7/23/2010

Test Plan

3190 Platte River Power Authority

Facility Information:

Rawhide

2700 East County Road 82

Wellington CO

Contact: Mike O'Brien

Phone: (970) 222-2325

Fax:

Email: obrienm@prpa.org

Testing Company:

Airtech Environmental Services Inc.

5776 Lamar Street

Arvada CO 80002

Contact: Jeff Johnson

Phone: (303) 670-0530

Fax: (303) 670-4130

Email: jjohnson@airtechenv.com

Air Permit Number:

6761

Permitted Source ID/Name:

101 Boiler 101

Permitted Maximum Process Rate:

N/A

Max. Normal Operation Process Rate:

N/A

Target Process Test Rate

N/A

1. What is the specific purpose for the proposed testing?

The primary reasons for performing this emissions test is to satisfy the EPA's Section 114 Letter requiring this testing.

3. Will the test results be used for other regulatory purposes (e.g., emission inventories, 

 permit applications, etc.) beyond that stated above? If yes, explain.

List any secondary purposes that you will use the data from this emissions test to address. If known list those 

pollutants that are of secondary interest. Some examples are: Determine emissions of CO, THC, VOC and

condensable PM emissions for use in emissions inventory reporting and determination of fees.

Industry NAICS: 221112

4a. Enter the process data to be documented during testing.

AFS #: 0806900053 FRS #: 110000607148

SCC / Description 10100202 External Combustion Boilers - Electric Generation - Bituminous/Subbituminous 

Coal - Pulverized Coal: Dry Bottom (Bituminous Coal) 

2. List all state and federal regulations that apply to the proposed testing:

Process Parameter Units Target Value Comments

Coal Burned 1000 Tons/hr 0.15 Provide estimated process 

rate for the test.

Unit Net Electric Generation MWh 280 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

Flue Gas Sampling Point Temperature Deg F 200 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

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Test Plan

3190 Platte River Power Authority

5a. Please give a brief description of the source (including control equipment) and attach source or

 process flow diagram:

The Rawhide Energy Station is a pulverized coal fired steam generating electric utility plant serving Northern 

Colorado. It has a nominal generating capacity of 305 MW (gross) at 100% load and a heat input rate of 2,800 

mmBtu per hour based on a coal feed rate of 157 tons per hour (as received). The coal is typically, as received 8,850 

Btu per pound and contains 0.28% sulfur and 5.3% ash. The boiler is tangentially fired and is equipped with LNC3 

concentric firing low-NOx burners with separated over fire air dampers. The hot boiler flue gas exits the air heater in 

a common inlet duct to the Spray Dry Absorber (SDA) SO2 emissions control inlet manifold. 

The SDA emissions control system is designed to control both SO2 and particulate. The process is based on initial 

absorption of SO2 onto "atomized" alkaline particles injected by the three slurry atomizers. The sulfate-laden flue 

gas particles, along with existing fly ash, are then separated from the flue gas in two fabric filter baghouses before 

passing through the two ID fans and into the common stack breech. The maximum EPA allowable sulfur dioxide 

emission rate is 0.13 lb/mmBtu with at least an 80% reduction of sulfur dioxide in the flue gas. The unit must also 

achieve a State-only SO2 emission limit of 0.09 lbs/mmBtu (calendar-year average) and a State-only NOx limit of 

0.18 lbs/mmBtu (calendar-year average).

5b. Control Devices:

6. Please enter sampling location information.

4b. Enter the process lab data to be documented during testing.

Control Device Name

BAGHOUSE

OVERFIRE AIR

SPRAY DRYER

Location

Round

Duct

Diam.

Distance from 

upstream dist.

Distance from

downstream dist.

Number of

Traverse Ports

Equiv. 

Diam

Min.Travers 

Points

Rect. Duct 

Length /Width

Flue Gas Carbon Dioxide Content % 14 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

Flue Gas Oxygen Content % 6 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

Flue Gas Flow Rate kscfh 40000 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

Steam Output 1000 lb steam/hr 1800 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

Average Heat Input MMBtu/hr 2500 Provide estimated process 

rate for the test as well as a 

daily average for a 30 day 

period encompassing the 

tests.

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3190 Platte River Power Authority

7. Please provide the following information for each test parameter.

7b. Please select the Emissions / Concentrations for each location.

Target

Parameter 

Test

Method

Number of

Test Runs

Test Run

Duration

Sample 

Location Points Comments

Stack Exit % H2O Method 1 - 4 6 180 0

Stack Exit Carbon Monoxide Method 10 3 120 0

Total organic 

compounds 

(TOC) as Propane

Stack Exit Method 25A 3 120 0

Stack Exit Hydrogen Fluoride Method 26A 3 180 0

Stack Exit Hydrogen Chloride Method 26A 3 180 0

Filterable PM2.5 OTM - 27/28 3 240 0 Use only for dry stacks. Delete 

Method 5/OTM28 tests.

Stack Exit

Total PM2.5 OTM - 27/28 3 240 0 Use only for dry stacks. Delete 

Method 5/OTM28 tests.

Stack Exit

Organic 

Condensible 

Particulate

OTM - 27/28 3 240 0 Use only for dry stacks. Delete 

Method 5/OTM28 tests.

