# Imagine the result

Surrogacy Testing in the MPCRF

Final Report
May 2, 2011

### Surrogacy Testing in the MPCRF Draft Final Report

Carl F. Singer Associate Project Manager 2

Prepared for: U.S. EPA NRMRL/APPCD Research Triangle Park, NC 27711

Prepared by: ARCADIS 4915 Prospectus Drive Suite F Durham North Carolina 27713 Tel 919.544.4535 Fax 919.544.5690

Our Ref.: RN990271.0050

Date: March 30, 2011

This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this document is strictly prohibited.i 

### Table of Contents

List of Tables iv
List of Figures vii List of Acronyms/Units ix

1. Introduction 1
1.1 Background and Program Objectives 1 1.2 Multipollutant Control Research Facility 1 1.2.1 Furnace 2
1.2.2 Selective Catalytic Reduction 3
1.2.3 Electrostatic Precipitator 3
1.2.4 Baghouse Fabric Filter 4
1.2.5 Wet Lime Flue Gas Desulfurization 4
1.3 Testing Program 5


### 2. Methods and Materials 7

3. Daily Run Summary 16
3.1 MPCRF Run February 16, 2010 16 3.1.1 Metals – February 16, 2010 18
3.1.2 SVOCs – February 16, 2010 20
3.1.3 Carbonyls – February 16, 2010 23
3.1.4 VOCs – February 16, 2010 23
3.1.5 Methane – February 16, 2010 23
3.2 MPCRF Run February 23, 2010 25 3.2.1 Metals – February 23, 2010 27
3.2.2 SVOCs – February 23, 2010 29
3.2.3 Carbonyls – February 23, 2010 29
3.2.4 VOCs – February 23, 2010 29
3.2.5 Methane – February 23, 2010 29ii 

### Table of Contents

3.3 MPCRF Run April 7, 2010 33 3.3.1 Halides – April 7, 2010 34
3.4 MPCRF Run April 21, 2010 36 3.4.1 Metals – April 21, 2010 37
3.4.2 SVOC – April 21, 2010 39
3.4.3 Carbonyls – April 21, 2010 40
3.4.4 VOCs – April 21, 2010 41
3.4.5 Methane – April 21, 2010 42
3.5 MPCRF Run April 28, 2010 42 3.5.1 Metals – April 28, 2010 43
3.5.2 SVOC – April 28, 2010 45
3.5.3 Carbonyls – April 28, 2010 46
3.5.4 VOCs – April 28, 2010 47
3.5.5 Methane – April 28, 2010 48
3.6 MPCRF Run May 20, 2010 48 3.6.1 Metals – May 20, 2010 50
3.6.2 SVOCs – May 20, 2010 52
3.6.3 Carbonyls – May 20, 2010 54
3.6.4 VOCs – May 20, 2010 54
3.6.5 VOCs – May 20, 2010 54
3.7 MPCRF Run May 25, 2010 55 3.7.1 Metals – May 25, 2010 57
3.7.2 SVOCs – May 25, 2010 59
3.7.3 Carbonyls – May 25, 2010 61
3.7.4 VOCs – May 25, 2010 61
3.7.5 VOCs – May 25, 2010 61
3.8 MPCRF Run June 2, 2010 62 3.8.1 Metals – June 2, 2010 64
3.8.2 SVOCs – June 2, 2010 66iii 

### Table of Contents

3.8.3 Carbonyls – June 2, 2010 68
3.8.4 VOCs – June 2, 2010 68
3.8.5 Methane – June 2, 2010 68
3.9 MPCRF Run June 16, 2010 70 3.9.1 Halides – June 16, 2010 71
3.10 MPCRF Run July 21, 2010 72 3.10.1 Metals – July 21, 2010 74
3.10.2 SVOCs – July 21, 2010 76
3.10.3 Carbonyls – July 21, 2010 78
3.10.4 VOCs – July 21, 2010 78
3.10.5 Methane – July 21, 2010 78
3.11 MPCRF Run July 28, 2010 80 3.11.1 Metals – July 28, 2010 81
3.11.2 SVOCs – July 28, 2010 81
3.11.3 Carbonyls – July 28, 2010 85
3.11.4 VOCs – July 28, 2010 85
3.11.5 Methane – July 28, 2010 85



### 4. Method Summary Results 87
4.1 Non-mercury Metal HAPs 87 4.2 Halides 93 4.3 SVOCs 93 4.4 Carbonyls 97 4.5 VOCs 100 4.6 Methane 107


### 5. Conclusions and Recommendations 109 Appendix A: Quality Control Evaluation 111
A.1 Method 2C Velocity 111 A.2 Method 3A Oxygen and Carbon Dioxide Quality Control 111iv 

### Table of Contents

A.3 Method 5 Particulate Quality Control 115 A.4 Method 6C Sulfur Dioxide Quality Control 116 A.5 Method 7E Nitrogen Oxides Quality Control 118 A.6 Method 10 Carbon Monoxide Quality Control 120 A.7 Method 25A Total Organic Carbon Quality Control 122 A.8 Method 5/29 Metals Quality Control 124 A.9 Method 26A Halides Quality Control 125 A.10 Method 0010 Semi-Volatile Organic Compounds 125 A.11 Method 0011 Carbonyls 127 A.12 Method 0031 Volatile Organic Compounds 128 A.13 Method 0040 Methane 129



### List of Tables
Table 1-1. Summary of MPCRF Surrogacy Test Conditi ons 5 Table 2-1. Fuel Analysis on As-fired Basis 11 Table 3-1. CEM Summary for February 16, 2010 18 Table 3-2. Metals Summary for February 16, 2010 19 Table 3-3. M0010 Full-Scan Emission Summary for Fe bruary 16, 2010 21 Table 3-4. M0010 SIM Emission Summary for February 16, 2010 22 Table 3-5. M0011 Carbonyl Emission Summary for Feb ruary 16, 2010 23 Table 3-6. VOCs Summary for February 16, 2010 24 Table 3-7. CEM Summary for February 23, 2010 26 Table 3-8. Metals Summary for February 23, 2010 28 Table 3-9. M0010 Full-Scan Emission Summary for Fe bruary 23, 2010 30 Table 3-10. M0010 SIM Emission Summary for Februar y 23, 2010 31 Table 3-11. M0011 Carbonyl Emission Summary for Fe bruary 23, 2010 31 Table 3-12. VOCs Summary for February 23, 2010 32 Table 3-13. CEM Summary for April 7, 2010 34 Table 3-14. Halide HAP Summary for April 7, 2010 3 5 Table 3-15. CEM Summary for April 21, 2010 37 Table 3-16. Metals Summary for April 21, 2010 38 Table 3-17. M0010 Full-Scan Emission Summary for A pril 21, 2010 39v 

### Table of Contents

Table 3-18. M0010 SIM Emission Summary for April 2 1, 2010 40 Table 3-19. M0011 Carbonyl Emission Summary for Ap ril 21, 2010 41 Table 3-20. VOCs Summary for April 21, 2010 41 Table 3-21. CEM Summary for April 28, 2010 43 Table 3-22. Metals Summary for April 28, 2010 44 Table 3-23. M0010 Full-Scan Emission Summary for A pril 28, 2010 45 Table 3-24. M0010 SIM Emission Summary for April 2 8, 2010 46 Table 3-25. M0011 Carbonyl Emission Summary for Ap ril 28, 2010 47 Table 3-26. VOCs Summary for April 28, 2010 47 Table 3-27. CEM Summary for May 20, 2010 50 Table 3-28. Metals Summary for May 20, 2010 51 Table 3-29. M0010 Full-Scan Emission Summary for M ay 20, 2010 52 Table 3-30. M0010 SIM Emission Summary for May 20, 2010 53 Table 3-31. M0011 Carbonyl Emission Summary for Ma y 20, 2010 54 Table 3-32. VOCs Summary for May 20, 2010 55 Table 3-33. CEM Summary for May 25, 2010 57 Table 3-34. Metals Summary for May 25, 2010 58 Table 3-35. M0010 Full-Scan Emission Summary for M ay 25, 2010 59 Table 3-36. M0010 SIM Emission Summary for May 25, 2010 60 Table 3-37. M0011 Carbonyl Emission Summary for Ma y 25, 2010 61 Table 3-38. VOCs Summary for May 25, 2010 62 Table 3-39. CEM Summary for June 2, 2010 64 Table 3-40. Metals Summary for June 2, 2010 65 Table 3-41. M0010 Full-Scan Emission Summary for J une 2, 2010 66 Table 3-42. M0010 SIM Emission Summary for June 2, 2010 67 Table 3-43. M0011 Carbonyl Emission Summary for Ju ne 2, 2010 68 Table 3-44. VOCs Summary for June 2, 2010 69 Table 3-45. CEM Summary for June 16, 2010 71 Table 3-46. Halide HAP Summary for June 16, 2010 7 2 Table 3-47. CEM Summary for July 21, 2010 74 Table 3-48. Metals Summary for July 21, 2010 75 Table 3-49. M0010 Full-Scan Emission Summary for J uly 21, 2010 76 Table 3-50. M0010 SIM Emission Summary for July 21 , 2010 77 Table 3-51. M0011 Carbonyl Emission Summary for Ju ly 21, 2010 78vi 

### Table of Contents

Table 3-52. VOCs Summary for July 21, 2010 79 Table 3-53. CEM Summary for July 28, 2010 81 Table 3-54. Metals Summary for July 28, 2010 82 Table 3-55. M0010 Full-Scan Emission Summary for J uly 28, 2010 83 Table 3-56. M0010 SIM Emission Summary for July 28 , 2010 84 Table 3-57. M0011 Carbonyl Emission Summary for Ju ly 28, 2010 85 Table 3-58. VOCs Summary for July 28, 2010 86 Table A-1. Flow Measurements for Qualification of Steady-State Operation 112 Table A-2. Oxygen CEM Calibration Error 112 Table A-3. Oxygen CEM System Bias 113 Table A-4. Oxygen CEM Drift 113 Table A-5. Carbon Dioxide CEM Calibration Error 11 4 Table A-6. Carbon Dioxide CEM System Bias 114 Table A-7. Carbon Dioxide CEM Drift 115 Table A-8. SO 2 CEM Calibration Error 117 Table A-9. SO 2 CEM System Bias 117 Table A-10. SO 2 CEM Drift 118 Table A-11. NO X

CEM System Bias 119 Table A-12. NO X

CEM Drift 119 Table A-13. Carbon Monoxide CEM Calibration Error 120 Table A-14. Carbon Monoxide CEM System Bias 121 Table A-15. Carbon Monoxide CEM Drift 121 Table A-16. TOC Calibration Error at PM Inlet 122 Table A-17. TOC Calibration Error at PM Inlet 123 Table A-18. TOC Calibration Drift at PM Inlet 123 Table A-19. M0031 Surrogate Recovery Summary for F ebruary16, 2010, and

February 23, 2010 128 Table A-20. M0031 Surrogate Recovery Summary for A pril 11, 2010, and April

28, 2010 129 Table A-21. M0031 Surrogate Recovery Summary for M ay 25, 2010, through

July 28, 2010. 129vii 

### Table of Contents

List of Figures
Figure 1-1. Overhead View of the Multipollutant Co ntrol Research Facility 2 Figure 2-1. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using Eastern Bituminous Coal 7 Figure 2-2. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using PRB Sub-bituminous Coal 8 Figure 2-3. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using Gulf Coast Lignite 9 Figure 2-4. Method 5/29 Sampling Train 12 Figure 3-1. PM Control Device Inlet Diluent and CO Summary for February 16, 2010 17 Figure 3-2. PM Control Device Inlet Diluent and CO Summary for February 23, 2010 26 Figure 3-3. PM Control Device Inlet Diluent and CO Summary for April 7, 2010 33 Figure 3-4. PM Control Device Inlet Diluent and CO Summary for April 21, 2010 36 Figure 3-5. PM Control Device Inlet Diluent and CO Summary for April 28, 2010 42 Figure 3-6. PM Control Device Inlet Diluent and CO Summary for May 20, 2010 48 Figure 3-7. PM Control Device Inlet Diluent and CO Summary for May 25, 2010 56 Figure 3-8. PM Control Device Inlet Diluent and CO Summary for June 2, 2010 63 Figure 3-9. PM Control Device Inlet Diluent and CO Summary for June 16, 2010 70 Figure 3-10. PM Control Device Inlet Diluent and C O Summary for July 21, 2010 73 Figure 3-11. PM Control Device Inlet Diluent and C O Summary for July 28, 2010 80 Figure 4-1. Control of PM and Antimony in MPCRF Te sts 87 Figure 4-2. Control of PM and Arsenic in MPCRF Tes ts 88 Figure 4-3. Control of PM and Beryllium in MPCRF T ests 88 Figure 4-4. Control of PM and Cadmium in MPCRF Tes ts 89 Figure 4-5. Control of PM and Chromium in MPCRF Te sts 89 Figure 4-6. Control of PM and Cobalt in MPCRF Test s 90 Figure 4-7. Control of PM and Lead in MPCRF Tests 90 Figure 4-8. Control of PM and Manganese in MPCRF T ests 91 Figure 4-9. Control of PM and Nickel in MPCRF Test s 91 Figure 4-10. Control of PM and Selenium in MPCRF T ests 92 Figure 4-11. Acenaphthylene Concentrations versus CO Concentrations 94 Figure 4-12. Anthracene Concentrations versus CO C oncentrations 95 Figure 4-13. Fluoranthene Concentrations versus CO Concentrations 96viii 

### Table of Contents

Figure 4-14. Pyrene Concentrations Versus CO Conce ntrations 96 Figure 4-15. Benzo(a)anthracene Concentrations Ver sus CO Concentrations 97 Figure 4-16. Phenol Concentrations Versus CO Conce ntrations 97 Figure 4-17. Formaldehyde Concentrations Versus CO Concentrations 98 Figure 4-18. Acetaldehyde Concentrations Versus CO Concentrations 98 Figure 4-19. Propionaldehyde Concentrations Versus CO Concentrations 99 Figure 4-20. Acetophenone Concentrations Versus CO Concentrations 99 Figure 4-21. Bromomethane Concentrations Versus CO Concentrations 101 Figure 4-22. Carbon Disulfide Concentrations Versu s CO Concentrations 101 Figure 4-23. Methylene Chloride Concentrations Ver sus CO Concentrations 102 Figure 4-24. Chloroform Concentrations Versus CO C oncentrations 102 Figure 4-25. Carbon Tetrachloride Concentrations V ersus CO Concentrations 103 Figure 4-26. Benzene Concentrations Versus CO Conc entrations 103 Figure 4-27. Toluene Concentrations Versus CO Conc entrations 104 Figure 4-28. Ethyl Benzene Concentrations Versus C O Concentrations 104 Figure 4-29. o-Xylene Concentrations Versus CO Con centrations 105 Figure 4-30. Styrene Concentrations Versus CO Conc entrations 105 Figure 4-31. Iodomethane Concentrations Versus CO Concentrations 106 Figure 4-32. 1,4-dioxane Concentrations Versus CO Concentrations 106ix 

### Table of Contents

List of Acronyms/Units
lb/TBtu Pounds per Trillion British Thermal Units acfm Actual Cubic Feet per Minute Btu British Thermal Unit CEM Continuous Emission Monitor dscf Dry Standard Cubic Foot dscm Dry Standard Cubic Meter EPA Environmental Protection Agency ESFF Electrostatic Enabled Fabric Filter ESP Electrostatic Precipitator F d F-factor FF Fabric Filter FGD Flue Gas Desulfurization HAP Hazardous Air Pollutant in w.g. Inches of Water Gauge kV Kilovolt M0010 SW-846 Method 0010 M0011 SW-846 Method 0011 M0031 SW-846 Method 0031 M0040 SW-846 Method 0040 MACT Maximum Achievable Control Technology Method 5/29 Combined EPA Method 5 and Method 25 MMBtu Million British Thermal Units MPCRF Multipollutant Control Research Facility MW t Megawatt-thermal OAQPS Office of Air Quality Planning and Standards OAR Office of Air and Radiation ORD Office of Research and Development PAH Polycyclic aromatic hydrocarbons PM Particulate Matter ppmvd Parts Per Million Volume Dry ppmvw Parts Per Million Volume Wet PRB Powder River Basinx 

### Table of Contents

QAPP Quality Assurance Project Plan QAPP Quality Assurance Project Plan QC Quality Control RPD Relative % Difference RTP Research Triangle Park, North Carolina scfm Standard Cubic Feet per Minute SCR Selective Catalytic Reduction SIM Selected Ion Monitoring SR Stoichiometric Ratio SVOC Semi-volatile Organic Compound TGA-LOI Thermogravimetric Analysis / Loss-on-Igniti on TOC Total Organic Carbon VOC Volatile Organic Compound vol%d Volume % Dry μ g Microgram μ m Micrometer1 

### Surrogacy Testing in the MPCRF

Draft Final Report



### 1. Introduction
1.1 Background and Program Objectives 

### The Environmental Protection Agency’s (EPA) Office of Air Quality Planning and Standards (OAQPS) is developing a maximum achievable control technology (MACT) rule to control hazardous air pollutant (HAP ) emissions from coal- and oil-fired electric utility boilers. The MACT rule has the potential to be wi de ranging and cover a number of HAP emissions. Control of so me HAP emissions is expected to coincide with control of other pollutants, such as criteria pollu tants. The use of other pollutants or process cond itions as a surrogate for HAP emissions can simplify both the rule development and the monitoring regime require d under a MACT rule.
In order to evaluate potential surrogacy relationsh ips, the EPA Office of Research and Development (OR D), in collaboration with the Office of Air and Radiati on (OAR), conducted a series of tests in the Agency ’s Multipollutant Control Research Facility (MPCRF), a pilot-scale combustion and control technology rese arch facility located at EPA’s Research Triangle Park, N orth Carolina, (RTP) campus. Eleven independent te sts were performed in the MPCRF in order to examine pot ential surrogacy relationships. Three types of coa l (bituminous, sub-bituminous, and Gulf Coast lignite ) were tested. The particulate matter (PM) control was also varied; in some tests, the electrostatic preci pitator (ESP) was used whereas the fabric filter (F F) was used in others. Three potential surrogacy relation ships were examined during the testing program. Th e potential for use of PM control as a surrogate for the control of the non-Hg metal HAP (Be, As, Cd, Co , Cr, Mn, Ni, Pb, Sb, and Se) was examined. The potentia l for acid gas control to predict the control of ha lide HAPS (HCl, HF, Cl 2 

### ) was studied. In addition, several potential surr ogate relationships were examined for the non-dioxin/furan organic HAP. No surrogate stu dies were conducted for Hg because there are no pla ns to use a surrogacy approach for Hg control. No sur rogacy studies were conducted for dioxin/furan orga nic HAP as it was anticipated that levels of these comp ounds would be very low and the approved sampling methods for dioxin/furan organic HAP require 8-hour sampling periods, which was not practical in the p ilot system.
This report presents the results of the MPCRF test program and examines the behavior of HAP concentrations or control with that of potential su rrogates.
1.2 Multipollutant Control Research Facility


### The MPCRF is a pilot-scale combustion research faci lity located at EPA’s RTP campus. A diagram of the facility with the sampling locations identified is shown in Figure 1-1. The combustor is rated at 4 M MBtu/hr, approximately 1.2 megawatt-thermal (MW t 

### ), and is capable of burning a variety of fuels inc luding pulverized coal of various ranks. The facility consists of a down-fired refractory-lined furnace with low-NO X 

### burner. The flue gas exits the furnace into a duct system t hat is equipped with a number of downstream heat2 

### Surrogacy Testing in the MPCRF

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### exchangers to preheat combustion air, simulate supe rheater outlet conditions, and simulate air heater outlet conditions. The system is equipped with a selectiv e catalytic reduction (SCR) unit with a Cormetech V 2 

### O 4 

### /WO 3 

### catalyst and ammonia injection for NO X 

### control. The flue gas may be routed through the E SP or through the FF to provide PM control. The exhaust of the PM collector passes through a lime-based wet flue gas desulfurization (FGD) scrubber for SO 2 

### control prior to exiting the facility.

Coal Feeder

Heat Exchangers Furnace

Air Pre-heater Wet Lime Scrubber

Heat Exchanger ESP

SCR

Secondary Combustion Air Fabric Filter Wall



### ESP Inlet PM Outlet

(FGD Inlet)

FGD Outlet

FF Inlet

Figure 1-1. Overhead View of the Multipollutant Co ntrol Research Facility

1.2.1 Furnace 

### The furnace consists of a refractory-lined shell wi th a 42-inch bore and a multi-fuel burner in a down -fire orientation. The burner design is based on the mov able-block swirl-adjustment technology developed by the International Flame Research Foundation. The b urner has separate, dedicated injection ports for g as, secondary combustion air, and coal/conveying air (p rimary air). The burner’s central “bluff body” pip e receives either the burner igniter or the oil gun. All fuel feed systems are connected to a single fl ame safety system and can be selected individually or in any c o-firing combination.3 

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### In its current configuration, the MPCRF can support a firing rate between 2.7 and 3.0 MMBtu/hour on co al. Coal is pulverized in an on-site hammer mill separa te from combustion operations. Coal is fed with a losson weight feeder and pneumatically conveyed to the burner with primary air. Secondary air is heated p rior to combustion with an air-to-air heat exchanger; se condary air temperature is controlled with dampers bypassing the heat exchanger. Combustion stoichiom etry is controlled with a variable frequency drive blower.
1.2.2 Selective Catalytic Reduction 

### The SCR unit consists of three full-length sections of honeycomb SCR catalyst elements. Each section of the catalyst is equipped with a flow straightener a nd a soot blower. The SCR is operated at a tempera ture of approximately 700 to 740 °F with a space velocit y of 1900 h -1 

### . Anhydrous ammonia is metered using a mass flow controller and injected into the flue gas about 4 feet prior to the SCR unit. Ammonia injec tion is designed to achieve 5 % root mean square deviation of ammonia concentration, reasonably well-mixed conditions simulating commercial practice. The SCR unit has sample ports located between each catalys t section.

The V 2 

### O 4



### /WO 3 

### catalyst used in this system was manufactured by C ormetech. Each section contains nine honeycomb catalyst elements of 1190 mm length and 1 50 mm square cross-section. The catalyst was extracted from a full-scale 300 MW unit after appro ximately 15,000 hours in DeNO X 

### service firing low-sulfur eastern bituminous fuel. The DeNO X 

### activity compared to fresh catalyst was estimated by Cormetech to have a 0.8 to 0.9 K/Ko value.

For these tests NH 3 

### was injected to achieve a targeted NO X 

### reduction of 90%. Neither the specific NH 3 

### flowrate, nor any NH 3 

### slip, was measured for any of the tests.
1.2.3 Electrostatic Precipitator 

### The ESP was designed to capture fly ash from flue g as generated by the combustion of lignite, subbituminous, and bituminous coal. The system is a “ dry” design and includes mechanical rappers to remo ve the collected fly ash cake from the collection plat es. The ESP is a BETH model No: KEF 4 standard ESP

. It has nominal dimensions of 14.8’ x 6.2’ x 21.7’ ( LxWxH). It contains 775 ft 2 

### of collecting electrode plate surface. Collected solids are discharged through a rotary valve mounted on the bottom of the unit. T he specific collection area (SCA) of the unit is 646 f t 2 

### /1000 acfm. For these tests, the ESP collection pl ates were cleaned (rapped) and the collection hopper was emptied prior to each test.4 

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1.2.4 Baghouse Fabric Filter 

### The baghouse stands nearly 32 ft tall and has an ap proximate 6 ft x 6 ft footprint. It contains 24 Ry ton bags (6-in diameter, 8 ft long) accessible through a wal k-in plenum above the bags. In operation, flue gas passes into the baghouse through a sidewall under t he bags. The gas then is drawn upward through the bags where the particulate is collected. The bags are cleaned by a pulse system where rows of bags ar e pulsed from above, dislodging the dust cake into th e hopper. After passing into the bags, the flue g as exits through the tube sheet and exits the outlet p lenum to the wet lime scrubber.
For these tests, the baghouse ∆ P varied steadily between 3" and 4" H 2 

### O (a saw tooth with the average right around 3.5"). The pulsing is controlled by ∆ P with a trigger point of 4" resulting in about 10 pulses per hour. The air-to-cloth ratio was approximately 3.9:1. Fo r these tests, the baghouse was cleaned (pulsed) an d the collection hopper was emptied prior to initiation o f each test.

