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 29
ii 

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 66
iii 

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 111
iv 

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 Conditions 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 February 16, 2010 21

Table 3-4. M0010 SIM Emission Summary for February 16, 2010 22

Table 3-5. M0011 Carbonyl Emission Summary for February 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 February 23, 2010 30

Table 3-10. M0010 SIM Emission Summary for February 23, 2010 31

Table 3-11. M0011 Carbonyl Emission Summary for February 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 35

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 April 21, 2010 39
v 

Table of Contents 

Table 3-18. M0010 SIM Emission Summary for April 21, 2010 40

Table 3-19. M0011 Carbonyl Emission Summary for April 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 April 28, 2010 45

Table 3-24. M0010 SIM Emission Summary for April 28, 2010 46

Table 3-25. M0011 Carbonyl Emission Summary for April 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 May 20, 2010 52

Table 3-30. M0010 SIM Emission Summary for May 20, 2010 53

Table 3-31. M0011 Carbonyl Emission Summary for May 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 May 25, 2010 59

Table 3-36. M0010 SIM Emission Summary for May 25, 2010 60

Table 3-37. M0011 Carbonyl Emission Summary for May 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 June 2, 2010 66

Table 3-42. M0010 SIM Emission Summary for June 2, 2010 67

Table 3-43. M0011 Carbonyl Emission Summary for June 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 72

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 July 21, 2010 76

Table 3-50. M0010 SIM Emission Summary for July 21, 2010 77

Table 3-51. M0011 Carbonyl Emission Summary for July 21, 2010 78
vi 

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 July 28, 2010 83

Table 3-56. M0010 SIM Emission Summary for July 28, 2010 84

Table 3-57. M0011 Carbonyl Emission Summary for July 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 114

Table A-6. Carbon Dioxide CEM System Bias 114

Table A-7. Carbon Dioxide CEM Drift 115

Table A-8. SO2 CEM Calibration Error 117

Table A-9. SO2 CEM System Bias 117

Table A-10. SO2 CEM Drift 118

Table A-11. NOX CEM System Bias 119

Table A-12. NOX 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 February16, 2010, and 

February 23, 2010 128

Table A-20. M0031 Surrogate Recovery Summary for April 11, 2010, and April 

28, 2010 129

Table A-21. M0031 Surrogate Recovery Summary for May 25, 2010, through 

July 28, 2010. 129
vii 

Table of Contents 

List of Figures 

Figure 1-1. Overhead View of the Multipollutant Control Research Facility 2

Figure 2-1. Estimated MPCRF Residence Time-Temperature Profile during 

Tests Using Eastern Bituminous Coal 7

Figure 2-2. Estimated MPCRF Residence Time-Temperature Profile during 

Tests Using PRB Sub-bituminous Coal 8

Figure 2-3. Estimated MPCRF Residence Time-Temperature 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 CO Summary for July 21, 2010 73

Figure 3-11. PM Control Device Inlet Diluent and CO Summary for July 28, 2010 80

Figure 4-1. Control of PM and Antimony in MPCRF Tests 87

Figure 4-2. Control of PM and Arsenic in MPCRF Tests 88

Figure 4-3. Control of PM and Beryllium in MPCRF Tests 88

Figure 4-4. Control of PM and Cadmium in MPCRF Tests 89

Figure 4-5. Control of PM and Chromium in MPCRF Tests 89

Figure 4-6. Control of PM and Cobalt in MPCRF Tests 90

Figure 4-7. Control of PM and Lead in MPCRF Tests 90

Figure 4-8. Control of PM and Manganese in MPCRF Tests 91

Figure 4-9. Control of PM and Nickel in MPCRF Tests 91

Figure 4-10. Control of PM and Selenium in MPCRF Tests 92

Figure 4-11. Acenaphthylene Concentrations versus CO Concentrations 94

Figure 4-12. Anthracene Concentrations versus CO Concentrations 95

Figure 4-13. Fluoranthene Concentrations versus CO Concentrations 96
viii 

Table of Contents 

Figure 4-14. Pyrene Concentrations Versus CO Concentrations 96

Figure 4-15. Benzo(a)anthracene Concentrations Versus CO Concentrations 97

Figure 4-16. Phenol Concentrations Versus CO Concentrations 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 Versus CO Concentrations 101

Figure 4-23. Methylene Chloride Concentrations Versus CO Concentrations 102

Figure 4-24. Chloroform Concentrations Versus CO Concentrations 102

Figure 4-25. Carbon Tetrachloride Concentrations Versus CO Concentrations 103

Figure 4-26. Benzene Concentrations Versus CO Concentrations 103

Figure 4-27. Toluene Concentrations Versus CO Concentrations 104

Figure 4-28. Ethyl Benzene Concentrations Versus CO Concentrations 104

Figure 4-29. o-Xylene Concentrations Versus CO Concentrations 105

Figure 4-30. Styrene Concentrations Versus CO Concentrations 105

Figure 4-31. Iodomethane Concentrations Versus CO Concentrations 106

Figure 4-32. 1,4-dioxane Concentrations Versus CO Concentrations 106
ix 

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 

Fd 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 

MWt 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 Basin 
x 

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-Ignition 

TOC Total Organic Carbon 

VOC Volatile Organic Compound 

vol%d Volume % Dry 

μg Microgram 

μm Micrometer 
1 

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 wide ranging 

and cover a number of HAP emissions. Control of some HAP emissions is expected to coincide with 

control of other pollutants, such as criteria pollutants. The use of other pollutants or process conditions as 

a surrogate for HAP emissions can simplify both the rule development and the monitoring regime required 

under a MACT rule. 

In order to evaluate potential surrogacy relationships, the EPA Office of Research and Development (ORD), 

in collaboration with the Office of Air and Radiation (OAR), conducted a series of tests in the Agency’s 

Multipollutant Control Research Facility (MPCRF), a pilot-scale combustion and control technology research 

facility located at EPA’s Research Triangle Park, North Carolina, (RTP) campus. Eleven independent tests 

were performed in the MPCRF in order to examine potential surrogacy relationships. Three types of coal 

(bituminous, sub-bituminous, and Gulf Coast lignite) were tested. The particulate matter (PM) control was 

also varied; in some tests, the electrostatic precipitator (ESP) was used whereas the fabric filter (FF) was 

used in others. Three potential surrogacy relationships were examined during the testing program. The 

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 potential for acid gas control to predict the control of halide 

HAPS (HCl, HF, Cl2) was studied. In addition, several potential surrogate relationships were examined for 

the non-dioxin/furan organic HAP. No surrogate studies were conducted for Hg because there are no plans 

to use a surrogacy approach for Hg control. No surrogacy studies were conducted for dioxin/furan organic 

HAP as it was anticipated that levels of these compounds 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 pilot 

system. 

This report presents the results of the MPCRF test program and examines the behavior of HAP 

concentrations or control with that of potential surrogates. 

1.2 Multipollutant Control Research Facility 

The MPCRF is a pilot-scale combustion research facility 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 MMBtu/hr, 

approximately 1.2 megawatt-thermal (MWt), and is capable of burning a variety of fuels including pulverized 

coal of various ranks. The facility consists of a down-fired refractory-lined furnace with low-NOX burner. 

The flue gas exits the furnace into a duct system that is equipped with a number of downstream heat 
2 

Surrogacy Testing in 

the MPCRF 

Draft Final Report 

exchangers to preheat combustion air, simulate superheater outlet conditions, and simulate air heater outlet 

conditions. The system is equipped with a selective catalytic reduction (SCR) unit with a Cormetech 

V2O4/WO3 catalyst and ammonia injection for NOX control. The flue gas may be routed through the ESP 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 SO2 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 Control Research Facility 

1.2.1 Furnace 

The furnace consists of a refractory-lined shell with a 42-inch bore and a multi-fuel burner in a down-fire 

orientation. The burner design is based on the movable-block swirl-adjustment technology developed by

the International Flame Research Foundation. The burner has separate, dedicated injection ports for gas, 

secondary combustion air, and coal/conveying air (primary air). The burner’s central “bluff body” pipe 

receives either the burner igniter or the oil gun. All fuel feed systems are connected to a single flame safety 

system and can be selected individually or in any co-firing combination. 
3 

Surrogacy Testing in 

the MPCRF 

Draft Final Report 

In its current configuration, the MPCRF can support a firing rate between 2.7 and 3.0 MMBtu/hour on coal. 

Coal is pulverized in an on-site hammer mill separate from combustion operations. Coal is fed with a losson weight feeder and pneumatically conveyed to the burner with primary air. Secondary air is heated prior 

to combustion with an air-to-air heat exchanger; secondary air temperature is controlled with dampers 

bypassing the heat exchanger. Combustion stoichiometry 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 and a soot blower. The SCR is operated at a temperature 

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 injection 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 catalyst 

section. 

The V2O4/WO3 catalyst used in this system was manufactured by Cormetech. Each section contains nine 

honeycomb catalyst elements of 1190 mm length and 150 mm square cross-section. The catalyst was 

extracted from a full-scale 300 MW unit after approximately 15,000 hours in DeNOX service firing low-sulfur 

eastern bituminous fuel. The DeNOX activity compared to fresh catalyst was estimated by Cormetech to 

have a 0.8 to 0.9 K/Ko value. 

For these tests NH3 was injected to achieve a targeted NOX reduction of 90%. Neither the specific NH3

flowrate, nor any NH3 slip, was measured for any of the tests. 

