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

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Section 1 Introduction .......................................................................................................... 1-1

1.1 Summary of Test Program.................................................................. 1-1 

Section 2 Facility Description .......................................................................... 2-1 

2.1 Harding Street 9 and 10 ...................................................................... 2-1 

2.1.1 Process Description...................................................................... 2-1 

2.1.2 Sampling 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 Sampling 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 Sampling 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 Test Methods .................................................................................... 4-1 

4.1 Volumetric Flow, Moisture, 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 Assurance/Quality Control ................................................. 5-1 

5.1 Sampling QA/QC................................................................................ 5-1 

5.2 Other QA/QC...................................................................................... 5-1 

5.3 Test Method Exceptions ..................................................................... 5-2 
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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 – Method 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

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LIST OF TABLES 

Page 

1-1 Summary of Harding Street Station Testing Requirements........................................ 1-1 

1-2 Harding Street Station Testing Dates.......................................................................... 1-1 

1-3 Summary of Test Results for Harding Street.............................................................. 1-2 

2-1 Summary of Boiler Operating Parameters for Boiler 9 .............................................. 2-3 

2-2 Summary of Boiler Operating Parameters for Boiler 10 ............................................ 2-4 

2-3 Summary of Boiler Operating Parameters for Boiler 60 ............................................ 2-7 

2-4 Summary of Boiler Operating 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 Compounds................................. 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 Compounds............................... 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 
SECTIONONE Introduction 

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1. Section 1 ONE Introduction 

1.1 SUMMARY OF TEST PROGRAM 

On November 10, 2009, USEPA published a notice in the Federal Register (Vol. 75, 

No. 216, pages 58012-58013) pursuant to Section 114 of the federal Clean Air Act regarding 

an Information Collection Request (ICR) for New 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 the 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 testing requirements and schedules. 

IP&L’s Harding Street Station 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 testing 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 results for each of the units 

tested, based on the average of all three valid test runs for each parameter. 
SECTIONONE Introduction 

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Table 1-3. Summary of Test Results for Harding Street 

Test Results 

Test Parameter HS9 HS10 HS60 HS70 Units 

Filterable PMb 1.04E-03 1.14E-03 1.36E-02 2.93E-02 lb/mmBtu 

PM2.5 [<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 PMc [<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% O2

4.17E-10 4.75E-10 -- -- lb/mmBtu PCB 0.48 0.55 -- -- ng/dscm@7% O2

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 NOX 115.3 112.8 -- -- ppmvd@7% O2

2.18E-02 2.54E-02 -- -- lb/mmBtu SO2 9.5 11.1 -- -- ppmvd@7% O2

1.79E-03 6.94E-04 -- -- lb/mmBtu CO 1.8 0.7 -- -- ppmvd@7% O2

[<5.39E-06] [<6.94E-06] -- -- lb/mmBtu HCHO [<5.01E-03] [<6.45E-03] -- -- ppmvd@7% O2

1.70E-03 3.27E-03 -- -- lb/mmBtu THC 1.1 2.1 -- -- ppmvd@7% O2

[<4.50E-05] 9.03E-04 -- -- lb/mmBtu CH4 [<0.08] 1.6 -- -- ppmvd@7% O2

Volatile Organic [<1.52E-04] [<1.70E-04] -- -- lb/mmBtu 

HAPe [<176] [<197] -- -- ug/dscm@7% O2

Semi-Volatile [<3.67E-06] [<2.90E-06] -- -- lb/mmBtu 

Organic HAPf [<4.25] [<3.36] -- -- ug/dscm@7% O2

a

 Results containing non-detect values are indicated with [<] and are reported at the full detection limit. b

 Based on RM 5/29 data 

c

 Based on OTM-027/028 data 

d

 NOX and SO2 based on averages from station CEM data e

 Excludes acetone, methylene chloride, and toluene used for Method 0010 recovery that was in field blanks. f

 Sum of 19 targeted PAH compounds. 
SECTIONONE Introduction 

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During the stack test periods, the units were operated 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 accordance 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 was terminated after 3.3 

hours due to an unexpected issue in the boiler control room that required interruption of 

testing until the issue was resolved. 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 the 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 Section 5 describes quality assurance parameters. 