1.2.5 Wet Lime Flue Gas Desulfurization



### Sulfur dioxide is controlled with a wet lime scrubb er, a Croll-Reynolds Multi-Rod Deck Scrubber. The MultiRod Deck scrubber is a counter-current vertical col umn utilizing multiple sections of parallel rods in series for gas/liquid contact. Scrubber slurry is sprayed uni formly over the entire cross section of the rod dec k. Scrubber slurry passes through the rod decks, remov ing SO 2 

### and other pollutants, and into a hold tank at the base of the scrubber. Hydrated lime slurry is added to the hold tank to maintain slurry pH. Scru bber slurry is then recirculated from the hold tank to r emove additional SO 2 

### . The scrubber is designed to achieve >95 % of SO 2 

### removal at 1200 scfm. The gas existing the scrubb er rod decks enters a chevronblade type mist eliminator en route to the induced draft fan. The absorber system does not exceed 6-i n w.g. gas pressure loss.
Two phenomena occur to produce the intimate contact between the gas and liquid phases. The spaces between the rods function as “mini-venturi scrubber s” generating increased gas velocity and producing much the same effect as a conventional venturi scru bber. In addition, a turbulent “froth” layer is fo rmed above the rod decks that provides extremely agitate d mixing of the gas and liquid streams and excellen t gas/liquid contact with highly effective mass trans fer. The Multi-Rod Deck Scrubber provides the type of mass transfer provided by a counter-current packed tower but without the tendency to plug in the prese nce of solids. Because of the action of the liquid and gas streams as they flow across the rod surfaces, it is difficult for any material to adhere to the surface s and is, therefore, self-cleaning.
For all of these tests, the scrubber recycle varied between 70 and 80 gpm. The liquid-to-gas ratio, th e L/G, was around 75 gallons per 1000 acf of flue gas. Pr evious measurements under the same operating conditions and using the same bituminous coal that was used in these tests have shown SO 2 

### control of 98.8%.5 

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1.3 Testing Program


### In order to evaluate potential surrogacy relationsh ips, ORD, in collaboration with OAR, implemented a test program using the MPCRF. The objective of the test ing program was to collect selected HAP emission data while firing various coals under varied test c onditions and evaluate relationships between those concentrations and other process concentrations and /or conditions. The principle objectives were to: (1) evaluate the control of non-mercury HAP metals thro ugh the primary PM control device (both the ESP and the FF) and compare that to the control of the filt erable PM; (2) to measure concentrations of nondioxin/furan organic HAP and compare to the emissio n of candidate surrogates (e.g., CO, total hydrocarbons, etc.), and (3) to evaluate halide rem oval in the wet FGD scrubber. These tests were conducted while burning bituminous, sub-bituminous, and lignite coals. The MPCRF surrogacy testing commenced February 16, 2010, and concluded on July 28, 2010. A summary of surrogacy test conditions are presented in Table 1-1. The test matrix is des igned to capture concentrations effects resulting f rom changing coal types and changing PM control devices . Due to the combination of physical, operational, and budgetary constraints, each test corresponds to a single 4-hour sampling window and precludes replication for most extractive samples. Some repl ication is provided in the test matrix by repeating test conditions. The system was routinely cleaned betwe en coal types (and sometimes between tests) to avoi d cross contamination.

Table 1-1. Summary of MPCRF Surrogacy Test Conditi ons
Test Date Coal Type PM Device Principle Components Measured Control Technique Evaluated
2/16/2010 Bituminous ESP PM, metals, organics PM, C ombustion 2/23/2010 Bituminous ESP PM, metals, organics PM, C ombustion 4/07/2010 Bituminous ESP Acid gases, halides Scrubb er 4/21/2010 Bituminous ESP PM, metals, organics PM, C ombustion 4/28/2010 Bituminous FF PM, metals, organics PM, Co mbustion 5/20/2010 Sub-bituminous FF PM, metals, organics PM , Combustion 5/25/2010 Sub-bituminous FF PM, metals, organics PM , Combustion 6/02/2010 Sub-bituminous ESP PM, metals, organics P M, Combustion 6/16/2010 Bituminous ESP Acid gases, halides Scrubb er 7/21/2010 Lignite ESP PM, metals, organics PM, Comb ustion 7/28/2010 Lignite FF PM, metals, organics PM, Combu stion6 

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### 2. Methods and Materials
The MPCRF is a pilot facility operated in a semi-co ntinuous manner. The furnace was fired with natura l gas to approach steady-state thermal conditions pri or to burning coal. Coal feed for each test was in itiated prior to initiating manual sampling procedures to a llow the MPCRF to come to thermal equilibrium with the fuel at test conditions. All tests were performed at nominally 2.5 MMBtu/hr firing rate and a target stoichiometric ratio (SR) of 1.4, based on air feed measurements. The 1.4 SR was high with respect to what is used in industrial and utility settings. U nfortunately it was necessary because the combustor would run too close to its high-temperature limit at lowe r SR values.
Coal feed rate was based on estimated higher heatin g value at the time of the test; coal analysis from operations were used to determine actual firing rat e and SR after the fact. The estimated TimeTemperature profiles through the MPCRF are illustra ted in Figures 2-1 through 2-3 for eastern bitumino us, Powder River Basin (PRB) sub-bituminous, and Gulf C oast lignite metals and organics tests, respectivel y. NO X 

### was controlled with anhydrous ammonia injection at the SCR to achieve nominally 90 % reduction; a constant flow of ammonia was maintained with a mass flow controller based on the NO X 

### concentration at the PM control device inlet before commencing ammonia i njection. Ammonia injection was begun at least 1 hour prior to testing to allow the catalyst to achi eve steady-state operation.



### Residence Time, seconds**Temperature, °C** 

### Furnace

Outlet

SCR Inlet

PM Inlet

Figure 2-1. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using Eastern Bituminous Coal8 

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### Residence Time, seconds**Temperature, °C** 

### Furnace Outlet

SCR Inlet

PM Inlet

Figure 2-2. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using PRB Sub-bituminous

Coal



### Residence Time, seconds**Temperature, °C** 

### Furnace Outlet

SCR Inlet

PM Inlet9 

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Figure 2-3. Estimated MPCRF Residence Time-Tempera ture Profile during Tests Using Gulf Coast Lignite 

### Original test plans included furnace operation at n ominal conditions representing typical combustion conditions and at perturbed (non-ideal) conditions. The perturbed conditions were intended to be represented by removing heat from the upper portion s of the furnace, either with a bayonet heat exchan ger (a water-cooled tube inserted in the upper combusti on zone) or by reducing secondary combustion air pr eheat. After the first test on February 16, 2010, o peration at intentionally non-ideal conditions was abandoned due to budget and schedule constraints. However, in tests using the Gulf Coast lignite, th e bayonet heat exchanger was needed to maintain accep table operating temperatures at the top of the furnace.
Three coals were burned in this test program: an ea stern bituminous, a PRB sub-bituminous, and a Gulf Coast lignite. Samples of the pulverized coal were collected from the feeder during each test day. C oal samples from multiple runs with the same coal were composited and subsequently analyzed. Bituminous coal from the first two tests were composited separ ately from the last two bituminous coal tests becau se of a planned delay; analytical results were evaluated af ter the first two tests to ensure components were measureable with the sampling methods as implemente d. Coal was analyzed by Standard Laboratories, Inc. (Cressen, PA) using ASTM International procedu res. Table 2-1 summarizes the coal properties on a n as-fired basis and the analytical methods used. EP A Method 19 was used to determine a coal specific F

factor (F d 

### ) to convert analytes from concentrations to energy based units. Of note is the relatively low moisture content of the sub-bituminous coal and the Gulf Coast lignite, both of which are on the lower end of the expected values. For these tests, the sub-bitu minous coal had been stored for several months in a covered facility prior. The Gulf Coast lignite was delivered just before use. Both fuels were pulver ized just prior to use in the facility.
An EPA Category III Quality Assurance Project Plan (QAPP) was developed, approved and implemented for the surrogacy test program detailing the tests to b e performed, sampling and analytical procedures, an d certain data validation and reporting procedures. The data generated from this test program was compi led in a separate data package containing MPCRF operati ons information, continuous emission monitor (CEM) data, sampling data, and analytical results. An ev aluation of data quality with respect to QAPP ident ified data quality indicators is attached in Appendix A o f this report. For the purposes of this report, an alytical results below detection limits were treated as zero in emission control evaluations. EPA source metho ds, described in 40 CFR part 60 Appendix A, were used f or PM, metals, halides, and CEM analysis. EPA Office of Solid Waste methods (i.e., SW-846) were u sed for speciated organics analysis. Analytical methods were selected to be consistent with the uti lity Information Collection Request and to minimize detection limits. Furthermore, extractive sampling was generally extended to 4 hours to achieve minim um detection limits within the constraints imposed by MPCRF pilot operations; a steady-state sampling win dow longer than 4 hours could not be assured. For each test, all components were sampled concurrently to ensure samples reflected the same combustion condit ions. Due to the size of the MPCRF ductwork and the number of concurrent samples, flow was evaluate d with Method 2C before and after each test while10 

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### sampling under the assumption of steady state opera tions. Isokinetic samples were collected at a sing le point of average flow at the center of the duct; lo cations were selected meeting undisturbed straight run flow criteria of 8 duct diameters upstream and 2 duct di ameters downstream.11 

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Table 2-1. Fuel Analysis on As-fired Basis

Sample 02/16/2010 02/23/2010 Composite 04/21/2010

04/28/2010 Composite 05/25/2010

05/25/2010 06/02/2010 Composite 07/21/2010

07/28/2010 Composite
Coal Type Eastern Bituminous Eastern

Bituminous PRB Subbituminous Gulf Coast

Lignite Proximate Moisture,% [ASTM D2961, D3302, D3173] 3.40 2.49 19. 82 27.24 Volatiles,% [ASTM D3175M] 35.91 35.97 39.81 39.94 Fixed Carbon, % [ASTM D3172] 53.11 54.09 33.98 21.5 6 Ash, % [ASTM D3174] 7.58 7.45 6.39 11.26 Ultimate Sulfur, %S [ASTM D4239 Method B] 2.00 1.88 0.74 0.8 4 Carbon, %C [ASTM D3178, D5373] 73.61 74.12 56.08 45 .35 Hydrogen, %H [ASTM D3178, D5373] 5.10 4.93 3.69 3.4 3 Nitrogen, %N [ASTM D3179, D5373] 1.61 1.49 0.82 0.8 9 Oxygen, %O[ASTM D3176] 6.70 7.64 12.46 10.99 Chlorine, %Cl [ASTM D4208] 0.19 0.13 0.0261 0.0143 HHV, Btu/lb [ASTM D5865] 13301 13375 9599 7925 F d , dscf/MMBtu 9734 9653 9797 9769 Trace Metals Antimony, ppm Sb [ASTM D3683,D3684] 4.82 ◊ 4.85 ◊

19.9 ◊

3.54 ◊ Arsenic, ppm As [ASTM D3683,D3684] 9.32 2.04 1.52 1 .78 Beryllium, ppm Be [ASTM D3683,D3684] 0.04 ◊ 0.04 ◊

0.03 ◊

0.03 ◊ Boron, ppm B [ASTM D3683,D3684] N/A 46.3 13.4 99.7 Cadmium, ppm Cd [ASTM D3683,D3684] 0.05 ◊ 0.92 0.77 0.04 ◊ Chromium, ppm Cr [ASTM D3683,D3684] 0.24 ◊ 18.0 4.48 8.15 Cobalt, ppm Co [ASTM D3683,D3684] 12.5 N/A N/A 0.18 ◊ Lead, ppm Pb[ASTM D3683,D3684] 3.90 4.05 2.44 4.08 Manganese, ppm Mn [ASTM D3683,D3684] 10.5 14.5 11.5 174 Nickel, ppm Ni [ASTM D3683,D3684] 7.60 10.5 4.48 5. 37 Selenium, ppm Se [ASTM D3683,D3684] 0.68 0.47 1.60 ◊ 4.21 ◊ Not Detected. Reporting Limit. N/A = not available12 

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### PM and metals were concurrently sampled upstream an d downstream of the PM control device using combined EPA Method 5 and Method 29 (Method 5/29) t rain. Samples were analyzed by Element One, Inc., Wilmington, NC. An example Method 5/29 sampl ing train is shown in Figure 2-4; since mercury was not evaluated in this test program, the permanganat e (KMnO 4 

### /H 2 

### SO 4 

### ) impingers were excluded in these tests. PM concentrations were evaluated from the f ront-half catch, the particulate collected on the f ilter and in the probe rinse in front of the filter. Metals concentrations were evaluated for front-half catch and backhalf catch separately. Back-half catch concentrati ons are generally gaseous passing through the filte r and are collected in the impingers and glassware rinses after the filter. Particulate samples were also c ollected after manual sampling events using a Method 17 trai n; particulate collected was analyzed by thermogravimetric analysis / loss-on-ignition (TGA- LOI) by EPA personnel to evaluate carbon in the fly ash.

Figure 2-4. Method 5/29 Sampling Train13 

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### For two runs, halides were concurrently sampled ups tream and downstream of the scrubber using EPA Method 26A. Samples were analyzed by Resolution An alytics, Inc., Sanford, NC. Due to the amount of acid gas present in the upstream samples, the alkal i in the second Method 26A impinger was exhausted i n the first halide test performed on April 7, 2010 re sulting in compromised Cl 2 

### collection. The second test performed on June 16, 2010 utilized higher concentr ation sodium hydroxide and shorter sampling time wi th resulting smaller sample volume to avoid exhaustion of the alkali in the second Method 26A impinger.
CEMs sampled upstream and downstream of the PM cont rol device using single point extraction and source sampling procedures:


# • Method 3C for O 2 

### /CO 2 

### [California Analytical Instruments Model 200 & Mod el 600 analyzers]


# • Method 6C for SO 2 

### [Advance Pollution Instrumentation Model 100AH ana lysers]


# • Method 7E for NO X 

### [Teledyne Model 200E analyzers]


# • Method 10 for CO [Horiba Model VIA-510 analyzers]


# • Method 25A for Total Organic Carbon (TOC) [Horiba M odel FAI-236 at PM inlet, California Analytical Instruments Model 300-HFID at PM outlet]
All CEM samples, except for TOC, were filtered and dried at the sample location resulting in dry basis concentrations. TOC sample was filtered and delive red to the CEM in a heated line resulting in wet ba sis analysis.
Semi-volatile organic compounds (SVOC) using Method 0010 (M0010) were concurrently sampled upstream and downstream of the PM control device. The front-half and back-half samples were extracted and analyzed as a combined sample producing a singl e analytical fraction for each train. Each analyti cal fraction was analyzed for the laboratory’s full-sca n target analyte list and by selective ion monitori ng (SIM) for a group of polycyclic aromatic hydrocarbons (PA H). Two independent analytical laboratories were utilized for M0010 analysis resulting in slightly d ifferent full-scan target components. Samples from the first two tests (February 16 and February 23 runs) were a nalyzed by Research Triangle Park Laboratories, Inc ., Raleigh, NC. Samples from the remaining tests were analyzed by Air Toxics, Ltd., Folsom, CA.
Carbonyls were sampled downstream of the PM control device using Method 0011 (M0011). The method was modified slightly to include a heated filter in front of the M0011 impingers. The filter was used for a parallel evaluation of organic carbon/elemental car bon concentrations not included in this report; car bon concentrations are not considered HAPs at this time . Due to sampling error, M0011 sample collected on February 16, 2010 was collected at the PM inlet loc ation. Samples were analyzed by Resolution Analyti cs, Inc., Sanford, NC.14 

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### Volatile organic compounds (VOC) using SW-846 Metho d 0031 (M0031) were sampled upstream of the PM control device. Each sample consisted of three set s of traps, two tenax and one anasorb, and condensa te for the entire sample. Each set of traps was analy zed independently for the laboratory’s target analy te list. Traps were often grouped within each set with the t wo tenax traps analyzed together and the anasorb tr ap analyzed separately. Two independent analytical la boratories were utilized for M0031 analysis resulti ng in slightly different full-scan target components. Sa mples from tests on or before April 28, 2010, were analyzed by Research Triangle Park Laboratories, In c. (Raleigh, NC). Samples from the remaining tests were analyzed by Air Toxics, Ltd. (Folsom, CA).
Methane was sampled from downstream of the PM contr ol device using a Method 0040 (M0040) train. A non-isokinetic sample was collected in a Tedlar bag and delivered to a local laboratory, Research Tria ngle Park Laboratories, Inc. (Raleigh, NC), for methane analysis using gas chromatography/flame ionization detector. The condensate fraction was not analyzed

. The specific location for some of the sampling trai ns was dictated by test objectives. Other sampling locations were determined by availability of a samp ling port. Filterable PM and total HAP metals were sampled upstream and downstream of the PM control d evice in order to characterize the control of the metals relative to the filterable PM. The semi-vol atile organics were sampled both upstream and downstream of the PM control device to characterize their formation and to determine if they were appreciately removed in the PM control device (they did not appear to). Other measurements, such as t he carbonyls and the volatile organics were measured d ownstream of the PM control device due to availabil ity of sampling ports and the assumption that the PM co ntrol device would not affect their concentrations. No measurements of PM or organics were taken downstrea m of the wet-FGD scrubber even though the scrubber can be expected to further reduce the conc entrations of PM and some organics. This was due t o budget limitations and because doing so would compl icate efforts to quantify removal of HAP metals acr oss the PM control device and would complicate efforts to quantify the formation of some organic species.15 

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### 3. Daily Run Summary
3.1 MPCRF Run February 16, 2010



### The MPCRF burned eastern bituminous coal on Februar y 16, 2010. The objective of the test was to colle ct data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the ESP. The average coal feed rate was 183 lb/hr resulting in a heat input of 2.43 MMBtu/hr at a SR of 1.43. A bayonet heat exchanger was installed in the furnace to create perturbed ( nonideal) operating conditions.
Sampling for metals and organics began at 11:49 and concluded at 15:55. Due to a system interruption, there was an unplanned shutdown during the sampling period. The coal feeding stopped and the system automatically switched to natural gas firing in ord er to maintain furnace temperature. The natural ga s-firing lasted approximately 5 minutes before coal feeding could be re-established. Sampling continued throu gh the shutdown and during re-establishment of test co nditions. Diluent and CO concentrations during the test period are shown in Figure 3-1. The furnace shutdo wn was observed in CEM data with a spike in CO and O 2 

### concentration between 12:30 and 13:00. Particulat e sample collected in-flight after the metals and organics sampling showed a TGA-LOI value of 23.4 %, which is much larger than would have been expected based on previous operating experience. A composite coal analysis from this test and from th e subsequent test (on February 23, 2010) showed that 18 % of the coal particles were larger than 28 mesh (595 μ m). Inspection of the coal mill screen showed dama ge to the screen. The large coal particle size and likely the use of the bayonet heat exchanger wa s believed to contribute to higher than expected TG ALOI. The coal mill screens were replaced for subse quent runs.17 

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### 0 200 400 600 800 1000 1200

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:24 10:48 13:12 15:36**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



### 02/16/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO Extractive Sampling Period

Figure 3-1. PM Control Device Inlet Diluent and CO Summary for February 16, 201018 

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### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 453 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 80 ppmv dry, an 82 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-1.

Table 3-1. CEM Summary for February 16, 2010
CEM Results ESP In ESP Out O 2 , vol%d 9.8 11.1 CO 2 , vol%d 10.0 8.9 SO 2 , ppmvd* 1109 1089 NO X , ppmvd* 100 104 CO, ppmvd* 69 65 † TOC, ppmvw* <13 <14 * Concentrations corrected to 7% oxygen † Failed QC checks

3.1.1 Metals – February 16, 2010 

### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized for this test in Table 3-2. The concent ration of metals in the coal, upstream of the PM co ntrol device, and downstream of the PM control device is also summarized in Table 3-2. Concentrations at th e PM control device inlet are generally less than the metals input based on the coal sample or the respe ctive detection limit in the coal sample. This is often the also case for similar measurements in subsequen t tests. This is due, in part, to some accumulation of parti culate matter in upstream control equipment (e.g., SCR, heat exchangers) and in the duct work. At the PM c ontrol device inlet, a significant fraction of each analyte reported to the back-half of the Method 29 train; t he back-half catch represented the majority of the concentrations for antimony, boron, and selenium. This was due, in part, to some particulate carryove r to the back half for this sampling train. At the PM c ontrol device outlet, most of the selenium and boro n reported to the back-half of the Method 29 train al ong with nearly half of the arsenic. Beryllium was not detected in the back-half portion at the PM control device outlet; beryllium at the detection limit wo uld be 27.2 % of the measured concentrations.19 

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Table 3-2. Metals Summary for February 16, 2010

Emission Coal ESP In ESP Out Change

Input lb/MMBtu Emission

lb/MMBtu Backhalf % Emission

lb/MMBtu Backhalf % Control

% Filterable PM N/A 4.1E-01 N/A 9.2E-03 N/A 97.8 Antimony, Sb 3.6E-04 ◊ 1.9E-05 63.9 1.2E-07 + 39.2 + 99.4 Arsenic, As 7.0E-04 2.0E-04 20.2 2.9E-06 47.0 98.6 Beryllium, Be 2.9E-06 ◊ 8.5E-06 13.0 2.5E-08 27.2 ◊ 99.7 Boron, B N/A 1.4E-03 81.6 9.3E-04 99.5 32.9 Cadmium, Cd 3.6E-06 ◊ 3.4E-06 14.7 1.7E-07 + 30.6 + 95.0 Chromium, Cr 1.8E-05 ◊ 1.1E-04 15.5 2.7E-06 16.1 + 97.5 Cobalt, Co 9.4E-04 4.3E-05 16.0 5.7E-07 + 74.4 + 98.7 Lead, Pb 2.9E-04 7.2E-05 17.1 8.1E-07 13.0 + 98.9 Manganese, Mn 7.9E-04 1.5E-04 14.2 8.9E-07 + 17.9 + 99.4 Nickel, Ni 5.7E-04 1.1E-04 16.8 5.3E-06 6.0 + 95.1 Phosphorous, P 2.5E-03 8.3E-04 16.8 1.3E-05 55.8 98.5 Selenium, Se 5.1E-05 4.8E-05 74.1 1.2E-05 89.7 73.9 Aluminum, Al 6.7E-01 2.8E-02 N/A 1.0E-04 + N/A 99.6 Calcium, Ca 8.0E-02 7.5E-03 N/A 8.0E-05 + N/A 98.9 Iron, Fe 9.0E-01 4.6E-02 N/A 2.0E-04 N/A 99.6 Magnesium, Mg 2.2E-02 1.7E-03 N/A 1.4E-05 + N/A 99.2 Potassium, K 6.2E-02 4.6E-03 N/A 1.6E-05 + N/A 99.6 Sodium, Na 1.5E-02 2.8E-03 N/A 5.4E-05 + N/A 98.1 Titanium, Ti 4.5E-02 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available20 

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3.1.2 SVOCs – February 16, 2010



### SVOC M0010 concentrations are summarized in Table 3 -3 and Table 3-4 from the February 16, 2010 test. For this test, M0010 concentrations are only availa ble at the ESP Outlet sampling location (we did not sample the ESP inlet). The highest M0010 concentrations i ndicated in the full-scan analysis are phenol and diethylphthalate. PAH concentrations detected in f ull-scan M0010 analysis include naphthalene, acenaphthylene, phenanthrene, anthracene, fluoranth ene, and pyrene; phenanthrene and anthracene do not appear to be differentiated in this analysis. SIM analysis of M0010 PAH concentrations, presented in Table 3- 4, quantified fluorene at high concentration, which was not identified in full-scan analysis and faile d to detect pyrene which was quantified in full-scan analysis.21 

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Table 3-3. M0010 Full-Scan Emission Summary for Fe bruary 16, 2010

Analyte ESP Out μ g/dscm* lb/TBtu Phenol 1.5E+00 1.4E+00 Benzyl Alcohol 2.5E-01 2.3E-01 ^ 3 & 4-Methylphenol 1.9E-01 1.7E-01 ^ Nitrobenzene 3.5E-01 3.2E-01 ^+ Naphthalene 2.2E-01 2.0E-01 ^ 1,4-Dinitrobenzene 5.1E-01 4.6E-01 1,3-Dinitrobezene 2.2E-01 2.0E-01 ^ Acenaphthylene 2.5E-01 2.3E-01 ^ 2,6-Dinitrotoluene 2.5E-01 2.3E-01 ^+ 1,2-Dinitrobenzene 4.8E-01 4.4E-01 3-Nitroaniline 1.9E-01 1.7E-01 ^ Diethylphthalate 1.1E+00 9.9E-01 Phenanthrene 7.3E-01 6.7E-01 Anthracene 7.3E-01 6.7E-01 Di-n-butyl phthalate 4.1E+00 3.8E+00 + Fluoranthene 4.1E-01 3.8E-01 Pyrene 3.2E-01 2.9E-01 Benzyl butyl phthalate 1.6E-01 1.5E-01 ^ Bis(2-ethylhexyl)adipate 4.8E-01 4.4E-01 + Bis(2-ethylhexyl) phthalate 3.9E+00 3.6E+00 + Di-n-octyl phthalate 3.8E-01 3.5E-01 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank22 

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Table 3-4. M0010 SIM Emission Summary for February 16, 2010
Analyte ESP Out
μ g/dscm* lb/TBtu Naphthalene 4.1E-01 3.8E-01 Acenaphthylene 1.2E+00 1.1E+00 Acenaphthene ND ND Fluorene 1.1E+01 1.0E+01 Phenanthrene 5.1E-01 4.6E-01 Anthracene 5.1E-01 4.6E-01 Fluoranthene 2.2E-01 2.0E-01 ^ Pyrene ND ND Benz[a]anthracene ND ND Chrysene ND ND Benzo[b]fluoranthene ND ND Benzo[k]fluoranthene ND ND Benzo[a]pyrene ND ND Indeno[1,2,3-cd]pyrene ND ND Dibenz[a,h]anthracene ND ND Benzo[ghi]perylene ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits ND = not detected23 

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3.1.3 Carbonyls – February 16, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-5 from the February 16, 2010, test. Due to sampling error, M0011 concentrations were sampled a t the ESP inlet sampling location for this date resulting in a high particulate load on the filter installed for this test series in front of the M001 1 impingers. Of the five carbonyl compounds quantified, acetalde hyde concentrations were the highest. No acetophenone or isophorone was detected.
3.1.4 VOCs – February 16, 2010 

### VOCs Summary for February 16, 2010, can be found in Table 3-6. A total of 32 compounds were quantified from Research Triangle Laboratories 8260 analyte list. Chloromethane, 1,3- butadiene, and 1,4- dioxane were indicated as the highest VOC concentra tions.

