# REVISED EMISSIONS TEST REPORT

EMISSION TESTING PROGRAM FOR COMPLIANCE WITH THE ELECTRIC UTILITY MACT PHASE III EPA SECTION 114 INFORMATION COLLECTION REQUEST FOR THE

AES / IPL Harding Street

Boilers 9, 10, 60, and 70

Prepared for:

Indianapolis Power and Light Harding Street Generating Station Indianapolis, Indiana

Prepared by:

URS Corporation 1600 Perimeter Park Drive

Morrisville, NC 27560

June 2010

## TABLE OF CONTENTS

ii Harding Street Test Report - Final r2 31827133 Section 1 Introduction

.......................................................................................................... 1-1 1.1 Summary of Test Program.................................................................. 1-1
Section 2 Facilit y Description .......................................................................... 2-1 2.1 Harding Street 9 and 10 ...................................................................... 2-1 2.1.1 Process Description...................................................................... 2-1 2.1.2 Sa mpling Location....................................................................... 2-1 2.1.3 Process Operating Data................................................................ 2-2 2.2 Boiler 60.............................................................................................. 2-4 2.2.1 Process Description...................................................................... 2-4 2.2.2 Sa mpling Location....................................................................... 2-5 2.2.3 Process Operating Data................................................................ 2-6 2.3 Boiler 70.............................................................................................. 2-6 2.3.1 Process Description...................................................................... 2-6 2.3.2 Sa mpling Location....................................................................... 2-8 2.3.3 Process Operating Data................................................................ 2-8 2.4 Fuel Analysis Data.............................................................................. 2-8
Section 3 Test Results ...................................................................................... 3-1 3.1 Boiler 9................................................................................................ 3-1 3.2 Boiler 10.............................................................................................. 3-6 3.3 Boiler 60............................................................................................ 3-11 3.4 Boiler 70............................................................................................ 3-12
Section 4 T est Methods .................................................................................... 4-1 4.1 Volum etric Flow, Moistu re, and Molecular Weight........................... 4-1 4.2 Particulate Matter from Dry Stacks .................................................... 4-1 4.3 Particulate Matter from Wet Stacks.................................................... 4-2 4.4 Sulfur Dioxide..................................................................................... 4-3 4.5 Oxides of Nitrogen.............................................................................. 4-3 4.6 Carbon Monoxide ............................................................................... 4-4 4.7 Methane............................................................................................... 4-4 4.8 Dioxins, Furans and PCB.................................................................... 4-5 4.9 Total HydrocarbonS............................................................................ 4-6 4.10 Hydrogen Chloride and Hydrogen Floride ......................................... 4-6 4.11 Filterable PM and Non-Mercury Metals............................................. 4-7 4.12 Mercury

............................................................................................... 4-7 4.13 Hydrogen Cyanide .............................................................................. 4-8 4.14 Semi-Volatile Organic Compounds.................................................... 4-9 4.15 Volatile Organic Compounds ........................................................... 4-10 4.16 Process Data...................................................................................... 4-10
Section 5 Quality Assura nce/Quality Control ................................................. 5-1 5.1 Sa mpling QA/QC................................................................................ 5-1 5.2 Other QA/QC...................................................................................... 5-1 5.3 Test Method Exceptions ..................................................................... 5-2

## TABLE OF CONTENTS

iii Harding Street Test Report - Final r2 31827133 APPENDICES Appendix A Sampling Data A-1 Harding Street 9 A-1-1 Preliminary Test Data A-1-2 Emission Test Data for PM, PM 2.5, and Metals A-1-3 Emission Test Data for Acid Gases A-1-4 Emissions Test Data for Non-Dioxin/Furan Organics A-1-5 Emissions Test Data for Dioxin Organics

A-2 Harding Street 10 A-2-1 Preliminary Test Data A-2-2 Emission Test Data for PM, PM 2.5, and Metals A-2-3 Emission Test Data for Acid Gases A-2-4 Emissions Test Data for Non-Dioxin/Furan Organics A-2-5 Emissions Test Data for Dioxin Organics

A-3 Harding Street 60 A-3-1 Preliminary Test Data A-3-2 Emission Test Data for PM, PM 2.5, and Metals

A-4 Harding Street 70 A-4-1 Preliminary Test Data A-4-2 Emission Test Data for PM, PM 2.5, and Metals

Appendix B Analytical Data B-1 Enthalpy Analytical Labs – EPA Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 B-2 Analytical Perspectives Labs – Method 23 Analysis B-3 Test America – Met hod 29 SW846-0031 Analysis B-4 URS – Gravimetric Analysis B-5 Columbia Analytical Fuel Analysis
Appendix C Hourly Process Operating Data Appendix D QA/QC Data Appendix E 30-Day Process Data Appendix F EPA ERT Files and Spreadsheets Appendix G Test Plans and Correspondence

## TABLE OF CONTENTS

iv Harding Street Test Report - Final r2 31827133 LIST OF TABLES Page 1-1 Summary of Harding Street Station T esting Requirements........................................ 1-1 1-2 Harding Street Station Testing Dates.......................................................................... 1-1 1-3 Summary of Test Resu lts for Harding Street

.............................................................. 1-2 2-1 Summary of Boiler Operati ng Parameters for Boiler 9

.............................................. 2-3 2-2 Summary of Boiler Operati ng Parameters for Boiler 10

............................................ 2-4 2-3 Summary of Boiler Operati ng Parameters for Boiler 60

............................................ 2-7 2-4 Summary of Boiler Operati ng Parameters for Boiler 70

............................................ 2-9 2-5 Summary of Fuel Analysis for Boilers 9, 10, 60, and 70.......................................... 2-10 3-1 Boiler 9 Test Schedule................................................................................................ 3-1 3-2 Boiler 9 Summary for Particulate Matter.................................................................... 3-2 3-3 Boiler 9 Summary for Metals ..................................................................................... 3-2 3-4 Boiler 9 Summary for Non-Dioxin Organic HAP

...................................................... 3-2 3-5 Boiler 9 Summary for Dioxins/Furans and PCB ........................................................ 3-3 3-6 Boiler 9 Summary for Semi-Volatile PAHs ............................................................... 3-3 3-7 Boiler 9 Summary for Acid Gases.............................................................................. 3-3 3-8 Boiler 9 Summary for Speciated Volatile Organic Com pounds................................. 3-4 3-9 Boiler 10 Test Schedule.............................................................................................. 3-6 3-10 Boiler 10 Summary for Particulate Matter.................................................................. 3-7 3-11 Boiler 10 Summary for Metals ................................................................................... 3-7 3-12 Boiler 10 Summary for Non-Dioxin Organic HAP

.................................................... 3-7 3-13 Boiler 10 Summary for Dioxins/Furans and PCB ...................................................... 3-8 3-14 Boiler 10 Summary for Semi-Volatile PAHs ............................................................. 3-8 3-15 Boiler 10 Summary for Acid Gases............................................................................ 3-8 3-16 Boiler 10 Summary for Speciated Volatile Organic Com pounds............................... 3-9 3-17 Boiler 60 Test Schedule............................................................................................ 3-11 3-18 Boiler 60 Summary for Particulate Matter................................................................ 3-11 3-19 Boiler 60 Summary for Metals ................................................................................. 3-12 3-20 Boiler 70 Test Schedule............................................................................................ 3-12 3-21 Boiler 70 Summary for Particulate Matter................................................................ 3-13 3-22 Boiler 70 Summary for Metals ................................................................................. 3-13

LIST OF FIGURES

2-1 Process Flow Diagram for Boilers 9 and 10 ............................................................... 2-1 2-2 Sampling Locations for Boilers 9 and 10 ................................................................... 2-2 2-3 Process Flow Diagram for Boiler 60 .......................................................................... 2-5 2-4 Sampling Location for Boiler 60 ................................................................................ 2-5 2-5 Process Flow Diagram for Boiler 70 .......................................................................... 2-6 2-6 Sampling Location for Boiler 70 ................................................................................ 2-8

## SECTION 

# ONE Introduction

1-1 Harding Street Test Report - Final r2 31827133 1. Section 1 ONE Introduction 

### 1.1 SUMMARY OF TEST PROGRAM On November 10, 2009, USEPA published a noti ce in the Federal Register (Vol. 75, No. 216, pages 58012-58013) pursuant to Section 114 of the federa l Clean Air Act regarding an Information Collection Request (ICR) for Ne w and Existing Coal and Oil-fired Electric Utility Steam Electric Units. The objective of the ICR was to obtain information related to hazardous air pollutant (HAP) emissions from th e coal- and oil-fired boilers used to produce electricity. In late December of 2009, the U.S. EPA sent ICR letters to affected facility owners defining unit-specific test ing requirements and schedules. IP&L’s Harding Street Stati on received such a letter on January 4, 2010. Included in the letter was the requirement to conduct the emissions testing summarized in Table 1-1. Table 1-1. Summary of Harding Street Station Testing Requirements

Boiler ID Acid Gas HAP Dioxin HAP Non-Dioxin HAP Metallic HAP Harding Street 9 X X X X Harding Street 10 X X X X Harding Street 60 X Harding Street 70 X

URS Corporation (URS) was contracted to conduct the emissions te sting required by the ICR. The actual test dates for each boiler are summarized in Table 1-2. Table 1-2. Harding Street Station Testing Dates

Boiler ID Testing Dates Harding Street 9 3/7-12/2010 Harding Street 10 3/2-6/2010 Harding Street 60 3/7-14/2010 Harding Street 70 4/13-15/2010

Table 1-3 is a summary of the compounds tested and the test re sults for each of the units tested, based on the average of all three valid test runs for each parameter.

## SECTION 

# ONE Introduction

1-2 Harding Street Test Report - Final r2 31827133 Table 1-3. Summary of Test Results for Harding Street

Test Results Test Parameter HS9 HS10 HS60 HS70 Units Filterable PM b 1.04E-03 1.14E-03 1.36E-02 2.93E-02 lb/mmBtu PM 2.5 [<4.25E-03] [<5.37E-03] 5.12E-02 3.72E-02 lb/mmBtu Aqueous CPM 1.81E-03 2.09E-03 2.52E-02 2.37E-02 lb/mmBtu Organic CPM 1.23E-03 2.03E-03 1.62E-02 6.31E-04 lb/mmBtu Total PM c [<6.21E-03] [<9.03E-03] 6.15E-02 3.72E-02 lb/mmBtu Antimony 2.11E-08 8.73E-08 8.63E-07 [<3.58E-07] lb/mmBtu Arsenic 1.99E-07 [<9.90E-07] 1.20E-05 3.25E-06 lb/mmBtu Beryllium [<9.42E-09] [<2.81E-08] [<5.66E-07] [<1.90E-07] lb/mmBtu Cadmium 7.37E-08 5.27E-07 3.20E-07 3.06E-07 lb/mmBtu Chromium 4.47E-07 2.26E-06 2.38E-06 4.72E-06 lb/mmBtu Cobalt 6.98E-08 9.66E-06 1.06E-06 3.03E-07 lb/mmBtu Lead 3.74E-06 5.08E-06 6.01E-06 7.83E-06 lb/mmBtu Manganese 7.69E-07 3.68E-06 2.13E-06 4.08E-06 lb/mmBtu Mercury 8.83E-08 2.90E-07 3.80E-06 9.89E-07 lb/mmBtu Nickel 7.09E-07 2.50E-06 5.51E-06 5.56E-06 lb/mmBtu Selenium [<1.48E-07] [<4.46E-07] 1.04E-04 1.86E-05 lb/mmBtu 4.16E-11 1.90E-10 -- -- lb/mmBtu PCDD/F 0.05 0.22 -- -- ng/dscm@7% O 2 4.17E-10 4.75E-10 -- -- lb/mmBtu PCB 0.48 0.55 -- -- ng/dscm@7% O 2 HCl [<9.59E-05] [<1.14E-04] -- -- lb/mmBtu HF [<9.83E-05] [<1.17E-04] -- -- lb/mmBtu HCN [<1.92E-05] [<2.53E-05] -- -- lb/mmBtu 1.90E-01 1.86E-01 -- -- lb/mmBtu NO X 115.3 112.8 -- -- ppmvd@7% O 2 2.18E-02 2.54E-02 -- -- lb/mmBtu SO 2 9.5 11.1 -- -- ppmvd@7% O 2 1.79E-03 6.94E-04 -- -- lb/mmBtu CO 1.8 0.7 -- -- ppmvd@7% O 2 [<5.39E-06] [<6.94E-06] -- -- lb/mmBtu HCHO [<5.01E-03] [<6.45E-03] -- -- ppmvd@7% O 2 1.70E-03 3.27E-03 -- -- lb/mmBtu THC 1.1 2.1 -- -- ppmvd@7% O 2 [<4.50E-05] 9.03E-04 -- -- lb/mmBtu CH 4 [<0.08] 1.6 -- -- ppmvd@7% O 2 [<1.52E-04] [<1.70E-04] -- -- lb/mmBtu Volatile Organic HAP e [<176] [<197] -- -- ug/dscm@7% O 2 [<3.67E-06] [<2.90E-06] -- -- lb/mmBtu Semi-Volatile Organic HAP f [<4.25] [<3.36] -- -- ug/dscm@7% O 2

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit. b Based on RM 5/29 data

c Based on OTM-027/028 data
d NO X and SO 2 based on averages from station CEM data

e Excludes acetone, methylene chloride, and toluene used for Method 0010 recovery th at was in field blanks.
f Sum of 19 targeted PAH compounds.