Raw data and calculation summaries are contained in the Appendices. 
SECTIONTWO Facility Description 

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2. Section 2 TWO Facility Description 

Section 2 describes each of the 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 units. Each is rated at 37 MW (summer, gross). The unit is 

wall-fired and combusts No. 2 distillate fuel oil. There are no add-on emission controls. 

Figure 2-1 is a process flow diagram for each unit. 

Figure 2-1. Process Flow Diagram 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 perpendicular test ports. 

Wall-Fired 

Boiler 

S

t

a

c

k 

Oil 

Air 
SECTIONTWO Facility Description 

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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 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. However, 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 operating data are presented 

in the EPA supplied Excel spreadsheets in Appendix F. 

>181” 

>724” 

Breaching 

duct 

Ports 

90.5 " 
SECTIONTWO Facility Description 

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Table 2-1. Summary of Boiler Operating Parameters for Boiler 9 

Run 

Boiler O2

(%) 

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

Average 6.74 226.84 1642.0 15.93 14.91

Methods 18, 23, 25A, 30B, and 316 

Org Run 2 6.60 228.61 1654.8 16.11 15.18

Org Run 3 6.47 228.04 1650.7 16.11 15.03

Org Run 4 8.52 188.99 1368.0 15.79 14.31

Average 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

Average 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

Average 7.01 230.71 1670.0 15.47 14.25
SECTIONTWO Facility Description 

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Table 2-2. Summary of Boiler Operating Parameters for Boiler 10 

Run 

BoilerO2

(%) 

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 NOX burners and over-fire air 

(LNB/OFA), selective noncatalytic reduction (SNCR), and an electrostatic precipitator (ESP) 

to reduce air emissions. Figure 2-3 is a process flow diagram for Boiler 60. 
SECTIONTWO Facility Description 

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Figure 2-3. Process Flow Diagram for Boiler 60 

2.2.2 Sampling Location 

Flue gas samples were collected through test ports located in stack. Port locations relative to 

the inlet breaching duct and stack outlet are illustrated in Figure 2-4. Sampling was 

conducted in each of four test ports. 

Figure 2-4. Sampling Location 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 
SECTIONTWO Facility Description 

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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 during 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 

SCR FGD 

Ammonia 
SECTIONTWO Faci

2-7 Hard

Table 2-3. Summary of Boiler Operating Parameters for Boiler 60 

Run 

Heat Input 

(MMBtu/hr) 

Steam Load 

(Klbs/hr) 

Gross Output 

(MW) 

Net Output 

(MW) Excess O2 (%) 

Op

Methods 5/29, and 5/OTM-028 

PM/Met Run 1 936.76 755.85 103.63 98.61 2.65 PM/Met Run 2 947.33 753.20 102.73 97.75 2.66 PM/Met Run 3 970.11 762.43 103.90 98.88 2.59 

Average 951.40 757.16 103.42 98.41 2.63 

Method 30B 

Hg Run 1 1063.40 804.20 109.89 104.68 2.46 Hg Run 2 783.04 578.51 79.97 75.41 3.02 Hg Run 3 1072.60 751.82 103.40 98.35 2.57 

Average 973.01 711.51 97.75 92.81 2.68 
SECTIONTWO Facility Description 

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2.3.2 Sampling Location 

Flue gas samples were collected through test ports located in stack. Port locations relative to 

the inlet breaching duct and stack outlet are illustrated in Figure 2-6. Sampling was 

conducted in each of four test ports. 

Figure 2-6. Sampling Location 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 during 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 " 
SECTIONTWO Facility Description 

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Table 2-4. Summary of Boiler Operating Parameters for Boiler 70 

Run 

Heat Input 

(MMBtu/hr) 

Steam Load 

(klbs/hr) 

Gross 

Output 

(MW) 

Net Output 

(MW) 

Excess O2

(%) 

SCR 

Operation 

(Y/N) 

FGD 

Pressure 

Drop 

(in H2O) 

Slurry Flow

(gpm) 

Scrubber 

Liquor pH 

Methods 5/29, and 5/OTM-028 

Run 1 3981.48 2915.62 445.22 417.38 3.32 YES 0.92 247.12 5.32 Run 2 4077.78 2968.14 444.72 417.03 3.31 YES 1.13 245.58 5.35 Run 3 3955.43 2926.30 445.14 417.18 3.32 YES 0.84 244.44 5.26 Average 4004.90 2936.69 445.03 417.20 3.32 YES 0.96 245.71 5.31 