Table 3-5. M0011 Carbonyl Emission Summary for Feb ruary 16, 2010

Analyte ESP In
μ g/dscm* lb/TBtu Formaldehyde 8.7E+00 7.9E+00 ^ Acetaldehyde 1.6E+01 1.5E+01 Propionaldehyde 7.6E+00 6.9E+00 Acetophenone ND ND Isophorone ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits ND = not detected

3.1.5 Methane – February 16, 2010 

### Methane for the February 16, 2010, sample was detec ted at 1.6 ppmvd. Correcting for dilution at the P M outlet sample location results in 2.7 ppmvd at 7% o xygen.24 

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Table 3-6. VOCs Summary for February 16, 2010

Analyte ESP In μg/dscm* lb/TBtu Chloromethane 1.3E+04 1.2E+04 Bromomethane 8.8E+01 8.1E+01 Freon 11 1.1E+00 1.0E+00 1,1-Dichloroethene 1.1E+00 9.8E-01 Carbon Disulfide 1.7E+02 1.6E+02 Acetone 3.2E+02 2.9E+02 Methylene Chloride 1.0E+01 9.2E+00 trans-1,2-Dichloroethene 9.2E-02 8.4E-02 Vinyl Acetate 4.1E+01 3.7E+01 2-Butanone (Methyl Ethyl Ketone) 1.7E+01 1.5E+01

Chloroform 7.5E-02 6.9E-02 Carbon Tetrachloride 1.2E-01 1.1E-01 Benzene 5.7E+01 5.2E+01 1,2-Dichloroethane 1.9E+01 1.8E+01 4-Methyl-2-pentanone 6.3E+00 5.7E+00 Tetrachloroethene 1.2E-01 1.1E-01 2-Hexanone 1.5E+01 1.4E+01 1,2-Dibromoethane (EDB) 1.5E+00 1.3E+00 Ethyl Benzene 1.5E+00 1.3E+00 o-Xylene 1.1E+00 1.0E+00 Styrene 2.2E+01 2.0E+01 Bromoform 3.0E+00 2.7E+00 1,3,5-Trimethylbenzene 5.3E+00 4.9E+00 Freon 12 9.7E+00 8.9E+00 1,3-Butadiene 4.5E+02 4.1E+02 Ethanol 1.7E+02 1.5E+02 Isopropyl alcohol 4.3E+00 3.9E+00 Methyl-t-butyl ether (MTBE) 4.3E-01 3.9E-01 Tetrahydrofuran 4.6E+00 4.2E+00 Heptane 3.7E+00 3.4E+00 1,4-dioxane 4.2E+02 3.8E+02 Benzyl chloride 5.3E+00 4.8E+00 * Concentrations corrected to 7% oxygen25 

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3.2 MPCRF Run February 23, 2010



### The MPCRF burned eastern bituminous coal on Februar y 23, 2010. The objective of the test was to colle ct data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. For this test, the flue gas was routed through the ESP for PM control. The average coal feed rate was 183 lb/hr resulting in a heat input of 2.44 MMBtu/hr at a SR of 1.44. The b ayonet heat exchanger was removed from the furnace to provide more representative operating conditions and to, hopefully, reduce the LOI in the resulting ash.
Sampling for metals and organics began at 10:29 and concluded at 14:35. Diluent and CO concentrations during the test period are shown in Figure 3-2. Pa rticulate sample collected in-flight after the meta ls and organics sampling indicated TGA-LOI of 12.5 %. The removal of the bayonet heat exchanger was apparently successful at reducing the LOI in the fl y ash (consistent with previous experience). Howev er the LOI was still higher than was expected based on pre vious operational experience. As mentioned previously, the large coal particle size (from the damaged coal mill screens) was likely contributed t o the higher than expected value for TGA-LOI.

NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 445 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 101 ppmv dry, a 77 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-7.26 

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### 0 20 40 60 80 100 120 140 160 180 200

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:24 10:48 13:12 15:36**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



### 02/23/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO

Extractive Sampling Period

Figure 3-2. PM Control Device Inlet Diluent and CO Summary for February 23, 2010 Table 3-7. CEM Summary for February 23, 2010
CEM Results ESP In ESP Out O 2 , vol%d 10.0 11.4 CO 2 , vol%d 9.8 8.7 SO 2 , ppmvd* 1115 1154 NO X , ppmvd* 129 129 CO, ppmvd* 47 32 † TOC, ppmvw* 2.2 † <15 * Concentrations corrected to 7% oxygen † Failed QC checks27 

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3.2.1 Metals – February 23, 2010 

### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized for this test in Table 3-8. The concent ration of metals in the coal, upstream of the PM co ntrol device, and downstream of the PM control device is also summarized in Table 3-8. As seen in the previ ous test, concentrations at the PM control device inlet are generally lower than the metals input based on the coal sample or the respective detection limit in th e coal sample. After the testing, inspection of th e duct work showed some accumulation of ash in the SCR. T his was cleaned for subsequent operations. Manganese concentration at the ESP outlet sample is suspect and has been omitted from this summary. The back-half manganese catch was inexplicably high without a commensurate increase in the front-half and would have resulted in negative control. These measurements seem consistent with a gross contamination in either sample collection or analys is with permanganate associated with mercury determinations. At the PM control device inlet, a minor fraction of most analytes reported to the bac k-half of the Method 29 train; the back-half catch represente d the majority of the concentration for selenium. At the PM control device outlet, the majority of antimony, arsenic, cobalt, and selenium reported to the back -half of the Method 29 train; large fractions of other analy tes may also report to the back-half but were confo unded with blank contamination at these levels.28 

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Table 3-8. Metals Summary for February 23, 2010

Emission Coal ESP In ESP Out Change

Input lb/MMBtu Emission

lb/MMBtu Backhalf % Emission

lb/MMBtu Backhalf % Control

% Filterable PM N/A 1.9E-01 N/A 1.6E-03 N/A 99.2 Antimony, Sb 3.6E-04 ◊ 6.0E-06 2.1 1.9E-07 + 65.6 96.9 Arsenic, As 7.0E-04 7.8E-05 4.1 2.9E-06 71.5 96.2 Beryllium, Be 2.9E-06 ◊ 4.4E-06 0.2 2.7E-08 ^ 20.2 ^ 99.4 Boron, B N/A N/A N/A N/A N/A N/A Cadmium, Cd 3.6E-06 ◊ 2.7E-06 1.4 + 1.2E-07 + 40.1 + 95.5 Chromium, Cr 1.8E-05 ◊ 4.5E-05 1.3 + 3.3E-06 + 20.4 + 92.7 Cobalt, Co 9.4E-04 1.1E-05 2.7 + 4.1E-06 62.7 63.3 Lead, Pb 2.9E-04 8.0E-05 0.4 + 9.7E-07 + 56.9 + 98.8 Manganese, Mn 7.9E-04 4.5E-05 14.8 Suspect N/A N/A Nickel, Ni 5.7E-04 4.1E-05 1.5 + 2.9E-06 + 25.2 + 93.1 Phosphorous, P 2.5E-03 3.0E-04 2.8 + 6.3E-06 + 65.3 + 97.9 Selenium, Se 5.1E-05 3.4E-05 90.0 1.9E-05 96.9 45.1 Aluminum, Al 6.7E-01 5.4E-03 N/A 1.0E-04 + N/A 98.1 Calcium, Ca 8.0E-02 2.5E-03 N/A 1.3E-04 + N/A 94.9 Iron, Fe 9.0E-01 1.8E-02 N/A 1.6E-04 N/A 99.1 Magnesium, Mg 2.2E-02 3.0E-04 N/A 2.6E-05 N/A 91.3 Potassium, K 6.2E-02 1.8E-03 N/A 2.2E-05 N/A 9 8.8 Sodium, Na 1.5E-02 1.3E-03 N/A 5.9E-05 + N/A 95.6 Titanium, Ti 4.5E-02 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available29 

### Surrogacy Testing in the MPCRF

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3.2.2 SVOCs – February 23, 2010



### SVOC M0010 concentrations are summarized in Table 3 -9 and Table 3-10 from the February 23, 2010 test. The highest M0010 concentrations indicated in the f ull-scan analysis at the ESP outlet are di-n-butyl phthalate, bis(2-ethylhexyl) phthalate, and phenol. PAH concentrations detected in full-scan M0010 analysis include naphthalene, acenaphthylene, phena nthrene, anthracene, fluoranthene, and pyrene; phenanthrene and anthracene do not appear to be dif ferentiated in this analysis. Full-scan analytes w ere not consistently detected at both ESP In and ESP Ou t sample locations; when detected at both locations , concentrations are generally in the same order of m agnitude. SIM analysis of M0010 PAH concentrations , presented in Table 3-10, quantified additional PAHs not detected by full-scan analysis. No general tr end in concentrations is apparent across the PM control de vice for M0010 SVOC.
3.2.3 Carbonyls – February 23, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-11 from the February 23, 2010 test. Of the fi ve carbonyl compounds quantified, acetophenone concent rations were the highest followed closely by formaldehyde. No isophorone was detected.
3.2.4 VOCs – February 23, 2010 

### VOCs Summary for February 23, 2010, can be found in Table 3-12. A total of 32 compounds were quantified from Research Triangle Laboratories 8260 analyte list. Chloromethane, 1,3-butadiene, and 1,4-dioxane were indicated as the highest VOC conce ntrations.
3.2.5 Methane – February 23, 2010 

### Methane for the February 23, 2010, sample was detec ted at 1.6 ppmvd. Correcting for dilution at the P M Outlet sample location results in 2.3 ppmvd at 7% o xygen.30 

### Surrogacy Testing in the MPCRF

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Table 3-9. M0010 Full-Scan Emission Summary for Fe bruary 23, 2010

Analyte ESP In ESP Out μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 2.1E+00 1.9E+00 1.4E+00 1.3E+00 Benzyl Alcohol 2.2E-01 2.0E-01 ^ 1.3E-01 1.2E-01 ^ N-nitroso-di-n-propylamine ND ND 1.3E-01 1.2E-01 ^ Nitrobenzene 4.2E-01 3.8E-01 + 3.1E-01 2.8E-01 + Naphthalene ND ND 1.6E-01 1.4E-01 ^ 2-Nitroaniline 1.0E+00 9.4E-01 2.1E-01 1.9E-01 ^ 1,4-Dinitrobenzene 1.0E+00 9.2E-01 5.2E-01 4.7E-01 Dimethyl phthalate 3.4E-01 3.1E-01 ND ND 1,3-Dinitrobezene 3.9E-01 3.6E-01 2.1E-01 1.9E-01 ^ Acenaphthylene 3.6E-01 3.3E-01 1.3E-01 1.2E-01 ^ 2,6-Dinitrotoluene 3.6E-01 3.3E-01 + 2.1E-01 1.9E-0 1 ^+ 1,2-Dinitrobenzene 7.3E-01 6.6E-01 3.6E-01 3.3E-01 4-Nitrophenol 2.7E+00 2.4E+00 ND ND Diethylphthalate 2.0E+00 1.9E+00 7.0E-01 6.4E-01 + Phenanthrene ND ND 3.6E-01 3.3E-01 Anthracene ND ND 3.6E-01 3.3E-01 Di-n-butyl phthalate 7.0E+00 6.4E+00 9.1E+00 8.3E+00 Fluoranthene ND ND 2.8E-01 2.6E-01 Pyrene ND ND 2.3E-01 2.1E-01 ^ Benzyl butyl phthalate 2.8E-01 2.6E-01 2.1E-01 1.9E-01 ^ Bis(2-ethylhexyl)adipate 3.9E-01 3.6E-01 + 1.7E+00 1.6E+00 + Bis(2-ethylhexyl) phthalate 4.3E+00 3.9E+00 + 5.3E+ 00 4.8E+00 Di-n-octyl phthalate 4.5E-01 4.1E-01 + 2.3E-01 2.1E -01 ^+ * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND= not detected31 

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Table 3-10. M0010 SIM Emission Summary for Februar y 23, 2010

Analyte ESP In ESP Out

μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 8.9E-01 7.2E-01 5.0E-01 4.3E-01 Acenaphthylene 8.0E-01 6.4E-01 1.1E+00 9.5E-01 Acenaphthene 3.5E-01 2.8E-01 3.9E-01 3.3E-01 Fluorene 6.8E+01 5.4E+01 1.3E+01 1.1E+01 Phenanthrene 9.5E-02 7.7E-02 ^ 2.8E-01 2.4E-01 Anthracene 9.5E-02 7.7E-02 ^ 2.8E-01 2.4E-01 Fluoranthene ND ND 1.1E-01 9.5E-02 ^ Pyrene 6.4E-02 5.1E-02 ^ 2.0E-01 1.7E-01 ^ Benz[a]anthracene 6.4E-02 5.1E-02 ^ 8.4E-02 7.1E-02 ^ Chrysene 6.4E-02 5.1E-02 ^ 8.4E-02 7.1E-02 ^ Benzo[b]fluoranthene ND ND 2.8E-02 2.4E-02 ^ Benzo[k]fluoranthene ND ND 2.8E-02 2.4E-02 ^ Benzo[a]pyrene 6.4E-02 5.1E-02 ^+ 2.8E-02 2.4E-02 ^ + Indeno[1,2,3-cd]pyrene ND ND ND ND Dibenz[a,h]anthracene ND ND ND ND Benzo[ghi]perylene ND ND ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

Table 3-11. M0011 Carbonyl Emission Summary for Fe bruary 23, 2010

Analyte ESP Out

μ g/dscm* lb/TBtu Formaldehyde 6.5E+01 6.0E+01 Acetaldehyde 1.1E+01 9.7E+00 Propionaldehyde 1.4E+01 1.2E+01 Acetophenone 9.2E+01 8.4E+01 Isophorone ND ND * Concentrations corrected to 7% oxygen ND = not detected32 

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Table 3-12. VOCs Summary for February 23, 2010

Analyte ESP In μg/dscm* lb/TBtu Chloromethane 9.7E+03 8.9E+03 Bromomethane 1.3E+01 1.2E+01 Freon 11 3.4E-01 3.1E-01 1,1-Dichloroethene 5.2E+00 4.7E+00 Acetone 8.2E+01 7.5E+01 Methylene Chloride 1.2E+01 1.1E+01 Vinyl Acetate 1.5E+01 1.4E+01 2-Butanone (Methyl Ethyl Ketone) 3.1E+00 2.8E+00

Chloroform 1.3E-01 1.2E-01 Carbon Tetrachloride 6.1E-02 5.6E-02 Benzene 1.2E+01 1.1E+01 1,2-Dichloroethane 9.7E+00 8.8E+00 4-Methyl-2-pentanone 4.8E+00 4.4E+00 2-Hexanone 6.0E+00 5.5E+00 1,2-Dibromoethane (EDB) 2.1E-01 1.9E-01 Ethyl Benzene 3.6E-01 3.3E-01 o-Xylene 2.2E-01 2.0E-01 Styrene 3.3E+00 3.0E+00 Bromoform 7.2E-01 6.6E-01 1,3-Dichlorobenzene 2.3E-01 2.1E-01 1,4-Dichlorobenzene 2.4E-01 2.2E-01 1,3,5-Trimethylbenzene 1.5E-01 1.4E-01 1,2,4-Trimethylbenzene 5.2E-02 4.7E-02 Freon 12 1.6E+00 1.4E+00 1,3-Butadiene 3.4E+02 3.1E+02 Ethanol 3.6E+01 3.3E+01 Isopropyl alcohol 7.3E+00 6.6E+00 Ethyl Acetate 2.7E-01 2.5E-01 Tetrahydrofuran 1.7E+00 1.5E+00 Heptane 3.6E-01 3.3E-01 1,4-dioxane 2.1E+02 1.9E+02 Benzyl chloride 6.0E+00 5.5E+00 * Concentrations corrected to 7% oxygen33 

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3.3 MPCRF Run April 7, 2010


### The MPCRF burned eastern bituminous coal on April 7 , 2010. The objective of the test was to collect d ata to evaluate the control of acid gases (HCl, HF, Cl 2 

### ) across the flue gas desulfurization (FGD) scrubbe r. No sampling of PM, HAP metals or organics was done dur ing this test. Flue gas was routed through the ESP

. The average coal feed rate was 184 lb/hr resulting in a heat input of 2.46 MMBtu/hr at a SR of 1.43.
Sampling for halides began at 11:14 and concluded a t 13:14. Diluent and CO concentrations during the test period are shown in Figure 3-3; CEM QC checks had not been completed at the beginning of sampling so the period between 12:22 and 13:14 was used for CEM concentrations.



### 0 50 100 150 200 250 300 350

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

10:48 12:00 13:12 14:24 15:36 16:48**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



### 04/07/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO Extractive Sampling Period

Figure 3-3. PM Control Device Inlet Diluent and CO Summary for April 7, 2010



### No ammonia was added to the SCR system during this test as NOx control was not necessary. CEM analysis during halides sampling is summarized in T able 3-13. Method 3A O 2 

### and Method 6C SO 2 

### measurements were not available on the MPCRF at the Scrubber Outlet sampling location. Diluent34 

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### concentrations from the ESP Outlet were used to cal culate concentrations for both Scrubber Inlet and Scrubber Outlet locations.

Table 3-13. CEM Summary for April 7, 2010
CEM Results ESP In ESP Out O 2 , vol%d 10.0 10.6 CO 2 , vol%d 9.8 9.2 SO 2 , ppmvd* 1093 † 1058 NO X , ppmvd* 571 555 CO, ppmvd* 94 N/A TOC, ppmvw* N/A N/A * Concentrations corrected to 7% oxygen † Failed QC checks N/A = not available

3.3.1 Halides – April 7, 2010 

### Though the MPCRF scrubber is designed and operated to remove SO 2 

### , no Method 6C data was available at the scrubber outlet to evaluate SO 2 

### removal efficiency. Previous and subsequent testi ng has shown a SO 2 

### removal efficiency of 98.8% at normal operating con ditions with the same coal used in the April 7, 201 0 testing. Halide concentrations were measured at th e Scrubber Inlet and the Scrubber Outlet sample locations. Halide HAP concentrations at both locat ions and halide control across the scrubber are summarized for this test in Table 3-14. As discuss ed in Appendix A, the Cl 2 

### measurement at the Scrubber Inlet is likely biased low due to exhaustion of the base in the sodium hydroxide impinger of Method 26 A. Both HF and Cl 2 

### concentrations were below detection limits at the Scrubber Outlet sample location; control efficiency was estimated using the reporting limit for these analytes.35 

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Table 3-14. Halide HAP Summary for April 7, 2010
Analyte Scrubber Inlet

lb/MMBtu Scrubber Outlet

lb/MMBtu Control % HCl 9.81E-2 1.41E-4 99.9 HF 1.67E-3 <1.38E-4 ◊ >91.7 Cl 2 2.96E-4 ‡ <7.1E-5 ◊ >76.0 ◊ Not detected. Reporting Limit used in Calculation ‡ Likely biased low due to base consumption in seco nd impinger36 

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3.4 MPCRF Run April 21, 2010


### The MPCRF burned eastern bituminous coal on April 2 1, 2010. The objective of the test was to collect data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the ESP. The average coal feed rate was 184 lb/hr resulting in a heat input of 2.46 MMBtu/hr at a SR of 1.43.
Sampling for metals and organics began at 11:26 and concluded at 15:27. Diluent and CO concentrations during the test period are shown in Figure 3-4. Pa rticulate samples collected in-flight during the pr eceding shake down day of operations at similar conditions resulted in 7.7 % TGA-LOI. Coal analysis from operations indicated that only 0.08 % of coal was l arger than 28 mesh (595 μ m), the coal mill screen had been repaired.



## 0 50 100 150 200 250

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

9:36 10:48 12:00 13:12 14:24 15:36**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 04/21/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO Extractive Sampling Period

Figure 3-4. PM Control Device Inlet Diluent and CO Summary for April 21, 201037 

### Surrogacy Testing in the MPCRF

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### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 321 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 33 ppmv dry, a 90 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-15.

Table 3-15. CEM Summary for April 21, 2010
CEM Results ESP In ESP Out O 2 , vol%d 9.4 10.4 CO 2 , vol%d 10.5 9.7 SO 2 , ppmvd* 1169 1206 NO X , ppmvd* 40 40 CO, ppmvd* 23 9 TOC, ppmvw* <12 <13 * Concentrations corrected to 7% oxygen

3.4.1 Metals – April 21, 2010


### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-16 from the April 21, 2010 te st. The concentration of metals in the coal, upstr eam of the PM control device, and downstream of the PM control device is also summarized in Table 3-16. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. Beryllium concentrations at the PM contr ol device inlet are higher than the concentration in t he coal sample. Arsenic concentrations at the PM c ontrol device inlet are slightly higher than the concentra tion in the coal sample. At the PM control device inlet, a minor fraction of most analytes reported to the bac k-half of the Method 29 train; the back-half catch represented the majority of concentrations for sele nium and boron. At the PM control device outlet, t he majority of most analytes reported to the back-half of the Method 29 train. Beryllium was not detecte d in the back-half portion at the PM control device outl et; beryllium at the detection limit would be 10.7 % of the measured concentrations.38 

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Table 3-16. Metals Summary for April 21, 2010

Emission Coal ESP In ESP Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half % Control % Filterable PM N/A 

### 9.1E-01 N/A 

### 4.0E-04 N/A 

### 100 Antimony, Sb 

### 3.6E-04 ◊ 8.5E-06 1.9 7.5E-07 96.6 91.2 Arsenic, As 

### 1.5E-04 2.0E-04 1.0 1.4E-05 98.0 93.1 Beryllium, Be 

### 2.9E-06 ◊ 1.4E-05 0.0 ^ 

### 7.5E-09 10.7 ◊ 99.9 Boron, B 

### 3.5E-03 1.5E-03 78.3 1.5E-03 99.6 0.3 Cadmium, Cd 

### 6.9E-05 5.4E-06 0.3 ^+ 

### 4.9E-08 ^+ 61.7 + 99.1 Chromium, Cr 

### 1.3E-03 1.4E-04 0.4 + 

### 1.3E-06 + 61.4 + 99.1 Cobalt, Co 

### N/A 3.8E-05 0.6 + 

### 2.0E-07 + 82.4 + 99.5 Lead, Pb 

### 3.0E-04 8.9E-05 0.2 + 

### 4.8E-07 + 44.5 + 99.5 Manganese, Mn 

### 1.1E-03 1.5E-04 0.2 + 

### 8.9E-07 + 63.9 99.4 Nickel, Ni 

### 7.9E-04 1.1E-04 0.3 + 

### 1.5E-06 + 63.1 98.7 Phosphorous, P 

### 6.1E-03 9.4E-04 0.7 3.5E-06 + 67.3 + 99.6 Selenium, Se 

### 3.5E-05 2.8E-05 59.1 5.3E-05 98.3 -88.1 Aluminum, Al 

### 6.3E-01 4.6E-02 N/A 

### 4.3E-05 + N/A 

### 99.9 Calcium, Ca 

### 8.7E-02 1.2E-02 N/A 

### 1.4E-04 + N/A 

### 98.8 Iron, Fe 

### 9.7E-01 6.9E-02 N/A 

### 3.5E-05 N/A 

### 99.9 Magnesium, Mg 

### 2.1E-02 2.6E-03 N/A 

### 7.0E-06 + N/A 

### 99.7 Potassium, K 

### 7.2E-02 1.0E-02 N/A 

### 9.6E-06 + N/A 

### 99.9 Sodium, Na 

### 1.9E-02 4.3E-03 N/A 

### 3.5E-05 + N/A 

### 99.2 Titanium, Ti 

### 3.0E-02 N/A N/A 

### N/A N/A 

### N/A
◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available39 

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3.4.2 SVOC – April 21, 2010



### SVOC M0010 concentrations are summarized in Table 3 -17 and Table 3-18 from the April 21, 2010 test. The highest M0010 concentrations indicated in the f ull-scan analysis at the ESP outlet are benzoic aci d and diethylphthalate; benzoic acid was not on the full- scan analyte list used by the prior lab. All PAH concentrations that were detected in full-scan M001 0 analysis were impacted by field blank contaminati on. All PAH detected in full-scan M0010 analysis were a t levels less than 3 times blank contamination and are noted as such in Table 3-17. Full-scan quantified concentrations for the ESP In and ESP Out sample locations were of the same order of magnitude. SIM analysis of M0010 PAH concentrations, presented in Table 3-18, quantified fluoranthene of the same ord er of magnitude at both ESP in and ESP out sample locations; other PAHs were either not detected or c onfounded with field blank contamination at low concentrations.