## SECTION 

# ONE Introduction

1-3 Harding Street Test Report - Final r2 31827133 During the stack test periods, the units were ope rated at their “normal” load. For oil-fired Boilers 9 and 10, normal load was approximately 50% of full load. For coal-fired Boilers 60 and 70, normal load was approximately 100% of full load. The emission testing program was conducted in a ccordance with the requirements of EPA’s Section 114 ICR and the guidance posted on the RTI Utility MACT Website. The test program contains the following exceptions to the reference methods, which are explained in detail in Section 5. Run 3 of the organic HAP testing on Boiler 9 wa s terminated after 3.3 hours due to an unexpected issue in the boiler control room that requ ired interruption of testing until the issue was resolv ed. Scrubber samples collected for total dissolved and total suspended solids analysis for Boiler 70 were not collected concurrently with emission testing for particulate matter and HAP metals. Section 2 of this report describes each of th e units tested, including sampling locations and operating conditions. Section 3 is a detailed summary of test results. Section 4 describes the test methods used for this program, and Sec tion 5 describes quality assurance parameters. Raw data and calculation summaries are contained in the Appendices.

## SECTION 

# TWO Facility Description

2-1 Harding Street Test Report - Final r2 31827133 2. Section 2 TWO Facility Description Section 2 describes each of th e tested units, the sampling locations, and the unit operating data during the testing.



### 2.1 HARDING STREET 9 AND 10

2.1.1 Process Description

Boilers 9 and 10 are identical uni ts. Each is rated at 37 MW (summer, gross). The unit is wall-fired and combusts No. 2 distillate fuel oil. There are no a dd-on emission controls. Figure 2-1 is a process flow diagram for each unit.

Figure 2-1. Process Flow Di agram for Boilers 9 and 10



### 2.1.2 Sampling Location Sampling was conducted at the stack sampling ports as shown on Figure 2-2. Sampling was conducted in two perpe ndicular test ports. Wall-Fired Boiler S
t

a

c k Oil

Air

## SECTION 

# TWO Facility Description

2-2 Harding Street Test Report - Final r2 31827133 Figure 2-2. Sampling Locations for Boilers 9 and 10



### 2.1.3 Process Operating Data Testing was conducted under normal operating conditions on March 7-12, 2010 on Boiler 9 and March 2-6, 2010 for Boiler 10. Table 2-1 and Table 2-2 summarizes the boiler operating parameters during the test pr ogram. A copy of the operating data compiled during each of the test runs is provided in Appendix C. As part of the ICR, the facility was required to track operating parameters for a 30-day period that includes the emissions testing period. Ho wever, because Boilers 9 and 10 are peaking units that are infrequently operated, the only time period that the boilers operated during this 30-day period was during the ICR-required stack testing. These operati ng data are presented in the EPA supplied Excel spreadsheets in Appendix F. >181”

>724”

Breaching duct Ports
90.5 "

## SECTION 

# TWO Facility Description

2-3 Harding Street Test Report - Final r2 31827133 Table 2-1. Summary of Boiler Operating Parameters for Boiler 9

Run Boiler O 2 (%) Heat Input (MMBtu/hr) Oil Flow (gallons/hr) Gross Output (MW) Net Output (MW)
Methods 5/29, and OTM-027/028

PM/Met Run 1 7.02 222.97 1614.0 15.51 14.51 PM/Met Run 2 6.59 228.78 1656.0 16.15 15.16 PM/Met Run 3 6.62 228.78 1656.0 16.12 15.05 Avera g e 6.74 226.84 1642.0 15.93 14.91 Methods 18, 23, 25A, 30B, and 316

Or g Run 2 6.60 228.61 1654.8 16.11 15.18 Or g Run 3 6.47 228.04 1650.7 16.11 15.03 Or g Run 4 8.52 188.99 1368.0 15.79 14.31 Avera g e 7.20 215.21 1557.8 16.00 14.84
Method 26 CTM 033

AG Run 1 6.66 240.17 1738.5 14.64 13.80 AG Run 2 7.04 231.26 1674.0 15.42 14.43 AG Run 3 7.01 231.26 1674.0 15.51 14.01 Avera g e 6.90 234.23 1695.5 15.19 14.08
Method SW846-0031 and SW846-0010

V/Svol Run 1 6.97 231.26 1674.0 15.56 14.25 V/Svol Run 2 7.03 230.43 1668.0 15.49 14.26 V/Svol Run 3 7.03 230.43 1668.0 15.35 14.23 Avera g e 7.01 230.71 1670.0 15.47 14.25

## SECTION 

# TWO Facility Description

2-4 Harding Street Test Report - Final r2 31827133 Table 2-2. Summary of Boiler Opera ting Parameters for Boiler 10

Run BoilerO 2 (%) Heat Input (MMBtu/hr) Oil Flow (gallons/hr) Gross Output (MW) Net Output (MW)
Methods 5/29, and OTM-027/028

PM/Met Run 1 7.68 217.41 1573.7 13.59 12.78 PM/Met Run 2 7.44 223.70 1619.3 14.41 13.33 PM/Met Run 3 7.30 226.65 1640.6 15.08 14.14 Average 7.47 222.59 1611.2 14.36 13.42 Methods 18, 23, 25A, 30B, and 316 Org Run 2 8.03 215.76 1561.8 13.96 13.16 Org Run 3 8.08 214.84 1555.1 13.83 12.90 Org Run 4 8.09 214.04 1549.3 13.62 12.56 Average 8.07 214.88 1555.4 13.80 12.87

Method 26A and CTM-033

AG Run 1 8.15 213.52 1545.6 13.13 12.25 AG Run 2 8.23 212.70 1539.6 13.40 12.21 AG Run 3 8.20 214.19 1550.4 13.38 12.45 Average 8.19 213.47 1545.2 13.30 12.31

Method SW846-0031 and SW846-0010

V/Svol Run 1 8.27 214.41 1552.0 12.98 12.46 V/Svol Run 2 8.22 216.07 1564.0 13.31 12.61 V/Svol Run 3 7.82 221.59 1604.0 13.98 12.95 Average 8.10 217.36 1573.3 13.42 12.67



### 2.2 BOILER 60

2.2.1 Process Description Boiler 60 is rated at 112 MW (gross, summer). The unit combusts bituminous coal and consists of a tangentially fired combustor equipped with low NO X burners and over-fire air (LNB/OFA), selective noncatalyt ic reduction (SNCR), and an elec trostatic precipitator (ESP) to reduce air emissions. Figure 2-3 is a process flow diagram for Boiler 60.

## SECTION 

# TWO Facility Description

2-5 Harding Street Test Report - Final r2 31827133 Figure 2-3. Process Flow Diagram for Boiler 60



### 2.2.2 Sampling Location Flue gas samples were collected through test ports located in stac k. Port locations relative to the inlet breaching duct and stack outlet ar e illustrated in Figure 2-4. Sampling was conducted in each of four test ports.

Figure 2-4. Sampling Lo cation for Boiler 60 >232”

>928”

Breaching duct Ports
116" T-Fired Boiler with LNB/OFA SNCR S
t

a

c k Coal

Air Urea

ESP

Flyash

## SECTION 

# TWO Facility Description

2-6 Harding Street Test Report - Final r2 31827133 

### 2.2.3 Process Operating Data Testing was conducted under normal operating conditions on March 7-14, 2010. Table 2-3 summarizes the boiler operating parameters dur ing the test program. A copy of the operating data compiled during each of the test runs is provided in Appendix C. As part of the ICR, the facility was required to track operating parameters for a 30-day period that includes the emissions testing period. The 30-day operating data are presented in the EPA-supplied Excel spreadsheet in Appendix F.



### 2.3 BOILER 70

2.3.1 Process Description Boiler 70 is rated at 463 MW (gross, summer). The unit combusts bituminous coal and consists of a tangentially fired combustor equipped with LNB/OFA, selective catalytic reduction (SCR), an ESP, and wet FGD to reduce air emissions. Figure 2-5 is a process flow diagram for Boiler 70.

Figure 2-5. Process Flow Diagram for Boiler 70 T-Fired Boiler with LNB/OFA ESP S
t

a

c k
Coal

Air

Caustic Liquor Flyash FGD SCR AmmoniaSECTIONTWOFacility Description2-7Harding Street Test Report - Final r231827133Table 2-3. Summary of Boiler Operating Parameters for Boiler 60RunHeat Input(MMBtu/hr)Steam Load(Klbs/hr)Gross Output(MW)Net Output(MW)Excess O2(%)SNCROperation (%)Methods 5/29, and 5/OTM-028PM/Met Run 1 936.76 755.85 103.63 98.612.65 100.00%PM/Met Run 2 947.33 753.20 102.73 97.752.66 100.00%PM/Met Run 3 970.11 762.43 103.90 98.882.59 100.00%Average951.40 757.16 103.42 98.41 2.63 100.00%Method 30BHgRun 1 1063.40 804.20 109.89 104.68 2.46 100.00%HgRun 2 783.04 578.51 79.9775.413.0298.33%HgRun 3 1072.60 751.82 103.40 98.352.57 100.00%Average973.01 711.51 97.75 92.81 2.68 99.44%

## SECTION 

# TWO Facility Description

2-8 Harding Street Test Report - Final r2 31827133 

### 2.3.2 Sampling Location Flue gas samples were collected through test ports located in stac k. Port locations relative to the inlet breaching duct and stack outlet ar e illustrated in Figure 2-6. Sampling was conducted in each of four test ports.

Figure 2-6. Sampling Lo cation for Boiler 70



### 2.3.3 Process Operating Data Testing was conducted under normal operating conditions on April 13-15, 2010. Table 2-1 summarizes the boiler operating parameters dur ing the test program. A copy of the operating data compiled during each of the test runs is provided in Appendix C. As part of the ICR, the facility was required to track operating parameters for a 30-day period that includes the emissions testing period. The 30-day operating data are presented in the EPA-supplied Excel spreadsheet in Appendix F.



### 2.4 FUEL ANALYSIS DATA The average fuel analysis values based on the fuel samples collected during the testing are summarized in Table 2-5. The analytical data associated with each test run are in Appendix B-5. >624”

>2496”

Breaching duct Ports
312 "SECTIONTWOFacility Description2-9Harding Street Test Report - Final r231827133Table 2-4. Summary of Boiler Operating Parameters for Boiler 70RunHeat Input(MMBtu/hr)Steam Load(klbs/hr)GrossOutput(MW)Net Output(MW)Excess O2(%)SCROperation(Y/N)FGDPressureDrop(in H2O)Slurry Flow(gpm)ScrubberLiquor pHScrubberRecyclePumps inService(#)AmmoniaFlow (lb/hr)TR Sets inService(#)Methods 5/29, and 5/OTM-028Run 13981.48 2915.62 445.22 417.38 3.32 YES 0.92 247.12 5.32 6 329.30 19.0Run 24077.78 2968.14 444.72 417.03 3.31 YES 1.13 245.58 5.35 6 342.94 19.0Run 33955.43 2926.30 445.14 417.18 3.32 YES 0.84 244.44 5.26 6 320.39 19.0Average4004.90 2936.69 445.03 417.20 3.32 YES 0.96 245.71 5.31 6 330.88 19.0Method 30BRun 54097.55 2968.01 443.94 416.00 3.31 YES 1.32 236.14 5.25 6 388.51 19.0Run 63992.55 2950.17 444.86 417.17 3.34 YES 1.02 257.36 5.37 6 334.76 18.5Run 74051.34 2965.96 445.42 417.47 3.34 YES 1.29 233.61 5.34 6 355.06 18.0Average4047.15 2961.38 444.74 416.88 3.33 YES 1.21 242.37 5.32 6 359.45 18.5

## SECTION 

# TWO Facility Description

2-10 Harding Street Test Report - Final r2 31827133 Table 2-5. Summary of Fuel Analysis for Boilers 9, 10, 60, and 70

