroxide solution

modified Greenburg-Smith impinger containing 100 ml of 3% hydrogen peroxide

Greenburg-Smith impinger containing 100 ml of DIH2O

modified Greenburg-Smith impinger containing 250g of silica gel
QThesample volume was measured by passing it through calibrated dry gas meter An Stype pitot tube was attached to the probe to measure stack gas velocity and to maintain

isokinetic sampling. K-type thermocouple was attached to the probe to measure the gas temperature.

After the run, the probe was disconnected from the sample train. The remaining portion was purged for 15 minutes at the average sampling rate of the run.

The probe, filter holder and condenser were triple rinsed with deionized and the washings

were retained for SO3/H2SO4 analysis. The peroxide and deionized H2O impingers'

contents were recovered and the impingers and connecting glassware were rinsed with

distilled water and were retained, however SO2 analysis was not performed Each sample

was analyzed by barium thorin titration to determine SO3/H2SO4 concentrations.

5.2 Stack Gas Velocity and Volumetric Flow Rate

An EPA Method stack gas velocity traverse was performed with each acid mist test run

to determine the velocity and volumetric flow rate as specified in the test protocol The

data was used for the calculation of acid mist test results in units of pound per hour (lb/hr).

5.3 O2 and CO2 EPA Method

The O2 and CO2 concentrations were determined simultaneously with each of the test

runs. sample was continuously extracted and introduced into Telgan O2/CO2

analyzer for determination of gas concentrations. The sample was extracted through

heated stainless steel probe, heated sample line and sample conditioner to dry the sample

before it enters the analyzers. sample flow control system was used to control the flow

mto the analyzers. The analyzers were calibrated prior to starting the testing with EPA

Protocol 1, calibration gases. system bias check was performed before each run by

introducing the zero and upscale gas at the back end of the sample probe. The system

bias check was repeated at the end of each test run to determine the analyzer zero and calibration drift.

The O2/CO2 analyzer spans were 0-23% and 0-18%, respectively. The O2 calibration

gases utilized were 12.03% and 22.72%. The CO2 calibration gases were 9.97% and

17.73%. The high calibration gas determined the span and was the basis for the mid gas,

as well as bias and drift calculations.

All the sampling procedures, quality assurance, analysis and calculations utilized for the

program were performed in accordance with the Code of Federal Regulations, Title 40, Part 60, Appendix A.
6.0 Operating Conditions

SRP personnel monitored operating conditions throughout the duration of the sampling

program. The units were operating under normal conditions as follows:

UNIT Gross MW

564

813

806

DATE

11/16/09

11/17/09

11/17/09

7.0 Quality Assurance Procedures

The quality assurance procedures utilized during the testing activities followed guidelines

set forth by the previously mentioned methods and the EPA Qualitj' Assurance Handbook

for Source Sampling. The specific procedures for this test program are listed below.

7.1 Sampling Equipment

The S-type pitot tubes were visually inspected and measured to meet the design

specifications of EPA Method for 0.84 pitot coefficient.

Both legs of the pitot tube were leak checked before and after each sample run.

The stack thermocouples were calibrated prior to the testing and post-test check was

performed after the testing project.

The manometer was leveled and zeroed before each sample run.

The dry gas meter is fully calibrated annually using an EPA intermediate standard. Post -test

dry gas meter checks were completed to verily the accuracy of the meter Yi.

Pre-test and post-test leak checks were completed and were less than 0.02 cfm at the highest

sampling vacuum.

7.2 Instrumental Methods

Analyzer calibrations, system bias check and drift checks were completed before and after

each sample run utilizing EPA Protocol calibration gases.

The analyzer interference responses were determined in accordance with Section 8.2.7 of

Method 7E and Section 16 of Method 6C.

7.3 Data and Calculations

manual calculation check is performed on single run for each parameter.
8.0 Discussion

8.1 Chain of Custody

The samples were analyzed by the Barium Chloride lilration method on site in the plant

laboratory. The field samples were then scaled and transported to the Catalyst facility in

Knoxville, TN and shipped to the Maxxam Analytics laboratory in Burlington, Ontario,

Canada under the supervision of Rick Derrera. The samples were labeled to identify the

following:

Client and source

Date

Type of Sample

Run number

Sample location

Sample fraction

8.2 Sampling Conditions and Concerns

There were no interruptions or delays during the testing.