Table 3-17. M0010 Full-Scan Emission Summary for A pril 21, 2010

Analyte ESP In ESP Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Benzoic Acid 7.2E+01 6.6E+01 9.2E+01 8.3E+01 Naphthalene 3.1E-01 2.8E-01 + 3.4E-01 3.1E-01 + Diethylphthalate 2.8E-01 2.5E-01 ^ 8.9E-01 8.1E-01 ^ di-n-Butylphthalate 8.9E-01 8.1E-01 ^+ 1.1E+00 1.0E +00 ^+ Butylbenzylphthalate 3.6E-01 3.3E-01 ^+ ND ND bis(2-Ethylhexyl)phthalate 3.3E+00 3.0E+00 + 1.7E+0 0 1.6E+00 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected40 

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Table 3-18. M0010 SIM Emission Summary for April 2 1, 2010

Analyte ESP In ESP Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 3.1E-01 2.8E-01 + 3.4E-01 3.1E-01 + 2-Methylnaphthalene 5.6E-02 5.0E-02 + 5.5E-02 4.9E- 02 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene ND ND ND ND Acenaphthene ND ND ND ND Fluorene ND ND ND ND Phenanthrene 4.2E-02 3.8E-02 + 2.3E-02 2.1E-02 ^+ Anthracene ND ND ND ND Fluoranthene 3.3E-02 3.0E-02 2.5E-02 2.2E-02 ^ Pyrene 2.8E-02 2.5E-02 + 2.5E-02 2.3E-02 ^+ Chrysene ND ND ND ND Benzo(a)anthracene ND ND ND ND Benzo(b)fluoranthene ND ND ND ND Benzo(k)fluoranthene 1.7E-02 1.5E-02 ^+ ND ND Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene ND ND ND ND Perylene ND ND ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.4.3 Carbonyls – April 21, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-19 from the April 21, 2010 test. Of the five carbonyl compounds quantified, propionaldehyde conc entrations were the highest. Formaldehyde and41 

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### acetaldehyde were detected at low concentrations co nfounded with field blank contamination. No isophorone was detected.

Table 3-19. M0011 Carbonyl Emission Summary for Ap ril 21, 2010

Analyte ESP Out
μ g/dscm* lb/TBtu Formaldehyde 1.6E+00 1.4E+00 ^+ Acetaldehyde 4.6E+00 4.2E+00 + Propionaldehyde 1.6E+01 1.4E+01 Acetophenone ND ND Isophorone ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.4.4 VOCs – April 21, 2010 

### VOCs Summary for April 21, 2010, can be found in Ta ble 3-20. Three compounds were quantified from Research Triangle Laboratories 8260 analyte list. 1,4-Dioxane was indicated as the highest emitting V OC, followed by benzene and toluene. It is not clear w hether the marked reduction in VOCs quantified was a direct result of improved combustion from reducing coal particle size or some other factor. Despite t he reduction in the number of quantifiable compounds f rom the February 16 and February 23 tests, both benzene and 1,4-dioxane concentrations are the same order of magnitude as these prior tests.

Table 3-20. VOCs Summary for April 21, 2010
Analyte ESP In

μg/dscm* lb/TBtu Benzene 2.2E+01 2.0E+01 Toluene 8.4E+01 7.6E+01 1,4-dioxane 1.9E+02 1.7E+02 * Concentrations corrected to 7% oxygen42 

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3.4.5 Methane – April 21, 2010 

### Methane for the April 21, 2010 sample was not detec ted at 1.0 ppmvd reporting limit. Correcting for d ilution at the PM Outlet sample location results in <1.3 pp mvd at 7% oxygen.
3.5 MPCRF Run April 28, 2010


### The MPCRF burned eastern bituminous coal on April 2 8, 2010. The objective of the test was to collect data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the FF. The average coal feed rate was 185 lb/hr resulting in a heat input of 2.47 MMB tu/hr at a SR of 1.42.
Sampling for metals and organics began at 12:13 and concluded at 16:21. Diluent and CO concentrations during the test period are shown in Figure 3-5. Pa rticulate sample collected in-flight after the meta ls and organics sampling resulted in 19.6 % TGA-LOI. Coal analysis from operations indicate 0.25 % of coal w as larger than 28 mesh (595 μ m).



## -200 0 200 400 600 800 1000 1200

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

9:21 10:33 11:45 12:57 14:09 15:21 16:33**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 04/28/2010

FF Inlet O2 FF Inlet CO2 FF Inlet CO

Extractive Sampling Period

Figure 3-5. PM Control Device Inlet Diluent and CO Summary for April 28, 201043 

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### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 317 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 34 ppmv dry, an 89 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-21.

Table 3-21. CEM Summary for April 28, 2010
CEM Results FF In FF Out O 2 , vol%d 9.7 11.3 CO 2 , vol%d 10.1 8.8 SO 2 , ppmvd* 1174 1182 NO X , ppmvd* 42 41 CO, ppmvd* 137 126 TOC, ppmvw* <12 0.6 † * Concentrations corrected to 7% oxygen † Failed QC checks

3.5.1 Metals – April 28, 2010 

### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-22 from the April 28, 2010 te st. The concentration of metals in the coal, upstr eam of the PM control device, and downstream of the PM control device is also summarized in Table 3-22. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. However, some concentrations (e.g., bery llium and arsenic) at the PM control device inlet are hig her than the concentration in the coal sample. At the PM control device inlet, a minor fraction of most anal ytes reported to the back-half of the Method 29 tra in; the back-half catch represented the majority of the con centration for selenium. At the PM control device outlet, the majority of antimony and arsenic reported to th e back-half of the Method 29 train; large fractions of other analytes may also report to the back-half but were confounded with blank contamination at these levels

. Beryllium was not detected in the back-half portion at the PM control device outlet; beryllium at the detection limit would be 47.2 % of the measured concentration s. Selenium was not detected in the back-half port ion at the PM control device outlet; selenium at the de tection limit would be 622 % of the measured concentrations.44 

### Surrogacy Testing in the MPCRF

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Table 3-22. Metals Summary for April 28, 2010

Emission Coal FF In FF Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half % Control % Filterable PM N/A 

### 1.8E+00 N/A 

### 1.5E-03 N/A 

### 99.9 Antimony, Sb 

### 3.6E-04 ◊ 1.2E-06 9.9 9.4E-08 ^+ 72.4 92.5 Arsenic, As 

### 1.5E-04 2.6E-04 5.0 2.5E-06 75.7 99.0 Beryllium, Be 

### 2.9E-06 ◊ 2.5E-05 0.0 ◊ 1.5E-08 47.2 ◊ 99.9 Boron, B 

### 3.5E-03 N/A N/A N/A N/A N/A Cadmium, Cd 

### 6.9E-05 1.0E-05 0.2 ^ 3.3E-08 ^+ 50.4 ^+ 99.7 Chromium, Cr 

### 1.3E-03 3.0E-04 0.3 + 1.9E-06 + 25.3 + 99.4 Cobalt, Co 

### N/A 5.8E-05 0.2 + 6.1E-07 + 83.3 + 99.0 Lead, Pb 

### 3.0E-04 1.6E-04 0.1 + 6.9E-07 + 61.6 + 99.6 Manganese, Mn 

### 1.1E-03 2.9E-04 0.1 + 1.3E-06 + 21.8 + 99.5 Nickel, Ni 

### 7.9E-04 2.7E-04 0.2 + 1.4E-06 + 26.3 + 99.5 Phosphorous, P 

### 6.1E-03 1.2E-03 0.7 + 1.1E-05 + 45.3 99.1 Selenium, Se 

### 3.5E-05 6.7E-05 53.3 2.2E-07 622. ◊ 99.7 Aluminum, Al 

### 6.3E-01 9.5E-02 N/A 

### N/A N/A 

### N/A Calcium, Ca 

### 8.7E-02 2.4E-02 N/A 

### N/A N/A 

### N/A Iron, Fe 

### 9.7E-01 1.0E-01 N/A 

### N/A N/A 

### N/A Magnesium, Mg 

### 2.1E-02 7.0E-03 N/A 

### N/A N/A 

### N/A Potassium, K 7.2E-02 1.8E-02 N/A N/A N/A N/A Sodium, Na 1.9E-02 9.6E-03 N/A N/A N/A N/A Titanium, Ti 3.0E-02 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available45 

### Surrogacy Testing in the MPCRF

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3.5.2 SVOC – April 28, 2010



### SVOC M0010 concentrations are summarized in Table 3 -23 and Table 3-24 from the April 28, 2010 test. The M0010 concentrations indicated in the full-scan analysis at the FF outlet are benzoic acid, phenol , and diethylphthalate. All PAH concentrations that were detected in full-scan M0010 analysis were impacted by field blank contamination. All PAH detected in ful l-scan M0010 analysis were at levels less than 3 ti mes blank contamination and are noted as such in Table 3-24. Full-scan quantified concentrations FF In an d FF Out sample locations were of the same order of magn itude. SIM analysis of M0010 PAH concentrations, presented in Table 3-24, quantified fluoranthene of the same order of magnitude at both FF In and FF O ut sample locations. Acenaphthene was detected at the FF Out sample location; other PAH concentrations were either not detected or confounded with field b lank contamination at low concentrations.

Table 3-23. M0010 Full-Scan Emission Summary for A pril 28, 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 3.6E+00 3.2E+00 ^ 1.9E+00 1.7E+00 Benzoic Acid 1.3E+02 1.1E+02 9.9E+01 9.0E+01 Naphthalene ND ND 3.3E-01 3.0E-01 + Diethylphthalate 4.1E-01 3.7E-01 ^ 5.4E-01 4.9E-01 ^ di-n-Butylphthalate 1.9E+00 1.7E+00 ^+ 2.5E+00 2.3E +00 ^+ Butylbenzylphthalate 4.7E-01 4.2E-01 ^+ 4.8E-01 4.3 E-01 ^+ bis(2-Ethylhexyl)phthalate 5.8E+00 5.2E+00 + 3.0E+0 0 2.7E+00 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected46 

### Surrogacy Testing in the MPCRF

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Table 3-24. M0010 SIM Emission Summary for April 2 8, 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 1.7E-01 1.5E-01 + 3.6E-01 3.3E-01 + 2-Methylnaphthalene 3.6E-02 3.2E-02 + 6.6E-02 6.0E- 02 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene ND ND 2.3E-02 2.1E-02 ^ Acenaphthene ND ND ND ND Fluorene ND ND 1.9E-02 1.7E-02 ^+ Phenanthrene 5.8E-02 5.2E-02 + 4.2E-02 3.8E-02 + Anthracene ND ND ND ND Fluoranthene 2.7E-02 2.4E-02 ^ 2.4E-02 2.2E-02 ^ Pyrene 2.8E-02 2.5E-02 + 2.1E-02 1.9E-02 ^+ Chrysene ND ND ND ND Benzo(a)anthracene ND ND ND ND Benzo(b)fluoranthene ND ND ND ND Benzo(k)fluoranthene ND ND ND ND Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene ND ND ND ND Perylene ND ND ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.5.3 Carbonyls – April 28, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-25 from the April 28, 2010 test. Of the five carbonyl compounds quantified, acetophenone concent rations were the highest. Formaldehyde and47 

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### acetaldehyde were detected at low concentrations co nfounded with field blank contamination. No isophorone or propionaldehyde was detected.

Table 3-25. M0011 Carbonyl Emission Summary for Ap ril 28, 2010
Analyte FF Out

μ g/dscm* lb/TBtu Formaldehyde 6.0E+00 5.5E+00 ^+ Acetaldehyde 9.7E+00 8.8E+00 + Propionaldehyde ND ND Acetophenone 5.9E+00 5.3E+00 Isophorone ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.5.4 VOCs – April 28, 2010 

### VOCs Summary for April 28, 2010, can be found in Ta ble 3-26. Three compounds were quantified from Research Triangle Laboratories 8260 analyte list. 1,4-Dioxane was indicated as the highest emitting V OC, followed by toluene and benzene. Emission of each compound was the same order of magnitude as concentrations from the April 21 test through the E SP.

Table 3-26. VOCs Summary for April 28, 2010

Analyte FF In μg/dscm* lb/TBtu Benzene 9.5E+00 8.6E+00 Toluene 2.0E+01 1.8E+01 1,4-dioxane 1.4E+02 1.3E+02 * Concentrations corrected to 7% oxygen48 

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3.5.5 Methane – April 28, 2010 

### Methane for the April 28, 2010 sample was not detec ted at 1.0 ppmvd reporting limit. Correcting for d ilution at the PM Outlet sample location results in <1.4 pp mvd at 7% oxygen.
3.6 MPCRF Run May 20, 2010 

### The MPCRF burned PRB sub-bituminous coal on May 20, 2010. The objective of the test was to collect data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the FF. The average coal feed rate was 267 lb/hr resulting in a heat input of 2.57 MMB tu/hr at a SR of 1.38.
Sampling for metals and organics began at 11:00 and concluded at 15:09. Diluent and CO concentrations during the test period are shown in Figure 3-6. Pa rticulate sample collected in-flight after the meta ls and organics sampling resulted in 1.2 % TGA-LOI. Coal analysis from operations indicate 0.55 % of coal wa s larger than 28 mesh (595 μ m).



## 0 20 40 60 80 100 120 140

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

9:50 11:02 12:14 13:26 14:38**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 05/20/2010

FF Inlet O2 FF Inlet CO2 FF Inlet CO

Extractive Sampling Period

Figure 3-6. PM Control Device Inlet Diluent and CO Summary for May 20, 201049 

### Surrogacy Testing in the MPCRF

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### Surrogacy Testing in the MPCRF

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### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 267 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 54 ppmv dry, an 80 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-27.

Table 3-27. CEM Summary for May 20, 2010
CEM Results FF In FF Out O 2 , vol%d 9.9 11.3 CO 2 , vol%d 10.6 9.2 SO 2 , ppmvd* N/A 235 NO X , ppmvd* 68 67 CO, ppmvd* 42 N/A TOC, ppmvw* <13 N/A * Concentrations corrected to 7% oxygen N/A = not available

3.6.1 Metals – May 20, 2010 

### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-28 from the May 20, 2010 test . The concentration of metals in the coal, upstrea m of the PM control device and downstream of the PM c ontrol device, is also summarized in Table 3-28. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. Beryllium and boron concentrations at th e PM control device inlet are higher than the concentrat ion in the coal sample. At the PM control device i nlet, a minor fraction of each analyte reported to the back -half of the Method 29 train. At the PM control de vice outlet, a significant fraction of arsenic reported to the back-half of the Method 29 train; large frac tions of other analytes may also report to the back-half but were confounded with blank contamination at these levels. Beryllium was not detected in the back-hal f portion at the PM control device outlet; berylliu m at the detection limit would be 73.5 % of the measured con centrations. Selenium was not detected in the back

half portion at the PM control device outlet; selen ium at the detection limit would be 106 % of the me asured concentration.51 

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Table 3-28. Metals Summary for May 20, 2010

Emission Coal FF In FF Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half % Control % Filterable PM N/A 

### 8.8E-01 N/A 

### 1.8E-03 N/A 

### 99.8 Antimony, Sb 

### 2.1E-03 ◊ 4.6E-06 0.3 ^+ 4.9E-08 ^+ 46.0 ^+ 99.0 Arsenic, As 

### 1.6E-04 6.6E-05 0.6 5.1E-07 35.0 99.2 Beryllium, Be 

### 3.3E-06 ◊ 5.5E-06 0.1 ◊ 1.7E-08 73.5 ◊ 99.7 Boron, B 

### 1.4E-03 1.9E-02 1.2 1.3E-04 92.4 + 99.3 Cadmium, Cd 

### 8.0E-05 8.7E-06 2.3 8.9E-08 ^+ 63.9 + 99.0 Chromium, Cr 

### 4.7E-04 1.3E-04 0.8 + 2.7E-06 + 42.6 + 97.9 Cobalt, Co 

### N/A 3.5E-05 0.5 + 2.1E-07 + 43.7 + 99.4 Lead, Pb 

### 2.5E-04 5.3E-05 1.3 + 6.8E-07 + 64.0 + 98.7 Manganese, Mn 

### 1.2E-03 1.5E-04 0.4 1.3E-06 + 24.1 + 99.1 Nickel, Ni 

### 4.7E-04 8.3E-05 0.7 + 2.2E-06 + 19.0 + 97.3 Phosphorous, P 

### 1.5E-02 5.3E-03 0.1 + 6.4E-06 + 57.6 + 99.9 Selenium, Se 

### 1.7E-04 ◊ 4.8E-06 6.0 4.6E-08 ^ 106. ◊ 99.0 Aluminum, Al 

### 5.8E-01 7.7E-02 N/A 

### 1.6E-04 + N/A 

### 99.8 Calcium, Ca 

### 6.3E-01 1.2E-01 N/A 

### 1.5E-04 + N/A 

### 99.9 Iron, Fe 

### 5.3E-01 4.0E-02 N/A 

### 1.9E-04 N/A 

### 99.5 Magnesium, Mg 

### 1.3E-01 1.0E-02 N/A 

### 2.1E-05 + N/A 

### 99.8 Potassium, K 

### 4.3E-02 4.1E-03 N/A 

### 2.5E-05 + N/A 

### 99.4 Sodium, Na 

### 4.2E-02 2.5E-02 N/A 

### 9.7E-05 + N/A 

### 99.6 Titanium, Ti 

### 8.0E-04 N/A N/A 

### N/A N/A 

### N/A
◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available52 

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3.6.2 SVOCs – May 20, 2010



### SVOC M0010 concentrations are summarized in Table 3 -29 and Table 3-30 from the May 20, 2010 test. The M0010 concentrations indicated in the full-scan analysis at the FF outlet are benzoic acid, phenol , and diethylphthalate. All PAH concentrations that were detected in full-scan M0010 analysis were impacted by field blank contamination. All PAH detected in ful l-scan M0010 analysis were at levels less than 3 ti mes blank contamination and are noted as such in Table 3-30. Full-scan quantified concentrations FF In an d FF Out sample locations were of the same order of magn itude. SIM analysis of M0010 PAH concentrations, presented in Table 3-30, quantified fluoranthene an d pyrene of the same order of magnitude at both FF In and FF Out sample locations; other PAHs were either not detected or confounded with field blank contamination at low concentrations.

Table 3-29. M0010 Full-Scan Emission Summary for M ay 20, 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 1.2E+00 1.1E+00 ^ 2.2E+00 2.0E+00 ^ 1,4-Dichlorobenzene 3.3E-01 3.0E-01 ND ND Benzoic Acid 3.6E+01 3.4E+01 + 8.5E+01 7.8E+01 Naphthalene 3.3E-01 3.0E-01 + ND ND 2-Methylnaphthalene 3.6E-01 3.4E-01 ND ND Diethylphthalate 5.3E-01 4.9E-01 ^ 8.5E-01 7.8E-01 ^ di-n-Butylphthalate 3.1E+00 2.9E+00 ^+ 4.7E+00 4.3E +00 ^+ bis(2-Ethylhexyl)phthalate 1.2E+01 1.1E+01 + 1.0E+0 1 9.2E+00 + Di-n-Octylphthalate 3.3E-01 3.0E-01 ^ ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected53 

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Table 3-30. M0010 SIM Emission Summary for May 20, 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 3.1E-01 2.8E-01 + 3.3E-01 3.0E-01 + 2-Methylnaphthalene 3.6E-01 3.4E-01 1.5E-01 1.4E-01 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene ND ND ND ND Acenaphthene ND ND ND ND Fluorene ND ND ND ND Phenanthrene 4.3E-02 4.0E-02 + 2.1E-01 1.9E-01 + Anthracene ND ND ND ND Fluoranthene 6.6E-02 6.1E-02 1.2E-01 1.1E-01 Pyrene 5.0E-02 4.6E-02 7.9E-02 7.3E-02 Chrysene ND ND ND ND Benzo(a)anthracene ND ND ND ND Benzo(b)fluoranthene ND ND ND ND Benzo(k)fluoranthene ND ND ND ND Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene ND ND ND ND Perylene ND ND ND ND * Concentrations corrected to 7% oxygen + Blank flagged data, less than 3 times field blank ND = not detected54 

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3.6.3 Carbonyls – May 20, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-31 from the May 20, 2010 test. Of the five carbonyl compounds quantified, acetophenone concent rations were the highest. Acetaldehyde was detected at low concentrations confounded with fiel d blank contamination. No isophorone was detected.

Table 3-31. M0011 Carbonyl Emission Summary for Ma y 20, 2010

Analyte FF Out

μ g/dscm* lb/TBtu Formaldehyde 1.9E+01 1.7E+01 Acetaldehyde 1.9E+01 1.7E+01 + Propionaldehyde 2.8E+01 2.6E+01 Acetophenone 9.4E+01 8.6E+01 Isophorone ND ND * Concentrations corrected to 7% oxygen + Blank flagged data, less than 3 times field blank ND = not detected

3.6.4 VOCs – May 20, 2010 

### VOCs Summary for May 20, 2010, can be found in Tabl e 3-32. Fourteen compounds were quantified from Air Toxics’ 8260 analyte list. Methylene chloride and chloromethane are indicated as the highest VOC concentrations; both were detected at concentration s above the calibrated range of the instrument. Hexane was the third most abundant VOC quantified.
3.6.5 VOCs – May 20, 2010 

### Methane for the May 20, 2010, sample was not detect ed at 1.0 ppmvd reporting limit. Correcting for dilution at the PM Outlet sample location results i n <1.4 ppmvd at 7% oxygen.55 

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Table 3-32. VOCs Summary for May 20, 2010

Analyte FF In μg/dscm* lb/TBtu Chloromethane 6.9E+02 6.4E+02 § Bromomethane 1.8E+00 1.6E+00 Freon 11 3.1E-01 2.9E-01 1,1-Dichloroethene 8.9E-01 8.2E-01 Carbon Disulfide 2.6E+00 2.4E+00 Acetone 3.0E+00 2.7E+00 Methylene Chloride 6.7E+03 6.1E+03 § trans-1,2-Dichloroethene 9.2E-01 8.4E-01 Hexane 1.9E+01 1.8E+01 Bromochloromethane 3.9E-01 3.5E-01 Benzene 3.2E+00 2.9E+00 Toluene 8.4E+00 7.7E+00 Styrene 2.7E-01 2.4E-01 Freon 12 2.1E+00 1.9E+00 * Concentrations corrected to 7% oxygen § Above calibrated range of the instrument

3.7 MPCRF Run May 25, 2010 

### The MPCRF burned PRB sub-bituminous coal on May 25, 2010. The objective of the test was to collect data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the FF. The average coal feed rate was 267 lb/hr resulting in a heat input of 2.57 MMB tu/hr at a SR of 1.39.
Sampling for metals and organics began at 10:06 and concluded at 14:09. Diluent and CO concentrations during the test period are shown in Figure 3-7. Pa rticulate sample collected in-flight after the meta ls and organics sampling resulted in 2.7 % TGA-LOI. Coal analysis from operations indicate 4.0 % of coal was larger than 28 mesh (595 μ m).56 

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## 0 50 100 150 200 250 300 350 400

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:09 9:21 10:33 11:45 12:57 14:09**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 05/25/2010

FF Inlet O2 FF Inlet CO2 FF Inlet CO

Extractive Sampling Period

Figure 3-7. PM Control Device Inlet Diluent and CO Summary for May 25, 2010



### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 294 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 29 ppmv dry, a 90 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-33.57 

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Table 3-33. CEM Summary for May 25, 2010
CEM Results FF In FF Out O 2 , vol%d 9.9 11.5 CO 2 , vol%d 10.5 9.1 SO 2 , ppmvd* 174 164 NO X , ppmvd* 37 37 CO, ppmvd* 58 50 TOC, ppmvw* <13 N/A * Concentrations corrected to 7% oxygen N/A = not available

3.7.1 Metals – May 25, 2010


### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-34 from the May 25, 2010 test . The concentration of metals in the coal, upstrea m of the PM control device, and downstream of the PM control device is also summarized in Table 3-34. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. At the PM control device inlet more than 10 % of antimony and boron reported to the back-half of the Method 29 train; selenium was not detected in t he back-half portion at the PM control device inlet bu t would constitute 14 % of the measured concentrati on at detection limits. At the PM control device outlet a significant fraction of boron reported to the bac k-half of the Method 29 train; large fractions of other analy tes may also report to the back-half but were confo unded with blank contamination at these levels. Berylliu m was not detected in the back-half portion at the PM control device outlet; beryllium at the detection l imit would be 1140 % of the measured concentration. Selenium was not detected in the back-half portion at the PM control device outlet; selenium at the de tection limit would be 521 % of the measured concentration.58 

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Table 3-34. Metals Summary for May 25, 2010

Emission Coal FF In FF Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half % Control % Filterable PM N/A 7.6E-01 N/A 6.3E-04 N/A 99.9 Antimony, Sb 2.1E-03 ◊ 1.1E-06 13.5 4.9E-08 ^+ 88.5 + 95.8 Arsenic, As 1.6E-04 3.5E-05 6.9 1.9E-07 ^ 54.1 ^ 99.5 Beryllium, Be 3.3E-06 ◊ 3.1E-06 3.7 2.6E-09 ^ 1140 ◊ 99.9 Boron, B 1.4E-03 6.3E-04 38.0 1.4E-04 99.1 77. 5 Cadmium, Cd 8.0E-05 2.4E-06 7.0 6.0E-08 + 50.2 + 97.5 Chromium, Cr 4.7E-04 4.1E-05 6.3 7.6E-07 + 39.3 + 98.2 Cobalt, Co N/A 2.0E-05 5.6 8.2E-08 + 70.4 + 99.6 Lead, Pb 2.5E-04 2.7E-05 3.5 2.8E-07 + 61.4 + 98 .9 Manganese, Mn 1.2E-03 8.6E-05 5.4 4.6E-07 + 37.1 + 99.5 Nickel, Ni 4.7E-04 4.8E-05 5.5 7.4E-07 + 26.1 + 98.5 Phosphorous, P 1.5E-02 4.7E-03 5.3 3.2E-06 + 62. 2 + 99.9 Selenium, Se 1.7E-04 ◊ 2.0E-06 14.4 ◊ 2.2E-08 ^ 521. ◊ 98.9 Aluminum, Al 5.8E-01 4.5E-02 N/A 2.7E-05 + N/A 99.9 Calcium, Ca 6.3E-01 7.9E-02 N/A 2.5E-05 + N/A 1 00.0 Iron, Fe 5.3E-01 2.1E-02 N/A 3.3E-05 N/A 99.8 Magnesium, Mg 1.3E-01 1.5E-02 N/A 5.9E-06 ^+ N/A 100.0 Potassium, K 4.3E-02 3.7E-03 N/A 9.1E-06 ^ N/A 99.8 Sodium, Na 4.2E-02 1.1E-02 N/A 4.8E-05 + N/A 99 .6 Titanium, Ti 8.0E-04 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available59 

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3.7.2 SVOCs – May 25, 2010



### SVOC M0010 concentrations are summarized in Table 3 -35 and Table 3-36 from the May 25, 2010 test. The M0010 concentrations indicated in the full-scan analysis at the FF outlet are phenol, fluoranthene and phenanthrene. Full-scan quantified concentrations FF In and FF Out sample locations were of the same order of magnitude. SIM analysis of M0010 PAH conc entrations, presented in Table 3-36, quantified fluoranthene, pyrene, and benzo(a)anthracene of the same order of magnitude at both FF In and FF Out sample locations; other PAHs were either not detect ed or confounded with blank contamination at low concentrations. Fluoranthene concentrations quanti fied with full-scan analysis were similar to fluora nthene concentrations quantified with SIM analysis.