1.2.3 Electrostatic Precipitator 

The ESP was designed to capture fly ash from flue gas generated by the combustion of lignite, subbituminous, and bituminous coal. The system is a “dry” design and includes mechanical rappers to remove 

the collected fly ash cake from the collection plates. 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 ft2 of collecting electrode plate 

surface. Collected solids are discharged through a rotary valve mounted on the bottom of the unit. The 

specific collection area (SCA) of the unit is 646 ft

2

/1000 acfm. For these tests, the ESP collection plates 

were cleaned (rapped) and the collection hopper was emptied prior to each test. 
4 

Surrogacy Testing in 

the MPCRF 

Draft Final Report 

1.2.4 Baghouse Fabric Filter 

The baghouse stands nearly 32 ft tall and has an approximate 6 ft x 6 ft footprint. It contains 24 Ryton bags 

(6-in diameter, 8 ft long) accessible through a walk-in plenum above the bags. In operation, flue gas

passes into the baghouse through a sidewall under the 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 are 

pulsed from above, dislodging the dust cake into the hopper. After passing into the bags, the flue gas 

exits through the tube sheet and exits the outlet plenum to the wet lime scrubber. 

For these tests, the baghouse ∆P varied steadily between 3" and 4" H2O (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. For these tests, the baghouse was cleaned (pulsed) and the 

collection hopper was emptied prior to initiation of each test. 

1.2.5 Wet Lime Flue Gas Desulfurization 

Sulfur dioxide is controlled with a wet lime scrubber, a Croll-Reynolds Multi-Rod Deck Scrubber. The MultiRod Deck scrubber is a counter-current vertical column utilizing multiple sections of parallel rods in series for 

gas/liquid contact. Scrubber slurry is sprayed uniformly over the entire cross section of the rod deck. 

Scrubber slurry passes through the rod decks, removing SO2 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. Scrubber 

slurry is then recirculated from the hold tank to remove additional SO2. The scrubber is designed to 

achieve >95 % of SO2 removal at 1200 scfm. The gas existing the scrubber rod decks enters a chevronblade type mist eliminator en route to the induced draft fan. The absorber system does not exceed 6-in 

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 scrubbers” generating increased gas velocity and producing 

much the same effect as a conventional venturi scrubber. In addition, a turbulent “froth” layer is formed 

above the rod decks that provides extremely agitated mixing of the gas and liquid streams and excellent 

gas/liquid contact with highly effective mass transfer. 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 presence 

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 surfaces and is, therefore, self-cleaning. 

For all of these tests, the scrubber recycle varied between 70 and 80 gpm. The liquid-to-gas ratio, the L/G, 

was around 75 gallons per 1000 acf of flue gas. Previous measurements under the same operating 

conditions and using the same bituminous coal that was used in these tests have shown SO2 control of 

98.8%. 
5 

Surrogacy Testing in 

the MPCRF 

Draft Final Report 

1.3 Testing Program 

In order to evaluate potential surrogacy relationships, ORD, in collaboration with OAR, implemented a test 

program using the MPCRF. The objective of the testing program was to collect selected HAP emission 

data while firing various coals under varied test conditions 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 through the primary PM control device (both the ESP and

the FF) and compare that to the control of the filterable PM; (2) to measure concentrations of nondioxin/furan organic HAP and compare to the emission of candidate surrogates (e.g., CO, total 

hydrocarbons, etc.), and (3) to evaluate halide removal 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 designed to capture concentrations effects resulting from 

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 replication is provided in the test matrix by repeating test 

conditions. The system was routinely cleaned between coal types (and sometimes between tests) to avoid 

cross contamination. 

Table 1-1. Summary of MPCRF Surrogacy Test Conditions 

Test Date Coal Type PM Device 

 Principle 

Components 

Measured 

Control Technique 

Evaluated 

2/16/2010 Bituminous ESP PM, metals, organics PM, Combustion 

2/23/2010 Bituminous ESP PM, metals, organics PM, Combustion 

4/07/2010 Bituminous ESP Acid gases, halides Scrubber 

4/21/2010 Bituminous ESP PM, metals, organics PM, Combustion 

4/28/2010 Bituminous FF PM, metals, organics PM, Combustion 

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 PM, Combustion 

6/16/2010 Bituminous ESP Acid gases, halides Scrubber 

7/21/2010 Lignite ESP PM, metals, organics PM, Combustion 

7/28/2010 Lignite FF PM, metals, organics PM, Combustion 
6 

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7 

Surrogacy Testing in 

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Draft Final Report 

2. Methods and Materials 

The MPCRF is a pilot facility operated in a semi-continuous manner. The furnace was fired with natural 

gas to approach steady-state thermal conditions prior to burning coal. Coal feed for each test was initiated 

prior to initiating manual sampling procedures to allow 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. Unfortunately it was necessary because the combustor would 

run too close to its high-temperature limit at lower SR values. 

Coal feed rate was based on estimated higher heating value at the time of the test; coal analysis from

operations were used to determine actual firing rate and SR after the fact. The estimated TimeTemperature profiles through the MPCRF are illustrated in Figures 2-1 through 2-3 for eastern bituminous, 

Powder River Basin (PRB) sub-bituminous, and Gulf Coast lignite metals and organics tests, respectively. 

NOX 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 NOX concentration at the 

PM control device inlet before commencing ammonia injection. Ammonia injection was begun at least 1 

hour prior to testing to allow the catalyst to achieve steady-state operation. 

Residence Time, seconds

Temperature, °C

Furnace 

Outlet

SCR Inlet

PM Inlet

Figure 2-1. Estimated MPCRF Residence Time-Temperature Profile during Tests Using Eastern Bituminous Coal 
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Residence Time, seconds

Temperature, °C

Furnace Outlet

SCR Inlet

PM Inlet

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

Coal 

Residence Time, seconds

Temperature, °C

Furnace Outlet

SCR Inlet

PM Inlet
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Figure 2-3. Estimated MPCRF Residence Time-Temperature Profile during Tests Using Gulf Coast Lignite 

Original test plans included furnace operation at nominal 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 portions of the furnace, either with a bayonet heat exchanger 

(a water-cooled tube inserted in the upper combustion zone) or by reducing secondary combustion air preheat. After the first test on February 16, 2010, operation at intentionally non-ideal conditions was 

abandoned due to budget and schedule constraints. However, in tests using the Gulf Coast lignite, the 

bayonet heat exchanger was needed to maintain acceptable operating temperatures at the top of the 

furnace. 

Three coals were burned in this test program: an eastern bituminous, a PRB sub-bituminous, and a Gulf 

Coast lignite. Samples of the pulverized coal were collected from the feeder during each test day. Coal 

samples from multiple runs with the same coal were composited and subsequently analyzed. Bituminous 

coal from the first two tests were composited separately from the last two bituminous coal tests because of a 

planned delay; analytical results were evaluated after the first two tests to ensure components were 

measureable with the sampling methods as implemented. Coal was analyzed by Standard Laboratories, 

Inc. (Cressen, PA) using ASTM International procedures. Table 2-1 summarizes the coal properties on an 

as-fired basis and the analytical methods used. EPA Method 19 was used to determine a coal specific Ffactor (Fd) 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-bituminous coal had been stored for several months in a

covered facility prior. The Gulf Coast lignite was delivered just before use. Both fuels were pulverized 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 be performed, sampling and analytical procedures, and 

certain data validation and reporting procedures. The data generated from this test program was compiled 

in a separate data package containing MPCRF operations information, continuous emission monitor (CEM) 

data, sampling data, and analytical results. An evaluation of data quality with respect to QAPP identified 

data quality indicators is attached in Appendix A of this report. For the purposes of this report, analytical 

results below detection limits were treated as zero in emission control evaluations. EPA source methods, 

described in 40 CFR part 60 Appendix A, were used for PM, metals, halides, and CEM analysis. EPA 

Office of Solid Waste methods (i.e., SW-846) were used for speciated organics analysis. Analytical 

methods were selected to be consistent with the utility Information Collection Request and to minimize

detection limits. Furthermore, extractive sampling was generally extended to 4 hours to achieve minimum 

detection limits within the constraints imposed by MPCRF pilot operations; a steady-state sampling window 

longer than 4 hours could not be assured. For each test, all components were sampled concurrently to 

ensure samples reflected the same combustion conditions. Due to the size of the MPCRF ductwork and 

the number of concurrent samples, flow was evaluated with Method 2C before and after each test while 
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sampling under the assumption of steady state operations. Isokinetic samples were collected at a single 

point of average flow at the center of the duct; locations were selected meeting undisturbed straight run flow 

criteria of 8 duct diameters upstream and 2 duct diameters downstream. 
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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 21.56 

Ash, % [ASTM D3174] 7.58 7.45 6.39 11.26 

Ultimate 

Sulfur, %S [ASTM D4239 Method B] 2.00 1.88 0.74 0.84 

Carbon, %C [ASTM D3178, D5373] 73.61 74.12 56.08 45.35 

Hydrogen, %H [ASTM D3178, D5373] 5.10 4.93 3.69 3.43 

Nitrogen, %N [ASTM D3179, D5373] 1.61 1.49 0.82 0.89 

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 

Fd, 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 available 
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PM and metals were concurrently sampled upstream and downstream of the PM control device using 

combined EPA Method 5 and Method 29 (Method 5/29) train. Samples were analyzed by Element One, 

Inc., Wilmington, NC. An example Method 5/29 sampling train is shown in Figure 2-4; since mercury was

not evaluated in this test program, the permanganate (KMnO4/H2SO4) impingers were excluded in these 

tests. PM concentrations were evaluated from the front-half catch, the particulate collected on the filter 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 concentrations are generally gaseous passing through the filter and 

are collected in the impingers and glassware rinses after the filter. Particulate samples were also collected 

after manual sampling events using a Method 17 train; 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 Train 
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For two runs, halides were concurrently sampled upstream and downstream of the scrubber using EPA 

Method 26A. Samples were analyzed by Resolution Analytics, Inc., Sanford, NC. Due to the amount of 

acid gas present in the upstream samples, the alkali in the second Method 26A impinger was exhausted in 

the first halide test performed on April 7, 2010 resulting in compromised Cl2 collection. The second test 

performed on June 16, 2010 utilized higher concentration sodium hydroxide and shorter sampling time with 

resulting smaller sample volume to avoid exhaustion of the alkali in the second Method 26A impinger. 