Method 30B 

Run 5 4097.55 2968.01 443.94 416.00 3.31 YES 1.32 236.14 5.25 Run 6 3992.55 2950.17 444.86 417.17 3.34 YES 1.02 257.36 5.37 Run 7 4051.34 2965.96 445.42 417.47 3.34 YES 1.29 233.61 5.34 Average 4047.15 2961.38 444.74 416.88 3.33 YES 1.21 242.37 5.32 
SECTIONTWO Facility Description 

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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 19,110 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 SO2

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 
SECTIONTHREE Test Results 

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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 Timesa 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, completed 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 summarize 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. 
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Table 3-2. Boiler 9 Summary for Particulate Matter 

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

Run 

Filterable PMb

(lb/MMBtu) 

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu) 

Total PMc

(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 with [<] 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 with [<] 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 316a

Run 

CO 

(lb/MMBtu) 

HCHO 

(lb/MMBtu) 

THC 

(lb/MMBtu) 

CH4

(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 with [<] and are reported at the full detection limit. 
SECTIONTHREE Test Results 

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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 with [<] 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 with [<] 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-33a

Run 

SO2

(lb/MMBtu)

NOX

(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 with [<] and are reported at the full detection limit. 
SECTIONTHREE Test Results 

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Table 3-8. 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 

trans-1,3-Dichloropropene [<1.92E-07] [<1.93E-07] [<1.92E-07] [<1.92E-07] 

Acetoneb 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 chlorideb 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] 

Tolueneb 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] 
SECTIONTHREE Test Results 

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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 with [<] and are reported at the full detection limit. b

 Acetone, methylene chloride, and toluene are solvents used during recovery 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 similar 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 operate during the 30-day 

period prior to and after the ICR-required testing. Therefore, 30-day CEM data is not 

included in report. 
SECTIONTHREE Test Results 

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3.2 BOILER 10 

The test schedule and run times for Harding Street Boiler 10 are shown in Table 3-9. 

Table 3-9. Boiler 10 Test Schedule 

Date Run Timesa 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, completed 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 program on a run-by-run basis. 

Supporting documentation and further details of the test results are provided in the 

appendices to this report. 
SECTIONTHREE Test Results 

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31827133 

Table 3-10. Boiler 10 Summary for Particulate Matter 

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

Run 

Filterable PMb 

(lb/MMBtu)

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu)

Total PMc

(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 with [<] 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-05b

 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 with [<] 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 316a

Run 

CO 

(lb/MMBtu) 

HCHO 

(lb/MMBtu) 

THC 

(lb/MMBtu) 

CH4 

(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 with [<] and are reported at the full detection limit. 
SECTIONTHREE Test Results 

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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 with [<] 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 with [<] and are reported at the full detection limit. 

Table 3-15. Boiler 10 Summary for Acid Gases 

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

Run 

SO2

(lb/MMBtu) 

NOX

(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 with [<] and are reported at the full detection limit. 
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Table 3-16. Boiler 10 Summary for Speciated 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] 
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Table 3-16 Continued. Boiler 10 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 [<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 with [<] 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 exception of benzene that were measured at levels above the 

detection limits were present in the field blanks. Acetone and methylene chloride were 

present in the proximity of the VOST sampling train due to their necessity to recovery the 

Method 0010 samples. The other four compounds detected 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 period prior to and after the ICR-required testing. Therefore, 

30-day process data is not included in report. 
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3.3 BOILER 60 

The test schedule and run times for Harding Street Boiler 60 are shown in Table 3-17. 

Table 3-17. Boiler 60 Test Schedule 

Date Run Timesa 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, completed 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 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. 

Table 3-18. Boiler 60 Summary for Particulate Matter 

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28 

Run 

Filterable PMb 

(lb/MMBtu)

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu)

Total PMc

(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 with [<] 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. 
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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 with [<] 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 Street Boiler 70 are shown in Table 3-20. 