Parameter Boiler 9 Boiler 10 Boiler 60 Boiler 70 Units HHV, as received 19,1 10 19,110 10,622 11,155 Btu/lb Moisture NA NA 15.5 12.5 % Ash 0.0 0.0 9.0 9.5 % HHV, dry NA NA 12,571 12,720 Btu/lb

Sulfur 0.02 0.02 3.73 6.19 lb/MMBtu as SO 2 Chlorine ND ND 1.1E-02 3.5E-02 lb/MMBtu Fluorine ND ND NA NA lb/MMBtu Arsenic ND ND 5.5E-04 2.5E-04 lb/MMBtu Beryllium ND ND 2.1E-04 1.7E-04 lb/MMBtu Cadmium ND ND 9.6E-05 7.5E-05 lb/MMBtu Chromium ND ND 8.0E-04 9.4E-04 lb/MMBtu

Cobalt ND ND 4.6E-04 2.4E-04 lb/MMBtu Lead ND ND 1.0E-03 5.0E-04 lb/MMBtu Manganese ND ND 1.3E-03 1.3E-03 lb/MMBtu

Mercury ND ND 4.8E-06 5.2E-06 lb/MMBtu

Nickel ND ND 1.9E-03 1.0E-03 lb/MMBtu Selenium ND ND 1.0E-04 2.4E-04 lb/MMBtu

## SECTION 

# THREE Test Results

3-1 Harding Street Test Report - Final r2 31827133 3. Section 3 THREE Test Results 

### 3.1 BOILER 9 The test schedule and run times for Harding Street Boiler 9 are shown in Table 3-1.
Table 3-1. Boiler 9 Test Schedule

Date Run Times a Test Methods Run #
3/11/2010 0355-0755 Acid Gases-1 3/11/2010 0747-1106 Acid Gases-2 3/11/2010 1122-1424 EPA Methods 1-4, 3A, 26A and CTM-033 Acid Gases-3 3/7-8/2010 2200-0108 PM/Metals-1

3/8/2010 1255-1820 PM/Metals-2 3/8-9/2010 2040-0242 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 3/9/2010 0405-1328 Organic HAPs-1 3/9/2010 1511-2320 Organic HAPs-2 3/10/2010 0000-0320 EPA Methods 1-4, 3A, 18, 23, 25A, and 316 Organic HAPs-3 3/9/2010 0415-0615 Hg-1 3/9/2010 1015-1215 Hg-2 3/9/2010 1535-1735 EPA Method 30B Hg-3 3/11/2010 2100-2305 V/Svol Run 1 3/11-12/2010 2340-0145 V/Svol Run 2

3/12/2010 0205-0410 SW846 Methods 0010 and 0031 V/Svol Run 3

a Run times are based on Eastern Standard Time (EST) The test team arrived on site on March 2, comp leted safety training, powered up the trailer, and began setting up the test equipment. Test runs on Boiler 9 were completed on March 7-12, as outlined in Table 3-1. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR, except for Run 3 of the organic HAP testing. Tables 3-2 through 3-8 summari ze the results from the test program on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report.

## SECTION 

# THREE Test Results

3-2 Harding Street Test Report - Final r2 31827133 Table 3-2. Boiler 9 Summary for Particulate Matter

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-027/028 a

Run Filterable PM b (lb/MMBtu) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 1.26E-03 5.10E-03 2.31E-03 1.32E-03 6.45E-03 2 1.17E-03 [<4.47E-03] 1.44E-03 1.22E-03 [<5.32E-03] 3 6.94E-04 [<3.18E-03] 1.69E-03 1.17E-03 [<6.85E-03] Avg. 1.04E-03 [<4.25E-03] 1.81E-03 1.23E-03 [<6.21E-03]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit);
b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA OTM-027/028 sampling train.

Table 3-3. Boiler 9 Summary for Metals
Reference Method Test Results for EPA Methods 29 and 30B (lb/MMBtu) a Run 1 2 3 Average Antimony 2.25E-08 3.33E-08 7.45E-09 2.11E-08 Arsenic 2.03E-07 3.40E-07 5.33E-08 1.99E-07 Beryllium [<1.10E-08] [<1.45E-08] [<2.77E-09] [<9.42E-09] Cadmium 1.12E-07 8.73E-08 2.19E-08 7.37E-08 Chromium 3.19E-07 9.22E-07 9.93E-08 4.47E-07 Cobalt 1.38E-07 4.83E-08 2.34E-08 6.98E-08 Lead 4.75E-06 4.99E-06 1.48E-06 3.74E-06 Manganese 7.78E-07 1.32E-06 2.11E-07 7.69E-07 Mercury 5.99E-08 5.80E-08 1.47E-07 8.83E-08
Nickel 7.83E-07 1.12E-06 2.21E-07 7.09E-07 Selenium [<1.56E-07] [<1.98E-07] [<9.05E-08] [<1.48E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Table 3-4. Boiler 9 Summary for Non-Dioxin Organic HAP
Reference Method Test Results for EPA Methods 1-4, 18, 23, 25A, and 316 a

Run CO (lb/MMBtu) HCHO (lb/MMBtu) THC (lb/MMBtu) CH 4 (lb/MMBtu) 1 0.00E00 [<4.58E-06] 0.00E00 [<4.46E-05] 2 0.00E00 [<5.71E-06] 3.24E-03 [<4.40E-05] 3 5.36E-03 [<5.88E-06] 1.86E-03 [<4.64E-05] Avg. 1.79E-03 [<5.39E-06] 1.70E-03 [<4.50E-05]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

## SECTION 

# THREE Test Results

3-3 Harding Street Test Report - Final r2 31827133 Table 3-5. Boiler 9 Summary for Dioxins/Furans and PCB
Reference Method Test Results for EPA Method 23 (lb/MMBtu) a Run 1 2 3 Average Total Dioxins & Furans [<1.86E-11] [<8.47E-11] [<2.14E-11] [<4.16E-11] Total PCBs [<3.90E-10] [<4.40E-10] [<4.22E-10] [<4.17E-10]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Table 3-6. Boiler 9 Summary for Semi-Volatile PAHs
Reference Method Test Results for EPA SW846 Methods 0010 (lb/MMBtu) a Analyte 1 2 3 Average Naphthalene [<6.29E-04] [<6.87E-04] [<5.93E-04] [<6.36E-04] 2-Methylnaphthalene [<5.35E-04] [<5.51E-04] [<4.96E-04] [<5.27E-04] Acenaphthylene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Acenaphthene (CCC) [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Fluorene [<1.60E-04] [<1.37E-04] [<9.81E-05] [<1.31E-04] Phenanthrene [<5.47E-04] [<4.45E-04] [<2.72E-04] [<4.20E-04] Anthracene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Fluoranthene (CCC) [<4.81E-04] [<4.08E-04] [<1.54E-04] [<3.46E-04] Pyrene [<3.45E-04] [<3.03E-04] [<1.25E-04] [<2.57E-04] Benzo(a)anthracene [<1.33E-04] [<1. 11E-04] [<9.63E-05] [<1.13E-04] Chrysene [<2.12E-04] [<1.84E-04] [<9.63E-05] [<1.64E-04] Benzo(b)fluoranthene [<1.08E-04] [<1.00E-04] [<9.63E-05] [<1.01E-04] Benzo(k)fluoranthene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Benzo(e)pyrene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Benzo(a)pyrene (CCC) [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Perylene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Indeno(1,2,3-cd)pyrene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Dibenz(a,h)anthracene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05] Benzo(g,h,i)perylene [<9.89E-05] [<9.59E-05] [<9.63E-05] [<9.70E-05]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Table 3-7. Boiler 9 Summary for Acid Gases
Reference Method Test Results for EPA Methods 1-4, 26A, & CTM-33 a

Run SO 2 (lb/MMBtu) NO X (lb/MMBtu) HCl (lb/MMBtu) HF (lb/MMBtu) HCN (lb/MMBtu) 1 1.87E-02 1.87E-01 [<8.70E-05] [<8.91E-05] [<2.06E-05] 2 2.40E-02 1.91E-01 [<1.01E-04] [<1.03E-04] [<1.89E-05] 3 2.26E-02 1.92E-01 [<1.00E-04] [<1.02E-04] [<1.81E-05] Avg. 2.18E-02 1.90E-01 [<9.59E-05] [<9.83E-05] [<1.92E-05]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

## SECTION 

# THREE Test Results

3-4 Harding Street Test Report - Final r2 31827133 Table 3-8. Boiler 9 Summary for Speci ated Volatile Organic Compounds

Reference Method Test Results for EPA SW846 Methods 0031 (lb/MMBtu) a Analyte 1 2 3 Average trans-1,3-Dichloropropene [<1.92E-07] [<1.93E-07] [<1.92E-07] [<1.92E-07] Acetone b 5.56E-05 1.49E-04 3.26E-04 1.77E-04 Ethylbenzene [<6.71E-07] [<6.22E-07] [<4.90E-07] [<5.94E-07] Trichlorofluoromethane [<8.89E-07] [<1.23E-06] [<1.57E-06] [<1.23E-06] Hexachlorobutadiene [<4.48E-07] [<4.51E-07] [<4.46E-07] [<4.48E-07] 2-Hexanone [<1.31E-06] [<1.25E-06] [<1.04E-06] [<1.20E-06] Isopropylbenzene [<2.87E-07] [<2.68E-07] [<2.11E-07] [<2.55E-07] p-Isopropyltoluene [<1.72E-07] [<1.53E-07] [<1.51E-07] [<1.59E-07] Methylene chloride b 2.91E-06 2.17E-05 1.88E-04 7.08E-05 4-Methyl-2-pentanone [<1.38E-05] [<1.39E-05] [<1.38E-05] [<1.38E-05] Naphthalene [<1.38E-06] [<1.38E-06] [<1.37E-06] [<1.38E-06] Benzene [<8.70E-05] [<9.94E-05] [<5.28E-05] [<7.97E-05] n-Propylbenzene [<3.75E-07] [<4.21E-07] [<3.01E-07] [<3.65E-07] Styrene [<8.26E-07] [<6.96E-07] [<3.73E-07] [<6.32E-07] 1,1,1,2-Tetrachloroethane [<1.78E-07] [<1.79E-07] [<1.77E-07] [<1.78E-07] 1,1,2,2-Tetrachloroethane [<4.30E-07] [<4.32E-07] [<4.28E-07] [<4.30E-07] Tetrachloroethene [<1.79E-07] [<1.77E-07] [<2.58E-07] [<2.05E-07] Toluene b 2.68E-06 [<2.20E-06] [<2.42E-06] [<2.43E-06] 1,2,3-Trichlorobenzene [<2.21E-07] [<2.22E-07] [<2.20E-07] [<2.21E-07] 1,2,4-Trichlorobenzene [<2.73E-07] [<2.74E-07] [<2.72E-07] [<2.73E-07] 1,1,1-Trichloroethane [<1.75E-07] [<1.76E-07] [<1.75E-07] [<1.75E-07] 1,1,2-Trichloroethane [<1.35E-06] [<1.36E-06] [<1.35E-06] [<1.35E-06] Trichloroethene [<3.21E-07] [<3.23E-07] [<3.20E-07] [<3.21E-07] 1,2,3-Trichloropropane [<3.37E-06] [<3.38E-06] [<3.35E-06] [<3.37E-06] 1,2,4-Trimethylbenzene [<1.47E-06] [<1.75E-06] [<1.22E-06] [<1.48E-06] 1,3,5-Trimethylbenzene [<5.37E-07] [<5.92E-07] [<4.56E-07] [<5.28E-07] Vinyl chloride [<3.30E-07] [<3.32E-07] [<3.29E-07] [<3.30E-07] o-Xylene [<9.12E-07] [<9.00E-07] [<6.72E-07] [<8.28E-07] m-Xylene & p-Xylene [<1.76E-06] [<2.14E-06 [<1.63E-06[ [<1.84E-06] Bromobenzene [<2.93E-07] [<2.95E-07] [<2.92E-07[ [<2.93E-07] Bromochloromethane [<4.27E-07] [<4.29E-07] [<4.25E-07[ [<4.27E-07] Bromodichloromethane [<2.11E-07] [<2.12E-07] [<2.10E-07[ [<2.11E-07] Bromoform [<1.62E-06] [<1.63E-06] [<1.62E-06[ [<1.62E-06] Bromomethane [<1.00E-06] [<9.13E-07] [<9.53E-07[ [<9.56E-07] 2-Butanone [<1.38E-05] [<1.39E-05] [<1.38E-05[ [<1.38E-05] n-Butylbenzene [<3.07E-07] [<4.00E-07] [<2.87E-07[ [<3.31E-07] sec-Butylbenzene [<1.70E-07] [<1.53E-07] [<1.51E-07[ [<1.58E-07] tert-Butylbenzene [<1.66E-07] [<1.67E-07] [<1.65E-07[ [<1.66E-07]