Table 3-35. M0010 Full-Scan Emission Summary for M ay 25, 2010

Analyte FF In FF Out μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol ND ND 1.4E+00 1.3E+00 Benzoic Acid 2.7E+01 2.5E+01 + 3.8E+01 3.5E+01 + Naphthalene 2.1E-01 1.9E-01 ^+ 1.3E-01 1.2E-01 ^+ 2-Methylnaphthalene 2.5E-01 2.3E-01 ^ ND ND Phenanthrene 8.2E-02 7.5E-02 ^ 4.3E-02 4.0E-02 ^ di-n-Butylphthalate 9.4E-01 8.7E-01 ^+ 1.1E+00 9.8E -01 ^+ Fluoranthene 6.6E-02 6.1E-02 ^ 7.4E-02 6.8E-02 ^ Pyrene 1.5E-01 1.4E-01 ^ ND ND bis(2-Ethylhexyl)phthalate 3.1E+00 2.8E+00 + 7.4E+0 0 6.8E+00 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected60 

### Surrogacy Testing in the MPCRF

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Table 3-36. M0010 SIM Emission Summary for May 25, 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 2.0E-01 1.9E-01 + 1.2E-01 1.1E-01 + 2-Methylnaphthalene 2.6E-01 2.4E-01 + 6.3E-02 5.8E- 02 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene ND ND ND ND Acenaphthene ND ND ND ND Fluorene 2.1E-02 2.0E-02 ^+ ND ND Phenanthrene 7.5E-02 6.9E-02 + 3.0E-02 2.8E-02 + Anthracene 9.7E-03 9.0E-03 ^ ND ND Fluoranthene 6.3E-02 5.8E-02 7.1E-02 6.5E-02 Pyrene 1.4E-01 1.3E-01 4.3E-02 4.0E-02 Chrysene 1.1E-02 9.8E-03 ^+ 1.3E-02 1.2E-02 ^+ Benzo(a)anthracene 1.1E-02 9.8E-03 ^ 1.2E-02 1.1E-0 2 ^ Benzo(b)fluoranthene ND ND ND ND Benzo(k)fluoranthene ND ND ND ND Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene 2.6E-02 2.4E-02 ^ ND ND Benzo(e)pyrene ND ND ND ND Perylene ND ND ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected61 

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3.7.3 Carbonyls – May 25, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-37 from the May 25, 2010 test. Of the five carbonyl compounds quantified, formaldehyde concent rations were the highest followed by propionaldehyd e and acetophenone. Acetaldehyde was detected at low concentrations confounded with blank contamination. No isophorone was detected.

Table 3-37. M0011 Carbonyl Emission Summary for Ma y 25, 2010
Analyte FF Out

μ g/dscm* lb/TBtu Formaldehyde 1.4E+01 1.3E+01 Acetaldehyde 5.4E+00 5.0E+00 + Propionaldehyde 7.0E+00 6.4E+00 Acetophenone 5.4E+00 5.0E+00 Isophorone ND ND * Concentrations corrected to 7% oxygen + Blank flagged data, less than 3 times field blank ND = not detected

3.7.4 VOCs – May 25, 2010 

### VOCs Summary for May 25, 2010, can be found in Tabl e 3-38. Thirteen compounds were quantified from Air Toxics’ 8260 analyte list. Benzene, methylene chloride, and carbon disulfide were indicated as th e highest VOC concentrations.
3.7.5 VOCs – May 25, 2010 

### Methane for the May 25, 2010, sample was detected a t 1.1 ppmvd. Correcting for dilution at the PM Out let sample location results in 1.6 ppmvd at 7% oxygen.62 

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Table 3-38. VOCs Summary for May 25, 2010

Analyte FF In μg/dscm* lb/TBtu Chloromethane 1.4E+00 1.3E+00 ^ Bromomethane 1.2E+00 1.1E+00 ^ Carbon Disulfide 1.4E+01 1.3E+01 Acetone 1.7E+00 1.6E+00 Methylene Chloride 2.3E+01 2.1E+01 Hexane 4.2E-02 3.9E-02 ^ Benzene 4.1E+01 3.7E+01 Toluene 2.7E-01 2.5E-01 ^ m,p-Xylene 2.7E-01 2.4E-01 ^ Styrene 8.0E-02 7.3E-02 ^ 1,2,3-Trichlorobenzene 2.7E-01 2.4E-01 ^ Iodomethane 4.0E-01 3.7E-01 ^ Freon 12 1.4E+00 1.3E+00 * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits § Above calibrated range of the instrument

3.8 MPCRF Run June 2, 2010


### The MPCRF burned PRB sub-bituminous coal on June 2, 2010. The objective of the test was to collect data to evaluate surrogacy relationships between co ntrol of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the ESP. The average coal feed rate was 268 lb/hr resulting in a heat input of 2.57 MMBtu/hr at a SR of 1.38.
Sampling for metals and organics began at 10:06 and concluded at 14:11. Diluent and CO concentrations during the test period are shown in Figure 3-8. Th e O 2 

### and CO 2 

### CEM at the PM control device inlet failed during the metals and organics sampling. The measu rements after commencement of sampling and before the failure were assumed representative of t he entire sampling period. Other CEM measurements were unaffected by this failure. Particulate sampl es collected in-flight after the metals and organic s63 

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### sampling resulted in 1.1 % TGA-LOI. Coal analysis from operations indicate 2.5 % of coal was larger t han 28 mesh (595 μ m).



## 0 100 200 300 400 500 600

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:52 10:04 11:16 12:28 13:40 14:52**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 06/02/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO

Extractive Sampling Period

Figure 3-8. PM Control Device Inlet Diluent and CO Summary for June 2, 2010



### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 254 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 28 ppmv dry, an 89 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-39.64 

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Table 3-39. CEM Summary for June 2, 2010
CEM Results ESP In ESP Out O 2 , vol%d 9.8 ‡ 10.7 CO 2 , vol%d 10.7 ‡ 9.9 SO 2 , ppmvd* 182 183 NO X , ppmvd* 35 46 CO, ppmvd* 43 27 TOC, ppmvw* <13 N/A * Concentrations corrected to 7% oxygen ‡ CEM failed during run, data before failure was us ed N/A = not available

3.8.1 Metals – June 2, 2010


### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-40 from the June 2, 2010 test . The concentration of metals in the coal, upstrea m of the PM control device, and downstream of the PM con trol device is also summarized in Table 3-40. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. Beryllium concentrations at the PM contr ol device inlet are higher than the concentration in t he coal sample. At the PM control device inlet, mo re than 10 % of antimony and boron reported to the back-hal f of the Method 29 train; a minor fraction of other analytes reported to the back-half of the Method 29 train. At the PM control device outlet, a signifi cant fraction of arsenic and boron reported to the back- half of the Method 29 train; large fractions of oth er analytes may also report to the back-half but were confounded with blank contamination at these levels

. Beryllium was not detected in the back-half portion at the PM control device outlet; beryllium at the detection limit would be 167 % of the measured concentration. Selenium was not detected in the back-half portio n at the PM control device outlet; selenium at the detec tion limit would be 234 % of the measured concentra tion.65 

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Table 3-40. Metals Summary for June 2, 2010

Emission Coal ESP In ESP Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half

% Control

% Filterable PM N/A 7.4E-01 N/A 8.0E-04 N/A 99.9 Antimony, Sb 2.1E-03 ◊ 3.6E-06 16.3 3.0E-07 + 8.0 ^ 91.5 Arsenic, As 1.6E-04 4.4E-05 0.4 1.5E-07 ^ 50.5 ^ 99.7 Beryllium, Be 3.3E-06 ◊ 4.6E-06 0.1 ◊ 4.0E-09 167. ◊ 99.9 Boron, B 1.4E-03 1.3E-03 22.4 2.2E-04 99.4 83. 4 Cadmium, Cd 8.0E-05 3.8E-06 1.3 + 3.4E-08 ^+ 27.6 ^+ 99.1 Chromium, Cr 4.7E-04 9.3E-05 0.6 + 9.5E-07 + 46.3 + 99.0 Cobalt, Co N/A 2.7E-05 0.2 + 7.8E-08 + 61.3 + 99. 7 Lead, Pb 2.5E-04 6.7E-05 0.3 + 2.5E-07 + 34.6 + 9 9.6 Manganese, Mn 1.2E-03 1.2E-04 0.2 + 4.9E-07 + 19. 9 + 99.6 Nickel, Ni 4.7E-04 6.9E-05 0.4 + 5.5E-07 + 30.6 + 99.2 Phosphorous, P 1.5E-02 4.2E-03 0.2 + 3.9E-06 + 62 .9 + 99.9 Selenium, Se 1.7E-04 ◊ 4.5E-06 0.6 ◊ 5.7E-08 234. ◊ 98.7 Aluminum, Al 5.8E-01 6.2E-03 N/A 5.6E-05 + N/A 99.1 Calcium, Ca 6.3E-01 3.9E-02 N/A 9.4E-05 + N/A 9 9.8 Iron, Fe 5.3E-01 2.4E-02 N/A 2.1E-05 + N/A 99.9 Magnesium, Mg 1.3E-01 5.0E-03 N/A 2.0E-05 + N/A 99.6 Potassium, K 4.3E-02 4.1E-03 N/A 1.1E-05 + N/A 99.7 Sodium, Na 4.2E-02 1.1E-02 N/A 5.6E-05 + N/A 99 .5 Titanium, Ti 8.0E-04 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available66 

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3.8.2 SVOCs – June 2, 2010



### SVOC M0010 concentrations are summarized in Table 3 -41 and Table 3-42 from the June 2, 2010 test. No M0010 concentrations indicated in the full-scan analysis at the ESP outlet. SIM analysis indicated M0010 PAH concentrations, presented in Table 3-42, were either not detected or confounded with blank contamination at low concentrations at the ESP Out sample location.

Table 3-41. M0010 Full-Scan Emission Summary for J une 2, 2010

Analyte ESP In ESP Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 2.1E+00 1.9E+00 ND ND Benzoic Acid 4.1E+01 3.8E+01 + 4.3E+01 4.0E+01 + Naphthalene 1.6E-01 1.4E-01 ^+ 1.6E-01 1.5E-01 ^+ Phenanthrene 1.1E-01 1.0E-01 ^ ND ND di-n-Butylphthalate 1.4E+00 1.2E+00 ^+ 9.8E-01 9.0E -01 ^+ bis(2-Ethylhexyl)phthalate 3.8E+00 3.5E+00 + 4.6E+0 0 4.2E+00 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected67 

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Table 3-42. M0010 SIM Emission Summary for June 2, 2010

Analyte ESP In ESP Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 1.5E-01 1.4E-01 + 1.5E-01 1.4E-01 + 2-Methylnaphthalene 6.8E-02 6.2E-02 + 5.5E-02 5.0E- 02 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene ND ND ND ND Acenaphthene ND ND ND ND Fluorene 2.4E-02 2.2E-02 ^+ ND ND Phenanthrene 9.4E-02 8.6E-02 + ND ND Anthracene ND ND ND ND Fluoranthene 3.8E-02 3.5E-02 ND ND Pyrene 3.3E-02 3.0E-02 ^ ND ND Chrysene ND ND ND ND Benzo(a)anthracene ND ND ND ND Benzo(b)fluoranthene ND ND ND ND Benzo(k)fluoranthene ND ND ND ND Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene ND ND ND ND Perylene ND ND ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected68 

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3.8.3 Carbonyls – June 2, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-43 from the June 2, 2010 test. Of the five carbonyl compounds quantified, formaldehyde concent rations were the highest followed by acetophenone and propionaldehyde. Acetaldehyde was detected at low concentrations confounded with blank contamination. No isophorone was detected.

Table 3-43. M0011 Carbonyl Emission Summary for Ju ne 2, 2010

Analyte ESP Out

μ g/dscm* lb/TBtu Formaldehyde 5.7E+01 5.3E+01 Acetaldehyde 9.4E+00 8.7E+00 + Propionaldehyde 1.0E+01 9.6E+00 Acetophenone 1.1E+01 1.0E+01 Isophorone ND ND * Concentrations corrected to 7% oxygen + Blank flagged data, less than 3 times field blank ND = not detected

3.8.4 VOCs – June 2, 2010 

### VOCs Summary for June 2, 2010, can be found in Tabl e 3-44. 27 compounds were quantified from Air Toxics’ 8260 analyte list. Chloromethane, methylen e chloride, and Freon 12 (dichlorodifluoromethane) were indicated as the highest VOC concentrations. Despite more quantifiable VOCs, concentrations of several of the VOCs quantified were lower than in t he May 20 and May 25 tests.

3.8.5 Methane – June 2, 2010 

### Methane for the June 2, 2010, sample was detected a t 1.3 ppmvd. Correcting for dilution at the PM Out let sample location results in 1.8 ppmvd at 7% oxygen.69 

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Table 3-44. VOCs Summary for June 2, 2010

Analyte ESP In μg/dscm* lb/TBtu Chloromethane 1.7E+01 1.6E+01 Bromomethane 8.1E-01 7.5E-01 Freon 11 1.1E+00 1.1E+00 ^ Freon 113 2.7E-01 2.5E-01 ^ Carbon Disulfide 7.1E-01 6.5E-01 ^ Acetone 3.8E+00 3.5E+00 ^ Methylene Chloride 6.8E+00 6.2E+00 2-Butanone (Methyl Ethyl Ketone) 2.1E-01 1.9E-01 ^

Chloroform 2.3E-01 2.2E-01 ^ Carbon Tetrachloride 5.2E-01 4.8E-01 ^ Benzene 5.6E-01 5.2E-01 Toluene 1.5E+00 1.4E+00 Tetrachloroethene 4.2E-02 3.9E-02 ^ Chlorobenzene 2.0E-02 1.8E-02 ^ Ethyl Benzene 1.0E-01 9.5E-02 ^ m,p-Xylene 2.9E-01 2.7E-01 ^ o-Xylene 1.1E-01 1.0E-01 ^ Styrene 1.5E-01 1.4E-01 ^ 1,3-Dichlorobenzene 4.2E-02 3.9E-02 ^ Cumene 1.3E-01 1.2E-01 ^ 1,2,4-Trimethylbenzene 1.2E-01 1.1E-01 ^ p-Cymene 2.0E-01 1.9E-01 ^ 1,2,4-Trichlorobenzene 2.3E-01 2.1E-01 ^ 1,2,3-Trichlorobenzene 2.8E-01 2.6E-01 ^ Butylbenzene 5.1E-01 4.7E-01 ^ Iodomethane 1.7E-01 1.6E-01 ^ Freon 12 4.5E+00 4.2E+00 *Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits70 

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3.9 MPCRF Run June 16, 2010



### The MPCRF burned eastern bituminous coal on June 16 , 2010. The objective of the test was to collect data to evaluate the control of acid gases (HCl, HF , Cl 2 

### ) across the flue gas desulfurization (FGD) scrubbe r. No sampling of PM, HAP metals or organics was done during this test. Flue gas was routed through the ESP. The average coal feed rate was 183 lb/hr resu lting in a heat input of 2.45 MMBtu/hr at a SR of 1 .43.
Sampling for halides at the Scrubber Outlet sample location began at 10:42 and concluded at 14:42. Th ree 1-hour method 26A samples were collected consecutiv ely within this time period at the Scrubber Inlet sample location. Diluent and CO concentrations dur ing the test period are shown in Figure 3-9; CEM QC checks had not been completed at the beginning of s ampling so the period between 12:00 and 14:42 was used for CEM concentrations.



## 0 100 200 300 400 500 600

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:52 10:04 11:16 12:28 13:40 14:52**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 6/16/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO Extractive Sampling Period

Figure 3-9. PM Control Device Inlet Diluent and CO Summary for June 16, 2010



### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 333 ppmv dry. Average NO X 

### at PM control inlet during the halides sampling wa s 35 ppmv dry, an 89 % reduction on an71 

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### absolute basis. CEM analysis during halides sampli ng is summarized in Table 3-45. Method 3A O 2 

### and Method 6C SO 2 

### measurements were not available on the MPCRF at th e Scrubber Outlet sampling location. Diluent concentrations from the ESP Outlet were use d to calculate concentrations for both Scrubber Inl et and Scrubber Outlet locations.

Table 3-45. CEM Summary for June 16, 2010
CEM Results ESP In ESP Out O 2 , vol%d 8.7 9.3 CO 2 , vol%d 11.1 10.5 SO 2 , ppmvd* 1091 1088 NO X , ppmvd* 40 37 CO, ppmvd* 57 † 36 TOC, ppmvw* N/A N/A * Concentrations corrected to 7% oxygen † Failed QC checks N/A = not available

3.9.1 Halides – June 16, 2010 

### Though the MPCRF scrubber is designed and operated to remove SO 2 

### , no Method 6C data was available at the scrubber outlet to evaluate SO 2 

### removal efficiency. Previous and subsequent testi ng has shown a SO 2 

### removal efficiency of 98.8% at normal operating con ditions with the same coal used in this testing. H alide concentrations were measured at the Scrubber Inlet and the Scrubber Outlet sample locations. Halide HAP concentrations at both locations and halide con trol across the scrubber are summarized in Table 3- 46 for the June 16, 2010 test. Relatively high halide concentrations at the scrubber inlet location affo rded the opportunity to decrease the sample time and replica te halide sampling at the scrubber inlet; three run s were performed in series to reflect average concentratio ns over the entire 4-hour halide sample at the scru bber outlet. The concentration of sodium hydroxide in t he scrubber inlet sample trains was increased to 1 Normal to prevent exhaustion of the base as encount ered in the April 7, 2010, test. Both HF and Cl 2 

### concentrations were below detection limits at the S crubber Outlet sample location; control efficiency was estimated using the reporting limit for these analy tes.72 

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Table 3-46. Halide HAP Summary for June 16, 2010
Analyte Scrubber Inlet

lb/MMBtu Scrubber Outlet

lb/MMBtu Control

% HCl: Run 1 Run 2 Run 3 Average 7.81E-2 8.28E-2 8.81E-2 8.30E-2 5.11E-5

---

--- 5.11E-5 ---

---

--- 99.9 HF: Run 1 Run 2 Run 3 Average 3.71E-4 4.85E-4 6.07E-4 4.88E-4 <1.18E-4

---

--- <1.18E-4 ◊ ---

---

--- >75.8 Cl 2 : Run 1 Run 2 Run 3 Average 5.55E-4 8.71E-5 1.58E-4 2.67E-4 <2.05E-5

---

--- <2.05E-5 ◊ ---

---

--- >92.3 ◊ Not detected. Reporting Limit used in Calculation

3.10 MPCRF Run July 21, 2010 

### The MPCRF burned Gulf Coast lignite coal on July 21 , 2010. The objective of the test was to collect d ata to evaluate surrogacy relationships between control of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the ESP. The average coal feed rate was 325 lb/hr resulting in a heat input of 2.57 MMBtu/hr at a SR of 1.38. A bayonet heat exchanger was installed in the furnace to control maximum furnace temperature at operating conditions.
Sampling for metals and organics began at 10:46 and concluded at 14:49. Diluent and CO concentrations during the test period are shown in Figure 3-10. A n air lance was used to blow ash off Heat Exchanger 1, immediately downstream of the furnace, to prevent o verheating at 12:08 and 13:45. Particulate samples collected in-flight after the metals and organics s ampling resulted in 1.1 % TGA-LOI. Coal analysis f rom operations indicated that 11 % of coal was larger t han 28 mesh (595 μ m).73 

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## 0 100 200 300 400 500 600 700 800 900 1000

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:52 10:04 11:16 12:28 13:40 14:52**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 7/21/2010

ESP Inlet O2 ESP Inlet CO2 ESP Inlet CO

Extractive Sampling Period

Figure 3-10. PM Control Device Inlet Diluent and C O Summary for July 21, 2010



### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 305 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 39 ppmv dry, an 87 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-47.74 

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Table 3-47. CEM Summary for July 21, 2010
CEM Results ESP In ESP Out O 2 , vol%d 8.4 9.1 CO 2 , vol%d 11.7 11.0 SO 2 , ppmvd* 837 833 NO X , ppmvd* 43 40 CO, ppmvd* 93 92 TOC, ppmvw* N/A N/A * Concentrations corrected to 7% oxygen N/A = not available

3.10.1 Metals – July 21, 2010


### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-48 from the July 21, 2010 tes t. The concentration of metals in the coal, upstre am of the PM control device and downstream of the PM cont rol device, is also summarized in Table 3-48. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. Cobalt and cadmium concentrations at the PM control device inlet are higher than the concentrat ion in the coal sample. At the PM control device i nlet, more than 10 % of antimony, beryllium, boron and se lenium reported to the back-half of the Method 29 t rain; a minor fraction of other analytes reported to the back-half of the Method 29 train. At the PM contro l device outlet, a significant fraction of antimony, arsenic , boron, and selenium reported to the back-half of the Method 29 train; large fractions of other analytes may also report to the back-half but were confounde d with blank contamination at these levels. Beryllium was not detected in the back-half portion at the PM co ntrol device outlet; beryllium at the detection limit wou ld be 25.8 % of the measured concentration.75 

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Table 3-48. Metals Summary for July 21, 2010

Emission Coal ESP In ESP Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half % Control % Filterable PM N/A 2.3E+00 N/A 3.1E-03 N/A 99.9 Antimony, Sb 4.5E-04 2.1E-06 25.2 8.0E-08 + 18.9 ^ 96.3 Arsenic, As 2.2E-04 1.7E-04 6.2 3.1E-06 85.2 9 8.2 Beryllium, Be 3.7E-06 ◊ 2.2E-07 100. 2.2E-08 25.8 ◊ 89.8 Boron, B 1.3E-02 7.3E-03 25.1 1.8E-03 99.9 74. 8 Cadmium, Cd 4.6E-06 ◊ 1.9E-05 1.3 4.8E-08 ^+ 31.8 ^+ 99.7 Chromium, Cr 1.0E-03 2.8E-04 1.7 1.1E-06 + 30.0 + 99.6 Cobalt, Co 2.3E-05 ◊ 7.0E-05 1.5 5.3E-07 + 80.4 + 99.2 Lead, Pb 5.2E-04 9.1E-05 4.1 5.7E-07 + 25.1 + 99 .4 Manganese, Mn 2.2E-02 2.4E-03 1.1 2.5E-06 5.8 + 99.9 Nickel, Ni 6.8E-04 1.8E-04 1.8 1.1E-06 + 29.4 + 99.3 Phosphorous, P 5.0E-03 5.9E-04 3.0 3.6E-06 + 69. 2 + 99.4 Selenium, Se 5.3E-04 2.3E-04 24.5 2.7E-05 93.1 88.5 Aluminum, Al 1.3E+00 2.7E-01 N/A 2.3E-04 N/A 9 9.9 Calcium, Ca 1.3E+00 2.5E-01 N/A 7.1E-04 N/A 99 .7 Iron, Fe 4.4E-01 5.4E-02 N/A 2.3E-04 N/A 99.6 Magnesium, Mg 2.5E-01 3.6E-02 N/A 5.2E-05 N/A 99.9 Potassium, K 6.3E-02 1.0E-02 N/A 2.2E-05 N/A 9 9.8 Sodium, Na 3.5E-02 1.1E-02 N/A 7.3E-05 + N/A 99 .3 Titanium, Ti 1.3E-01 N/A N/A N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available76 

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3.10.2 SVOCs – July 21, 2010



### SVOC M0010 concentrations are summarized in Table 3 -49 and Table 3-50 from the July 21, 2010 test. The highest M0010 concentrations indicated in the f ull-scan analysis at the ESP outlet are benzoic aci d and phenol; a number of PAHs were also quantified. Ful l-scan quantified concentrations ESP In and ESP Out sample locations were of the same order of magnitud e. SIM analysis of M0010 PAH concentrations, presented in Table 3-50, quantified a number of PAH s; fluoranthene, pyrene, and phenanthrene had the highest concentrations at the ESP out sample locati on. Concentrations quantified with SIM analysis we re similar to concentrations quantified with full-scan analysis.