Table 3-20. Boiler 70 Test Schedule 

Date Run Timesa 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 difficulties resulting from cooling tower 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 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. 
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Table 3-21. Boiler 70 Summary for Particulate Matter 

Reference Method Test Results for EPA Methods 1-4, 5, and OTM-28 

Run 

Filterable 

PMb 

(lb/MMBtu)

PM 2.5 

(lb/MMBtu) 

Aqueous 

Condensible 

Matter 

(lb/MMBtu) 

Organic 

Condensible 

Matter 

(lb/MMBtu)

Total PMc

(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 with [<] 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 with [<] and are reported at the full detection limit. 
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4. Section 4 FOUR Test Methods 

The following sections present information on the 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 weight, and the gas moisture content. Vent gas 

velocity and moisture content were measured at the stack location in conjunction with 

isokinetic sampling trains. Flue gas molecular weight was calculated using EPA Method 3A 

to determine concentrations of O2 and CO2 in the stack gas. 

4.2 PARTICULATE MATTER FROM DRY STACKS 

For stacks not having entrained water droplets, 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-isokinetically through an Apex Instruments PM 2.5 cyclone and 

in-stack 63 mm glass filter. Sampling was conducted at a fixed sampling rate using the 

calculations from the test method to determine dwell time at each sample point. The 

remaining sample gas passed through a heated probe and transfer 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 parts of the impinger train were connected with an in-train 

Teflon membrane filter. The sample gas passing 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 impinger train consisted of two standard size 

modified Greenberg-Smith impingers, the first of which contained 100 ml of organic free 

water with the final impinger containing silica gel. The back half 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 recovered by brushing and 

rinsing each fraction individually with acetone into separately labeled sample. Front half 

rinse samples were dried, desiccated for 24 hours, and analyzed gravimetrically at the URS 

Laboratory in Morrisville, NC. The glass fiber filter was also desiccated, 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 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 high purity organic free water, high purity acetone, and high 

purity MeCl to remove and preserve the condensable particulate for evaporation and 

gravimetric analysis at the laboratory. Rinses were kept separate from the condensed 

moisture fraction until combined by the laboratory. 
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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 calculate the stack gas velocity. 

Samples were all given a unique identification number and logged into a table as they were 

collected and recovered. Identification numbers were included on all sample containers 

during the analytical process. All EPA Method 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 droplets, PM-concentration was determined using 

EPA Method 5 and Other Test Method 028. A measured 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 passed through a heated transfer 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 parts of the impinger train were connected with an in-train 

Teflon membrane filter. The sample gas passing 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 impinger train consisted of two standard size 

modified Greenberg-Smith impingers, the first of which contained 100 ml of organic free 

water with the final impinger containing silica gel. The back half 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 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 hours, 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 water, high purity acetone, and 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 high purity organic free 

water, high purity acetone, and high purity MeCl to remove and preserve the condensable 
SECTIONFOUR Test Methods 

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particulate for evaporation and gravimetric analysis 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 calculate the stack gas velocity. 

Samples were all given a unique identification number and logged into a table as they were 

collected and recovered. Identification numbers 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 determined using the procedures provided in EPA 

Method 6C using the facility’s certified CEMS instrumentation. The SO2 analyzer works off 

the ultraviolet (UV) absorption principle. The sample stream passes through a sample 

chamber within the analyzer at a constant pressure which has a UV light source present at 

one end. The SO2 molecules in the sample stream absorb a portion of the energy from the UV 

lamp which excites the particle causing it to decay to a lower energy state. As the particle 

decays, it gives of ultraviolet light at a different wavelength. The emission of that light is 

measured by a photomultiplier tube located perpendicular to the UV light source further 

down the sample path. The intensity of the light detected by the photomultiplier tube is 

proportional in relation to the concentration of SO2 in the sample stream. The light intensity 

measured by the analyzer corresponds to a signal that was transferred to the DAS and 

recorded in by the historian. 

4.5 OXIDES OF NITROGEN 

EPA Method 7E was used to determine concentrations of oxides of nitrogen in the flue gas 

using the facility’s certified CEMS instrumentation. The NOX analyzer operates off the 

chemiluminescent principle and is equipped with a catalytic thermal converter to convert 

NO2 to NO. The sample gas is passed through the converter and heated to break one of the 

oxygen bonds in the NO2 molecule. After the conversion, the 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 chemical reaction between the NO and O3 produces a photon 

of light for each molecule. The chemiluminescent photons are measured by a photomultiplier 
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tube at the end of the reaction chamber to produce a signal that is linear in relation to 

concentration. 