## SECTION 

# THREE Test Results

3-5 Harding Street Test Report - Final r2 31827133 Table 3-8 Continued. Boiler 9 Summary for Speciated Volatile Organic Compounds
Reference Method Test Results for EPA SW846 Methods 0031 (lb/MMBtu) a

Analyte 1 2 3 Average Carbon disulfide [<3.18E-07] [<3.14E-07] [<2.82E-07] [<3.05E-07] Carbon tetrachloride [<3.79E-07] [<3.94E-07] [<3.70E-07] [<3.81E-07] Chlorobenzene [<1.57E-07] [<1.88E-07] [<1.56E-07] [<1.67E-07] Chlorodibromomethane [<3.31E-07] [<3.33E-07] [<3.30E-07] [<3.31E-07] 1,2-Dibromo-3-chloropropane [<1.90E-06] [<1.91E-06] [<1.90E-06] [<1.90E-06] Chloroethane [<8.90E-07] [<8.95E-07] [<8.86E-07] [<8.90E-07] Chloroform [<1.66E-07] [<1.67E-07] [<1.66E-07] [<1.66E-07] Chloromethane [<1.17E-05] [<1.30E-05] [<9.45E-06] [<1.14E-05] 2-Chlorotoluene [<1.88E-07] [<2.16E-07] [<1.88E-07] [<1.97E-07] 4-Chlorotoluene [<2.14E-07] [<2.16E-07] [<2.14E-07] [<2.14E-07] 1,2-Dibromoethane [<2.43E-07] [<2.44E-07] [<2.42E-07] [<2.43E-07] Dibromomethane [<3.36E-07] [<3.38E-07] [<3.35E-07] [<3.36E-07] 1,2-Dichlorobenzene [<2.57E-07] [<2.58E-07] [<2.56E-07] [<2.57E-07] 1,3-Dichlorobenzene [<2.10E-07] [<2.11E-07] [<2.09E-07] [<2.10E-07] 1,4-Dichlorobenzene [<2.27E-07] [<2.48E-07] [<2.45E-07] [<2.40E-07] Dichlorodifluoromethane [<5.60E-07] [<2.54E-06] [<5.08E-06] [<2.73E-06] 1,1-Dichloroethane [<1.52E-07] [<1.53E-07] [<1.51E-07] [<1.52E-07] 1,2-Dichloroethane [<2.51E-07] [<2.52E-07] [<2.50E-07] [<2.51E-07] 1,1-Dichloroethene [<2.38E-07] [<2.39E-07] [<2.37E-07] [<2.38E-07] cis-1,2-Dichloroethene [<1.65E-07] [<1.66E-07] [<1.64E-07] [<1.65E-07] trans-1,2-Dichloroethene [<2.83E-07] [<2.85E-07] [<2.82E-07] [<2.83E-07] 1,2-Dichloropropane [<2.52E-07] [<2.53E-07] [<2.51E-07] [<2.52E-07] 1,3-Dichloropropane [<2.05E-07] [<2.06E-07] [<2.04E-07] [<2.05E-07] 2,2-Dichloropropane [<1.64E-07] [<1.65E-07] [<1.64E-07] [<1.64E-07] 1,1-Dichloropropene [<1.57E-07] [<1.58E-07] [<1.57E-07] [<1.57E-07] cis-1,3-Dichloropropene [<2.59E-07] [<2.61E-07] [<2.58E-07] [<2.59E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

b Acetone, methylene chloride, and to luene are solvents used during reco very of the Method 0010 sampling train and were present in the field blank at similar levels.

Compounds that were found above the detection limit were all present in si milar levels in the field blanks. Acetone, methylene chloride, and toluene were present as solvents in near proximity to the VOST sampling train due their use for the Method 0010 recovery. Further details of the emissions for each compound are provided in Appendix A. As noted in Section 2, Boiler 9 is a peaking boiler that did not opera te during the 30-day period prior to and after the ICR-required testing. Therefor e, 30-day CEM data is not included in report.

## SECTION 

# THREE Test Results

3-6 Harding Street Test Report - Final r2 31827133 

### 3.2 BOILER 10 The test schedule and run times for Harding St reet Boiler 10 are shown in Table 3-9.
Table 3-9. Boiler 10 Test Schedule

Date Run Times a Test Methods Run #
3/5/2010 0509-0911 Acid Gases-1 3/5/2010 1022-1500 Acid Gases-2 3/5/2010 1511-1812 EPA Methods 1-4, 3A, 26A and CTM-033 Acid Gases-3 3/2/2010 0140-0754 PM/Metals-1 3/2/2010 1010-1716 PM/Metals-2 3/2-3/2010 2000-0218 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 3/3-4/2010 2145-0642 Organic HAPs-1

3/4/2010 0930-1840 Organic HAPs-2 3/4-5/2010 1955-0400 EPA Methods 1-4, 3A, 18, 23, 25A, and 316 Organic HAPs-3

3/3/2010 0330-0530 Hg-1 3/3/2010 0615-0815 Hg-2 3/3/2010 1127-1327 EPA Method 30B Hg-3 3/5-6/2010 2330-0140 V/Svol Run 1

3/6/2010 0245-0455 V/Svol Run 2 3/6/2010 0515-0720 SW846 Methods 0010 and 0031 V/Svol Run 3

a Run times are based on Eastern Standard Time (EST)
The test team arrived on site on March 2, comp leted safety training, powered up the trailer, and began setting up the test equipment. Test runs on Boiler 10 were completed on March 2- 6, as outlined in Table 3-9. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR. Tables 3-10 through 3-16 summarize the results from the test pr ogram on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report.

## SECTION 

# THREE Test Results

3-7 Harding Street Test Report - Final r2 31827133 Table 3-10. Boiler 10 Summary for Particulate Matter

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-027/028 a

Run Filterable PM b (lb/MMBtu ) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 1.38E-03 [<6.89E-03] 3.01E-03 2.95E-03 [<1.27E-02] 2 1.27E-03 [<6.09E-03] 2.88E-03 2.06E-03 [<1.00E-02] 3 7.50E-04 3.12E-03 3.80E-04 1.09E-03 4.30E-03 Avg. 1.14E-03 [<5.37E-03] 2.09E-03 2.03E-03 [<9.03E-03]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit);
b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA OTM-027/028 sampling train.

Table 3-11. Boiler 10 Summary for Metals
Reference Method Test Results for EPA Methods 29 and 30B (lb/MMBtu) a
Run 1 2 3 Average Antimony 1.45E-07 8.44E-08 3.31E-08 8.73E-08 Arsenic [<1.59E-06] [<1.04E-06] [<3.32E-07] [<9.90E-07] Beryllium [<4.47E-08] [<3.00E-08] [<9.48E-09] [<2.81E-08] Cadmium 8.45E-07 5.36E-07 2.02E-07 5.27E-07 Chromium 3.54E-06 2.42E-06 8.20E-07 2.26E-06 Cobalt 1.79E-07 2.87E-05 b 4.96E-08 9.66E-06 Lead 7.51E-06 5.96E-06 1.77E-06 5.08E-06 Manganese 6.47E-06 3.48E-06 1.09E-06 3.68E-06 Mercury 1.04E-07 4.06E-07 3.60E-07 2.90E-07
Nickel 3.80E-06 2.75E-06 9.35E-07 2.50E-06 Selenium 5.50E-07 [<7.09E-07] [<8.01E-08] [<4.46E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

b Apparent outlier. High cobalt level during Run 2 due to elevated back-half concentration (all other runs for Boilers 9 and 10 had non-detects in back half).

Table 3-12. Boiler 10 Summary for Non-Dioxin Organic HAP
Reference Method Test Results for EPA Methods 1-4, 18, 23, 25A, and 316 a

Run CO (lb/MMBtu) HCHO (lb/MMBtu) THC (lb/MMBtu) CH 4 (lb/MMBtu) 1 3.57E-05 8.33E-06 3.04E-03 5.94E-04 2 5.99E-04 5.84E-06 2.63E-03 2.27E-04 3 1.45E-03 [<6.66E-06] 4.13E-03 1.89E-03 Avg. 6.94E-04 [<6.94E-06] 3.27E-03 9.03E-04

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

## SECTION 

# THREE Test Results

3-8 Harding Street Test Report - Final r2 31827133 Table 3-13. Boiler 10 Summary for Dioxins/Furans and PCB
Reference Method Test Results for EPA Method 23 (lb/MMBtu) a
Run 1 2 3 Average Total Dioxins & Furans [<2.76E-10] [<2.62E-11] [<2.67E-10] [<1.90E-10] Total PCBs [<3.99E-10] [<4.90E-10] [<5.38E-10] [<4.75E-10]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.
Table 3-14. Boiler 10 Summary for Semi-Volatile PAHs
Reference Method Test Results for EPA SW846 Methods 0010 (lb/MMBtu) a Analyte 1 2 3 Average Naphthalene [<3.00E-07] [<2.80E-07] [<2.11E-07] [<2.55E-07] 2-Methylnaphthalene [<1.88E-07] [<1.53E-07] [<9.15E-08] [<1.35E-07] Acenaphthylene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Acenaphthene (CCC) [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Fluorene [<1.64E-07] [<1.20E-07] [<7.30E-08] [<1.11E-07] Phenanthrene [<5.66E-07] [<3.89E-07] [<2.62E-07] [<3.81E-07] Anthracene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Fluoranthene (CCC) [<6.29E-07] [<4.08E-07] [<1.51E-07] [<3.54E-07] Pyrene [<5.17E-07] [<3.25E-07] [<1.22E-07] [<2.87E-07] Benzo(a)anthracene [<1.81E-07] [<1. 48E-07] [<7.30E-08] [<1.24E-07] Chrysene [<2.94E-07] [<1.84E-07] [<7.30E-08] [<1.65E-07] Benzo(b)fluoranthene [<1.52E-07] [<1.18E-07] [<7.30E-08] [<1.07E-07] Benzo(k)fluoranthene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Benzo(e)pyrene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Benzo(a)pyrene (CCC) [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Perylene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Indeno(1,2,3-cd)pyrene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Dibenz(a,h)anthracene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08] Benzo(g,h,i)perylene [<1.19E-07] [<1.18E-07] [<7.30E-08] [<9.80E-08]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.
Table 3-15. Boiler 10 Summary for Acid Gases

Reference Method Test Results fo r EPA Methods 1-4, 26A, & CTM-33 a

Run SO 2 (lb/MMBtu) NO X (lb/MMBtu) HCl (lb/MMBtu) HF (lb/MMBtu) HCN (lb/MMBtu) 1 2.49E-02 1.86E-01 [<1.01E-04] [<1.03E-04] [<2.33E-05] 2 2.70E-02 1.86E-01 [<1.28E-04] [<1.32E-04] [<2.82E-05] 3 2.44E-02 1.87E-01 [<1.13E-04] [<1.15E-04] [<2.43E-05] Avg. 2.54E-02 1.86E-01 [<1.14E-04] [<1.17E-04] [<2.53E-05]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

## SECTION 

# THREE Test Results

3-9 Harding Street Test Report - Final r2 31827133 Table 3-16. Boiler 10 Summary for Speci ated Volatile Organic Compounds