Table 3-49. M0010 Full-Scan Emission Summary for J uly 21, 2010

Analyte ESP In ESP Out

μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 1.4E+00 1.3E+00 ^ 1.3E+00 1.2E+00 Benzoic Acid 6.5E+01 6.0E+01 8.7E+01 8.0E+01 Naphthalene 7.4E-01 6.8E-01 + 4.5E-01 4.1E-01 + Diethylphthalate 2.4E+00 2.2E+00 ND ND Phenanthrene 8.3E-02 7.7E-02 ^ 3.2E-01 3.0E-01 Anthracene ND ND 3.5E-02 3.2E-02 ^ di-n-Butylphthalate 1.8E+00 1.6E+00 ^+ 1.7E+00 1.6E +00 ^+ Fluoranthene 1.7E-01 1.6E-01 ^ 4.2E-01 3.9E-01 Pyrene 1.5E-01 1.3E-01 ^ 3.5E-01 3.2E-01 Butylbenzylphthalate 5.3E-01 4.8E-01 ^+ 3.2E-01 3.0 E-01 ^+ Chrysene 4.9E-02 4.5E-02 ^ 1.3E-01 1.2E-01 ^ Benzo(a)anthracene 4.9E-02 4.5E-02 ^ 1.4E-01 1.3E-0 1 ^ bis(2-Ethylhexyl)phthalate 6.5E+00 6.0E+00 + 5.0E+0 0 4.6E+00 + Di-n-Octylphthalate 3.0E-01 2.7E-01 ^ ND ND Benzo(b)fluoranthene ND ND 4.0E-02 3.7E-02 ^ * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected77 

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Table 3-50. M0010 SIM Emission Summary for July 21 , 2010

Analyte ESP In ESP Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 8.0E-01 7.4E-01 + 5.2E-01 4.8E-01 + 2-Methylnaphthalene 6.2E-02 5.7E-02 + 4.2E-02 3.9E- 02 + 2-Chloronaphthalene 4.9E-03 4.5E-03 ^ 4.2E-03 3.9E- 03 ^ Acenaphthylene 9.0E-03 8.2E-03 ^ 1.3E-02 1.2E-02 ^ Acenaphthene 7.1E-03 6.5E-03 ^+ 9.2E-03 8.5E-03 ^+ Fluorene 2.1E-02 1.9E-02 ^+ 3.2E-02 3.0E-02 + Phenanthrene 8.7E-02 7.9E-02 + 3.5E-01 3.2E-01 Anthracene 1.4E-02 1.3E-02 ^ 4.2E-02 3.9E-02 Fluoranthene 1.9E-01 1.8E-01 4.7E-01 4.4E-01 Pyrene 1.9E-01 1.7E-01 4.5E-01 4.1E-01 Chrysene 4.0E-02 3.7E-02 + 1.5E-01 1.4E-01 Benzo(a)anthracene 3.7E-02 3.4E-02 1.5E-01 1.4E-01 Benzo(b)fluoranthene ND ND 4.0E-02 3.7E-02 Benzo(k)fluoranthene ND ND 3.7E-02 3.4E-02 + Benzo(a)pyrene ND ND 1.5E-02 1.4E-02 ^ Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene 1.4E-02 1.3E-02 ^ 1.7E-02 1.6E-02 ^ Perylene ND ND 1.5E-02 1.4E-02 ^ * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected78 

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3.10.3 Carbonyls – July 21, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-51 from the July 21, 2010 test. Of the five carbonyl compounds quantified, acetophenone concent rations were the highest followed by propionaldehyde. Acetaldehyde and formaldehyde wer e detected at low concentrations confounded with blank contamination. No isophorone was detected.

Table 3-51. M0011 Carbonyl Emission Summary for Ju ly 21, 2010

Analyte ESP Out
μ g/dscm* lb/TBtu Formaldehyde 6.9E-01 6.4E-01 ^+ Acetaldehyde 4.6E+00 4.2E+00 + Propionaldehyde 5.0E+01 4.6E+01 Acetophenone 1.5E+02 1.3E+02 Isophorone ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.10.4 VOCs – July 21, 2010 

### A VOCs summary for July 21, 2010, can be found in T able 3-52. A total of 22 compounds were quantified from Air Toxics’ 8260 analyte list. Carbon disulfi de, benzene, and methylene chloride were indicated as the highest VOC concentrations. Carbon disulfide and b enzene concentrations exceeded the calibrated range of the instrument.
3.10.5 Methane – July 21, 2010 

### Methane for the July 21, 2010, sample was not detec ted at 1.0 ppmvd reporting limit. Correcting for d ilution at the PM Outlet sample location results in <1.2 pp mvd at 7% oxygen.79 

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Table 3-52. VOCs Summary for July 21, 2010

Analyte ESP In μg/dscm* lb/TBtu Bromomethane 8.5E+00 7.8E+00 Freon 11 2.2E-01 2.1E-01 ^ Freon 113 1.3E-01 1.2E-01 ^ Carbon Disulfide 3.3E+02 3.0E+02 § Acetone 1.2E+00 1.1E+00 ^ Methylene Chloride 2.5E+01 2.3E+01 Acrylonitrile 1.5E-01 1.4E-01 ^ Hexane 1.1E-01 1.0E-01 ^ Chloroform 8.3E-02 7.6E-02 ^ Benzene 1.4E+02 1.2E+02 § Toluene 3.6E-01 3.3E-01 ^ Chlorobenzene 4.7E-02 4.3E-02 ^ Styrene 3.4E-02 3.1E-02 ^ 1,4-Dichlorobenzene 3.8E-02 3.5E-02 ^ Cumene 1.7E-02 1.6E-02 ^ Bromobenzene 9.6E-02 8.8E-02 ^ Propylbenzene 2.4E-02 2.2E-02 ^ 4-Chlorotoluene 2.4E-02 2.2E-02 ^ 1,3,5-Trimethylbenzene 2.0E-02 1.8E-02 ^ Butylbenzene 1.0E-01 9.4E-02 ^ Iodomethane 6.0E+00 5.5E+00 ^ Freon 12 1.7E+00 1.5E+00 * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits § Above calibrated range of the instrument80 

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3.11 MPCRF Run July 28, 2010 

### The MPCRF burned Gulf Coast lignite coal on July 28 , 2010. The objective of the test was to collect d ata to evaluate surrogacy relationships between control of filterable PM and HAP metals and surrogacy relationships between combustion conditions and non -dioxin organic HAP formation. The flue gas was routed through the FF. The average coal feed rate was 324 lb/hr resulting in a heat input of 2.57 MMB tu/hr at a SR of 1.39. A bayonet heat exchanger was inst alled in the furnace to control maximum furnace temperature at operating conditions.
Sampling for metals and organics began at 10:16 and concluded at 14:20. Diluent and CO concentrations during the test period are shown in Figure 3-11. A n air lance was used to blow ash off Heat Exchanger 1, immediately downstream of the furnace, to prevent o verheating at 12:25. Particulate sample collected inflight after the metals and organics sampling resul ted in 1.1 % TGA-LOI. Coal analysis from operation s indicated that 0.45 % of coal was larger than 28 me sh (595 μ m).



## 0 50 100 150 200 250 300 350 400 450

0.0 3.0 6.0 9.0 12.0 15.0 18.0 21.0

8:52 10:04 11:16 12:28 13:40 14:52**Raw CO Concentration, ppmv dry O2 and CO2 Concentrations, percent dry** 



## 7/28/2010

FF Inlet O2 FF Inlet CO2 FF Inlet CO

Extractive Sampling Period

Figure 3-11. PM Control Device Inlet Diluent and C O Summary for July 28, 201081 

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### NO X 

### concentration at PM control inlet before beginning ammonia addition to SCR was 277 ppmv dry. Average NO X 

### at PM control inlet during the metals and organics sampling was 36 ppmv dry, an 87 % reduction on an absolute basis. CEM analysis durin g metals and organics sampling is summarized in Table 3-53.

Table 3-53. CEM Summary for July 28, 2010
CEM Results FF In FF Out O 2 , vol%d 8.6 10 CO 2 , vol%d 11.5 10.2 SO 2 , ppmvd* 819 823 NO X , ppmvd* 41 40 CO, ppmvd* 129 119 TOC, ppmvw* N/A N/A * Concentrations corrected to 7% oxygen N/A = not available

3.11.1 Metals – July 28, 2010 

### PM concentrations upstream of the PM control device and downstream of the PM control device are summarized in Table 3-54 from the July 28, 2010 tes t. The concentration of metals in the coal, upstre am of the PM control device, and downstream of the PM con trol device is also summarized in Table 3-54. Concentrations at the PM control device inlet are g enerally less than the metals input based on the co al sample or the respective detection limit in the coa l sample. Beryllium, cadmium and cobalt concentrat ions at the PM control device inlet are higher than the concentration in the coal sample. At the PM contro l device inlet, more than 10 % of boron and selenium reported to the back-half of the Method 29 train; a minor fraction of other analytes reported to the back-hal f of the Method 29 train. As discussed in Section 2.3, metals concentrations at the PM control device outl et were not considered reliable for this test.
3.11.2 SVOCs – July 28, 2010



### SVOC M0010 concentrations are summarized in Table 3 -55 and Table 3-56 from the July 28, 2010 test. The highest M0010 concentrations indicated in the f ull-scan analysis at the ESP outlet are benzoic aci d and phenol; a number of PAHs were also quantified. Ful l-scan quantified concentrations FF In and FF Out sample locations were of the same order of magnitud e. SIM analysis of M0010 PAH concentrations, presented in Table 3-56, quantified a number of PAH s; fluoranthene, pyrene, and phenanthrene had the82 

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### highest concentrations at the FF Out sample locatio n. Concentrations quantified with SIM analysis wer e similar to concentrations quantified with full-scan analysis.

Table 3-54. Metals Summary for July 28, 2010

Emission Coal FF In FF Out Change

Input lb/MMBtu Emission

lb/MMBtu Back-half

% Emission

lb/MMBtu Back-half

% Control

% Filterable PM N/A 

### 2.4E+00 N/A 

### 4.7E-03 N/A 

### 99.8 Antimony, Sb 4.5E-04 

### 1.1E-05 4.2 N/A N/A N/A Arsenic, As 2.2E-04 

### 1.1E-04 3.5 N/A N/A N/A Beryllium, Be 3.7E-06 ◊ 

### 1.2E-05 0.1 ◊ N/A N/A N/A Boron, B 1.3E-02 

### 6.2E-03 24.9 N/A N/A N/A Cadmium, Cd 4.6E-06 ◊ 

### 1.1E-05 0.2 ^ N/A N/A N/A Chromium, Cr 1.0E-03 

### 1.4E-04 0.2 + N/A N/A N/A Cobalt, Co 2.3E-05 ◊ 

### 4.2E-05 0.2 + N/A N/A N/A Lead, Pb 5.2E-04 

### 1.1E-04 0.1 + N/A N/A N/A Manganese, Mn 2.2E-02 

### 2.0E-03 1.9 N/A N/A N/A Nickel, Ni 6.8E-04 

### 1.0E-04 0.7 + N/A N/A N/A Phosphorous, P 5.0E-03 

### 3.4E-04 2.3 + N/A N/A N/A Selenium, Se 5.3E-04 

### 1.3E-04 13.0 N/A N/A N/A Aluminum, Al 1.3E+00 

### 1.1E-01 N/A 

### N/A N/A N/A Calcium, Ca 1.3E+00 

### 2.8E-01 N/A 

### N/A N/A N/A Iron, Fe 4.4E-01 

### 3.0E-02 N/A 

### N/A N/A N/A Magnesium, Mg 2.5E-01 

### 2.7E-02 N/A 

### N/A N/A N/A Potassium, K 6.3E-02 

### 5.5E-03 N/A 

### N/A N/A N/A Sodium, Na 3.5E-02 

### 7.3E-03 N/A 

### N/A N/A N/A Titanium, Ti 1.3E-01 

### N/A N/A 

### N/A N/A N/A ◊ Not detected. Reporting Limit used for input and back-half % numerator. ^ Below Reporting Limit but above Detection Limits for back-half and/or > 20% of total emission + Blank flagged data, less than 3 times field blank for back-half and/or > 20% of total emission N/A = not available83 

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Table 3-55. M0010 Full-Scan Emission Summary for J uly 28, 2010

Analyte FF In FF Out μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Phenol 2.9E+00 2.7E+00 3.0E+00 2.7E+00 Benzoic Acid 9.6E+01 8.8E+01 1.4E+02 1.3E+02 Naphthalene 1.0E-01 9.6E-02 ^+ 1.2E-01 1.1E-01 ^+ 2-Methylnaphthalene 7.7E-02 7.1E-02 ^ ND ND Diethylphthalate 3.2E+00 2.9E+00 ND ND Phenanthrene 8.6E-02 7.8E-02 ^ 2.2E-01 2.0E-01 ^ di-n-Butylphthalate 1.3E+00 1.2E+00 ^+ 7.8E-01 7.2E -01 ^+ Fluoranthene 2.9E-01 2.7E-01 2.6E-01 2.4E-01 ^ Pyrene 2.7E-01 2.5E-01 2.5E-01 2.3E-01 ^ Butylbenzylphthalate 3.2E-01 2.9E-01 ^+ ND ND Chrysene 7.5E-02 6.9E-02 ^ 8.4E-02 7.7E-02 ^ Benzo(a)anthracene 8.6E-02 7.8E-02 ^ 9.2E-02 8.4E-0 2 ^ bis(2-Ethylhexyl)phthalate 3.2E+00 2.9E+00 + 1.9E+0 0 1.8E+00 + * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected84 

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Table 3-56. M0010 SIM Emission Summary for July 28 , 2010

Analyte FF In FF Out
μ g/dscm* lb/TBtu μ g/dscm* lb/TBtu Naphthalene 1.2E-01 1.1E-01 + 1.3E-01 1.2E-01 + 2-Methylnaphthalene 8.6E-02 7.8E-02 + 7.3E-02 6.7E- 02 + 2-Chloronaphthalene ND ND ND ND Acenaphthylene 2.4E-02 2.2E-02 ^ 2.7E-02 2.5E-02 Acenaphthene 8.3E-03 7.6E-03 ^+ 1.0E-02 9.2E-03 ^+ Fluorene 1.9E-02 1.7E-02 ^+ 2.1E-02 2.0E-02 ^+ Phenanthrene 8.6E-02 7.8E-02 + 2.2E-01 2.0E-01 Anthracene 1.8E-02 1.6E-02 ^ 3.2E-02 3.0E-02 Fluoranthene 3.2E-01 2.9E-01 3.0E-01 2.7E-01 Pyrene 3.2E-01 2.9E-01 2.7E-01 2.5E-01 Chrysene 6.9E-02 6.4E-02 + 8.4E-02 7.7E-02 Benzo(a)anthracene 7.2E-02 6.6E-02 8.1E-02 7.4E-02 Benzo(b)fluoranthene 1.0E-02 9.6E-03 ^ 1.8E-02 1.6E -02 ^ Benzo(k)fluoranthene 9.1E-03 8.3E-03 ^+ 2.0E-02 1.9 E-02 ^+ Benzo(a)pyrene ND ND ND ND Indeno(1,2,3-c,d)pyrene ND ND ND ND Dibenz(a,h)anthracene ND ND ND ND Benzo(g,h,i)perylene ND ND ND ND Benzo(e)pyrene ND ND 8.9E-03 8.2E-03 ^ Perylene ND ND 9.4E-03 8.7E-03 ^ * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected85 

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3.11.3 Carbonyls – July 28, 2010 

### M0011 Carbonyl concentrations are summarized in Tab le 3-57 from the July 28, 2010 test. Of the five carbonyl compounds quantified, acetophenone concent rations were the highest followed by propionaldehyde. Acetaldehyde and formaldehyde wer e detected at low concentrations confounded with blank contamination. No isophorone was detected.

Table 3-57. M0011 Carbonyl Emission Summary for Ju ly 28, 2010
Analyte FF Out

μ g/dscm* lb/TBtu Formaldehyde 9.3E-01 8.5E-01 ^+ Acetaldehyde 7.7E+00 7.1E+00 + Propionaldehyde 2.6E+01 2.4E+01 Acetophenone 7.1E+01 6.6E+01 Isophorone ND ND * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits + Blank flagged data, less than 3 times field blank ND = not detected

3.11.4 VOCs – July 28, 2010 

### A VOCs summary for July 28, 2010, can be found in T able 3-58. A total of 27 compounds were quantified from Air Toxics’ 8260 analyte list. Carbon disulfi de, Methylene chloride, and benzene were indicated as the highest VOC concentrations. Indicated concentratio ns of carbon disulfide, Methylene chloride, and benzene were lower than concentrations from the Jul y 21, 2010 test.
3.11.5 Methane – July 28, 2010 

### Methane for the July 28, 2010, sample was not detec ted at 1.0 ppmvd reporting limit. Correcting for d ilution at the PM Outlet sample location results in <1.3 pp mvd at 7% oxygen.86 

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Table 3-58. VOCs Summary for July 28, 2010

Analyte FF In μg/dscm* lb/TBtu Vinyl Chloride 3.0E-02 2.8E-02 ^ Bromomethane 9.3E-01 8.5E-01 Freon 11 1.5E-01 1.4E-01 ^ Freon 113 6.3E-02 5.7E-02 ^ Carbon Disulfide 1.1E+01 1.0E+01 Acetone 2.4E-01 2.2E-01 ^ Methylene Chloride 7.6E+00 6.9E+00 2-Butanone (Methyl Ethyl Ketone) 1.8E-01 1.6E-01 ^

Chloroform 1.2E-01 1.1E-01 ^ Carbon Tetrachloride 7.3E-02 6.7E-02 ^ Benzene 2.8E+00 2.6E+00 1,2-Dichloroethane 1.4E-01 1.3E-01 ^ Toluene 2.5E-01 2.3E-01 Chlorobenzene 6.5E-02 6.0E-02 ^ Ethyl Benzene 4.4E-02 4.1E-02 ^ m,p-Xylene 2.6E-01 2.4E-01 ^ o-Xylene 4.4E-02 4.1E-02 ^ 1,3-Dichlorobenzene 4.0E-02 3.7E-02 ^ Bromobenzene 8.9E-02 8.1E-02 ^ Propylbenzene 1.8E-02 1.7E-02 ^ 1,3,5-Trimethylbenzene 2.8E-02 2.6E-02 ^ 1,2,4-Trimethylbenzene 1.2E-01 1.1E-01 ^ p-Cymene 3.7E-01 3.4E-01 ^ Naphthalene 6.5E-02 5.9E-02 ^ Butylbenzene 8.6E-02 7.9E-02 ^ Iodomethane 8.8E-01 8.0E-01 ^ Freon 12 1.3E+00 1.1E+00 * Concentrations corrected to 7% oxygen ^ Below Reporting Limit but above Detection Limits87 

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### 4. Method Summary Results
4.1 Non-mercury Metal HAPs


### Emission control through the PM control device is s hown in Figures 4-1 through 4-10 for PM and individ ual HAP metals. Filterable PM control was fairly consi stent across all tests, whether controlled through an ESP or FF, resulting in between 98 and 99+ % removal. With few exceptions, metal concentrations were also well controlled through the PM control device. As illustrated in Figure 4-6, cobalt concentration at the PM control device outlet on February 23, 2010, appear anomalously high; though back-half concentration at the PM outlet exceed back-half concentration at the PM control device inlet, no analytical problems are ap parent in the data report. Figure 4-10 illustrates that s elenium control is much less consistent than filter able PM control.

0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Antimony Test Date Coal Type Control Device

Figure 4-1. Control of PM and Antimony in MPCRF Te sts88 

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0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Arsenic Test Date Coal Type Control Device

Figure 4-2. Control of PM and Arsenic in MPCRF Tes ts

0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Beryllium Test Date Coal Type Control Device

Figure 4-3. Control of PM and Beryllium in MPCRF T ests89 

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0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Cadmium Test Date Coal Type Control Device

Figure 4-4. Control of PM and Cadmium in MPCRF Tes ts

0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Chromium Test Date Coal Type Control Device

Figure 4-5. Control of PM and Chromium in MPCRF Te sts90 

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0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Cobalt Test Date Coal Type Control Device

Figure 4-6. Control of PM and Cobalt in MPCRF Test s

0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Lead Test Date Coal Type Control Device

Figure 4-7. Control of PM and Lead in MPCRF Tests91 

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0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Manganese Test Date Coal Type Control Device

Figure 4-8. Control of PM and Manganese in MPCRF T ests

0% 20% 40% 60% 80% 100% 120%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Nickle Test Date Coal Type Control Device

Figure 4-9. Control of PM and Nickel in MPCRF Test s92 

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-100% -50% 0% 50% 100% 150%

2/16/2010

Bit. ESP 2/23/2010

Bit ESP 4/21/2010

Bit ESP 4/28/2010

Bit FF 5/20/2010

Sub FF 5/25/2010

Sub FF 6/02/2010

Sub ESP 7/21/2010

Lig ESP**Control Across PM Control Device**

PM Selenium Test Date Coal Type Control Device

Figure 4-10. Control of PM and Selenium in MPCRF T ests



### The results of the program indicated that the contr ol of all of the non-Hg metal HAP (except Se) was consistently similar to the control of the bulk PM. The average filterable PM control during the test s was 99.5 %. The non-Hg metal HAPs were controlled alon g with the PM at levels greater than 95 % using either the ESP or the FF baghouse. Average control for the test series for each of the metals was (fo r all coals and all configurations):


# • Sb: 95.3%


# • As: 98.0%


# • Be: 98.5%


# • Cd: 98.7%


# • Cr: 98.0%


# • Co: 99.3%


# • Pb: 99.2%


# • Mn: 99.5%


# • Ni: 97.6%93 

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### The results for Se control were less consistent. W hen sub-bituminous coal was fired, the control of S e was consistently very good, averaging 98.9 % regardless of the PM control device being used. When using t he FF as the primary PM control device (regardless of coal type), the Se control was consistently very go od, averaging 99.2 %. Control of Se when the ESP was t he primary PM control device was variable. When sub-bituminous coal was fired, the control of Se th rough the ESP was 99+ %. When lignite was fired, t he control through the ESP was about 80 %. However, w hen the eastern bituminous coal was fired, the Se control through the ESP ranged from zero to 73 %.
The variability in the performance of Se control wi th coal rank and PM control device can be explained by the known behavior and chemistry of Se in the combu stion and flue gas environments. Selenium is a metalloid that sits just below sulfur on the period ic table and is, chemically, very similar to sulfur . In the high temperature combustion environment, Se is likely to be present as gas phase SeO 2 

### behaving similar to sulfur which is predominantly present as SO 2 

### . Much like SO 2 

### , SeO 2 

### is a weak acid gas. The testing in the pilot-scale combustion facility showed that Se in t he flue gas entering the PM control device tended t o be predominantly in the gas phase (55 to 90%) when fir ing eastern bituminous coal and predominantly in th e solid phase when firing sub-bituminous coal (greate r than 95%) and Gulf Coast lignite (80%). This is likely due to expected higher alkalinity associated with h igher calcium content in the sub-bituminous coal an d lignite ashes relative to bituminous coal ash. The refore, it is likely that Se will be controlled wit h PM in the lower rank coals with high calcium content while be ing controlled as an acid gas with coals containing lower ash calcium content.

4.2 Halides 

### Concentrations of halide HAPs were quantified at th e scrubber inlet sampling location for tests perfor med April 7, 2010, and July 16, 2010. Concentrations a t the scrubber outlet were quantified for HCl for b oth tests; the concentration of HF and Cl 2 

### were too low to quantify with the procedures used. Control of HCl was 99.9 % for both test days. The control of HF w as greater than 92 % for the first test and greater than 76 % for the second test. The control of Cl 2 

### was greater than 76 % for the first test and great er than 92 % for the second test. These control efficiencies we re likely much higher than the reported values beca use the outlet measurements were below the detection li mits for both HF and Cl 2 

### . The control efficiencies were calculated using the detection limit value.) The sc rubber was designed and operated to provide approximately 98 % SO 2 

### removal.

4.3 SVOCs


### SVOCs concentrations from MPCRF operations were sam pled using M0010 at PM inlet and outlet locations. Concentrations were quantified for the full 8270 li st standard at the analytical laboratory without re spect to status of individual compounds as HAPs or whether i ndividual compounds had been validated for M0010; these concentrations have been presented in Section 3 of this report. Analysis by SIM appears to have94 

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### quantified PAH concentrations consistent with the c oncentrations quantified by a full scan analysis us ing 8270 for the majority of tests; poor agreement was generally confined to February 16, 2010 and Februar y 23, 2010 tests. In addition, the generally poor su rrogate recoveries encountered in February 16, 2010 and February 23, 2010 tests suggested this data should be discounted. This data has been excluded from further analysis in this report.
Several PAH were quantified by both full-scan and S IM analysis. Background contamination has confounded the quantification of some PAH, notably naphthylene, 2-methyl naphthylene, and most detections of phenanthrene. SIM analysis was used to enhance the detection limit of 20 PAH. Despite the enhanced detection limit, several PAH were not detected in any test and many more were detected sporadically. Correlation of PAH quantified from m ultiple tests with CO concentrations at the PM inle t sample location are presented in Figures 4-11 throu gh 4-15. TOC concentrations were not reliably quantified in this test program due to low average concentrations and, therefore, could not be compare d against SVOC concentrations.
A few non-PAH SVOCs were quantified by M0010 tests but most were found only sporadically. Phenol, benzoic acid, and diethyl phthalate were quantified in several tests; of these, only phenol is listed as a HAP. Phenol concentrations were plotted against CO conce ntrations at the PM inlet sample location and shown in Figure 4-16.