CEMs sampled upstream and downstream of the PM control device using single point extraction and source

sampling procedures: 

• Method 3C for O2/CO2 [California Analytical Instruments Model 200 & Model 600 analyzers] 

• Method 6C for SO2 [Advance Pollution Instrumentation Model 100AH analysers] 

• Method 7E for NOX [Teledyne Model 200E analyzers] 

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

• Method 25A for Total Organic Carbon (TOC) [Horiba Model 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 delivered to the CEM in a heated line resulting in wet basis 

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 single analytical fraction for each train. Each analytical 

fraction was analyzed for the laboratory’s full-scan target analyte list and by selective ion monitoring (SIM) 

for a group of polycyclic aromatic hydrocarbons (PAH). Two independent analytical laboratories were 

utilized for M0010 analysis resulting in slightly different full-scan target components. Samples from the first 

two tests (February 16 and February 23 runs) were analyzed 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 carbon concentrations not included in this report; carbon 

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 location. Samples were analyzed by Resolution Analytics, 

Inc., Sanford, NC. 
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Volatile organic compounds (VOC) using SW-846 Method 0031 (M0031) were sampled upstream of the PM 

control device. Each sample consisted of three sets of traps, two tenax and one anasorb, and condensate 

for the entire sample. Each set of traps was analyzed independently for the laboratory’s target analyte list. 

Traps were often grouped within each set with the two tenax traps analyzed together and the anasorb trap 

analyzed separately. Two independent analytical laboratories were utilized for M0031 analysis resulting in 

slightly different full-scan target components. Samples from tests on or before April 28, 2010, were 

analyzed by Research Triangle Park Laboratories, Inc. (Raleigh, NC). Samples from the remaining tests

were analyzed by Air Toxics, Ltd. (Folsom, CA). 

Methane was sampled from downstream of the PM control device using a Method 0040 (M0040) train. A 

non-isokinetic sample was collected in a Tedlar bag and delivered to a local laboratory, Research Triangle 

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 trains was dictated by test objectives. Other sampling

locations were determined by availability of a sampling port. Filterable PM and total HAP metals were

sampled upstream and downstream of the PM control device in order to characterize the control of the 

metals relative to the filterable PM. The semi-volatile 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 the 

carbonyls and the volatile organics were measured downstream of the PM control device due to availability 

of sampling ports and the assumption that the PM control device would not affect their concentrations. No 

measurements of PM or organics were taken downstream of the wet-FGD scrubber even though the 

scrubber can be expected to further reduce the concentrations of PM and some organics. This was due to 

budget limitations and because doing so would complicate efforts to quantify removal of HAP metals across 

the PM control device and would complicate efforts to quantify the formation of some organic species. 
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3. Daily Run Summary 

3.1 MPCRF Run February 16, 2010 

The MPCRF burned eastern bituminous coal on February 16, 2010. The objective of the test was to collect 

data 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 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 order to maintain furnace temperature. The natural gas-firing 

lasted approximately 5 minutes before coal feeding could be re-established. Sampling continued through 

the shutdown and during re-establishment of test conditions. Diluent and CO concentrations during the test 

period are shown in Figure 3-1. The furnace shutdown was observed in CEM data with a spike in CO and 

O2 concentration between 12:30 and 13:00. Particulate 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 the 

subsequent test (on February 23, 2010) showed that 18 % of the coal particles were larger than 28 mesh

(595 μm). Inspection of the coal mill screen showed damage to the screen. The large coal particle size 

and likely the use of the bayonet heat exchanger was believed to contribute to higher than expected TGALOI. The coal mill screens were replaced for subsequent runs. 
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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, 2010 
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NOX concentration at PM control inlet before beginning ammonia addition to SCR was 453 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 80 ppmv dry, an 82 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 9.8 11.1 

CO2, vol%d 10.0 8.9 

SO2, ppmvd* 1109 1089 

NOX, 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 concentration of metals in the coal, upstream of the PM control 

device, and downstream of the PM control device is also summarized in Table 3-2. Concentrations at the 

PM control device inlet are generally less than the metals input based on the coal sample or the respective 

detection limit in the coal sample. This is often the also case for similar measurements in subsequent tests. 

This is due, in part, to some accumulation of particulate matter in upstream control equipment (e.g., SCR, 

heat exchangers) and in the duct work. At the PM control device inlet, a significant fraction of each analyte 

reported to the back-half of the Method 29 train; the back-half catch represented the majority of the 

concentrations for antimony, boron, and selenium. This was due, in part, to some particulate carryover to 

the back half for this sampling train. At the PM control device outlet, most of the selenium and boron 

reported to the back-half of the Method 29 train along 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 would be 

27.2 % of the measured concentrations. 
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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 available 
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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 available at the ESP Outlet sampling location (we did not sample 

the ESP inlet). The highest M0010 concentrations indicated in the full-scan analysis are phenol and 

diethylphthalate. PAH concentrations detected in full-scan M0010 analysis include naphthalene, 

acenaphthylene, phenanthrene, anthracene, fluoranthene, 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 failed to detect 

pyrene which was quantified in full-scan analysis. 
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Table 3-3. M0010 Full-Scan Emission Summary for February 16, 2010 

Analyte 

ESP Out 

μg/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 blank
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Table 3-4. M0010 SIM Emission Summary for February 16, 2010 

Analyte 

ESP Out 

μg/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 detected 
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3.1.3 Carbonyls – February 16, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-5 from the February 16, 2010, test. Due to 

sampling error, M0011 concentrations were sampled at 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 M0011 impingers. 

Of the five carbonyl compounds quantified, acetaldehyde 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 concentrations. 

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

Analyte 

ESP In 

μg/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 detected at 1.6 ppmvd. Correcting for dilution at the PM 

outlet sample location results in 2.7 ppmvd at 7% oxygen. 
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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% oxygen 
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3.2 MPCRF Run February 23, 2010 

The MPCRF burned eastern bituminous coal on February 23, 2010. The objective of the test was to collect 

data to evaluate surrogacy relationships between control 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 bayonet 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. Particulate sample collected in-flight after the metals 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 fly ash (consistent with previous experience). However the 

LOI was still higher than was expected based on previous operational experience. As mentioned 

previously, the large coal particle size (from the damaged coal mill screens) was likely contributed to the 

higher than expected value for TGA-LOI. 

NOX concentration at PM control inlet before beginning ammonia addition to SCR was 445 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 101 ppmv dry, a 77 % 

reduction on an absolute basis. CEM analysis during metals and organics sampling is summarized in 

Table 3-7. 
26 

Surrogacy Testing in 

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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 

O2, vol%d 10.0 11.4 

CO2, vol%d 9.8 8.7 

SO2, ppmvd* 1115 1154 

NOX, ppmvd* 129 129 

CO, ppmvd* 47 32 † 

TOC, ppmvw* 2.2 † <15 

* Concentrations corrected to 7% oxygen 

† Failed QC checks 
27 

Surrogacy Testing in 

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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 concentration of metals in the coal, upstream of the PM control 

device, and downstream of the PM control device is also summarized in Table 3-8. As seen in the previous 

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 the coal sample. After the testing, inspection of the duct 

work showed some accumulation of ash in the SCR. This 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 analysis with permanganate associated with mercury 

determinations. At the PM control device inlet, a minor fraction of most analytes reported to the back-half of 

the Method 29 train; the back-half catch represented 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 analytes may also report to the back-half but were confounded 

with blank contamination at these levels. 
28 

Surrogacy Testing in 

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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 98.8 

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 available 
29 

Surrogacy Testing in 

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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 full-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, phenanthrene, anthracene, fluoranthene, and pyrene; 

phenanthrene and anthracene do not appear to be differentiated in this analysis. Full-scan analytes were 

not consistently detected at both ESP In and ESP Out sample locations; when detected at both locations, 

concentrations are generally in the same order of magnitude. SIM analysis of M0010 PAH concentrations, 

presented in Table 3-10, quantified additional PAHs not detected by full-scan analysis. No general trend in 

concentrations is apparent across the PM control device for M0010 SVOC. 

3.2.3 Carbonyls – February 23, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-11 from the February 23, 2010 test. Of the five 

carbonyl compounds quantified, acetophenone concentrations 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 concentrations. 