Reference Method Test Results for EPA SW846 Methods 0031 ( lb/MMBtu ) a Analyte 1 2 3 Average trans-1,3-Dichloropropene [<1.93E-07] [<1.82E-07] [<1.84E-07] [<1.86E-07] Acetone 1.63E-04 1.38E-03 1.31E-04 5.59E-04 Ethylbenzene [<2.51E-07] [<4.00E-07] [<5.36E-07] [<3.96E-07] Trichlorofluoromethane [<6.65E-07] [<1.03E-06] [<1.01E-06] [<9.01E-07] Hexachlorobutadiene [<4.50E-07] [<4.25E-07] [<4.28E-07] [<4.34E-07] 2-Hexanone [<1.30E-06] [<1.92E-06] [<1.48E-06] [<1.57E-06] Isopropylbenzene [<1.54E-07] [<1.45E-07] [<1.51E-07] [<1.50E-07] p-Isopropyltoluene [<1.57E-07] [<1.73E-07] [<1.93E-07] [<1.75E-07] Methylene chloride 4.11E-06 [<7.48E-05] 1.94E-03 [<6.73E-04] 4-Methyl-2-pentanone [<1.39E-05] [<1.31E-05] [<1.32E-05] [<1.34E-05] Naphthalene [<1.38E-06] [<1.31E-06] [<1.31E-06] [<1.33E-06]
Benzene 8.41E-05 9.52E-05 9.55E-05 9.16E-05 n-Propylbenzene [<1.69E-07] [<2.06E-07] [<2.06E-07] [<1.94E-07] Styrene [<6.18E-07] [<1.10E-06] [<9.74E-07] [<8.96E-07] 1,1,1,2-Tetrachloroethane [<1.79E-07] [<1.69E-07] [<1.70E-07] [<1.72E-07] 1,1,2,2-Tetrachloroethane [<4.32E-07] [<4.08E-07] [<4.11E-07] [<4.17E-07] Tetrachloroethene [<1.77E-07] [<2.42E-07] [<3.77E-07] [<2.65E-07] Toluene [<1.23E-06] [<2.26E-06] 6.98E-06 [<3.49E-06] 1,2,3-Trichlorobenzene [<2.22E-07] [<2.09E-07] [<2.11E-07] [<2.14E-07] 1,2,4-Trichlorobenzene [<2.74E-07] [<2.59E-07] [<2.60E-07] [<2.64E-07] 1,1,1-Trichloroethane [<1.76E-07] [<1.66E-07] [<1.69E-07] [<1.70E-07] 1,1,2-Trichloroethane [<1.36E-06] [<1.28E-06] [<1.29E-06] [<1.31E-06] Trichloroethene [<3.25E-07] [<3.41E-07] [<6.16E-07] [<4.28E-07] 1,2,3-Trichloropropane [<3.38E-06] [<3.19E-06] [<3.21E-06] [<3.26E-06] 1,2,4-Trimethylbenzene [<2.37E-07] [<3.25E-07] [<4.80E-07] [<3.47E-07] 1,3,5-Trimethylbenzene [<2.46E-07] [<2.32E-07] [<2.65E-07] [<2.48E-07] Vinyl chloride [<3.31E-07] [<3.13E-07] [<3.15E-07] [<3.20E-07] o-Xylene [<2.19E-07] [<3.32E-07] [<5.03E-07] [<3.51E-07] m-Xylene & p-Xylene [<3.98E-07] [<6.58E-07] [<1.03E-06] [<6.95E-07] Bromobenzene [<2.94E-07] [<2.78E-07] [<2.80E-07] [<2.84E-07] Bromochloromethane [<4.28E-07] [<4.05E-07] [<4.07E-07] [<4.13E-07] Bromodichloromethane [<2.12E-07] [<2.00E-07] [<2.02E-07] [<2.05E-07] Bromoform [<1.63E-06] [<1.54E-06] [<1.55E-06] [<1.57E-06] Bromomethane [<1.53E-06] [<8.13E-07] [<8.19E-07] [<1.05E-06] 2-Butanone [<1.39E-05] [<1.31E-05] [<1.32E-05] [<1.34E-05] n-Butylbenzene [<1.88E-07] [<2.07E-07] [<1.85E-07] [<1.93E-07] sec-Butylbenzene [<1.53E-07] [<1.44E-07] [<1.45E-07] [<1.47E-07] tert-Butylbenzene [<1.66E-07] [<1.57E-07] [<1.58E-07] [<1.60E-07]

## SECTION 

# THREE Test Results

3-10 Harding Street Test Report - Final r2 31827133 Table 3-16 Continued. Boiler 10 Summary fo r Speciated Volatile Organic Compounds

Reference Method Test Results for EPA SW846 Methods 0031 ( lb/MMBtu ) a

Analyte 1 2 3 Average Carbon disulfide [<4.03E-07] [<3.81E-07] [<4.16E-07] [<4.00E-07] Carbon tetrachloride [<3.12E-07] [<4.77E-07] [<4.52E-07] [<4.14E-07] Chlorobenzene [<1.65E-07] [<1.48E-07] [<1.49E-07] [<1.54E-07] Chlorodibromomethane [<3.32E-07] [<3.14E-07] [<3.16E-07] [<3.21E-07] 1,2-Dibromo-3-chloropropane [<1.91E-06] [<1.80E-06] [<1.82E-06] [<1.84E-06] Chloroethane [<1.07E-06] [<8.44E-07] [<8.50E-07] [<9.21E-07] Chloroform [<1.67E-07] [<1.68E-07] [<1.59E-07] [<1.65E-07] Chloromethane [<2.77E-05] [<1.49E-05] [<1.80E-05] [<2.02E-05] 2-Chlorotoluene [<1.89E-07] [<1.79E-07] [<1.80E-07] [<1.82E-07] 4-Chlorotoluene [<2.15E-07] [<2.03E-07] [<2.05E-07] [<2.08E-07] 1,2-Dibromoethane [<2.44E-07] [<2.30E-07] [<2.32E-07] [<2.35E-07] Dibromomethane [<3.37E-07] [<3.18E-07] [<3.21E-07] [<3.25E-07] 1,2-Dichlorobenzene [<2.57E-07] [<2.43E-07] [<2.45E-07] [<2.49E-07] 1,3-Dichlorobenzene [<2.11E-07] [<1.99E-07] [<2.00E-07] [<2.03E-07] 1,4-Dichlorobenzene [<2.39E-07] [<2.35E-07] [<2.41E-07] [<2.38E-07] Dichlorodifluoromethane [<4.27E-06] [<4.45E-06] [<4.66E-06] [<4.46E-06] 1,1-Dichloroethane [<1.53E-07] [<1.44E-07] [<1.45E-07] [<1.47E-07] 1,2-Dichloroethane [<2.52E-07] [<2.38E-07] [<2.39E-07] [<2.43E-07] 1,1-Dichloroethene [<2.39E-07] [<2.25E-07] [<2.27E-07] [<2.30E-07] cis-1,2-Dichloroethene [<1.66E-07] [<1.56E-07] [<1.58E-07] [<1.60E-07] trans-1,2-Dichloroethene [<2.84E-07] [<2.68E-07] [<2.73E-07] [<2.75E-07] 1,2-Dichloropropane [<2.53E-07] [<2.39E-07] [<2.41E-07] [<2.44E-07] 1,3-Dichloropropane [<2.06E-07] [<1.95E-07] [<1.96E-07] [<1.99E-07] 2,2-Dichloropropane [<1.65E-07] [<1.56E-07] [<1.57E-07] [<1.59E-07] 1,1-Dichloropropene [<1.58E-07] [<1.49E-07] [<1.50E-07] [<1.52E-07] cis-1,3-Dichloropropene [<2.60E-07] [<2.46E-07] [<2.47E-07] [<2.51E-07]

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Further details of the emissions for each compound are provided in Appendix A. All of the compounds with the ex ception of benzene that were m easured at levels above the detection limits were present in the field bl anks. Acetone and met hylene chloride were present in the proximity of the VOST sampling tr ain due to their necessity to recovery the Method 0010 samples. The other four compounds de tected were used as spikes and exhibited recoveries of greater than 100%. As noted in Section 2, Boiler 10 is a peaking boiler that did not operate during the 30-day pe riod prior to and after the I CR-required testing. Therefore, 30-day process data is not included in report.

## SECTION 

# THREE Test Results

3-11 Harding Street Test Report - Final r2 31827133 

### 3.3 BOILER 60 The test schedule and run times for Harding St reet Boiler 60 are shown in Table 3-17.
Table 3-17. Boiler 60 Test Schedule

Date Run Times a Test Methods Run #
3/13/2010 0905-1519 PM/Metals-1 3/13/2010 1610-2226 PM/Metals-2 3/14/2010 0900-1515 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 3/7/2010 1135-1335 Hg-1 3/7/2010 1440-1640 Hg-2 3/7/2010 1735-1935 EPA Method 30B Hg-3

a Run times are based on Eastern Standard Time (EST) The test team arrived on site on March 2, comp leted safety training, powered up the trailer, and began setting up the test equipment. Test runs on Boiler 60 were completed March 7-14, as outlined in Table 3-17 above. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR. Tables 3-18 and 3-19 summarize th e results from the test program on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report. Table 3-18. Boiler 60 Summary for Particulate Matter
Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28

Run Filterable PM b (lb/MMBtu ) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 1.05E-02 4.16E-02 9.88E-03 2.32E-02 5.27E-02 2 1.13E-02 6.46E-02 3.71E-02 1.67E-02 7.69E-02 3 1.89E-02 4.74E-02 2.87E-02 8.88E-03 5.49E-02 Avg. 1.36E-02 5.12E-02 2.52E-02 1.62E-02 6.15E-02

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit);
b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA OTM-027/028 sampling train.

## SECTION 

# THREE Test Results

3-12 Harding Street Test Report - Final r2 31827133 Table 3-19. Boiler 60 Summary for Metals
Reference Method Test Results for EPA Methods 29 and 30B (lb/MMBtu) a Run 1 2 3 Average Antimony 9.26E-07 9.36E-07 7.27E-07 8.63E-07
Arsenic 1.03E-05 1.58E-05 9.94E-06 1.20E-05 Beryllium [<5.91E-07] 6.22E-07 [<4.87E-07] [<5.66E-07]
Cadmium 3.51E-07 3.20E-07 2.90E-07 3.20E-07
Chromium 2.45E-06 2.14E-06 2.53E-06 2.38E-06
Cobalt 1.12E-06 1.16E-06 9.12E-07 1.06E-06
Lead 6.10E-06 6.90E-06 5.02E-06 6.01E-06 Manganese 2.17E-06 2.35E-06 1.87E-06 2.13E-06 Mercury 3.75E-06 3.21E-06 4.44E-06 3.80E-06
Nickel 5.96E-06 5.78E-06 4.78E-06 5.51E-06
Selenium 1.32E-04 9.89E-05 8.02E-05 1.04E-04

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

Further details of the emissions for each compound are provided in Appendix A.



### 3.4 BOILER 70 The test schedule and run times for Harding St reet Boiler 70 are shown in Table 3-20.
Table 3-20. Boiler 70 Test Schedule

Date Run Times a Test Methods Run #
4/13/2010 0820-1305 PM/Metals-1 4/13/2010 1440-1910 PM/Metals-2 4/14/2010 0820-1030 EPA Methods 1-4, 3A, 5/29, and OTM-027/OTM-028 PM-Metals-3 4/14/2010 1540-1640 Hg-1 4/15/2010 0800-1000 Hg-2 4/15/2010 1155-1355 EPA Method 30B Hg-3

a Run times are based on Eastern Standard Time (EST) During the first deployment (when Boilers 9, 10, and 60 were tested), Boiler 70 was not tested due to process difficul ties resulting from cooling towe r operating issues. Testing was performed during a separate and later deployment. Test runs were completed on April 13-15, as outlined in Table 3-21 above. Emission testing was performed as required by the EPA 114 ICR. Test durations and target sample volumes were specified by the guidance document that accompanied the ICR. Tables 3-21 and 3-22 summarize th e results from the test program on a run-by-run basis. Supporting documentation and further details of the test results are provided in the appendices to this report.

## SECTION 

# THREE Test Results

3-13 Harding Street Test Report - Final r2 31827133 Table 3-21. Boiler 70 Summary for Particulate Matter
Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28

Run Filterable PM b (lb/MMBtu ) PM 2.5 (lb/MMBtu) Aqueous Condensible Matter (lb/MMBtu) Organic Condensible Matter (lb/MMBtu) Total PM c (lb/MMBtu) 1 2.98E-02 3.79E-02 2.26E-02 7.22E-04 3.79E-02 2 3.02E-02 4.23E-02 3.24E-02 7.15E-04 4.23E-02 3 2.78E-02 3.15E-02 1.61E-02 4.55E-04 3.15E-02 Avg. 2.93E-02 3.72E-02 2.37E-02 6.31E-04 3.72E-02

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit); b Filterable particulate matter emissions reported from EPA Method 5/29 sampling train.

c Total particulate matter emissions reported from EPA M5 and OTM-028 sampling train.

Table 3-22. Boiler 70 Summary for Metals

Reference Method Test Results for EPA Methods 29 and 30B ( lb/MMBtu ) a Run 1 2 3 Average Antimony 4.93E-07 4.27E-07 [<1.54E-07] [<3.58E-07] Arsenic 4.46E-06 3.86E-06 1.42E-06 3.25E-06 Beryllium [<2.59E-07] [<2.26E-07] [<8.58E-08] [<1.90E-07] Cadmium 4.43E-07 3.33E-07 1.41E-07 3.06E-07 Chromium 7.30E-06 4.01E-06 2.85E-06 4.72E-06 Cobalt 4.10E-07 3.20E-07 1.80E-07 3.03E-07 Lead 4.91E-06 1.46E-05 3.93E-06 7.83E-06 Manganese 6.80E-06 3.19E-06 2.26E-06 4.08E-06 Mercury 1.07E-06 9.99E-07 8.92E-07 9.89E-07 Nickel 9.79E-06 4.78E-06 2.11E-06 5.56E-06 Selenium 2.31E-05 2.08E-05 1.18E-05 1.86E-05

a Results containing non-detect values are indicated w ith [<] and are reported at the full detection limit.