4.6 CARBON MONOXIDE 

EPA Method 10 was used to determine concentrations of carbon monoxide in the flue gas 

using the facility’s certified CEMS instrumentation as well as by the test crew on site. The 

concentration of carbon monoxide in the stack exhaust was selectively measured by a gas 

filter correlation analyzer. The analyzer’s operation is based on the principle that carbon 

monoxide absorbs infrared light at a specific wavelength. The instrument produces an 

infrared light signal which passes through a spinning correlation wheel. The light signal is 

modulated by alternating back and forth between two chambers on the wheel, one of which 

contains nitrogen (measurement cell) and the other contains carbon monoxide (the reference 

cell). The nitrogen cell is transparent to the infrared light and allows the entire light signal to 

pass though while the carbon monoxide cell absorbs all of the light at the effected 

wavelengths providing a baseline. After the light 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 between the modulations in the signal is a nonlinear correlation that represents the concentration of carbon monoxide in the sample. The 

signal is linearized by the internal 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 gases with the resultant test data being corrected for bias and 

drift. 

4.7 METHANE 

EPA Method 18 was performed to determine concentration of methane in the flue gas. A 

sample of the stack gas was extracted from the test location through an in-stack filter and 

transported to the test trailer through a heated sample line and 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 stream by molecular size, allowing the smaller 

compounds to pass through first. Once the hydrocarbon constituents have passed through the 

column they are introduced to a flame ionization detector (FID). The ionizer heats the 

compounds to break the carbon bonds. 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 

response. Because the compounds have been speciated by passing them through the column, 

the resultant intensity of the response is attributed to a specific organic 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 three concentrations to 

develop a linear regression curve. Each test run consisted of at least five injects to the 

GC/FID followed by a 3 replicate calibration check. Results for each test run were averaged 

and compared against the calibration curve to determine concentrations. 
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4.8 DIOXINS, FURANS AND PCB 

The procedures from EPA Method 23 were employed to determine emissions of 

polychlorinated dibenzo-p-dioxins, polychlorinated 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 pretreated glass filter before passing into a waterjacketed condenser followed by a module containing 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 during 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 console. After the final leak check had been 

performed the sample train was partially disassembled and transported 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 glassware 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 recovery process, the XAD-2 

Resin was reweighed for the moisture determination, the thermocouple was removed, and the 

ends were properly sealed with Teflon tape and aluminum foil. The module was then covered 

with aluminum foil to prevent excess exposure, labeled and kept cool in a sample refrigerator 

until the test program was completed. 

Prior to the sampling event all of the glassware 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 transport to the facility. 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 with 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 × HN × QIS) / ( HIS × 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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 W is the weight of the sample (for method 23 samples this value is always 1) 

 RRF is the calculated relative response factor for the analyte 

4.9 TOTAL HYDROCARBONS 

EPA Method 25A was used to determine concentration of total hydrocarbons (THC) in the 

gas stream. A sample of the stack gas was extracted from the test location through an in-stack 

filter and heated line and transported to the mobile 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 response. 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. For this program, the calibration basis was methane so the 

resultant response is on an as methane basis. The instrument was calibrated using EPA 

Protocol 1 gases with the resultant data being corrected for drift. 

4.10 HYDROGEN CHLORIDE AND HYDROGEN FLORIDE 

EPA Method 26A was used to determine emissions of HCl, Cl2, and HF in the gas stream. A 

sample of the stack gas was extracted from the test location through a glass nozzle, heated 

probe, and filter assembly prior to entering the 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 oversized knockout Greenberg-Smith impinger 

containing 50 ml of 0.1 N H2SO4 followed by two standard size Greenberg-Smith impingers 

also containing 0.1N H2SO4. The sample then passed through two standard size modified 

Greenberg-Smith impingers containing 0.1N NaOH followed by a silica gel impinger before 

being measured by a dry gas meter. Hydrogenated halogen compounds were captured in the 

acidic impinger solutions while the remaining elemental halogens are captured in the basic 

impinger solutions. After completion of the test run, a leak check was performed and the 

sampling system was partially disassembled and transported to the mobile laboratory for 

recovery. 