3.2.5 Methane – February 23, 2010 

Methane for the February 23, 2010, sample was detected at 1.6 ppmvd. Correcting for dilution at the PM 

Outlet sample location results in 2.3 ppmvd at 7% oxygen. 
30 

Surrogacy Testing in 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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-01 ^+ 

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 detected 
31 

Surrogacy Testing in 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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 February 23, 2010 

Analyte 

ESP Out 

μg/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 detected 
32 

Surrogacy Testing in 

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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% oxygen 
33 

Surrogacy Testing in 

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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 data 

to evaluate the control of acid gases (HCl, HF, Cl2) across the flue gas desulfurization (FGD) scrubber. 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 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 at 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 Table 3-13. Method 3A O2 and Method 6C SO2

measurements were not available on the MPCRF at the Scrubber Outlet sampling location. Diluent 
34 

Surrogacy Testing in 

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concentrations from the ESP Outlet were used to calculate concentrations for both Scrubber Inlet and 

Scrubber Outlet locations. 

Table 3-13. CEM Summary for April 7, 2010 

CEM Results ESP In ESP Out 

O2, vol%d 10.0 10.6 

CO2, vol%d 9.8 9.2 

SO2, ppmvd* 1093 † 1058 

NOX, 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 SO2, no Method 6C data was available at 

the scrubber outlet to evaluate SO2 removal efficiency. Previous and subsequent testing has shown a SO2

removal efficiency of 98.8% at normal operating conditions with the same coal used in the April 7, 2010 

testing. Halide concentrations were measured at the Scrubber Inlet and the Scrubber Outlet sample 

locations. Halide HAP concentrations at both locations and halide control across the scrubber are 

summarized for this test in Table 3-14. As discussed in Appendix A, the Cl2 measurement at the Scrubber 

Inlet is likely biased low due to exhaustion of the base in the sodium hydroxide impinger of Method 26A. 

Both HF and Cl2 concentrations were below detection limits at the Scrubber Outlet sample location; control 

efficiency was estimated using the reporting limit for these analytes. 
35 

Surrogacy Testing in 

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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 

Cl2 2.96E-4 ‡ <7.1E-5 ◊ >76.0 

◊ Not detected. Reporting Limit used in Calculation

‡ Likely biased low due to base consumption in second impinger 
36 

Surrogacy Testing in 

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3.4 MPCRF Run April 21, 2010 

The MPCRF burned eastern bituminous coal on April 21, 2010. The objective of the test was to collect 

data 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 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. Particulate samples collected in-flight during the preceding 

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 larger than 28 mesh (595 μm), 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, 2010 
37 

Surrogacy Testing in 

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NOX concentration at PM control inlet before beginning ammonia addition to SCR was 321 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 33 ppmv dry, a 90 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 9.4 10.4 

CO2, vol%d 10.5 9.7 

SO2, ppmvd* 1169 1206 

NOX, 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 test. The concentration of metals in the coal, upstream 

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 generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. Beryllium concentrations at the PM control 

device inlet are higher than the concentration in the coal sample. Arsenic concentrations at the PM control 

device inlet are slightly higher than the concentration in the coal sample. At the PM control device inlet, a 

minor fraction of most analytes reported to the back-half of the Method 29 train; the back-half catch 

represented the majority of concentrations for selenium and boron. At the PM control device outlet, the 

majority of most analytes reported to the back-half of the Method 29 train. Beryllium was not detected in 

the back-half portion at the PM control device outlet; beryllium at the detection limit would be 10.7 % of the 

measured concentrations. 
38 

Surrogacy Testing in 

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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 available 
39 

Surrogacy Testing in 

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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 full-scan analysis at the ESP outlet are benzoic acid 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 M0010 analysis were impacted by field blank contamination. 

All PAH detected in full-scan M0010 analysis were at 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 order of magnitude at both ESP in and ESP out sample 

locations; other PAHs were either not detected or confounded with field blank contamination at low 

concentrations. 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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+00 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 detected 
40 

Surrogacy Testing in 

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Table 3-18. M0010 SIM Emission Summary for April 21, 2010 

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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 Table 3-19 from the April 21, 2010 test. Of the five 

carbonyl compounds quantified, propionaldehyde concentrations were the highest. Formaldehyde and 
41 

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acetaldehyde were detected at low concentrations confounded with field blank contamination. No 

isophorone was detected. 

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

Analyte 

ESP Out 

μg/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 Table 3-20. Three compounds were quantified from 

Research Triangle Laboratories 8260 analyte list. 1,4-Dioxane was indicated as the highest emitting VOC, 

followed by benzene and toluene. It is not clear whether the marked reduction in VOCs quantified was a 

direct result of improved combustion from reducing coal particle size or some other factor. Despite the 

reduction in the number of quantifiable compounds from 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% oxygen 
42 

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3.4.5 Methane – April 21, 2010 

Methane for the April 21, 2010 sample was not detected at 1.0 ppmvd reporting limit. Correcting for dilution 

at the PM Outlet sample location results in <1.3 ppmvd at 7% oxygen. 

3.5 MPCRF Run April 28, 2010 

The MPCRF burned eastern bituminous coal on April 28, 2010. The objective of the test was to collect 

data 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 185 lb/hr resulting in a heat input of 2.47 MMBtu/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. Particulate sample collected in-flight after the metals and 

organics sampling resulted in 19.6 % TGA-LOI. Coal analysis from operations indicate 0.25 % of coal was 

larger than 28 mesh (595 μm). 

-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, 2010 
43 

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NOX concentration at PM control inlet before beginning ammonia addition to SCR was 317 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 34 ppmv dry, an 89 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 9.7 11.3 

CO2, vol%d 10.1 8.8 

SO2, ppmvd* 1174 1182 

NOX, 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 test. The concentration of metals in the coal, upstream 

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 generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. However, some concentrations (e.g., beryllium 

and arsenic) at the PM control device inlet are higher than the concentration in the coal sample. At the PM 

control device inlet, a minor fraction of most analytes reported to the back-half of the Method 29 train; the 

back-half catch represented the majority of the concentration for selenium. At the PM control device outlet, 

the majority of antimony and arsenic reported to the 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 concentrations. Selenium was not detected in the back-half portion 

at the PM control device outlet; selenium at the detection limit would be 622 % of the measured 

concentrations. 
44 

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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 available 
45 

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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 full-scan M0010 analysis were at levels less than 3 times 

blank contamination and are noted as such in Table 3-24. Full-scan quantified concentrations FF In and FF 

Out sample locations were of the same order of magnitude. 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 Out 

sample locations. Acenaphthene was detected at the FF Out sample location; other PAH concentrations 

were either not detected or confounded with field blank contamination at low concentrations. 

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

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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 4.3E-01 ^+ 

bis(2-Ethylhexyl)phthalate 5.8E+00 5.2E+00 + 3.0E+00 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 detected 
46 

Surrogacy Testing in 

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Table 3-24. M0010 SIM Emission Summary for April 28, 2010 

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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 Table 3-25 from the April 28, 2010 test. Of the five 

carbonyl compounds quantified, acetophenone concentrations were the highest. Formaldehyde and 
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acetaldehyde were detected at low concentrations confounded with field blank contamination. No 

isophorone or propionaldehyde was detected. 

Table 3-25. M0011 Carbonyl Emission Summary for April 28, 2010 

Analyte 

FF Out 

μg/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 Table 3-26. Three compounds were quantified from 

Research Triangle Laboratories 8260 analyte list. 1,4-Dioxane was indicated as the highest emitting VOC, 

followed by toluene and benzene. Emission of each compound was the same order of magnitude as 

concentrations from the April 21 test through the ESP. 

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% oxygen 
48 

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3.5.5 Methane – April 28, 2010 

Methane for the April 28, 2010 sample was not detected at 1.0 ppmvd reporting limit. Correcting for dilution 

at the PM Outlet sample location results in <1.4 ppmvd 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 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 267 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 11:00 and concluded at 15:09. Diluent and CO concentrations

during the test period are shown in Figure 3-6. Particulate sample collected in-flight after the metals and 

organics sampling resulted in 1.2 % TGA-LOI. Coal analysis from operations indicate 0.55 % of coal was 

larger than 28 mesh (595 μm). 

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, 2010 
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50 

Surrogacy Testing in 

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NOX concentration at PM control inlet before beginning ammonia addition to SCR was 267 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 54 ppmv dry, an 80 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 9.9 11.3 

CO2, vol%d 10.6 9.2 

SO2, ppmvd* N/A 235 

NOX, 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, upstream 

of the PM control device and downstream of the PM control device, is also summarized in Table 3-28. 

Concentrations at the PM control device inlet are generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. Beryllium and boron concentrations at the PM 

control device inlet are higher than the concentration in the coal sample. At the PM control device inlet, a 

minor fraction of each analyte reported to the back-half of the Method 29 train. At the PM control device 

outlet, a significant fraction of arsenic reported to the 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 73.5 % of the measured concentrations. Selenium was not detected in the backhalf portion at the PM control device outlet; selenium at the detection limit would be 106 % of the measured 

concentration. 
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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 available 
52 

Surrogacy Testing in 

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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 full-scan M0010 analysis were at levels less than 3 times 

blank contamination and are noted as such in Table 3-30. Full-scan quantified concentrations FF In and FF 

Out sample locations were of the same order of magnitude. SIM analysis of M0010 PAH concentrations, 

presented in Table 3-30, quantified fluoranthene and 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 May 20, 2010 

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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+01 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 detected 
53 

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

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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 detected 
54 

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3.6.3 Carbonyls – May 20, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-31 from the May 20, 2010 test. Of the five 

carbonyl compounds quantified, acetophenone concentrations were the highest. Acetaldehyde was 

detected at low concentrations confounded with field blank contamination. No isophorone was detected.