0.000 0.005 0.010 0.015 0.020 0.025 0.030

0 20 40 60 80 100 120 140 160**Acenaphthylene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 PM Inlet PM Outlet

Figure 4-11. Acenaphthylene Concentrations versus CO Concentrations95 

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### 0.000 0.005 0.010 0.015 0.020 0.025 0.030 0.035 0.040 0.045

0 20 40 60 80 100 120 140**Anthracene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 PM Inlet PM Outlet
Figure 4-12. Anthracene Concentrations versus CO C oncentrations



### 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50

0 20 40 60 80 100 120 140 160**Fluoranthene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 PM Inlet PM Outlet96 

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Figure 4-13. Fluoranthene Concentrations versus CO Concentrations



### 0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50

0 20 40 60 80 100 120 140**Pyrene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2
PM Inlet PM Outlet
Figure 4-14. Pyrene Concentrations Versus CO Conce ntrations



### 0.00 0.02 0.04 0.06 0.08 0.10 0.12 0.14 0.16

0 20 40 60 80 100 120 140**Benzo(a)anthracene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 PM Inlet PM Outlet97 

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Figure 4-15. Benzo(a)anthracene Concentrations Ver sus CO Concentrations



### 0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5

0 20 40 60 80 100 120 140 160**Phenol Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 PM Inlet PM Outlet
Figure 4-16. Phenol Concentrations Versus CO Conce ntrations

4.4 Carbonyls 

### Carbonyl concentrations from MPCRF operations were sampled using M0011. Samples were analyzed for the full M0011 list of compounds: formaldehyde, ace taldehyde, propionaldehyde, acetophenone, and isophorone. Emission for each compound varied cons iderably over the test program with the exception o f Isophorone; no Isophorone was detected in this test program. The relative concentrations of the carbo nyls changed with run conditions; the highest emitting c arbonyl changed from run to run in no immediately discernable fashion. Though the M0011 sample for F ebruary 16, 2010 was extracted from the PM inlet sampling location instead of the PM outlet location , there is no indication that this change significa ntly impacted concentrations. Carbonyl concentrations w ere plotted against CO concentrations at the PM inl et sample location and are shown in Figures 4-17 throu gh 4-20. TOC concentrations were not reliably quantified in this test program due to low average concentrations and, therefore, could not be compare d against carbonyl concentrations.98 

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### 0 10 20 30 40 50 60 70

0 20 40 60 80 100 120 140 160**Formaldehyde Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Formaldehyde
Figure 4-17. Formaldehyde Concentrations Versus CO Concentrations



### 0 2 4 6 8 10 12 14 16

0 10 20 30 40 50 60 70 80**Acetaldehyde Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Acetaldehyde
Figure 4-18. Acetaldehyde Concentrations Versus CO Concentrations99 

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### 0 10 20 30 40 50 60

0 20 40 60 80 100 120 140 160**Propionaldehyde Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Propionaldehyde
Figure 4-19. Propionaldehyde Concentrations Versus CO Concentrations



### 0 20 40 60 80 100 120 140 160

0 20 40 60 80 100 120 140 160**Acetophenone Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Acetophenone
Figure 4-20. Acetophenone Concentrations Versus CO Concentrations100 

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4.5 VOCs


### VOC concentrations from MPCRF operations were sampl ed using M0031 at the PM inlet sample locations. Concentrations were quantified for the full 8260 li st standard at the analytical laboratory without re spect to the status of individual compounds as HAPs or wheth er individual compounds had been validated for M0031; these concentrations have been presented in Section 3 of this report. Chloromethane, acetone, and 2-butanone were frequently detected but are spe cifically excluded from the M0031 method. Other compounds reported in Section 3 may also be inappro priate for quantification with M0031 if they presen t positive or negative bias through interactions with media or with solvents used in analytical determin ation. Tests on and before April 28, 2010, were analyzed b y Research Triangle Laboratory, whose 8260 analyte list included compounds — significantly 1,3-butadie ne and 1,4-dioxane — not included in subsequent tes t. Tests subsequent to April 28, 2010, were analyzed b y Air Toxics; no significant VOC concentrations wer e found in these samples for compounds not included o n the Research Triangle Laboratory 8260 analyte lis t. Many of the HAPs quantified by VOC analysis were fo und on a sporadic basis. VOC HAPs quantified frequently in this test program included bromometha ne, carbon disulfide, methylene chloride, chlorofor m, carbon tetrachloride, benzene, toluene, ethyl benze ne, o-xylene, styrene, iodomethane, and 1,4-dioxane

. VOC concentrations of these HAPs are plotted agains t CO concentrations at the PM inlet sample location and are shown in Figures 4-21 through 4-32. The gr aph of methylene chloride concentrations (Figure 4- 23) is skewed by a single extraordinary data point, whi ch exceeded instrument calibration range; the other tests are clustered between 6 and 23 lb/TBtu methylene ch loride concentrations. TOC concentrations were not reliably quantified in this test program due to low average concentrations and, therefore, could not b e compared against carbonyl concentrations.101 

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

0 20 40 60 80 100 120 140 160**Bromomethane Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2



## Bromomethane

Bromomethane
Figure 4-21. Bromomethane Concentrations Versus CO Concentrations



### 0 50 100 150 200 250 300 350

0 20 40 60 80 100 120 140 160**Carbon Disulfide Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Carbon Disulfide
Figure 4-22. Carbon Disulfide Concentrations Versu s CO Concentrations102 

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### 0 1000 2000 3000 4000 5000 6000 7000

0 20 40 60 80 100 120 140 160**Methylene Chloride Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Methylene Chloride
Figure 4-23. Methylene Chloride Concentrations Ver sus CO Concentrations



### 0.00 0.05 0.10 0.15 0.20 0.25

0 20 40 60 80 100 120 140 160**Chloroform Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Chloroform
Figure 4-24. Chloroform Concentrations Versus CO C oncentrations103 

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### 0.0 0.1 0.2 0.3 0.4 0.5 0.6

0 20 40 60 80 100 120 140 160**Carbon Tetrachloride Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Carbon Tetrachloride
Figure 4-25. Carbon Tetrachloride Concentrations V ersus CO Concentrations



### 0 20 40 60 80 100 120 140 160

0 20 40 60 80 100 120 140 160**Benzene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2
Benzene
Figure 4-26. Benzene Concentrations Versus CO Conc entrations104 

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### 0 10 20 30 40 50 60 70 80

0 20 40 60 80 100 120 140 160**Toluene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Toluene
Figure 4-27. Toluene Concentrations Versus CO Conc entrations



### 0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6

0 20 40 60 80 100 120 140 160**Ethyl Benzene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Ethyl Benzene
Figure 4-28. Ethyl Benzene Concentrations Versus C O Concentrations105 

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### 0.0 0.2 0.4 0.6 0.8 1.0 1.2

0 20 40 60 80 100 120 140 160**o-Xylene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2

o - Xylene
Figure 4-29. o-Xylene Concentrations Versus CO Con centrations



### 0 5 10 15 20 25

0 20 40 60 80 100 120 140 160**Styrene Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Styrene
Figure 4-30. Styrene Concentrations Versus CO Conc entrations106 

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### 0 1 2 3 4 5 6 7

0 20 40 60 80 100 120 140 160**Iodomethane Emissions, lb/TBtu**



### CO Concentration, ppmv dry at 7% O2 Iodomethane
Figure 4-31. Iodomethane Concentrations Versus CO Concentrations



### 0 50 100 150 200 250 300 350 400 450

0 20 40 60 80 100 120 140 160**1,4-dioxane Emissions; #/TBtu**



### CO Concentration; ppmv dry at 7% O2 1,4

- dioxane
Figure 4-32. 1,4-dioxane Concentrations Versus CO Concentrations107 

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4.6 Methane



### Methane concentrations measured at the PM outlet ra nged from less than the 1.0 ppmvd reporting limit f or the analytical method to 1.6 ppmvd. Five of the ni ne methane samples were below the reporting limit. Quantifiable concentrations were in a narrow range close to the reporting limit. Correlation of metha ne concentrations with HAP concentrations was not purs ued with this data set.108 

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### 5. Summary and Conclusions
Bituminous, sub-bituminous, and lignite coals were burned in the MPCRF with flue gas routed through ei ther an ESP or a FF. Filterable PM and total metals wer e sampled and analyzed upstream and downstream of the PM control device. SVOCs were evaluated upstre am and downstream of the PM control device, carbonyls were evaluated downstream of the PM contr ol device, and VOCs were evaluated upstream of the PM control device. Diluent and other gases were al so sampled and analyzed by CEM both upstream and downstream of the PM control device. Concentration s were corrected for dilution to generate energy-ba sed concentrations.

Two runs were undertaken to examine the control of acid gases and halides (HCl, HF, Cl 2 

### ) using the limebased wet FGD scrubber. The ability of alkaline sl urry wet scrubbers to effectively control acid gase s is well known. These tests were intended to confirm t hat and to quantify the removal of the species; as such, these measurements were not the primary focus of th is overall test program.
Control of PM and HAP metals were compared. Measur ement of PM and metals was considered adequate for determining control as planned. Metal s concentrations were determined through analysis o f front-half, from the probe to the filter, and back- half, from after the filter through the impingers. At the PM control device inlet, most of the analytes largely report to the front-half of the Method 29 train; si gnificant portions of some analytes, particularly boron and s elenium, report to the back-half of the Method 29 t rain. Concentrations from the PM control device may be af fected by blank contamination and low mass of metal s in some samples. At the PM control device outlet, a significant fraction of many of the analytes may report to the back-half of the Method 29 train.
Control of organics concentrations was largely dete rmined by combustion conditions and quantified by t he concentrations themselves. Quantified concentratio ns for specific compounds were compared against CO concentrations at the PM inlet sample location. So me apparent correlation was found between CO concentrations and some specific organic compounds while no apparent correlation was indicated with others. Many of the organics concentrations were i mpacted by blank contamination at the low concentrations quantifiable with modern analysis. Despite the blank contamination, large groups of compounds could be evaluated with this data set.
One of the goals of this testing was to determine o r demonstrate a relationship between concentrations of organic compounds and combustion conditions. Most certainly, such a relationship would be expected to exist. However, due to low emission levels, non-de tect and other complexities, the key conclusion tha t can be drawn from the results of this testing is that t esting did not disprove an expected relationship between some organic concentrations and combustion conditio ns and that additional testing to further examine surrogacy relationships is warranted.110 

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### Appendix A: Quality Control Evaluation
A test program was implemented in 2010 at EPA’s Mul tipollutant Control Research Facility (MPCRF) in Research Triangle Park, NC to evaluate potential su rrogacy relationships for Hazardous Air Pollutants (HAP) from coal combustion. A Quality Assurance Pr oject Plan was developed for this program identifyi ng critical measurements and data quality indicator go als to evaluate these measurements. An extensive d ata package was prepared and submitted to EPA under sep arate cover summarizing the data collected including CEM averages, sampling data sheets, and e xternal lab reports. Data quality indicator goals were met except as described herein.
A.1 Method 2C Velocity



### Due to the duct size and access restrictions of the MPCRF in this test program, velocity measurement w as performed separately from sample extraction. Isoki netic sampling was performed under a steady-state assumption with Method 2C traverses performed befor e and after sample extraction. Flow is considered steady state if drift ≤ 10 %. Flow was calculated using the average O 2 

### and CO 2 

### from run conditions and moisture from a representative sample, typically Me thod 5/29. Flow data resulting from Method 2C traverses is summarized in Table A-1. No traverse data was taken after the extractive sampling for th e April 7, 2010, halides measurements; flow downstrea m of the PM control device was 1502 acfm and downstream of the scrubber was 1200 acfm. Halide m easurements around the scrubber on June 16, 2010, required flow downstream of the PM control and down stream of the scrubber; flows downstream of the scrubber were 1201 acfm before testing and 1203 acf m after testing for a drift of 0.2 %.
A minor drift was encountered on the first test day , February 16, 2010, downstream of the particulate collector. A much more significant drift was encou ntered on May 20, 2010, downstream of the particula te collector; the pre-test flow is believed to be in e rror. Isokinetics for these runs is potentially co mpromised.
A.2 Method 3A Oxygen and Carbon Dioxide Quality Con trol


### Results of calibration error checks, bias checks an d drift checks for O 2 

### and CO 2 

### CEM are summarized in Tables A-2 through A-7. Calibration error, both up stream and downstream of the PM control device, was < 2 % of span for O 2 

### and CO 2 

### . Bias checks, both upstream and downstream of the PM control device, were within 5 % of span for O 2 

### and CO 2 

### . Drift checks, both upstream and downstream of th e PM control device, were within 3 % of span for O 2 

### and CO 2 

### ; O 2 

### zero drift at the PM outlet on February 23, 2010, was 3.0 % of span. These measurements are deemed reliable and a dequate for this test program.112 

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Table A-1. Flow Measurements for Qualification of Steady-State Operation

Date Upstream of PM Control Downstream of PM Control

Pre-test Flow; acfm Post-test Flow;

acfm Drift; % Pre-test Flow; acfm Post-test Flow;

acfm Drift; %
2/16/2010 1492 1540 3.2 1511 1709 13.1 2/17/2010 a 1610 1654 2.7 1659 1684 1.5 2/23/2010 1529 1503 -1.7 1560 1597 2.4 4/7/2010 N/A N/A N/A 1502 N/A N/A 4/21/2010 1515 1535 1.3 1501 1503 0.1 4/28/2010 1510 1530 1.3 1533 1536 0.2 5/20/2010 1334 1340 0.4 701 1490 112.6 5/25/2010 1361 1387 1.9 1453 1479 1.8 6/2/2010 1444 1509 4.5 1517 1503 -0.9 6/16/2010 N/A N/A N/A 1517 1555 2.5 7/21/2010 1447 1462 1.0 1509 1504 -0.3 7/28/2010 1466 1490 1.6 1496 1506 0.7

a No CEM data is available for molecular weight deter mination; a default of 28 (nitrogen) was used to co mpare flows. N/A = not available

Table A-2. Oxygen CEM Calibration Error

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.2 0.6 0.8 -0.2 0.1 -0.1 02/23/2010 0.2 0.6 0.8 -0.2 0.1 -0.1 04/07/2010 0.3 0.5 0.9 -0.5 -0.6 0.1 04/21/2010 0.0 0.3 0.7 -0.1 0.0 0.3 04/28/2010 0.1 0.3 0.5 -0.1 0.0 -0.3 05/20/2010 0.0 0.1 0.7 0.3 0.3 0.3 05/25/2010 0.0 0.5 1.1 0.2 -0.1 0.1 06/02/2010 0.3 0.2 0.4 0.2 0.1 0.2 06/16/2010 0.0 -0.3 -0.7 0.4 0.4 0.3 07/21/2010 0.3 0.4 0.7 0.1 0.1 0.3 07/28/2010 -0.1 0.1 0.5 -0.1 0.1 0.1113 

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Table A-3. Oxygen CEM System Bias

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.8 -0.1 N/A 2.3 -1.0 N/A 02/23/2010 0.7 -0.1 N/A -0.3 -1.0 N/A 04/07/2010 0.5 -0.3 N/A 0.9 2.4 N/A 04/21/2010 1.0 0.4 N/A 1.5 0.1 N/A 04/28/2010 0.8 0.0 N/A 1.0 0.1 N/A 05/20/2010 0.5 -0.1 N/A 1.1 0.7 N/A 05/25/2010 0.6 -0.3 N/A 1.0 0.1 N/A 06/02/2010 0.5 -0.3 N/A 0.7 -0.3 N/A 06/16/2010 0.3 0.5 N/A 1.8 0.9 N/A 07/21/2010 -0.1 -0.9 N/A 3.3 1.3 N/A 07/28/2010 0.2 0.3 N/A 0.2 -0.3 N/A N/A = not available

Table A-4. Oxygen CEM Drift

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 -0.1 0.0 N/A -2.5 0.0 N/A 02/23/2010 0.4 0.7 N/A 3.0 2.6 N/A 04/07/2010 0.0 -0.1 N/A -0.2 -2.5 N/A 04/21/2010 0.3 0.1 N/A 0.3 0.0 N/A 04/28/2010 2.2 1.4 N/A -0.1 0.4 N/A 05/20/2010 0.3 0.1 N/A -0.1 -0.2 N/A 05/25/2010 0.1 0.0 N/A -0.1 -0.2 N/A 06/02/2010 1.0 0.4 N/A -0.1 0.0 N/A 06/16/2010 -0.3 -0.5 N/A 0.1 -0.3 N/A 07/21/2010 -0.1 0.6 N/A -1.6 -0.8 N/A 07/28/2010 0.1 0.0 N/A 0.1 -0.4 N/A N/A = not available114 

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Table A-5. Carbon Dioxide CEM Calibration Error

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.0 -0.7 0.5 -0.2 -1.5 0.0 02/23/2010 0.0 -0.7 0.5 -0.2 -1.5 0.0 04/07/2010 0.0 -0.8 0.5 -0.1 -1.5 0.0 04/21/2010 0.0 -0.7 0.6 -0.1 -1.4 0.0 04/28/2010 0.0 -0.6 0.1 -0.1 -1.6 -0.1 05/20/2010 0.0 -0.8 0.2 -0.1 -1.3 0.0 05/25/2010 0.0 -0.5 0.7 -0.1 -0.1 0.0 06/02/2010 0.0 -0.7 0.5 0.0 -1.2 -0.1 06/16/2010 0.1 -0.5 0.3 -0.1 -0.9 0.3 07/21/2010 0.0 -0.7 0.5 0.0 -0.8 0.2 07/28/2010 0.0 -0.9 0.0 -0.1 -0.8 0.1

Table A-6. Carbon Dioxide CEM System Bias

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.1 -0.3 N/A 2.4 0.0 N/A 02/23/2010 0.2 -0.2 N/A 0.2 -0.3 N/A 04/07/2010 0.0 -0.5 N/A 0.0 -1.6 N/A 04/21/2010 0.0 -0.7 N/A -0.2 -1.0 N/A 04/28/2010 0.2 -0.6 N/A 0.0 0.1 N/A 05/20/2010 0.0 -0.4 N/A 0.1 -0.5 N/A 05/25/2010 0.2 -0.5 N/A 0.1 -1.1 N/A 06/02/2010 0.0 -1.1 N/A 0.1 -0.7 N/A 06/16/2010 -0.1 -0.3 N/A 0.1 -0.8 N/A 07/21/2010 0.0 -0.6 N/A 0.1 -2.0 N/A 07/28/2010 0.0 -0.1 N/A 0.1 -0.4 N/A N/A = not available115 

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Table A-7. Carbon Dioxide CEM Drift

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.0 0.1 N/A -2.2 -0.3 N/A 02/23/2010 -0.2 -0.3 N/A 0.0 -0.6 N/A 04/07/2010 0.0 0.0 N/A 0.0 1.2 N/A 04/21/2010 0.0 -0.2 N/A 0.5 -0.4 N/A 04/28/2010 -0.1 -0.8 N/A 0.1 -0.1 N/A 05/20/2010 -0.1 -0.1 N/A 0.5 0.9 N/A 05/25/2010 0.0 -0.4 N/A 0.1 -0.3 N/A 06/02/2010 0.1 0.0 N/A 0.0 -0.3 N/A 06/16/2010 0.1 0.0 N/A -0.1 -0.1 N/A 07/21/2010 0.0 0.2 N/A -0.1 -0.3 N/A 07/28/2010 0.0 0.1 N/A 0.0 -0.3 N/A N/A = not available



### On April 7, 2010, and June 16, 2010, the calibratio n error and bias checks were not completed prior to beginning the Method 26A sampling; measurements aft er the bias check through the end of the test were assumed representative of the entire sampling perio d.
On June 2, 2010, the O 2 

### and CO 2 

### CEM at the PM control device inlet failed during t he metals and organics sampling. The measurements after commencement of s ampling and before the failure were assumed representative of the entire sampling period.
A.3 Method 5 Particulate Quality Control


### Method 5 particulate (front-half) determination was performed as a quality assurance measure on Februa ry 17, 2010, the operating day immediately preceding t he first metals sampling event. Additionally, all Method 29 samples for metals analysis were performed with coincident Method 5 particulate determination. The sample volumes for all these determinations are con sidered reliable as the test meters were calibrated before sampling and all test meters were within 5 % drift at the conclusion of sampling.
Particulate is expected to be representatively samp led for the February 17, 2010 runs since velocity traverses were consistent with steady state operati on and the sampling rate was within 10 % of isokine tic. Filter particulate determination was performed for this sample by baking followed by desiccation and s ingle116 

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### mass determination as permitted under Method 5; ace tone rinse determinations were within 0.5 mg on sequential weighing. No field blank was provided t o this laboratory for particulate.
While particulate determinations in conjunction wit h Method 29 were generally within Method 5 specifications, several deviations were encountered during this test program. Flow measurements at th e PM control outlet on February 16, 2010, failed to m eet criteria for steady state operation with 13 % d rift; although the run did pass with respect to isokineti c sampling rate at 92 % of isokinetic. On May 20, 2010, the PM outlet velocity determination appears to hav e been grossly in error resulting in failure of bot h steady state criteria, 112 % drift, and isokinetic criteri a, 54 % of isokenetic based on post run velocity tr averse; the initial velocity determination was used to set the constant sampling rate for each test. On May 25, 2 010, the PM outlet was oversampled resulting in a rate 1 24 % of isokinetic. All three of these failures in sampling rate were at the PM outlet location which is less impacted by sampling rate.
All mass determinations in conjunction with Method 29 were performed with subsequent weighings within 0.5 mg or 1 % of net weight. Mass calibration chec ks were within 0.5 mg for each determination. The field blank collected on February 16, 2010, resulted in 0 .3 mg for the front-half catch. The field blank co llected on July 21, 2010, resulted in 1.4 mg for the front- half catch. Front-half catch upstream of PM contro l ranged from 747 mg to 9527 mg; these results are cl early not significantly biased by the blanks. Fron t-half catch downstream of PM control ranged from 1.5 mg t o 18.5 mg; these results have not been blank corrected and may be biased by blank contamination.
A.4 Method 6C Sulfur Dioxide Quality Control


### Results of calibration error checks, bias checks an d drift checks for SO 2 

### CEM are summarized in Tables A-8 through A-10. Calibration error, both upstream and downstream of the PM control device, was less than 2 % of span for SO 2 

### . Bias checks, both upstream and downstream of the PM control device, were within 5 % of span for SO 2 

### . Drift checks, both upstream and downstream of th e PM control device, were generally within 3 % of span for SO 2 

### ; SO 2 

### mid-scale drift at the PM inlet on April 7, 2010, was 3.8 % of span. These measurements are deemed reliable and adequate for t his test program.117 

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Table A-8. SO 2 CEM Calibration Error

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.2 -0.7 0.0 0.0 -0.9 0.1 02/23/2010 0.2 -0.7 0.0 0.0 -0.9 0.1 04/07/2010 0.2 -0.8 0.0 0.0 -1.3 0.2 04/21/2010 0.1 -0.7 0.2 0.0 -0.4 0.2 04/28/2010 0.0 -1.1 -0.4 0.0 -1.1 0.1 05/20/2010 0.1 -1.2 0.0 0.1 -0.6 0.6 05/25/2010 0.2 -0.2 -0.3 0.0 -0.2 0.0 06/02/2010 0.1 0.0 0.0 0.0 -0.6 0.0 06/16/2010 0.2 N/A -0.5 0.0 N/A 0.5 07/21/2010 0.1 -0.1 0.3 0.0 -1.3 0.2 07/28/2010 0.4 0.1 0.9 0.1 -1.5 0.3

Table A-9. SO 2 CEM System Bias

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.1 -3.0 N/A 0.0 -1.6 N/A 02/23/2010 0.1 -1.9 N/A 0.0 -1.3 N/A 04/07/2010 0.2 -2.1 N/A 0.2 -1.1 N/A 04/21/2010 -0.1 -2.4 N/A -0.1 -1.3 N/A 04/28/2010 0.3 -2.6 N/A 0.3 -3.6 N/A 05/20/2010 0.0 -2.4 N/A 0.3 -2.2 N/A 05/25/2010 0.1 -3.7 N/A 0.8 -1.7 N/A 06/02/2010 0.1 -3.8 N/A 0.1 -3.0 N/A 06/16/2010 0.3 N/A -2.2 0.1 N/A -1.3 07/21/2010 0.9 -4.6 N/A 0.2 -3.6 N/A 07/28/2010 -0.1 -3.8 N/A 0.3 -1.6 N/A N/A = not available118 