## SECTION 

# FOUR Test Methods

4-1 Harding Street Test Report - Final r2 31827133 4. Section 4 FOUR Test Methods The following sections present information on th e test methods used for the test program.



### 4.1 VOLUMETRIC FLOW, MOISTURE, AND MOLECULAR WEIGHT
EPA Reference Methods 1, 2, 3, and 4 were used to determine the sample traverse point locations, volumetric flow, flue gas molecular we ight, and the gas moisture content. Vent gas velocity and moisture content were measured at the stack locati on in conjunction with isokinetic sampling trains. Flue gas molecular weight was cal culated using EPA Method 3A to determine concentrations of O 2 and CO 2 in the stack gas.



### 4.2 PARTICULATE MATTER FROM DRY STACKS For stacks not having entrained water droplet s, particulate matter concentration was determined using EPA Other Test Method 027 and 028. A measured volume of stack gas was drawn from the stack pseudo-is okinetically through an Apex Instruments PM 2.5 cyclone and in-stack 63 mm glass filter. Sampling was c onducted at a fixed sampling rate using the calculations from the test method to determ ine dwell time at each sample point. The remaining sample gas passed through a heated pr obe and transfer line followed by a vertical water-jacketed condensing coil before enteri ng the impinger train. The front half of the impinger train consisted of an oversized short stem impinger followed by a standard modified impinger. The two part s of the impinger train were connected with an in-train Teflon membrane filter. The sample gas pa ssing through the filter was monitored and maintained at just below 85  F by controlling the temperature of the front half water bath surrounding the impingers. The back half of the imp inger train consisted of two standard size modified Greenberg-Smith impingers, the firs t of which contained 100 ml of organic free water with the final impinger c ontaining silica gel. The back ha lf of the sampling train was immersed in an ice bath to maintain the exit temperature to below 68 F. After exiting the impinger train, the dry gas was measured using a dry gas metering console. Particulate matter trapped in the fractions of the cyclone was r ecovered by brushing and rinsing each fraction individuall y with acetone into separately labeled sample. Front half rinse samples were dried, desiccated for 24 hour s, and analyzed gravimetrically at the URS Laboratory in Morrisville, NC. Th e glass fiber filter was also de siccated, and the weight gain was added to the rinse weight. The back half of the sampling train (after the 63 mm in-stack filter) including the heated sample probe, transfer line, and condenser coil were rinsed with high purity organic free water, high purity acetone, and high purity MeCl to recover any condensable matter that may have accumulated during the test run. The impi nger train was sealed and transported to the mobile laboratory where it was purged with nitrogen at 20 lp m for one hour before being recovered and extracted with high purity or ganic free water, high purity acetone, and high purity MeCl to remove and preserve the c ondensable particulate for evaporation and gravimetric analysis at the laboratory. Rinses were kept separate from the condensed moisture fraction until combined by the laboratory.

## SECTION 

# FOUR Test Methods

4-2 Harding Street Test Report - Final r2 31827133 Moisture in the gas streams was determined using EPA Method 4. In this method, the weight gain in the chilled impingers is used to calculate the percentage of moisture in the stack gas sample. Molecular weight, carbon dioxide, and oxygen content of the gas samples were determined using either EPA Method 3A or 3B. Stack gas velocity and volumetric flow rate were determined using EPA Method 2. In this method, a Type S pitot is used to traverse the duct using traverse points determined by EPA Method 1. The pitot pressures and temperature data collected during each sampling traverse are used to calcul ate the stack gas velocity. Samples were all given a unique identification nu mber and logged into a table as they were collected and recovered. Identification number s were included on all sample containers during the analytical process. All EPA Met hod OTM-027 samples were analyzed at the URS RTP Field Laboratory. Enthalpy Analytical of Durham, North Carolina performed the EPA Method OTM-028 analysis. Appendix B contains the analytical data sheets and laboratory report from Enthalpy Analytical.



### 4.3 PARTICULATE MATTER FROM WET STACKS For wet stacks containing entrained water dr oplets, PM-concentration was determined using EPA Method 5 and Other Test Method 028. A m easured volume of stack gas was drawn from the stack isokinetically through a button hook style glass nozzle followed by a heated quartz filter. The remaining sample gas passe d through a heated tran sfer line followed by a vertical water-jacketed condensing coil before entering the impinger train. The front half of the impinger train consisted of an oversized short stem impinger followed by a standard modified impinger. The two part s of the impinger train were connected with an in-train Teflon membrane filter. The sample gas pa ssing through the filter was monitored and maintained at just below 85  F by controlling the temperature of the front half water bath surrounding the impingers. The back half of the imp inger train consisted of two standard size modified Greenberg-Smith impingers, the firs t of which contained 100 ml of organic free water with the final impinger c ontaining silica gel. The back ha lf of the sampling train was immersed in an ice bath to mainta in the exit temperature to below 68  F. After exiting the impinger train, the dry gas was measured using a dry gas metering console. Particulate matter trapped in the heated probe and filter assembly was recovered by brushing and rinsing each fraction individually with acetone into separately labeled sample. Front half rinse samples were dried, desiccated for 24 hour s, and analyzed gravimetrically at the URS Laboratory in Morrisville, NC. The quartz fiber filter was also desiccated, and the weight gain was added to the rinse weight. The back half of the sampling train, including the heated transfer line and condensing coil, was rinsed with high purity organic free wate r, high purity acetone, a nd high purity MeCl to recover any condensable matter that may have accumulated during the test run. The impinger train was sealed and transported to the mobile laboratory where it was purged with nitrogen at 20 lpm for one hour before being recovered and extracted with hi gh purity organic free water, high purity acetone, and high purity MeCl to remove and preserve the condensable

## SECTION 

# FOUR Test Methods

4-3 Harding Street Test Report - Final r2 31827133 particulate for evaporation and gravimetric anal ysis at the laboratory. Rinses were kept separate from the condensed moisture fraction until combined by the laboratory. Moisture in the gas streams was determined using EPA Method 4. In this method, the weight gain in the chilled impingers is used to calculate the percentage of moisture in the stack gas sample. Molecular weight, carbon dioxide, and oxygen content of the gas samples were determined using EPA Method 3A or 3B. Stack gas velocity and volumetric flow rate were determined using EPA Method 2. In this method, a Type S pitot is used to traverse the duct using traverse points determined by EPA Method 1. The pitot pressures and temperature data collected during each sampling traverse are used to calcul ate the stack gas velocity. Samples were all given a unique identification nu mber and logged into a table as they were collected and recovered. Identification number s were included on all sample containers during the analytical process. All EPA Method 5 samples were analyzed at the URS RTP Field Laboratory. Enthalpy Analytical of Durham, North Carolina performed the EPA Method OTM-028 analysis. Appendix B contains the analytical data sheets and laboratory report from Enthalpy Analytical.



### 4.4 SULFUR DIOXIDE

Emissions of sulfur dioxide were determin ed using the procedures provided in EPA Method 6C using the facility’s cer tified CEMS instrumentation. The SO 2 analyzer works off the ultraviolet (UV) absorption principle. The sample stream pa sses through a sample chamber within the analyzer at a constant pr essure which has a UV li ght source present at one end. The SO 2 molecules in the sample stream abso rb a portion of the energy from the UV lamp which excites the particle causing it to d ecay to a lower energy state. As the particle decays, it gives of ultraviolet light at a diffe rent wavelength. The emission of that light is measured by a photomultiplier tube located pe rpendicular to the UV light source further down the sample path. The intensity of the li ght detected by the photomultiplier tube is proportional in relation to the concentration of SO 2 in the sample stream. The light intensity measured by the analyzer corresponds to a si gnal that was transf erred to the DAS and recorded in by the historian.



### 4.5 OXIDES OF NITROGEN

EPA Method 7E was used to determine concentra tions of oxides of nitrogen in the flue gas using the facility’s certified CEMS instrumentation. The NO X analyzer operates off the chemiluminescent principle and is equipped with a catalytic thermal converter to convert NO 2 to NO. The sample gas is passed through th e converter and heated to break one of the oxygen bonds in the NO 2 molecule. After the conversion, th e oxides all exist as NO in the sample stream. The gas is then blended with ozone in a reaction chamber that is held under constant vacuum. The resulting chem ical reaction between the NO and O 3 produces a photon of light for each molecule. The chemilumine scent photons are measured by a photomultiplier

## SECTION 

# FOUR Test Methods

4-4 Harding Street Test Report - Final r2 31827133 tube at the end of the reaction chamber to pr oduce a signal that is linear in relation to concentration.



### 4.6 CARBON MONOXIDE

EPA Method 10 was used to determine concentr ations of carbon monoxide in the flue gas using the facility’s certified CEMS instrumenta tion as well as by the test crew on site. The concentration of carbon monoxide in the stack exhaust was se lectively measured by a gas filter correlation analyzer. The analyzer’s op eration is based on the principle that carbon monoxide absorbs infrared light at a speci fic wavelength. The instrument produces an infrared light signal which pa sses through a spinning correlati on wheel. The light signal is modulated by alternating back and forth betw een two chambers on the wheel, one of which contains nitrogen (measurement cell) and the ot her contains carbon monoxide (the reference cell). The nitrogen cell is transparent to the infr ared light and allows the entire light signal to pass though while the carbon monoxide cell abso rbs all of the light at the effected wavelengths providing a baseline. After the lig ht source is chopped it passes through the sample chamber where the continuous stream of sample gas is maintained at a constant temperature and pressure. The chamber contains multiple mirrors to extend the path length during which the signal is in contact with the sample gas before being measured by the detector. The amplitude of the difference betw een the modulations in the signal is a nonlinear correlation that repres ents the concentration of car bon monoxide in the sample. The signal is linearized by the intern al software of the instrument resulting in a voltage output that is recorded by a data acquisition system. The gas filter correlation analyzer was calibrated using EPA Protocol 1 ga ses with the resultant test data being corrected for bias and drift.



### 4.7 METHANE EPA Method 18 was performed to determine con centration of methane in the flue gas. A sample of the stack gas was extracted from th e test location through an in-stack filter and transported to the test traile r through a heated sample line an d heated head pump. A slip stream of the sample gas was injected directly to the GC/FID heated manifold. The column separates the constituents in the gas str eam by molecular size, allowing the smaller compounds to pass through first. Once the hydr ocarbon constituents have passed through the column they are introduced to a flame ioniza tion detector (FID). The ionizer heats the compounds to break the carbon bonds. As each ca rbon bond breaks the intensity of the flame as well as the chamber conductivity increase, which is measured by the detector to provide a response. Because the compounds have been sp eciated by passing them through the column, the resultant intensity of the response is attribut ed to a specific or ganic compound based on the time it takes the response to be detected after being injected into the column and the level of response. The GC/FID is calibrated using EPA Protocol 1 gases at th ree concentrations to develop a linear regression curve. Each test r un consisted of at least five injects to the GC/FID followed by a 3 replicate calibration ch eck. Results for each test run were averaged and compared against the calibration curve to determine concentrations.