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

Analyte 

FF Out 

μg/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 Table 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 concentrations 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 detected at 1.0 ppmvd reporting limit. Correcting for 

dilution at the PM Outlet sample location results in <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 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 267 lb/hr resulting in a heat input of 2.57 MMBtu/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. Particulate sample collected in-flight after the metals and 

organics sampling resulted in 2.7 % TGA-LOI. Coal analysis from operations indicate 4.0 % of coal was

larger than 28 mesh (595 μm). 
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 

NOX concentration at PM control inlet before beginning ammonia addition to SCR was 294 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 29 ppmv dry, a 90 % 

reduction on an absolute basis. CEM analysis during metals and organics sampling is summarized in 

Table 3-33. 
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Table 3-33. CEM Summary for May 25, 2010 

CEM Results FF In FF Out 

O2, vol%d 9.9 11.5 

CO2, vol%d 10.5 9.1 

SO2, ppmvd* 174 164 

NOX, 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, upstream 

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 generally less than the metals input based on the coal 

sample or the respective detection limit in the coal 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 the 

back-half portion at the PM control device inlet but would constitute 14 % of the measured concentration at 

detection limits. At the PM control device outlet a significant fraction of boron reported to the 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 1140 % of the measured concentration. 

Selenium was not detected in the back-half portion at the PM control device outlet; selenium at the detection 

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 100.0 

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 available 
59 

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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 concentrations, 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 detected or confounded with blank contamination at low 

concentrations. Fluoranthene concentrations quantified with full-scan analysis were similar to fluoranthene 

concentrations quantified with SIM analysis. 

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

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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+00 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 detected 
60 

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

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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-02 ^ 

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 detected 
61 

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3.7.3 Carbonyls – May 25, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-37 from the May 25, 2010 test. Of the five 

carbonyl compounds quantified, formaldehyde concentrations were the highest followed by propionaldehyde 

and acetophenone. Acetaldehyde was detected at low concentrations confounded with blank 

contamination. No isophorone was detected. 

Table 3-37. M0011 Carbonyl Emission Summary for May 25, 2010 

Analyte 

FF Out 

μg/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 Table 3-38. Thirteen compounds were quantified from 

Air Toxics’ 8260 analyte list. Benzene, methylene chloride, and carbon disulfide were indicated as the 

highest VOC concentrations. 

3.7.5 VOCs – May 25, 2010 

Methane for the May 25, 2010, sample was detected at 1.1 ppmvd. Correcting for dilution at the PM Outlet 

sample location results in 1.6 ppmvd at 7% oxygen. 
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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 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 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. The O2 and CO2 CEM at the PM control device inlet failed 

during the metals and organics sampling. The measurements after commencement of sampling and 

before the failure were assumed representative of the entire sampling period. Other CEM measurements 

were unaffected by this failure. Particulate samples collected in-flight after the metals and organics 
63 

Surrogacy Testing in 

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sampling resulted in 1.1 % TGA-LOI. Coal analysis from operations indicate 2.5 % of coal was larger than 

28 mesh (595 μm). 

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 

NOX concentration at PM control inlet before beginning ammonia addition to SCR was 254 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 28 ppmv dry, an 89 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 9.8 ‡ 10.7 

CO2, vol%d 10.7 ‡ 9.9 

SO2, ppmvd* 182 183 

NOX, 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 used 

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, upstream of 

the PM control device, and downstream of the PM control device is also summarized in Table 3-40. 

Concentrations at the PM control device inlet are generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. Beryllium concentrations at the PM control 

device inlet are higher than the concentration in the coal sample. At the PM control device inlet, more than 

10 % of antimony and boron reported to the back-half 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 significant 

fraction of arsenic and boron reported to the 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 167 % of the measured concentration. Selenium was not detected in the back-half portion at 

the PM control device outlet; selenium at the detection limit would be 234 % of the measured concentration. 
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 + 99.6 

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 99.8 

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 available 
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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 June 2, 2010 

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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+00 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 detected 
67 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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 detected 
68 

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3.8.3 Carbonyls – June 2, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-43 from the June 2, 2010 test. Of the five 

carbonyl compounds quantified, formaldehyde concentrations 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 June 2, 2010 

Analyte 

ESP Out 

μg/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 Table 3-44. 27 compounds were quantified from Air 

Toxics’ 8260 analyte list. Chloromethane, methylene 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 the May 20 and May 25 tests. 

3.8.5 Methane – June 2, 2010 

Methane for the June 2, 2010, sample was detected at 1.3 ppmvd. Correcting for dilution at the PM Outlet 

sample location results in 1.8 ppmvd at 7% oxygen. 
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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 Limits 
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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, Cl2) across the flue gas desulfurization (FGD) scrubber. 

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 resulting 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. Three 

1-hour method 26A samples were collected consecutively within this time period at the Scrubber Inlet 

sample location. Diluent and CO concentrations during the test period are shown in Figure 3-9; CEM QC

checks had not been completed at the beginning of sampling 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 

NOX concentration at PM control inlet before beginning ammonia addition to SCR was 333 ppmv dry. 

Average NOX at PM control inlet during the halides sampling was 35 ppmv dry, an 89 % reduction on an 
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absolute basis. CEM analysis during halides sampling is summarized in Table 3-45. Method 3A O2 and 

Method 6C SO2 measurements were not available on the MPCRF at the Scrubber Outlet sampling location. 

Diluent concentrations from the ESP Outlet were used to calculate concentrations for both Scrubber Inlet 

and Scrubber Outlet locations. 

Table 3-45. CEM Summary for June 16, 2010 

CEM Results ESP In ESP Out 

O2, vol%d 8.7 9.3 

CO2, vol%d 11.1 10.5 

SO2, ppmvd* 1091 1088 

NOX, 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 SO2, no Method 6C data was available at 

the scrubber outlet to evaluate SO2 removal efficiency. Previous and subsequent testing has shown a SO2

removal efficiency of 98.8% at normal operating conditions with the same coal used in this testing. Halide 

concentrations were measured at the Scrubber Inlet and the Scrubber Outlet sample locations. Halide 

HAP concentrations at both locations and halide control across the scrubber are summarized in Table 3-46 

for the June 16, 2010 test. Relatively high halide concentrations at the scrubber inlet location afforded the 

opportunity to decrease the sample time and replicate halide sampling at the scrubber inlet; three runs were 

performed in series to reflect average concentrations over the entire 4-hour halide sample at the scrubber 

outlet. The concentration of sodium hydroxide in the scrubber inlet sample trains was increased to 1 

Normal to prevent exhaustion of the base as encountered in the April 7, 2010, test. Both HF and Cl2

concentrations were below detection limits at the Scrubber Outlet sample location; control efficiency was 

estimated using the reporting limit for these analytes. 
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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 

Cl2: 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 data 

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. An air lance was used to blow ash off Heat Exchanger 1, 

immediately downstream of the furnace, to prevent overheating at 12:08 and 13:45. Particulate samples

collected in-flight after the metals and organics sampling resulted in 1.1 % TGA-LOI. Coal analysis from 

operations indicated that 11 % of coal was larger than 28 mesh (595 μm). 
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 CO Summary for July 21, 2010 

NOX concentration at PM control inlet before beginning ammonia addition to SCR was 305 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 39 ppmv dry, an 87 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 8.4 9.1 

CO2, vol%d 11.7 11.0 

SO2, ppmvd* 837 833 

NOX, 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 test. The concentration of metals in the coal, upstream of 

the PM control device and downstream of the PM control device, is also summarized in Table 3-48. 

Concentrations at the PM control device inlet are generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. Cobalt and cadmium concentrations at the PM 

control device inlet are higher than the concentration in the coal sample. At the PM control device inlet, 

more than 10 % of antimony, beryllium, boron and selenium reported to the back-half 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 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 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 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 98.2 

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 99.9 

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 99.8 

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 available 
76 

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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 full-scan analysis at the ESP outlet are benzoic acid and 

phenol; a number of PAHs were also quantified. Full-scan quantified concentrations ESP In and ESP Out

sample locations were of the same order of magnitude. SIM analysis of M0010 PAH concentrations, 

presented in Table 3-50, quantified a number of PAHs; fluoranthene, pyrene, and phenanthrene had the 

highest concentrations at the ESP out sample location. Concentrations quantified with SIM analysis were 

similar to concentrations quantified with full-scan analysis. 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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 3.0E-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-01 ^ 

bis(2-Ethylhexyl)phthalate 6.5E+00 6.0E+00 + 5.0E+00 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 detected 
77 

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

Analyte 

ESP In ESP Out 

μg/dscm* lb/TBtu μg/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 detected 
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3.10.3 Carbonyls – July 21, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-51 from the July 21, 2010 test. Of the five 

carbonyl compounds quantified, acetophenone concentrations were the highest followed by 

propionaldehyde. Acetaldehyde and formaldehyde were detected at low concentrations confounded with 

blank contamination. No isophorone was detected. 

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

Analyte 

ESP Out 

μg/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 Table 3-52. A total of 22 compounds were quantified

from Air Toxics’ 8260 analyte list. Carbon disulfide, benzene, and methylene chloride were indicated as the 

highest VOC concentrations. Carbon disulfide and benzene concentrations exceeded the calibrated range

of the instrument. 

3.10.5 Methane – July 21, 2010 

Methane for the July 21, 2010, sample was not detected at 1.0 ppmvd reporting limit. Correcting for dilution 

at the PM Outlet sample location results in <1.2 ppmvd at 7% oxygen. 
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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 instrument 
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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 data 

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 MMBtu/hr 

at a SR of 1.39. A bayonet heat exchanger was installed in the furnace to control maximum furnace 

temperature at operating conditions. 