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Table A-10. SO 2 CEM Drift

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.0 1.1 N/A 0.1 0.3 N/A 02/23/2010 0.0 1.3 N/A 0.0 2.6 N/A 04/07/2010 0.0 -3.8 N/A -0.2 -2.1 N/A 04/21/2010 0.1 0.1 N/A 0.3 1.2 N/A 04/28/2010 0.0 0.4 N/A -0.3 2.3 N/A 05/20/2010 N/A N/A N/A -0.2 0.4 N/A 05/25/2010 0.5 0.1 N/A -0.4 -0.2 N/A 06/02/2010 0.5 -1.1 N/A 0.4 -0.5 N/A 06/16/2010 0.0 N/A 0.5 0.3 N/A -1.6 07/21/2010 0.1 0.9 N/A 0.7 -0.4 N/A 07/28/2010 1.1 1.0 N/A -0.1 0.1 N/A N/A = not available



### On April 7, 2010, and June 16, 2010, the calibratio n error and bias checks were not completed prior to beginning the Method 26A sampling; measurements aft er the bias check through the end of the test were assumed representative of the entire sampling perio d.
On May 20, 2010, sample flow to the PM inlet SO 2 

### CEM failed during the test. PM inlet SO 2 

### concentrations are not available for this test.
A.5 Method 7E Nitrogen Oxides Quality Control


### Results of calibration error checks, bias checks an d drift checks for NO X 

### CEM are summarized in Tables A11 through A-13. Calibration error, both upstream and downstream of the PM control device, was less t han 2 % of span for NO X 

### . Bias checks, both upstream and downstream of the PM control device, were within 5 % of span for NO X 

### . Drift checks, both upstream and downstream of th e PM control device, were within 3 % of span for NO X 

### . These measurements are deemed reliable and adequ ate for this test program.119 

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Table A-11. NO X CEM System Bias

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.0 -0.7 N/A 0.0 -1.3 N/A 02/23/2010 0.0 -0.9 N/A 0.1 -1.0 N/A 04/07/2010 0.2 -1.8 N/A 0.1 -1.7 N/A 04/21/2010 0.1 -1.5 N/A 0.0 -1.8 N/A 04/28/2010 0.0 -1.5 N/A 0.0 -2.4 N/A 05/20/2010 0.1 -0.6 N/A -0.2 -1.9 N/A 05/25/2010 0.0 -2.4 N/A 0.2 -3.0 N/A 06/02/2010 2.0 -1.5 N/A 0.0 -2.1 N/A 06/16/2010 -0.2 N/A -1.1 -0.6 N/A -3.7 07/21/2010 0.0 -1.7 N/A -0.3 -2.4 N/A 07/28/2010 -0.1 -0.7 N/A 0.0 -1.7 N/A N/A = not available

Table A-12. NO X CEM Drift

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 -0.1 -0.2 N/A 0.0 0.3 N/A 02/23/2010 0.0 -0.8 N/A 0.0 -1.7 N/A 04/07/2010 -0.2 -0.9 N/A 0.0 -1.6 N/A 04/21/2010 0.0 -0.6 N/A 0.0 -0.7 N/A 04/28/2010 0.0 -0.4 N/A 0.0 1.3 N/A 05/20/2010 -0.1 -1.4 N/A 0.1 -0.1 N/A 05/25/2010 0.3 -0.4 N/A -0.2 0.2 N/A 06/02/2010 -1.9 -0.3 N/A 0.0 -0.3 N/A 06/16/2010 0.2 N/A 0.0 0.1 N/A -2.5 07/21/2010 0.1 0.3 N/A -0.3 -0.7 N/A 07/28/2010 0.2 -0.1 N/A 0.0 -0.4 N/A N/A = not available120 

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Table A-13. Carbon Monoxide CEM Calibration Error

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.1 -0.4 0.1 0.2 1.9 0.6 02/23/2010 0.1 -0.4 0.1 0.2 1.9 0.6 04/07/2010 -0.2 -0.5 0.0 N/A N/A N/A 04/21/2010 -0.1 -0.5 -0.1 0.3 0.6 -0.5 04/28/2010 -0.2 -0.3 -0.1 0.5 1.2 -0.1 05/20/2010 -0.1 -0.5 0.0 0.0 0.4 0.4 05/25/2010 0.0 -0.4 -0.2 -0.2 0.9 0.5 06/02/2010 -0.5 -0.2 0.1 0.1 0.9 -0.2 06/16/2010 -0.3 -0.6 -0.4 0.0 0.9 0.6 07/21/2010 0.0 -0.2 0.1 0.5 1.3 0.4 07/28/2010 0.0 -0.4 -0.1 0.1 1.5 0.7 N/A = not available



### On April 7, 2010, and June 16, 2010, the calibratio n error and bias checks were not completed prior to beginning the Method 26A sampling; measurements aft er the bias check through the end of the test were assumed representative of the entire sampling perio d.
A.6 Method 10 Carbon Monoxide Quality Control


### Results of calibration error checks, bias checks an d drift checks for CO CEM are summarized in Tables A-14 through A-16. Calibration error, both upstrea m and downstream of the PM control device, was less than 2 % of span for CO. Bias checks, both upstrea m and downstream of the PM control device, were generally within 5 % of span for CO; mid-scale syst em bias at the PM outlet was >5 % on February 16 an d 23, 2010. Drift checks, both upstream and downstre am of the PM control device, were generally within 3 % of span for CO; mid-scale drift at the PM inlet was 5.2 % on June 16, 2010. These measurements are deemed reliable and adequate for this test program.121 

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Table A-14. Carbon Monoxide CEM System Bias

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 -0.4 0.1 N/A -3.2 -7.3 N/A 02/23/2010 0.1 0.1 N/A -3.4 -5.7 N/A 04/07/2010 0.2 -0.1 N/A N/A N/A N/A 04/21/2010 0.3 -0.1 N/A -0.2 -2.5 N/A 04/28/2010 0.4 -0.1 N/A -4.4 -4.9 N/A 05/20/2010 -0.7 -0.2 N/A -3.3 -3.2 N/A 05/25/2010 -0.8 -0.5 N/A -2.3 -3.9 N/A 06/02/2010 -0.3 -0.9 N/A -2.8 -4.5 N/A 06/16/2010 0.1 2.0 N/A -3.0 -4.8 N/A 07/21/2010 0.1 3.6 N/A -3.6 -4.7 N/A 07/28/2010 0.0 -0.2 N/A -2.6 -4.9 N/A N/A = not available

Table A-15. Carbon Monoxide CEM Drift

Date PM Inlet, % PM Outlet, %

Zero Mid-scale Up-scale Zero Mid-scale Up-scale 02/16/2010 0.5 0.0 N/A -0.2 1.6 N/A 02/23/2010 0.1 0.3 N/A -0.2 -1.1 N/A 04/07/2010 0.0 -0.3 N/A N/A N/A N/A 04/21/2010 -0.1 -0.4 N/A 1.4 2.2 N/A 04/28/2010 -0.2 -0.7 N/A 1.8 1.5 N/A 05/20/2010 0.5 -0.4 N/A -0.8 -2.0 N/A 05/25/2010 0.7 -0.3 N/A -0.2 -0.1 N/A 06/02/2010 0.0 -0.5 N/A -0.8 -0.7 N/A 06/16/2010 -0.6 -5.2 N/A -1.5 -0.8 N/A 07/21/2010 -0.2 0.1 N/A -0.2 -0.5 N/A 07/28/2010 -0.5 -0.2 N/A -0.3 -0.1 N/A N/A = not available122 

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Table A-16. TOC Calibration Error at PM Inlet Date Zero Low Level Mid-Level High Level 02/16/2010 N/A -0.3 -0.3 N/A 02/23/2010 N/A -0.3 -0.3 N/A 04/07/2010 N/A N/A N/A N/A 04/21/2010 N/A -0.2 0.0 0.2 04/28/2010 N/A -1.9 -1.1 -0.3 05/20/2010 N/A 0.0 -0.2 0.2 05/25/2010 N/A -0.2 -0.5 -0.1 06/02/2010 N/A 2.4 1.8 -0.1 06/16/2010 N/A N/A N/A N/A 07/21/2010 N/A N/A N/A N/A 07/28/2010 N/A N/A N/A N/A N/A = not available



### On April 7, 2010, and June 16, 2010, the calibratio n error and bias checks were not completed prior to beginning the Method 26A sampling; measurements aft er the bias check through the end of the test were assumed representative of the entire sampling perio d. In addition, the CO CEM at the PM outlet was no t functioning on April 7, 2010.
A.7 Method 25A Total Organic Carbon Quality Control



### Results of calibration error checks and calibration drift checks for TOC CEM are summarized in Tables A-17 and A-18 for the PM inlet location. Calibration er ror at the PM inlet was generally < 2 % of span for TOC; low-level calibration error on June 2, 2010, was 2. 4 % of span. Calibration drift checks were not consistently within 3 % of span for TOC at the PM i nlet; three of the seven tests in which the TOC CEM was functional failed to meet the 3 % criteria for one calibration gas. The TOC CEM typically reported ne gative concentrations for the test period. Two tests with positive PM Inlet TOC failed calibration drift tes ts. The TOC concentrations reported are, at best, indicativ e of low concentrations, perhaps < 10 ppmv propane. TOC concentrations in the test program cannot be pr oven to be significantly different from zero with t he measurement system employed.123 

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Table A-17. TOC Calibration Error at PM Inlet Date Zero Low Level Mid-Level High Level 02/16/2010 N/A -0.3 -0.3 N/A 02/23/2010 N/A -0.3 -0.3 N/A 04/07/2010 N/A N/A N/A N/A 04/21/2010 N/A -0.2 0.0 0.2 04/28/2010 N/A -1.9 -1.1 -0.3 05/20/2010 N/A 0.0 -0.2 0.2 05/25/2010 N/A -0.2 -0.5 -0.1 06/02/2010 N/A 2.4 1.8 -0.1 06/16/2010 N/A N/A N/A N/A 07/21/2010 N/A N/A N/A N/A 07/28/2010 N/A N/A N/A N/A N/A = not available

Table A-18. TOC Calibration Drift at PM Inlet Date Zero Low Level Mid-Level High Level 02/16/2010 -1.7 -0.7 N/A N/A 02/23/2010 0.9 N/A 4.8 N/A 04/07/2010 N/A N/A N/A N/A 04/21/2010 -0.3 -0.3 N/A N/A 04/28/2010 0.3 -10.4 N/A N/A 05/20/2010 -0.6 N/A -0.1 N/A 05/25/2010 0.2 N/A -0.6 N/A 06/02/2010 0.0 N/A -3.5 N/A 06/16/2010 N/A N/A N/A N/A 07/21/2010 N/A N/A N/A N/A 07/28/2010 N/A N/A N/A N/A N/A = not available124 

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### The TOC CEM failed to operate on several test days. Because of the consistent lack of measureable TOC , operation of this CEM was not considered critical t o these tests and testing proceeded without TOC CEM operation.
A.8 Method 5/29 Metals Quality Control


### All Method 29 samples for metals analysis were coll ected with coincident Method 5 particulate determination. The sample volumes for all these de terminations are considered reliable as the test me ters were calibrated before sampling and all test meters were within 5 % drift at the conclusion of samplin g. Several deviations from Method 29 sample requiremen ts were encountered during this test program. Flow measurements at the PM control outlet on February 1 6, 2010, failed to meet criteria for steady state operation with 13 % drift; though the run did pass with respect to an isokinetic sampling rate at 92 % of isokinetic. On May 20, 2010, the PM outlet velocit y determination appears to have been grossly in err or, resulting in failure of both steady state criteria, 112 % drift, and isokinetic criteria, 54 % of isok enetic based on post run velocity traverse; the initial velocity determination was used to set the constant samplin g rate for each test. On May 25, the PM outlet was oversample d resulting in a rate 124 % of isokinetic. All thr ee of these failures in sampling rate were at the PM outl et location which is less impacted by sampling rate

. The majority of laboratory quality control (QC) mea sures for accuracy, precision, and interference wer e within method acceptable criteria. Second source c alibration checks met the 10 % accuracy criteria fo r each analysis. Precision of duplicate analyses wer e generally within 20 relative % difference (RPD) w ith the exception of PM control outlet back-half antimo ny for the February 16, 2010 run, this analyte resu lted in 21.3 RPD. Interference was found in several analys es on various metals but was generally corrected through dilution; the exceptions were the PM contro l outlet back-half selenium spikes on May 25, 2010, and June 2, 2010, correlating with non-detect sample co ncentrations for selenium in both instances.
Method 29 field blanks were performed on February 1 6, 2010, and July 21, 2010. Beryllium and selenium were not detected in the field blanks and these ana lytes do not require qualification with respect to quantification. With the exception of PM control i nlet front-half results, most analyses failed to me et a 5 % contamination threshold based on field blanks. Res ults less than detection limits have been excluded in emission calculations. Results that are less than three times the highest field blank have been flagg ed as blank contaminated but are used in emission calcula tions.
In addition to the planned quality control measures , the reasonableness of the reported metal content was evaluated. The PM control outlet front-half minera l content on April 28, 2010, exceeded the mass of particulate collected in the front-half of the trai n; these results have been summarily excluded. All results from the PM control outlet front-half analysis on J uly 28, 2010, appear to be two orders of magnitude higher than expected and again exceed the mass of particul ate collected in the front-half; these results have been similarly excluded. Working with the analytical la boratory, we failed to identify any cause for these125 

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### abnormalities. Metals concentrations have been fla gged if analytical flagged data comprised 20 % or m ore of the total metal. PM control inlet concentration s are not significantly impacted by flagged data. PM control outlet concentrations are generally confoun ded with blank compromised data; these concentratio ns may be biased to the high side since blanks are not subtracted in this analysis.
A.9 Method 26A Halides Quality Control



### Method 26A was used to determine halide concentrati ons downstream of the PM control device and downstream of the scrubber; the sample location dow nstream of the PM control device is the sample poin t immediately upstream of the scrubber. The sample v olumes for all these determinations are considered reliable as the test meters were calibrated before sampling and all test meters were within 5 % drift at the conclusion of sampling. No evaluation of steady-st ate operation can be made for the April 7, 2010 tes t based on Method 2C traverses since only pre-test tr averses were performed; stability of oxygen and car bon dioxide concentrations and general agreement with f lows, measured June 16, 2010, suggest flow was at steady state. Isokinetics for Method 26A samples r anged from 94.7 to 102.1 %, well within the 100 % g oal (± 10%) of the test program. Method 26A sample ext raction was considered representative for the purposes of this test program.
The majority of laboratory QC measures for accuracy and precision were within method tolerances. Second source calibration checks met the 10 % accur acy criteria for each analysis as specified in the QAPP in lieu of an EPA audit sample. Each sample was an alyzed in duplicate; the precision was within 5 RPD for each analysis. The laboratory did note, however, t hat neutralization capacity of the sodium hydroxide fraction of the April 7, 2010, scrubber inlet sampl e had been exceeded resulting in an acidic fraction . As a result, the Cl 2 

### analysis for this sample must be suspect, biased l ow, because acidic solutions are not effective at capturing Cl 2 

### . Blanks performed in coordination with the April 7, 2010, samples resulted in no detections for both th e acid and basic fractions. The June 16, 2010, scrubber i nlet samples used a stronger base, 1 Normal sodium hydroxide, to increase the neutralization capacity of the impinger. The 1 Normal sodium hydroxide was also run as a blank resulting in no detections for Cl 2 

### . A.10 Method 0010 Semi-Volatile Organic Compounds


### M0010 is an isokinetic sampling method. The partic ulate and front-half rinse were digested and analyz ed with the resin. The sampling objective was to main tain sampling rates between 90 and 110 % of the ide al isokinetic rate. Three sampling runs at the PM out let location (February 23, May 20, and May 25 runs) failed to meet this standard with 117-, 57-, and 12 4 % isokinetic, respectively. Thirteen of the eigh teen Method 0010 sampling runs met this standard. Due t o the depletion of large particles, isokinetic performance is very unlikely to have affected SVOC collection efficiency, due to the fact that small p articles126 

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### follow streamlines characteristic of a gas. Any SV OCs associated with such small particles would then be collected and analyzed in the same proportion as th e metered gas sample. Two sampling runs at the PM inlet location (June 2 and July 21 runs) failed to meet the isokinetic standard with 75- and 80 % isok inetic, respectively. The overall effect on SVOC concentra tion is unknown but should be less than the isokine tic error, as many compounds are gaseous at stack tempe ratures (~250 °F) and would be unaffected by isokinetic error. The sample volumes for all of th ese determinations are considered reliable, as the test meters were calibrated before sampling and all test meters were within 5 % drift at the conclusion of sampling.
Samples from the first two tests (February 16 and F ebruary 23 runs) were analyzed by Research Triangle Park Laboratories, Inc. This laboratory did not us e a K-D (Kuderna-Danish) concentrator when processi ng samples. Method spike recoveries, comparable to a second source standard, for the full-scan target analyte list were generally poor for lower molecula r weight compounds and generally improved for highe r molecular weight compounds; this is consistent with the use of a single-stage evaporation-type concent rator. Of the 71 target analyte compounds, 42 achieved met hod spike recoveries of < 70 %; all target analyte list compounds achieved < 130 % recoveries. Surrogate s pikes were in line with these results with the lowe r molecular weight compounds exhibiting poor recoveri es:



# • 2-Fluorophenol 2.1 – 24.2% recovery



# • Phenol-d6 8.8 – 36.0% recovery



# • Nitrobenzene-d5 15.7 – 31.3% recovery



# • 2-Fluorobiphenyl 45.8 – 94.5% recovery



# • 2,4,6-Tribromophenol 27.0 – 65.8% recovery



# • Pyrene-d10 59.8 – 105% recovery



# • P-Terphenyl-d14 61.7 – 107% recovery
A duplicate analysis of a February 16, 2010, scrubb er inlet concentrate indicates good precision; all target analyte list compounds detected and surrogate spike s were within the 50 RPD goal. Di-n-butyl phthalat e, Bis(2-ethylhexyl) adipate, Bis(2-ethylhexyl) phthal ate were found above the reporting limit in the ful l-scan field blank; Di-n-butyl phthalate was found above t he reporting limit in the full-scan method blank. Fluorene was found above the reporting limit in both the (SI M) field blank and method blank.127 

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### Samples from the remaining tests were analyzed by A ir Toxics, Ltd. This lab appears to be fully compl iant with M0010 procedures. Continuing calibration veri fication standards confirm analytical accuracy with in acceptance limits for all samples. Surrogate spike s were generally acceptable meeting the objectives set for this test program:



# • 2-Fluorophenol 67-91% recovery



# • Phenol-d5 68-99% recovery



# • Nitrobenzene-d5 66-102% recovery



# • 2-Fluorobiphenol 69-86% recovery



# • 2,4,6-Tribromophenol 94-134% recovery



# • Terphenyl-d14 66-130% recovery



# • Fluoranthene-d10 54-93% recovery



# • Benzo(a)pyrene-d12 39-92% recovery
2,4,6-Tribromophenol failed the lab-established QC criteria for four samples but met the test program objectives of <150 % recovery for all surrogates. Fluoranthene-d10 and Benzo(a)pyrene-d12 were pre-sampling spikes. Benzo(a)pyrene-d12 failed lab -specific QC and the test program objective of 50 % recovery for the April 20, 2010, ESP inlet sample. Duplicate digest analysis performed with each lab set indicates good precision; all target analyte list c ompounds detected and surrogate spikes were within the 50- RPD goal established for these tests. Two field bl anks from this test series were analyzed by the laboratory; field blanks quantified benzoic acid, n aphthalene, 2,6-dinitrotoluene, di-n-butylphthalate , butylbenzylphthalate, 3,3'-Dichlorobenzidine, and B is(2-ethylhexyl) phthalate. All data less than 3 t imes the highest field blank concentration were flagged; an emission rate was calculated for blank-impacted dat a without any correction, but these data were conside red non-detects.
A.11 Method 0011 Carbonyls


### M0011 is an isokinetic sampling method and was run as an isokinetic method despite the addition of a f ilter before the impingers in this test program. The obj ective was to maintain sampling rates between 90 an d 110 % of the ideal isokinetic. Two sampling runs, sampled after the PM control, failed isokinetic goa ls. One run was operated at 52 % isokinetic and the oth er at 125 %. Due to the low concentration of large particles after the PM device, isokinetic performan ce is less critical for any particle-bound analyte. A filter128 

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### was inserted to provide particulate sample for subs equent organic carbon/elemental carbon analysis; a filter was not included in the M0011 recovery for carbonyl s. This failure is not expected to materially affe ct the data. The sample volumes for all of these determin ations are considered reliable, as the test meters were calibrated before sampling, and all test meters wer e within 5 % drift at the conclusion of sampling.
All M0011 samples were analyzed in duplicate and wi th a laboratory audit sample; no matrix spike was applied to the samples. All duplicate analysis wer e within the 30-RPD goal set for this test program. All audit sample results were within the 10 % accuracy goal set for this test program. One field blank wa s prepared. The field blank contained quantifiable a mounts of formaldehyde and acetaldehyde. All data less than three times the highest field blank conce ntration were flagged; an emission rate was calcula ted for blank-impacted data without any correction, but the se data were considered non-detects.
A.12 Method 0031 Volatile Organic Compounds


### M0031 samples were collected in a non-isokinetic fa shion at the PM inlet location. Sample locations w ere near bends in ductwork, however, this was not deeme d important for these samples since organics were expected to be gaseous at sampling temperatures. T he sample volumes for all these determinations are considered reliable, as the test meters were calibr ated before sampling, and all test meters were with in 5 % drift at the conclusion of sampling. Samples are c ollected in three sets for each run with each set consisting of two Tenax tubes in series followed by an Anasorb tube.
M0031 samples from tests on or before April 28, 201 0, were analyzed by Research Triangle Park Laboratories. For the February 16 and February 23 tests, the Tenax tubes were analyzed separately fro m the Anasorb tubes in each set. Surrogate recoverie s, summarized in Table A-19, were generally within the 50- to 150 % recovery objective set for this test p rogram. The low bromochloromethane surrogate recov ery for one Anasorb set had an unknown impact on data q uality for that set, as Anasorb is intended to coll ect low boiling compounds. The high 1,4-difluorobenzen e recoveries for Anasorb are not likely to impact d ata quality for these sets.
For the April 21 and April 28 tests, all three tube s from each set were analyzed together. Surrogate recoveries are summarized in Table A-20. All of th ese sets satisfied the 50- to 150 % surrogate recov ery goal established for this test program.

Table A-19. M0031 Surrogate Recovery Summary for F ebruary16, 2010, and February 23, 2010 Surrogate Condensate, % Tenax, % Anasorb, % 1,4-Difluorobenzene 99-123 117-131 72-174 Bromochloromethane 61-80 71-93 44-107129 

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Table A-20. M0031 Surrogate Recovery Summary for A pril 11, 2010, and April 28, 2010 Surrogate Condensate, % Tubes, % 1,4-Difluorobenzene 53-57 62-84 Bromochloromethane 109-113 111-146



### M0031 samples from the remaining tests were analyze d by Air Toxics, Ltd. The Tenax tubes were analyzed separately from the Anasorb tubes in each set. Surrogate recoveries are summarized in Table A21. Surrogate recoveries were generally acceptable . Low recoveries for Toluene-d8 for Anasorb sets a re not likely to significantly impact results since An asorb is intended to collect low boiling compounds after Tenax. Low recoveries of 4-bromofluorobenzene in T enax have an unknown impact on the data quality in this range but is only slightly outside the objecti ve of 50- to 150 % recovery.

Table A-21. M0031 Surrogate Recovery Summary for M ay 25, 2010, through July 28, 2010.

Surrogate Condensate, % Tenax, % Anasorb, % Dibromodifluoromethane 98-107 83-104 102-144 1,2-Dichloroethane-d4 96-112 65-116 82-149 Toluene-d8 98-107 81-101 42-104 4- Bromofluorobenzene 94-107 43-106 N/A N/A = not available



### A M0031 field blank was collected with the February 16, March 21, and May 25 samples, as well as every subsequent sample. Blanks were analyzed in the sam e manner as the traps for the accompanying samples. A significant number of compounds were fo und in the blanks. Samples were validated against blank values for the corresponding fraction: Tenax compared to Tenax, Anasorb compared to Anasorb. VOCs detected in samples at less than three times t he blank concentration were considered non-detects. No correction was applied for blank contamination. All analysis included the laboratory’s full 8260 l ist without regard for whether a compound had been vali dated for this method or if it were a HAP.

A.13 Method 0040 Methane


### Methane was sampled with a M0040 train into a Tedla r bag at the PM outlet. Sample extraction was nonisokinetic occurring during a small fraction of the sample window for concurrent organics samples with M0010, M0011, and M0031. Samples were analyzed by gas chromatography/flame ionization detector using ASTM D-2820 (withdrawn) by Research Triangle Park Laboratories, Inc. Since only methane was of interest, the condensate was not analyzed. Methane was not considered a critical parameter to the130 

### Surrogacy Testing in the MPCRF

Draft Final Report



### performance of this project but provided ancillary information. As a result, no data quality indicato r goals were established in the QAPP for this measurement. The laboratory performed 4 point calibration and a calibration curve check; all calibration curve chec k results were within 10% of the standard. In addi tion, a field blank was performed April 21, 2010, by fillin g a Tedlar bag with nitrogen; blank analysis was be low reporting limits of 1.0 ppmvd.End of Document