## SECTION 

# FOUR Test Methods

4-5 Harding Street Test Report - Final r2 31827133 

### 4.8 DIOXINS, FURANS AND PCB The procedures from EPA Method 23 were employed to determine emissions of polychlorinated dibenzo-p-dioxins, polych lorinated dibenzofurans (PCDD/F), and polychlorinated biphynals in the stack gas. A sample of the gas stream was extracted isokinetically from the source through a glass nozzle and heated probe and filter assembly. The gas stream was then filtered through a pretre ated glass filter before passing into a waterjacketed condenser followed by a module cont aining XAD-2 resin to remove the remaining PCDD/F and PCB constituents. The exhaust of the condenser was monitored to remain at or below 68 degrees Fahrenheit duri ng the test. The flue gas then passed through an ice bath impinger train containing HPLC grade water and silica gel to remove any remaining moisture prior to being measured by a dry gas metering c onsole. After the final leak check had been performed the sample train was partially di sassembled and trans ported to the mobile laboratory for recovery. The front half of the train was rinsed with acetone and toluene as prescribed in the ICR. Rinses of the back half connecting glasswar e and condenser were added to the front half rinses in the mobile laboratory. All three solvent rinses were kept separate until received by the analytical laboratory. During the recove ry process, the XAD-2 Resin was reweighed for the moisture determination, the thermocouple was removed, and the ends were properly sealed with Teflon tape a nd aluminum foil. The module was then covered with aluminum foil to prevent excess exposure, la beled and kept cool in a sample refrigerator until the test program was completed. Prior to the sampling event all of the glassw are was washed with Alconox and deionized water and baked at 300 degrees Celsius for 4 hours. A final rinse of the glassware with MeCl was performed prior to being packaged for tr ansport to the facilit y. XAD-2 Resin traps and glass filters were prepared by the laboratory prior to the sampling program. Filters were baked to remove any contaminants. XAD modules were cleaned and baked according to the procedures above before being packed w ith XAD-2 Resin. The XAD modules were then spiked with know concentrations of PCDD/F prior to shipment to the URS Laboratory. Sample traps were maintained on ice or in a sample refrigerator prior to and following the sampling event until they arrived back at the laboratory for analysis. Analysis of the EPA Method 23 samples was performed by Analytical Perspectives in Wilmington, North Carolina. Analytical Perspectives calculated detection limits using the equation: DL = ( 2.5 × H N × Q IS ) / ( H IS × W × RRF)
Where:

 DL is the estimated detection limit for homologous 2,3,7,8-substituted PCDD/PCDFs

 HN is the height of the noise (using 20-30 data points to determine s, with 4s used as the value)

 QIS is the amount (in pg) of extraction standard added to the sample before extraction

 HIS is the peak height of the extraction standard

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# FOUR Test Methods

4-6 Harding Street Test Report - Final r2 31827133  W is the weight of the sample (for met hod 23 samples this value is always 1)

 RRF is the calculated relative re sponse factor for the analyte



### 4.9 TOTAL HYDROCARBONS

EPA Method 25A was used to determine concen tration of total hydrocarbons (THC) in the gas stream. A sample of the stack gas was extract ed from the test location through an in-stack filter and heated line and transported to the m obile laboratory with the aid of a heated head pump. A slip stream of the hot gas is directed to the flame ionization analyzer. The ionizer heats the gas to break the carbon bonds of the organic compounds. As each carbon bond breaks, the intensity of the flame as well as the chamber conductivity increase, which is measured by the detector to provide a res ponse. Because the organic compounds have not been speciated, the detector only documents the number of carbon bonds broken on the basis of the calibration gas used. Fo r this program, the calibration basis was methane so the resultant response is on an as methane basi s. The instrument was calibrated using EPA Protocol 1 gases with the resultan t data being corrected for drift.



### 4.10 HYDROGEN CHLORIDE AND HYDROGEN FLORIDE
EPA Method 26A was used to determine emissions of HCl, Cl 2 , and HF in the gas stream. A sample of the stack gas was extracted from th e test location through a glass nozzle, heated probe, and filter assembly prior to entering th e sample train. The sample was filtered through a Teflon coated quartz filter maintained at greater than 248 degrees Fahrenheit meeting the specifications for particle retention of 99.95 % for 0.3um as prescribed in the test method. The sample then passed thorough an overs ized knockout Greenberg-Smith impinger containing 50 ml of 0.1 N H 2 SO 4 followed by two standard size Greenberg-Smith impingers also containing 0.1N H 2 SO 4 . The sample then passed through two standard size modified Greenberg-Smith impingers containing 0.1N Na OH followed by a silica gel impinger before being measured by a dry gas meter. Hydrogena ted halogen compounds we re captured in the acidic impinger solutions while the remaining el emental halogens are captured in the basic impinger solutions. After completion of the te st run, a leak check was performed and the sampling system was partially disassembled a nd transported to the mobile laboratory for recovery. Sampling trains were weighed gravimetrically for moisture calculations, and recovered into appropriately labeled sample jars with DI H 2 O. Sodium thiosulfate was added to the basic impinger solutions by the labor atory prior to analysis. Enthalpy Analytical in Durham, North Carolina performed the analysis for these samples by ion chromatography. Gravimetric analysis of the front-half samples was performed by URS Corporation in Morrisville, North Carolina. Even though the ICR did not request that analysis of Cl 2 be conducted along with this sampling train it was performed, and the results are included in the appendices of this test report. Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation

## SECTION 

# FOUR Test Methods

4-7 Harding Street Test Report - Final r2 31827133 of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria, a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.



### 4.11 FILTERABLE PM AND NON-MERCURY METALS Emissions of antimony, arsenic, beryllium, cad mium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium were determined using the procedures prescribed in EPA Method 29. A sample of the stack gas was wit hdrawn isokinetically fr om the source through a glass nozzle, heated probe, and heater filt er prior to entering the impinger train. The impinger train was maintained in an ice bath wi th an exit temperature of less than 68 degrees Fahrenheit prior to being measured by a dry gas metering console. The impinger train consisted of an oversized impinger and two standard size impingers (the second being a Greenberg-Smith with the other two being modi fied Greenberg-Smith). The second and third impingers contained a solution of 5% HNO 3 and 10% H 2 O 2 in water. The fourth impinger was an empty modified Greenberg-Smith impi nger. Impingers 5 and 6 were both modified Greenberg-Smith Impingers containing a solution of 4% KMnO 4 and 10% H 2 SO 4 in water. The final impinger contained silica gel. At th e completion of each test run, following the final leak check, the sampling train was partially disassembled and transp orted to the mobile laboratory for sample recovery. The probe a nd nozzle was first rinsed and brushed with acetone followed by 0.1 N HNO 3 into separate jars. In the la boratory, the train was weighed gravimetrically for moisture determinations a nd recovered as prescribed in the test method. Once the samples were transported back to the URS Laboratory in Morrisville, North Carolina, the acetone rinses were dried down at ambient temperatures and desiccated along with the filters. Following gravimetric analys is of the samples, the acetone rinses were reconstituted with 0.1N HNO 3 and added to the front half nitric rinses. Samples were then shipped to the Test America Laboratory in Sacramento, California for analysis by ICP-MS and CVAAS. Test America calculated a MDL using the method of 7 replicate samples spiked at greater than 3 times the estimated MDL. The complete details and formulae used are in the SOP attached as an addendum to the analytical report. Regent blanks showed no significant levels of contamination except for nickel. The filter blank resulted in a contamination level of 3.6 ug. Analytical results we re corrected for this blank value only.



### 4.12 MERCURY

EPA Reference Method 30B “Determination of Total Vapor Phase Mercury Emissions From Coal-Fired Combustion Sources Using Carbon Traps” was used to determine vaporous mercury concentration in each With Method 30B, flue gas is extracted from a stack or duct using paired, two-section sorbent media traps at a constant flow rate. The use of in-stack sorbent traps minimizes potential loss of me rcury during transport through a probe/sample

## SECTION 

# FOUR Test Methods

4-8 Harding Street Test Report - Final r2 31827133 line. For each test run, paired train sampling is used to determine measurement precision and verify acceptability of the measured emissions data. This test consisted of collecting an integrated sample (3 point short- line) using Method 30B at sampling points 0.4, 1.2, and 2.0 meters from the stack wall. A single port was used to collect the samples. A dual console Apex Instruments Model XC 260 sorbent tube sampling system was used to sample flue gas at both the stack. The sorbent traps were procured from Ohio Lumex. For the field recovery test the front section of one t ube in each pair was spiked by URS with a known concentration of elemental mercury prior to sampling. QA/QC procedures required by Method 30B were adhered to throughout the program. The sorbent traps were analyzed on-site by URS using an Ohio Lumex 915+ thermal analyzer with M324 attachment. A Field Recovery Test based on recovery of an elemental Hg spike was used to assess measurement bias and to verify data acceptability. In accordance with Method 30B section 8.2.3.1.1, an Hg o analytical bias test was performed to confirm that the analytical system results we re within ±10% of the target value. Table 4-3 shows the results of the Hg o analytical bias test. All sample s at three different spike levels passed the ±10% spike recovery criteria for the test program. All samples were analyzed by the URS laboratory in Morrisville, NC. In accordance with Method 30B section 8.2.3.1.2, an Hg +2 analytical bias test was performed prior to field deployment to confirm that the an alytical system results were within ±10% of the target value. Table 4-4 shows the results of the Hg +2 analytical bias tests. All samples at three different spike levels passed th e ±10% spike recovery criteria. As previously approved by the EPA, sources including oil and coke fired units where the presence of mercury is not anticipated, test runs were conducted usi ng tubes spiked at 50 ng of mercury with two hour samples being co llected at a nominal 2-hours. Using these procedures, if the QA/QC criteri a for paired trap agreement of spike concentration with respect to sample concentration are not met, the test runs will still be considered as valid.



### 4.13 HYDROGEN CYANIDE Emissions of hydrogen cyanide were measured using the procedures prescribed in EPA Conditional Test Method 33. A sa mple of the stack gas was ex tracted isokinetically through a glass nozzle and heated probe assembly. The sa mple passed through a heated filter assembly to remove particulate followed by a five-impinger train before being measured by a dry gas metering console. The impinger train was mainta ined in an ice bath to control the exit impinger temperature to at or below 68 degrees Fahrenheit. The configuration of the train included a primary impinger containing lead acetate, a knock-out impinger, two impingers containing 100 ml of 4N NaOH eac h, and a final silica gel impinge r. The purpose of the lead acetate was to remove SO 2 from the sample stream in order to maintain the pH of the NaOH above 12. As recommended by the test method A lizarin Yellow was utilized in the NaOH impingers as an indicator of pH. At the completion of each test run, the sample train was partially disassembled and transported to th e mobile laboratory for recovery. The probe nozzle and connection glassware were brushed an d recovered into a glass sample jar with

## SECTION 

# FOUR Test Methods

4-9 Harding Street Test Report - Final r2 31827133 acetone to be archived for PM analysis. In the mobile laboratory, the impinger train was weighed gravimetrically for moisture determin ation. The impinger contents were recovered into sample jars followed by rinses of lead acetate for the first and second impingers and high purity water for the NaOH impingers. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. A field blank was collected and analyzed once per facility. . As prescribed in the test method, a field spike was prepared once for each facility and analyzed along with the samples. Enthalpy Analytical in Durham, North Carolina conducted the analysis of the samples. Lead acetate was prepared by Enthalpy and used with in the 10-day holding time provided in the test method. Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria, a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.



### 4.14 SEMI-VOLATILE ORGANIC COMPOUNDS Emissions of speciated semi-volatile or ganic compounds were measured using the procedures prescribed in Solid Waste Asso ciation 846 Method 0010. A sample of the stack gas was extracted isokinetically through a glass nozzle and heat ed probe assembly. The gas then passed through a glass filter to remove filterable constituents followed by a horizontal condenser and XAD-2 Resin trap before entering the impinger train. The temperature of the sample gas was monitored through a thermo well at the entrance of the resin trap to ensure the temperature was below 68 O F. After exiting the resin tr ap, the sample stream passed through an impinger train containi ng organic free water to rem ove any residual semi-volatile compounds and residual moisture before bei ng measured by a dry gas meter. The impinger train was maintained in an ice bath to control the exit impinger temperature to at or below 68 F. The impinger train consisted two standard size impingers with containing 100 ml of organic free water each followed by an third empty impinger. The fourth and final impinger contained silica gel. At the completion of each test run, the sample train was partially disassembled and transported to the mobile laboratory for recovery. The probe nozzle and connection glassware were brushe d and recovered into a glass sa mple jar with acetone first followed by MeCl as prescribed in the ICR. In the mobile laboratory, the impinger train was weighed gravimetrically for moisture determ ination. The first impinger contents were recovered into sample jars followed by rinses of acetone and MeCl with all rinses and samples being recovered into their separate sample jars. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. A field blank was collected and analyzed once per facility. Enthalpy Analytical in Durham, North Carolina prepared the filters and XAD-2 Resin traps for the sampling event. Resin traps were us ed within the 30-day hold time after being prepared. Enthalpy Analytical provided the analysis for these samples.

## SECTION 

# FOUR Test Methods

4-10 Harding Street Test Report - Final r2 31827133 Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a concentration near the expected MDL. To dete rmine the MDL value, the standard deviation of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of re plicates analyzed. The MDL value meets the criteria stated in CFR Title 40, Part 136B. If the MDL determined did not meet these criteria, a default MDL value was used of 1/10 of the c oncentration of the standard used to produce the MDL value.