Sampling for metals and organics began at 10:16 and concluded at 14:20. Diluent and CO concentrations

during the test period are shown in Figure 3-11. An air lance was used to blow ash off Heat Exchanger 1, 

immediately downstream of the furnace, to prevent overheating at 12:25. Particulate sample collected inflight after the metals and organics sampling resulted in 1.1 % TGA-LOI. Coal analysis from operations 

indicated that 0.45 % of coal was larger than 28 mesh (595 μm). 

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 CO Summary for July 28, 2010 
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NOX concentration at PM control inlet before beginning ammonia addition to SCR was 277 ppmv dry. 

Average NOX at PM control inlet during the metals and organics sampling was 36 ppmv dry, an 87 % 

reduction on an absolute basis. CEM analysis during 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 

O2, vol%d 8.6 10 

CO2, vol%d 11.5 10.2 

SO2, ppmvd* 819 823 

NOX, 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 test. The concentration of metals in the coal, upstream of 

the PM control device, and downstream of the PM control device is also summarized in Table 3-54. 

Concentrations at the PM control device inlet are generally less than the metals input based on the coal 

sample or the respective detection limit in the coal sample. Beryllium, cadmium and cobalt concentrations 

at the PM control device inlet are higher than the concentration in the coal sample. At the PM control 

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-half of the Method 29 train. As discussed in Section 2.3, 

metals concentrations at the PM control device outlet 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 full-scan analysis at the ESP outlet are benzoic acid and 

phenol; a number of PAHs were also quantified. Full-scan quantified concentrations FF In and FF Out 

sample locations were of the same order of magnitude. SIM analysis of M0010 PAH concentrations, 

presented in Table 3-56, quantified a number of PAHs; fluoranthene, pyrene, and phenanthrene had the 
82 

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highest concentrations at the FF Out sample location. Concentrations quantified with SIM analysis were 

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 available 
83 

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

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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-02 ^ 

bis(2-Ethylhexyl)phthalate 3.2E+00 2.9E+00 + 1.9E+00 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 detected 
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Table 3-56. M0010 SIM Emission Summary for July 28, 2010 

Analyte 

FF In FF Out 

μg/dscm* lb/TBtu μg/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 1.9E-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 detected 
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3.11.3 Carbonyls – July 28, 2010 

M0011 Carbonyl concentrations are summarized in Table 3-57 from the July 28, 2010 test. Of the five 

carbonyl compounds quantified, acetophenone concentrations were the highest followed by 

propionaldehyde. Acetaldehyde and formaldehyde were detected at low concentrations confounded with 

blank contamination. No isophorone was detected. 

Table 3-57. M0011 Carbonyl Emission Summary for July 28, 2010 

Analyte 

FF Out 

μg/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 Table 3-58. A total of 27 compounds were quantified

from Air Toxics’ 8260 analyte list. Carbon disulfide, Methylene chloride, and benzene were indicated as the 

highest VOC concentrations. Indicated concentrations of carbon disulfide, Methylene chloride, and 

benzene were lower than concentrations from the July 21, 2010 test. 

3.11.5 Methane – July 28, 2010 

Methane for the July 28, 2010, sample was not detected at 1.0 ppmvd reporting limit. Correcting for dilution 

at the PM Outlet sample location results in <1.3 ppmvd at 7% oxygen. 
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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 Limits 
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4. Method Summary Results 

4.1 Non-mercury Metal HAPs 

Emission control through the PM control device is shown in Figures 4-1 through 4-10 for PM and individual 

HAP metals. Filterable PM control was fairly consistent 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 apparent 

in the data report. Figure 4-10 illustrates that selenium control is much less consistent than filterable 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 Tests 
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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 Tests 

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 Tests 
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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 Tests 

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 Tests 
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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 Tests 

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 Tests 
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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 Tests 

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 Tests 
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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 Tests 

The results of the program indicated that the control 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 tests was 

99.5 %. The non-Hg metal HAPs were controlled along 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 (for 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% 
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The results for Se control were less consistent. When sub-bituminous coal was fired, the control of Se was 

consistently very good, averaging 98.9 % regardless of the PM control device being used. When using the 

FF as the primary PM control device (regardless of coal type), the Se control was consistently very good, 

averaging 99.2 %. Control of Se when the ESP was the primary PM control device was variable. When 

sub-bituminous coal was fired, the control of Se through the ESP was 99+ %. When lignite was fired, the 

control through the ESP was about 80 %. However, when 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 with coal rank and PM control device can be explained by 

the known behavior and chemistry of Se in the combustion and flue gas environments. Selenium is a 

metalloid that sits just below sulfur on the periodic table and is, chemically, very similar to sulfur. In the high 

temperature combustion environment, Se is likely to be present as gas phase SeO2 behaving similar to 

sulfur which is predominantly present as SO2. Much like SO2, SeO2 is a weak acid gas. The testing in the 

pilot-scale combustion facility showed that Se in the flue gas entering the PM control device tended to be 

predominantly in the gas phase (55 to 90%) when firing eastern bituminous coal and predominantly in the 

solid phase when firing sub-bituminous coal (greater than 95%) and Gulf Coast lignite (80%). This is likely 

due to expected higher alkalinity associated with higher calcium content in the sub-bituminous coal and 

lignite ashes relative to bituminous coal ash. Therefore, it is likely that Se will be controlled with PM in the 

lower rank coals with high calcium content while being controlled as an acid gas with coals containing lower 

ash calcium content. 

4.2 Halides 

Concentrations of halide HAPs were quantified at the scrubber inlet sampling location for tests performed 

April 7, 2010, and July 16, 2010. Concentrations at the scrubber outlet were quantified for HCl for both 

tests; the concentration of HF and Cl2 were too low to quantify with the procedures used. Control of HCl 

was 99.9 % for both test days. The control of HF was greater than 92 % for the first test and greater than 

76 % for the second test. The control of Cl2 was greater than 76 % for the first test and greater than 92 % 

for the second test. These control efficiencies were likely much higher than the reported values because 

the outlet measurements were below the detection limits for both HF and Cl2. The control efficiencies were 

calculated using the detection limit value.) The scrubber was designed and operated to provide 

approximately 98 % SO2 removal. 

4.3 SVOCs 

SVOCs concentrations from MPCRF operations were sampled using M0010 at PM inlet and outlet locations. 

Concentrations were quantified for the full 8270 list standard at the analytical laboratory without respect to 

status of individual compounds as HAPs or whether individual compounds had been validated for M0010; 

these concentrations have been presented in Section 3 of this report. Analysis by SIM appears to have
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quantified PAH concentrations consistent with the concentrations quantified by a full scan analysis using 

8270 for the majority of tests; poor agreement was generally confined to February 16, 2010 and February 

23, 2010 tests. In addition, the generally poor surrogate 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 SIM 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 multiple tests with CO concentrations at the PM inlet 

sample location are presented in Figures 4-11 through 4-15. TOC concentrations were not reliably 

quantified in this test program due to low average concentrations and, therefore, could not be compared 

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 concentrations 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 Concentrations 
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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 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 80 100 120 140 160

Fluoranthene Emissions, lb/TBtu

CO Concentration, ppmv dry at 7% O2 

PM Inlet PM Outlet
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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 Concentrations 

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 Outlet
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Figure 4-15. Benzo(a)anthracene Concentrations Versus 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 Concentrations 

4.4 Carbonyls 

Carbonyl concentrations from MPCRF operations were sampled using M0011. Samples were analyzed for 

the full M0011 list of compounds: formaldehyde, acetaldehyde, propionaldehyde, acetophenone, and 

isophorone. Emission for each compound varied considerably over the test program with the exception of 

Isophorone; no Isophorone was detected in this test program. The relative concentrations of the carbonyls 

changed with run conditions; the highest emitting carbonyl changed from run to run in no immediately 

discernable fashion. Though the M0011 sample for February 16, 2010 was extracted from the PM inlet 

sampling location instead of the PM outlet location, there is no indication that this change significantly 

impacted concentrations. Carbonyl concentrations were plotted against CO concentrations at the PM inlet 

sample location and are shown in Figures 4-17 through 4-20. TOC concentrations were not reliably 

quantified in this test program due to low average concentrations and, therefore, could not be compared 

against carbonyl concentrations. 
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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 Concentrations 
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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 Concentrations 
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4.5 VOCs 

VOC concentrations from MPCRF operations were sampled using M0031 at the PM inlet sample locations. 

Concentrations were quantified for the full 8260 list standard at the analytical laboratory without respect to 

the status of individual compounds as HAPs or whether 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 specifically excluded from the M0031 method. Other 

compounds reported in Section 3 may also be inappropriate for quantification with M0031 if they present 

positive or negative bias through interactions with media or with solvents used in analytical determination. 

Tests on and before April 28, 2010, were analyzed by Research Triangle Laboratory, whose 8260 analyte 

list included compounds — significantly 1,3-butadiene and 1,4-dioxane — not included in subsequent test. 

Tests subsequent to April 28, 2010, were analyzed by Air Toxics; no significant VOC concentrations were 

found in these samples for compounds not included on the Research Triangle Laboratory 8260 analyte list. 

Many of the HAPs quantified by VOC analysis were found on a sporadic basis. VOC HAPs quantified 

frequently in this test program included bromomethane, carbon disulfide, methylene chloride, chloroform, 

carbon tetrachloride, benzene, toluene, ethyl benzene, o-xylene, styrene, iodomethane, and 1,4-dioxane. 