Stack Exit

Inorganic 

(Aqueous) 

Condensible Part.

OTM - 27/28 3 240 0 Use only for dry stacks. Delete 

Method 5/OTM28 tests.

Stack Exit

Stack Exit Antimony Method 29 3 240 0

Stack Exit Arsenic Method 29 3 240 0

Stack Exit Beryllium Method 29 3 240 0

Stack Exit Cadmium Method 29 3 240 0

Stack Exit Chromium Method 29 3 240 0

Stack Exit Lead Method 29 3 240 0

Stack Exit Manganese Method 29 3 240 0

Stack Exit Nickel Method 29 3 240 0

Filterable 

Particulate

Stack Exit Method 29 3 240 0

Stack Exit Cobalt Method 29 0

Phosphorus 

(yellow or white)

Stack Exit Method 29 0

Stack Exit Selenium Method 29 3 240 0

Nitrogen oxides 

(NOx)

Stack Exit Method 7E 3 180 0

Stack Exit 240 480 1920 4 0 0 240 12

Test

Method

Emissions /

 Concentrations

Corrected 

Analyte

Corrected

Location Percent

Stack Exit Method 10 lb/million BTU using O2 0

Stack Exit Method 10 ppm corrected O2 7

Stack Exit Method 25A lb/million BTU using O2 0

Stack Exit Method 25A ppm corrected O2 7

Stack Exit Method 26A lb/million BTU using O2 0

Stack Exit Method 26A mg/dscm 0

Stack Exit Method 26A mg/dscm corrected O2 7

Stack Exit Method 29 lb/hr 0

Stack Exit Method 29 lb/million BTU using O2 0

Stack Exit Method 29 mg/dscm 0

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3190 Platte River Power Authority

8. Describe below or attach complete documentation of all modifications and/or deviations to

 the applicable test methods. If alternative methods requested, attach documentation of 

request 

The following is a list of the test methods that are to be used for this test program and their respective promulgation 

dates:

Methods 1 through 29 – August 1997

Method 30B – January 2008

Other Test Methods 27 and 28 – April 2009

SW-846 0010 – September 1986

SW-846 0030 – December 1996

9. Does the proposed sampling location meet the minimum EPA Method 1 criteria for 

acceptable 

 measurement sites? Please list below or attach the supporting documentation.

10. Has absence of cyclonic flow been verified per EPA Method 1 (Section 2.4)? If no,

 absence of cyclonic flow must be verified prior to testing. If yes, please attach

 supporting documentation.

The verification of absence of cyclonic flow was not necessary as per Section 11.4.1 of EPA Method 1.

11. Select the method that will determine the oxygen concentration : M3B-Orsat

13. Has all testing equipment been calibrated within the past year? If no, please 

explain.

Yes No

Yes No

Yes No

Yes No

Yes No

14. Will all calibration gases be certified by EPA Traceability Protocol

 procedures? If No, describe certification procedure below.

15. Is a dilution system (via EPA Method 205) proposed?

Yes No N/A

Yes No N/A

Zero nitrogen and/or zero air was used for zero calibrations.

16. If applicable, list the expected calibration gas concentrations for all proposed instrumental

 test methods. Include as much information as is known at this time.

12. Do any of the proposed test methods require analysis of EPA audit samples? If

 yes, notify Regional Office at least 45 days prior to testing to allow for audit

 sample preparation and shipment.

Stack Exit Method 29 mg/dscm corrected O2 7

Stack Exit Method 7E lb/million BTU using O2 0

Stack Exit Method 7E ppm 0

Stack Exit Method 7E ppm corrected O2 7

Stack Exit OTM - 27/28 lb/million BTU using O2 0

Stack Exit Method 10 ppm 0

Stack Exit Method 25A ppm 0

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3190 Platte River Power Authority

17. What is the proposed test schedule? 

The testing will be performed during the week of May 4th, 2010.

18. Additional comments:

Name: Mike O'Brien

Title: Environmental Specialist

Company: Platte River Power Authority

Sign Date: 7/23/2010

Name: Chet Gutwein

Title: Engineer

Company: Airtech Environmental Services Inc.

Sign Date: 7/22/2010

Permitted Facility Representative Testing Company Re Date presentative Date

19. Required Personal Protection Equipment:

Required PPE: hardhat, steel-toed boots, safety glasses, gloves, hearing protection, and fall protection if necessary.

Compound 

(Analyte)

Certification

Procedure 

Cert.

Value

Uncertianty

Percent

Cylinder Certification

Date

Expiration

Date

Zero Nitrogen NA 0 0 10/29/2009 10/29/2012

AAL933 NOX G1 179 1 2/17/2010 2/17/2012

sx12373 NOX G1 852.4 1 3/30/2010 3/30/2012

XC030124B CO G1 49.38 1 9/1/2009 9/1/2012

SG9104876BAL CO G1 101.5 1 3/3/2009 3/3/2012

CC52193 Propane G1 30.15 1 12/2/2008 12/2/2011

CC78858 Propane G1 50 0.5 9/5/2007 9/4/2010

CC115970 Propane G1 84.4 0.7 9/5/2007 9/4/2010

Wednesday, July 21, 2010 Test Plan Page 5 of 5