### 4.15 VOLATILE ORGANIC COMPOUNDS Emissions of speciated volatile organic com pounds were measured using the procedures prescribed in Solid Waste Association 846 Method 0031. A sample of the stack gas was extracted glass lined heated probe assembly maintained at 130 + 5 O C containing an organic free glass wool plug to filter out particulat e matter. The gas was then passed through a condenser maintained at below 20 O C, two Tenax sorbent traps, a condensate trap, and an Anasorb trap to collect the volatile compounds. The gas pass es through a final silica gel reservoir before being measured by a dry gas me ter. The system was operated as to collect a nominal 1 liter per minute of gas for 20 minutes pe r tube set. A test run as described in the ICR consisted of four sets of traps with one condensate sample. A field blank was performed for each test run to document any contamination issues that may have been present. Samples were maintained in a sample refrigerator or on ice until they were received by the laboratory for analysis. Additional QA/QC samples includi ng one pre-test train blank per source, one trip blank per cooler, and a reagent bla nk were collected for each facility. TestAmerica located in Knoxville, Tennessee prep ared the traps and performed the analysis. Analytes for this test method were not specifi cally requested by the ICR therefore a list of 64 typical compounds of interest for this test method were reported in the test results. Test America calculated a MDL using the method of 7 replicate samples spiked at greater than 3 times the estimated MDL. The complete details and formulae used are in the SOP attached as an addendum to the analytical report.



### 4.16 PROCESS DATA

Process data from each of the units was record ed by the facility DAS and PI system. Process indicators that were monitored included boile r steaming rate (Klbs/hr), fuel firing rates (mmBtu/hr calculated heat i nput), and scrubber operation (q uench flow and differential pressure of the scrubber as compliance indicat ors for PM, pH, and recirculation rates of scrubber liquid are also included as requested ). Additionally, CEM data recorded by the facilities 40CFR Parts 60 and 75 system on the boiler were recorded over the 30-day monitoring period for NOx, SO 2 , and CO. Copies of the proc ess operating data records are included in Appendix C. Copies of the 30-day monitoring data are provided in Appendix E. During the second mobilization to test Boiler 70, a miscommunication resulted in a failure to collect the scrubber samples required for the total dissolved and total suspended solids analysis. Angelique Oliger of IP &L contacted Bill Maxwell of EPA to inquire as to how to proceed. The EPA provided guidance to collec t the scrubber samples after the fact and

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# FOUR Test Methods

4-11 Harding Street Test Report - Final r2 31827133 document the delay in collection in the test report. Testing for th e PM and Metallic HAP subgroup was completed on April 14, 2010. Three individual scrubber samples were collected on April 15, 2010 in two-hour increments beginni ng at around 10 AM and ending at around 2 PM. Operating parameters for Boiler 70 remained consistent over both the testing and scrubber sample collection times.

## SECTION 

# FIVE Quality Assurance/Quality Control

5-1 Harding Street Test Report - Final r2 31827133 5. Section 5 FIVE Quality Assurance/Quality Control Specific quality assurance and quality control ( QA/QC) procedures were used during the test program to cover field sampling, recovery, sample analysis, data reduc tion, and interpretation of results. QA/QC procedures were strictly foll owed to ensure the production of useful and valid data. This section will describe these procedures and will report the test program QA parameters, which indicate data quality.



### 5.1 SAMPLING QA/QC Prior to and immediately following each test run, leak checks of all manual method sampling trains were performed to verify no sample dilution of the sampled stack gas was occurring during the test. All leak checks were recorded properly and met the leak criterion. Where any leak check failed, the test run was aborted a nd repeated. Prior to and following the test program, pitot leak checks were performed on th e pressure differential measuring systems. CEM analyzers were calibrated according to the relevant test method with bias and drift checks being performed as require d. Analyzers were calibrated using EPA Protocol 1 gases. Copies of the cylinder certificatio ns are included in the appendices. Prior to beginning the test program a leak check was performed on the CEMS sampling system to verify the absence of leaks by cappi ng the tip of the sample probe and pulling a vacuum. Flow rate was monitored until the ab sence of flow was detection using in-line rotometers on the flow control manifold. A stratification check was performed on the stack prior to beginning the first test run for all reference method CEMS instrumentation. The results of that traverse showed the absence of any significant stratification. Results of that QC check are provided in Appendix D. Sampling media and glassware were prepared using the prescribed procedures for the applicable test method. Where glassware wa s used on multiple units, the glassware was blanked between them to verify cleanliness between units.



### 5.2 OTHER QA/QC The sampling and recovery procedures sp ecified in EPA Methods 5, 18, 23, 25A, 26A, 29, OTM027/OTM028, CTM 033, SW846-0010, SW846-0061, and SW846-0031. The following QA/QC procedures were satisfied for the purpose of ensuring valid results:

 All sampling equipment passed a thorough vi sual and operation check prior to and after transport to ensure clean and operab le parts. Equipment that failed to pass this check was not used in the field.

 Manometers were leveled and zeroed before measuring the differential pressure across the S-type pitot tubes.

 The temperature measurement system was capable of measuring the ambient temperature prior to each traverse to within  2  C of the average measured ambient temperature.

 The field personnel reviewed sampling da ta forms daily on-site during testing.

## SECTION 

# FIVE Quality Assurance/Quality Control

5-2 Harding Street Test Report - Final r2 31827133  Ice was maintained in the impinger baths at all times; exit temperatures were maintained at less than 20  C (<68  F) except for the front half of the OTM028 impinger train which was maintained at less than 29 o C (<85 o F).

 Each leg of the S-type pitot tube achieved the prescribed leak criterion described in EPA Method 2.

 Readings of the dry gas meter, stack gas velocity head (  P), sample line orifice meter pressure differential (  H), temperature, and vacuum pump were made during sampling at each traverse point at a minimum of one every five minutes.

 Dry gas meters were calibrated before the test program and the calibration was rechecked after the test was completed using the ALT-009 Gamma QA procedure.

 Methods 23, 316, CTM-033, SW846-0010, and SW846-0031 samples were kept on ice until analyzed.

 A field spike and field blank were perf ormed as part of the CTM-033 sampling portion of the test program. Results for the field spike are provided in the Enthalpy Analytical Report in Appe ndix B and met the method criteria.

 Field blanks were conducted and analyzed for each manual test method performed on-site. Reagent blanks were collected a nd archived in case of further need for analysis.



### 5.3 TEST METHOD EXCEPTIONS The following exceptions to test methods and qual ity control parameters were noted as part of this testing effort. Run 3 of the organic HAP testing on Boiler 9 was interrupted after 3.3 hours due to an unexpected issue in the boiler control room th at required a 24-hour in terruption in boiler operation until issue was resolved. Bill Maxwell at U.S. EPA was contacted and indicated that run should not be re-start ed due to length of interruption and should be flagged in test report. Scrubber samples collected for total dissolved and total suspended solid s analysis for Boiler 70 were not collected concurre ntly with emission testing for particulate matter and HAP metals. Due to the low level of Hg in oil, spiked c oncentrations of Hg on th e 30B sorbent tubes for Boilers 9 and 10 did not meet the 50% to 150 % guidance as per the te st method. Discussions with the U.S. EPA have confirmed the spiking cr iteria as being only as guidance and not as a requirement for the ICR testing.

### APPENDIX A Sampling Data

APPENDIX A-1 HARDING STREET 9 A-1-1 Preliminary Test Data
A-1-2 Emission Test Data fo r PM, PM 2.5, and Metals
A-1-3 Emission Test Data for Acid Gases
A-1-4 Emissions Test Data fo r Non-Dioxin/Furan Organics
A-1-5 Emissions Test Da ta for Dioxin Organics

APPENDIX A-2 HARDING STREET 10 A-2-1 Preliminary Test Data
A-2-2 Emission Test Data fo r PM, PM 2.5, and Metals
A-2-3 Emission Test Data for Acid Gases
A-2-4 Emissions Test Data fo r Non-Dioxin/Furan Organics
A-2-5 Emissions Test Da ta for Dioxin Organics

APPENDIX A-3 HARDING STREET 60 A-3-1 Preliminary Test Data
A-3-2 Emission Test Data fo r PM, PM 2.5, and Metals

A-4 HARDING STREET 70 A-4-1 Preliminary Test Data
A-4-2 Emission Test Data fo r PM, PM 2.5, and MetalsAPPENDIX A-1
HARDING STREET 9

Appendix A-1-1 Preliminary Test Data Appendix A-1-2 Emission Test Da ta for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3A

Appendix A-1-3 Emission T est Data for Acid Gases EPA Methods 3A, 6C, and 7E EPA Method 26A EPA CTM-033

Appendix A-1-4 Emissions Test Data for Non-Dioxin/Furan Organics EPA Methods 3A, 10, and 25A EPA Method 18 EPA Method 316 SW846-0010 SW846-0031

Appendix A-1-5 Emissions Test Data for PCDD/F and Coplanar PCBs EPA Method 23 EPA Method 3AAppendix A-1-1 Preliminary Test DataAppendix A-1-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods OTM-027/028EPA Method 30BEPA Method 3AAppendix A-1-3
Emission Test Data for Acid GasesEPA Method 3A, 6C, and 7EEPA Method 26AEPA CTM-033Appendix A-1-4
Emissions Test Data for Non-Dioxin/Furan OrganicsEPA Methods 3A, 10, and 25AEPA Method 18EPA Method 316SW846-0010SW846-0031Appendix A-1-5 Emissions Test Data for PCDD/F and Coplanar PCBsEPA Method 23EPA Method 3A

(See Appendix A-1-4)APPENDIX A-2
HARDING STREET 10

Appendix A-2-1 Preliminary Test Data Appendix A-2-2 Emission Test Da ta for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3A

Appendix A-2-3 Emission T est Data for Acid Gases EPA Methods 3A, 6C, and 7E EPA Method 26A EPA CTM-033

Appendix A-2-4 Emissions Test Data for Non-Dioxin/Furan Organics EPA Methods 3A, 10, and 25A EPA Method 18 EPA Method 316 SW846-0010 SW846-0031

Appendix A-2-5 Emissions Test Data for PCDD/F and Coplanar PCBs EPA Method 23 EPA Method 3AAppendix A-2-1 Preliminary Test DataAppendix A-2-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods OTM-027/028EPA Method 30BEPA Method 3AAppendix A-2-3
Emission Test Data for Acid GasesEPA Methods 3A, 6C, and 7EEPA Method 26AEPA CTM-033Appendix A-2-4
Emissions Test Data for Non-Dioxin/Furan OrganicsEPA Methods 3A, 10, and 25AEPA Method 18EPA Method 316SW846-0010SW846-0031Appendix A-2-5 Emissions Test Data for PCDD/F and Coplanar PCBsEPA Method 23EPA Method 3A (See Appendix A-2-4)APPENDIX A-3
HARDING STREET 60

Appendix A-3-1 Preliminary Test Data Appendix A-3-2 Emission Test Da ta for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods OTM-027/028 EPA Method 30B EPA Method 3BAppendix A-3-1 Preliminary Test DataAppendix A-3-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods OTM-027/028EPA Method 30BEPA Method 3BAPPENDIX A-4
HARDING STREET 70

Appendix A-4-1 Preliminary Test Data Appendix A-4-2 Emission Test Da ta for PM, PM 2.5, and HAP Metals EPA Methods 5 and 29 EPA Methods 5/OTM-028 EPA Method 30B EPA Method 3BAppendix A-4-1 Preliminary Test DataAppendix A-4-2 Emission Test Data for PM, PM 2.5, and HAP MetalsEPA Methods 5 and 29EPA Methods 5/OTM-028EPA Method 30BEPA Method 3B

### APPENDIX B Analytical Data

Appendix B-1 Enthalpy Analytical Labs Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 Appendix B-2 Analytical Persp ectives Labs – M23 Analysis Appendix B-3 Test America – Methods 29 and SW846-0031 Appendix B-4 URS Gravimetric Analysis Appendix B-5 Columbia Analytical Fuel AnalysisAPPENDIX B-1 Enthalpy Analytical Labs Methods 26A, 316, CTM-033, OTM-028, and SW846-0010APPENDIX B-2 Analytical Perspectives Labs Method 23 AnalysisAPPENDIX B-3
Test America
Method 29 and SW846-0031APPENDIX B-4
URS Gravimetric AnalysisAPPENDIX B-5 Columbia Analytical Fuel Analysis

### APPENDIX C Hourly Process Operating Data

Appendix C-1 Harding Street 9 Appendix C-2 Harding Street 10 Appendix C-3 Harding Street 60 Appendix C-4 Harding Street 70APPENDIX C-1 Harding Street 9APPENDIX C-2 Harding Street 10APPENDIX C-3 Harding Street 60APPENDIX C-4 Harding Street 70

### APPENDIX D QA/QC Data

### APPENDIX E 30-Day Process and CEM Data

Appendix E-1 Harding Street 60 Appendix E-2 Harding Street 70APPENDIX E-1 Harding Street 60APPENDIX E-2 Harding Street 70

### APPENDIX F EPA ERT Files and Spreadsheets

### APPENDIX G Test Plans and Correspondence