VOC concentrations of these HAPs are plotted against CO concentrations at the PM inlet sample location

and are shown in Figures 4-21 through 4-32. The graph of methylene chloride concentrations (Figure 4-23) 

is skewed by a single extraordinary data point, which exceeded instrument calibration range; the other tests 

are clustered between 6 and 23 lb/TBtu methylene chloride concentrations. TOC concentrations were not

reliably quantified in this test program due to low average concentrations and, therefore, could not be 

compared against carbonyl concentrations. 
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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 Versus CO Concentrations 
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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 Versus 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 Concentrations 
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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 Versus 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 Concentrations 
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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 Concentrations 

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 CO Concentrations 
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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 Concentrations 

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 Concentrations 
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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 Concentrations 
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4.6 Methane 

Methane concentrations measured at the PM outlet ranged from less than the 1.0 ppmvd reporting limit for 

the analytical method to 1.6 ppmvd. Five of the nine methane samples were below the reporting limit. 

Quantifiable concentrations were in a narrow range close to the reporting limit. Correlation of methane 

concentrations with HAP concentrations was not pursued with this data set. 
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5. Summary and Conclusions 

Bituminous, sub-bituminous, and lignite coals were burned in the MPCRF with flue gas routed through either 

an ESP or a FF. Filterable PM and total metals were sampled and analyzed upstream and downstream of 

the PM control device. SVOCs were evaluated upstream and downstream of the PM control device, 

carbonyls were evaluated downstream of the PM control device, and VOCs were evaluated upstream of the 

PM control device. Diluent and other gases were also sampled and analyzed by CEM both upstream and 

downstream of the PM control device. Concentrations were corrected for dilution to generate energy-based 

concentrations. 

Two runs were undertaken to examine the control of acid gases and halides (HCl, HF, Cl2) using the limebased wet FGD scrubber. The ability of alkaline slurry wet scrubbers to effectively control acid gases is 

well known. These tests were intended to confirm that and to quantify the removal of the species; as such, 

these measurements were not the primary focus of this overall test program. 

Control of PM and HAP metals were compared. Measurement of PM and metals was considered 

adequate for determining control as planned. Metals concentrations were determined through analysis of 

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; significant 

portions of some analytes, particularly boron and selenium, report to the back-half of the Method 29 train. 

Concentrations from the PM control device may be affected by blank contamination and low mass of metals 

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 determined by combustion conditions and quantified by the 

concentrations themselves. Quantified concentrations for specific compounds were compared against CO 

concentrations at the PM inlet sample location. Some 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 impacted 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 or 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-detect and other complexities, the key conclusion that can 

be drawn from the results of this testing is that testing did not disprove an expected relationship between 

some organic concentrations and combustion conditions and that additional testing to further examine 

surrogacy relationships is warranted. 
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Appendix A: Quality Control Evaluation 

A test program was implemented in 2010 at EPA’s Multipollutant Control Research Facility (MPCRF) in 

Research Triangle Park, NC to evaluate potential surrogacy relationships for Hazardous Air Pollutants 

(HAP) from coal combustion. A Quality Assurance Project Plan was developed for this program identifying 

critical measurements and data quality indicator goals to evaluate these measurements. An extensive data 

package was prepared and submitted to EPA under separate cover summarizing the data collected 

including CEM averages, sampling data sheets, and external 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 was 

performed separately from sample extraction. Isokinetic sampling was performed under a steady-state 

assumption with Method 2C traverses performed before and after sample extraction. Flow is considered 

steady state if drift ≤ 10 %. Flow was calculated using the average O2 and CO2 from run conditions and 

moisture from a representative sample, typically Method 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 the 

April 7, 2010, halides measurements; flow downstream of the PM control device was 1502 acfm and 

downstream of the scrubber was 1200 acfm. Halide measurements around the scrubber on June 16, 2010, 

required flow downstream of the PM control and downstream of the scrubber; flows downstream of the 

scrubber were 1201 acfm before testing and 1203 acfm 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 encountered on May 20, 2010, downstream of the particulate 

collector; the pre-test flow is believed to be in error. Isokinetics for these runs is potentially compromised. 

A.2 Method 3A Oxygen and Carbon Dioxide Quality Control 

Results of calibration error checks, bias checks and drift checks for O2 and CO2 CEM are summarized in 

Tables A-2 through A-7. Calibration error, both upstream and downstream of the PM control device, was < 

2 % of span for O2 and CO2. Bias checks, both upstream and downstream of the PM control device, were 

within 5 % of span for O2 and CO2. Drift checks, both upstream and downstream of the PM control device, 

were within 3 % of span for O2 and CO2; O2 zero drift at the PM outlet on February 23, 2010, was 3.0 % of 

span. These measurements are deemed reliable and adequate for this test program. 
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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 

2/17/2010a 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 determination; a default of 28 (nitrogen) was used to compare 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 0.1 
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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 available 
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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 available 
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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 calibration error and bias checks were not completed prior to

beginning the Method 26A sampling; measurements after the bias check through the end of the test were 

assumed representative of the entire sampling period. 

On June 2, 2010, the O2 and CO2 CEM at the PM control device inlet failed during the metals and organics 

sampling. The measurements after commencement of sampling 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 February 

17, 2010, the operating day immediately preceding the 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 considered 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 sampled for the February 17, 2010 runs since velocity 

traverses were consistent with steady state operation and the sampling rate was within 10 % of isokinetic. 

Filter particulate determination was performed for this sample by baking followed by desiccation and single 
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mass determination as permitted under Method 5; acetone rinse determinations were within 0.5 mg on 

sequential weighing. No field blank was provided to this laboratory for particulate. 

While particulate determinations in conjunction with Method 29 were generally within Method 5 

specifications, several deviations were encountered during this test program. Flow measurements at the 

PM control outlet on February 16, 2010, failed to meet criteria for steady state operation with 13 % drift; 

although the run did pass with respect to isokinetic sampling rate at 92 % of isokinetic. On May 20, 2010, 

the PM outlet velocity determination appears to have been grossly in error resulting in failure of both steady 

state criteria, 112 % drift, and isokinetic criteria, 54 % of isokenetic based on post run velocity traverse; the 

initial velocity determination was used to set the constant sampling rate for each test. On May 25, 2010, 

the PM outlet was oversampled resulting in a rate 124 % 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 checks 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 collected 

on July 21, 2010, resulted in 1.4 mg for the front-half catch. Front-half catch upstream of PM control 

ranged from 747 mg to 9527 mg; these results are clearly not significantly biased by the blanks. Front-half 

catch downstream of PM control ranged from 1.5 mg to 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 and drift checks for SO2 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 SO2. Bias checks, both upstream and downstream of the PM control device, were within 5 % 

of span for SO2. Drift checks, both upstream and downstream of the PM control device, were generally 

within 3 % of span for SO2; SO2 mid-scale drift at the PM inlet on April 7, 2010, was 3.8 % of span. These 

measurements are deemed reliable and adequate for this test program. 
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Table A-8. SO2 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. SO2 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 available 
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Table A-10. SO2 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 calibration error and bias checks were not completed prior to

beginning the Method 26A sampling; measurements after the bias check through the end of the test were 

assumed representative of the entire sampling period. 

On May 20, 2010, sample flow to the PM inlet SO2 CEM failed during the test. PM inlet SO2 concentrations 

are not available for this test. 

A.5 Method 7E Nitrogen Oxides Quality Control 

Results of calibration error checks, bias checks and drift checks for NOX CEM are summarized in Tables A11 through A-13. Calibration error, both upstream and downstream of the PM control device, was less than 

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

% of span for NOX. Drift checks, both upstream and downstream of the PM control device, were within 3 % 

of span for NOX. These measurements are deemed reliable and adequate for this test program. 
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Table A-11. NOX 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. NOX 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 available 
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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 calibration error and bias checks were not completed prior to

beginning the Method 26A sampling; measurements after the bias check through the end of the test were 

assumed representative of the entire sampling period. 

A.6 Method 10 Carbon Monoxide Quality Control 

Results of calibration error checks, bias checks and drift checks for CO CEM are summarized in Tables 

A-14 through A-16. Calibration error, both upstream and downstream of the PM control device, was less

than 2 % of span for CO. Bias checks, both upstream and downstream of the PM control device, were 

generally within 5 % of span for CO; mid-scale system bias at the PM outlet was >5 % on February 16 and 

23, 2010. Drift checks, both upstream and downstream 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.
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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 available 
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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 calibration error and bias checks were not completed prior to

beginning the Method 26A sampling; measurements after the bias check through the end of the test were 

assumed representative of the entire sampling period. In addition, the CO CEM at the PM outlet was not 

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 error 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 inlet; 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 negative 

concentrations for the test period. Two tests with positive PM Inlet TOC failed calibration drift tests. The 

TOC concentrations reported are, at best, indicative of low concentrations, perhaps < 10 ppmv propane. 

TOC concentrations in the test program cannot be proven to be significantly different from zero with the 

measurement system employed. 
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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 available 
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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 to 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 collected with coincident Method 5 particulate 

determination. The sample volumes 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. 

Several deviations from Method 29 sample requirements were encountered during this test program. Flow

measurements at the PM control outlet on February 16, 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 velocity determination appears to have been grossly in error, 

resulting in failure of both steady state criteria, 112 % drift, and isokinetic criteria, 54 % of isokenetic based 

on post run velocity traverse; the initial velocity determination was used to set the constant sampling rate for 

each test. On May 25, the PM outlet was oversampled resulting in a rate 124 % of isokinetic. All three of 

these failures in sampling rate were at the PM outlet location which is less impacted by sampling rate. 