Sampling trains were weighed gravimetrically for moisture calculations, and recovered into 

appropriately labeled sample jars with DI H2O. Sodium thiosulfate was added to the basic 

impinger solutions by the laboratory 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 Cl2 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 determine the MDL value, the standard deviation 
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of the replicate analysis was calculated and that number was multiplied by the Student tfactor that corresponds to the number of replicates 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 concentration of the standard used to produce 

the MDL value. 

4.11 FILTERABLE PM AND NON-MERCURY METALS 

Emissions of antimony, arsenic, beryllium, cadmium, 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 withdrawn isokinetically from the source through 

a glass nozzle, heated probe, and heater filter prior to entering the impinger train. The 

impinger train was maintained in an ice bath with 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 modified Greenberg-Smith). The second and third 

impingers contained a solution of 5% HNO3 and 10% H2O2 in water. The fourth impinger 

was an empty modified Greenberg-Smith impinger. Impingers 5 and 6 were both modified 

Greenberg-Smith Impingers containing a solution of 4% KMnO4 and 10% H2SO4 in water. 

The final impinger contained silica gel. At the completion of each test run, following the 

final leak check, the sampling train was partially disassembled and transported to the mobile 

laboratory for sample recovery. The probe and nozzle was first rinsed and brushed with 

acetone followed by 0.1 N HNO3 into separate jars. In the laboratory, the train was weighed 

gravimetrically for moisture determinations and 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 analysis of the samples, the acetone rinses were 

reconstituted with 0.1N HNO3 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 were 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 mercury during transport through a probe/sample 
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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 tube 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 Hgo

 analytical bias test was performed 

to confirm that the analytical system results were within ±10% of the target value. Table 4-3 

shows the results of the Hgo analytical bias test. All samples 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 analytical 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 the ±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 using tubes spiked at 50 ng 

of mercury with two hour samples being collected at a nominal 2-hours. Using these 

procedures, if the QA/QC criteria 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 sample of the stack gas was extracted isokinetically through a 

glass nozzle and heated probe assembly. The sample 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 maintained 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 each, and a final silica gel impinger. The purpose of the lead 

acetate was to remove SO2 from the sample stream in order to maintain the pH of the NaOH 

above 12. As recommended by the test method Alizarin 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 the mobile laboratory for recovery. The probe 

nozzle and connection glassware were brushed and recovered into a glass sample jar with 
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acetone to be archived for PM analysis. In the mobile laboratory, the impinger train was 

weighed gravimetrically for moisture determination. 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 within 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 determine 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 replicates 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 concentration of the standard used to produce 

the MDL value. 

4.14 SEMI-VOLATILE ORGANIC COMPOUNDS 

Emissions of speciated semi-volatile organic compounds were measured using the 

procedures prescribed in Solid Waste Association 846 Method 0010. A sample of the stack 

gas was extracted isokinetically through a glass nozzle and heated 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 OF. After exiting the resin trap, the sample stream passed 

through an impinger train containing organic free water to remove any residual semi-volatile 

compounds and residual moisture before being 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 brushed and recovered into a glass sample jar with acetone first 

followed by MeCl as prescribed in the ICR. In the mobile laboratory, the impinger train was 

weighed gravimetrically for moisture determination. 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 used within the 30-day hold time after being 

prepared. Enthalpy Analytical provided the analysis for these samples. 
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Enthalpy calculated detection limits by the analysis of at least seven replicate standards at a 

concentration near the expected MDL. To determine 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 replicates 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 concentration of the standard used to produce 

the MDL value. 

4.15 VOLATILE ORGANIC COMPOUNDS 

Emissions of speciated volatile organic compounds 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 OC containing an organic 

free glass wool plug to filter out particulate matter. The gas was then passed through a 

condenser maintained at below 20 OC, two Tenax sorbent traps, a condensate trap, and an 

Anasorb trap to collect the volatile compounds. The gas passes through a final silica gel 

reservoir before being measured by a dry gas meter. The system was operated as to collect a 

nominal 1 liter per minute of gas for 20 minutes per 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 including one pre-test train blank per source, one 

trip blank per cooler, and a reagent blank were collected for each facility. 

TestAmerica located in Knoxville, Tennessee prepared the traps and performed the analysis. 