The majority of laboratory quality control (QC) measures for accuracy, precision, and interference were 

within method acceptable criteria. Second source calibration checks met the 10 % accuracy criteria for 

each analysis. Precision of duplicate analyses were generally within 20 relative % difference (RPD) with 

the exception of PM control outlet back-half antimony for the February 16, 2010 run, this analyte resulted in 

21.3 RPD. Interference was found in several analyses on various metals but was generally corrected 

through dilution; the exceptions were the PM control outlet back-half selenium spikes on May 25, 2010, and 

June 2, 2010, correlating with non-detect sample concentrations for selenium in both instances. 

Method 29 field blanks were performed on February 16, 2010, and July 21, 2010. Beryllium and selenium

were not detected in the field blanks and these analytes do not require qualification with respect to 

quantification. With the exception of PM control inlet front-half results, most analyses failed to meet a 5 % 

contamination threshold based on field blanks. Results less than detection limits have been excluded in 

emission calculations. Results that are less than three times the highest field blank have been flagged as 

blank contaminated but are used in emission calculations. 

In addition to the planned quality control measures, the reasonableness of the reported metal content was 

evaluated. The PM control outlet front-half mineral content on April 28, 2010, exceeded the mass of 

particulate collected in the front-half of the train; these results have been summarily excluded. All results 

from the PM control outlet front-half analysis on July 28, 2010, appear to be two orders of magnitude higher 

than expected and again exceed the mass of particulate collected in the front-half; these results have been 

similarly excluded. Working with the analytical laboratory, we failed to identify any cause for these
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abnormalities. Metals concentrations have been flagged if analytical flagged data comprised 20 % or more 

of the total metal. PM control inlet concentrations are not significantly impacted by flagged data. PM 

control outlet concentrations are generally confounded with blank compromised data; these concentrations 

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 concentrations downstream of the PM control device and 

downstream of the scrubber; the sample location downstream of the PM control device is the sample point 

immediately upstream of the scrubber. The sample volumes 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-state operation can be made for the April 7, 2010 test 

based on Method 2C traverses since only pre-test traverses were performed; stability of oxygen and carbon 

dioxide concentrations and general agreement with flows, measured June 16, 2010, suggest flow was at 

steady state. Isokinetics for Method 26A samples ranged from 94.7 to 102.1 %, well within the 100 % goal 

(± 10%) of the test program. Method 26A sample extraction 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 % accuracy criteria for each analysis as specified in the QAPP 

in lieu of an EPA audit sample. Each sample was analyzed in duplicate; the precision was within 5 RPD for 

each analysis. The laboratory did note, however, that neutralization capacity of the sodium hydroxide

fraction of the April 7, 2010, scrubber inlet sample had been exceeded resulting in an acidic fraction. As a 

result, the Cl2 analysis for this sample must be suspect, biased low, because acidic solutions are not 

effective at capturing Cl2. 

Blanks performed in coordination with the April 7, 2010, samples resulted in no detections for both the acid 

and basic fractions. The June 16, 2010, scrubber inlet 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 Cl2. 

A.10 Method 0010 Semi-Volatile Organic Compounds 

M0010 is an isokinetic sampling method. The particulate and front-half rinse were digested and analyzed 

with the resin. The sampling objective was to maintain sampling rates between 90 and 110 % of the ideal 

isokinetic rate. Three sampling runs at the PM outlet location (February 23, May 20, and May 25 runs)

failed to meet this standard with 117-, 57-, and 124 % isokinetic, respectively. Thirteen of the eighteen 

Method 0010 sampling runs met this standard. Due to the depletion of large particles, isokinetic 

performance is very unlikely to have affected SVOC collection efficiency, due to the fact that small particles 
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follow streamlines characteristic of a gas. Any SVOCs associated with such small particles would then be 

collected and analyzed in the same proportion as the 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 % isokinetic, 

respectively. The overall effect on SVOC concentration is unknown but should be less than the isokinetic 

error, as many compounds are gaseous at stack temperatures (~250 °F) and would be unaffected by 

isokinetic error. The sample volumes for all of 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. 

Samples from the first two tests (February 16 and February 23 runs) were analyzed by Research Triangle

Park Laboratories, Inc. This laboratory did not use a K-D (Kuderna-Danish) concentrator when processing 

samples. Method spike recoveries, comparable to a second source standard, for the full-scan target 

analyte list were generally poor for lower molecular weight compounds and generally improved for higher 

molecular weight compounds; this is consistent with the use of a single-stage evaporation-type concentrator. 

Of the 71 target analyte compounds, 42 achieved method spike recoveries of < 70 %; all target analyte list 

compounds achieved < 130 % recoveries. Surrogate spikes were in line with these results with the lower 

molecular weight compounds exhibiting poor recoveries: 

• 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, scrubber inlet concentrate indicates good precision; all target 

analyte list compounds detected and surrogate spikes were within the 50 RPD goal. Di-n-butyl phthalate, 

Bis(2-ethylhexyl) adipate, Bis(2-ethylhexyl) phthalate were found above the reporting limit in the full-scan 

field blank; Di-n-butyl phthalate was found above the reporting limit in the full-scan method blank. Fluorene 

was found above the reporting limit in both the (SIM) field blank and method blank. 
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Samples from the remaining tests were analyzed by Air Toxics, Ltd. This lab appears to be fully compliant 

with M0010 procedures. Continuing calibration verification standards confirm analytical accuracy within 

acceptance limits for all samples. Surrogate spikes 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 compounds detected and surrogate spikes were within the 50-

RPD goal established for these tests. Two field blanks from this test series were analyzed by the 

laboratory; field blanks quantified benzoic acid, naphthalene, 2,6-dinitrotoluene, di-n-butylphthalate, 

butylbenzylphthalate, 3,3'-Dichlorobenzidine, and Bis(2-ethylhexyl) phthalate. All data less than 3 times the 

highest field blank concentration were flagged; an emission rate was calculated for blank-impacted data 

without any correction, but these data were considered 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 filter 

before the impingers in this test program. The objective was to maintain sampling rates between 90 and 

110 % of the ideal isokinetic. Two sampling runs, sampled after the PM control, failed isokinetic goals. 

One run was operated at 52 % isokinetic and the other at 125 %. Due to the low concentration of large

particles after the PM device, isokinetic performance is less critical for any particle-bound analyte. A filter 
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was inserted to provide particulate sample for subsequent organic carbon/elemental carbon analysis; a filter 

was not included in the M0011 recovery for carbonyls. This failure is not expected to materially affect the 

data. The sample volumes for all of 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. 

All M0011 samples were analyzed in duplicate and with a laboratory audit sample; no matrix spike was 

applied to the samples. All duplicate analysis were 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 was 

prepared. The field blank contained quantifiable amounts of formaldehyde and acetaldehyde. All data 

less than three times the highest field blank concentration were flagged; an emission rate was calculated for 

blank-impacted data without any correction, but these data were considered non-detects. 

A.12 Method 0031 Volatile Organic Compounds 

M0031 samples were collected in a non-isokinetic fashion at the PM inlet location. Sample locations were 

near bends in ductwork, however, this was not deemed important for these samples since organics were 

expected to be gaseous at sampling temperatures. The sample volumes 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. Samples are collected 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, 2010, were analyzed by Research Triangle Park 

Laboratories. For the February 16 and February 23 tests, the Tenax tubes were analyzed separately from 

the Anasorb tubes in each set. Surrogate recoveries, summarized in Table A-19, were generally within the 

50- to 150 % recovery objective set for this test program. The low bromochloromethane surrogate recovery 

for one Anasorb set had an unknown impact on data quality for that set, as Anasorb is intended to collect 

low boiling compounds. The high 1,4-difluorobenzene recoveries for Anasorb are not likely to impact data 

quality for these sets. 

For the April 21 and April 28 tests, all three tubes from each set were analyzed together. Surrogate 

recoveries are summarized in Table A-20. All of these sets satisfied the 50- to 150 % surrogate recovery 

goal established for this test program. 

Table A-19. M0031 Surrogate Recovery Summary for February16, 2010, and February 23, 2010 

Surrogate Condensate, % Tenax, % Anasorb, % 

1,4-Difluorobenzene 99-123 117-131 72-174 

Bromochloromethane 61-80 71-93 44-107 
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Table A-20. M0031 Surrogate Recovery Summary for April 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 analyzed 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 are 

not likely to significantly impact results since Anasorb is intended to collect low boiling compounds after 

Tenax. Low recoveries of 4-bromofluorobenzene in Tenax have an unknown impact on the data quality in 

this range but is only slightly outside the objective of 50- to 150 % recovery. 

Table A-21. M0031 Surrogate Recovery Summary for May 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 same manner as the traps for the accompanying 

samples. A significant number of compounds were found 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 the blank concentration were considered non-detects. 

No correction was applied for blank contamination. All analysis included the laboratory’s full 8260 list 

without regard for whether a compound had been validated for this method or if it were a HAP. 

A.13 Method 0040 Methane 

Methane was sampled with a M0040 train into a Tedlar 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 the 
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performance of this project but provided ancillary information. As a result, no data quality indicator goals 

were established in the QAPP for this measurement. The laboratory performed 4 point calibration and a

calibration curve check; all calibration curve check results were within 10% of the standard. In addition, a 

field blank was performed April 21, 2010, by filling a Tedlar bag with nitrogen; blank analysis was below 

reporting limits of 1.0 ppmvd. 
End of Document