Analytes for this test method were not specifically 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 recorded by the facility DAS and PI system. Process 

indicators that were monitored included boiler steaming rate (Klbs/hr), fuel firing rates 

(mmBtu/hr calculated heat input), and scrubber operation (quench flow and differential 

pressure of the scrubber as compliance indicators 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, SO2, and CO. Copies of the process 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 collect the scrubber samples after the fact and 
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document the delay in collection in the test report. Testing for the 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 beginning 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. 
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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 reduction, and interpretation 

of results. QA/QC procedures were strictly followed 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 and repeated. Prior to and following the test 

program, pitot leak checks were performed on the pressure differential measuring systems. 

CEM analyzers were calibrated according to the relevant test method with bias and drift 

checks being performed as required. Analyzers were calibrated using EPA Protocol 1 gases. 

Copies of the cylinder certifications 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 capping the tip of the sample probe and pulling a 

vacuum. Flow rate was monitored until the absence 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 was 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 specified 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 visual and operation check prior to and 

after transport to ensure clean and operable 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 data forms daily on-site during testing. 
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 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 29oC (<85oF). 

 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 performed 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 Appendix B and met the method criteria. 

 Field blanks were conducted and analyzed for each manual test method performed 

on-site. Reagent blanks were collected and archived in case of further need for 

analysis. 

5.3 TEST METHOD EXCEPTIONS 

The following exceptions to test methods and quality 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 that required a 24-hour interruption in boiler 

operation until issue was resolved. Bill Maxwell at U.S. EPA was contacted and indicated 

that run should not be re-started due to length of interruption and should be flagged in test 

report. 

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. 

Due to the low level of Hg in oil, spiked concentrations of Hg on the 30B sorbent tubes for 

Boilers 9 and 10 did not meet the 50% to 150 % guidance as per the test method. Discussions 

with the U.S. EPA have confirmed the spiking criteria 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 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 

APPENDIX 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 

APPENDIX 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 A-1 

HARDING STREET 9

Appendix A-1-1 Preliminary Test Data 

Appendix A-1-2 Emission Test Data 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 Test 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 3A 
Appendix A-1-1 

Preliminary Test Data 
Appendix A-1-2 

Emission Test Data 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 Test Data for Acid Gases 
EPA Method 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 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 Data 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 Test 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 3A 
Appendix A-2-1 

Preliminary Test Data 
Appendix A-2-2 

Emission Test Data 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 Test 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 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 Data for PM, PM 2.5, and HAP 

Metals 

 EPA Methods 5 and 29 

 EPA Methods OTM-027/028 

 EPA Method 30B 

EPA Method 3B 
Appendix A-3-1 

Preliminary Test Data 
Appendix A-3-2 

Emission Test Data for PM, PM 2.5, and HAP Metals 
EPA Methods 5 and 29 
EPA Methods OTM-027/028 
EPA Method 30B 
EPA Method 3B 
APPENDIX A-4 

HARDING STREET 70 

Appendix A-4-1 Preliminary Test Data 

Appendix A-4-2 Emission Test Data for PM, PM 2.5, and HAP 

Metals 

 EPA Methods 5 and 29 

 EPA Methods 5/OTM-028 

 EPA Method 30B 

EPA Method 3B 
Appendix A-4-1 

Preliminary Test Data 
Appendix A-4-2 

Emission Test Data for PM, PM 2.5, and HAP Metals 
EPA Methods 5 and 29 
EPA Methods 5/OTM-028 
EPA Method 30B 
EPA 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 Perspectives 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 Analysis 
APPENDIX B-1 

Enthalpy Analytical Labs 

Methods 26A, 316, CTM-033, OTM-028, and SW846-0010 
APPENDIX B-2 

Analytical Perspectives Labs 

Method 23 Analysis 
APPENDIX B-3 

Test America 

Method 29 and SW846-0031 
APPENDIX B-4 

URS 

Gravimetric Analysis 
APPENDIX 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 70 
APPENDIX C-1 

Harding Street 9 
APPENDIX C-2 

Harding Street 10 
APPENDIX C-3 

Harding Street 60 
APPENDIX 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 70 
APPENDIX E-1 

Harding Street 60 
APPENDIX E-2 

Harding Street 70 
APPENDIX F 

EPA ERT Files and Spreadsheets 
APPENDIX G 

Test Plans and Correspondence