Mr. Lynn Haynes

United States Environmental Protection Agency, Region 4

Atlanta Federal Center 61 Forsyth Street SW Atlanta, GA 30303-3104

Re: Jacksonville Electric Authority Northside Generating Station Unit 1 (ORIS Code 667, NADB ID 01) Report on December 6-7, 1999 RATA

Dear Mr. Haynes:

The Emissions Monitoring Section has reviewed the RATA report for the SO 2 , NO X , and flow RATAs performed at the above referenced unit. Based on our review the SO 2 , NO X , and flow RATAs should be rejected for the following reasons and repeated at the earliest opportunity.

1. The SO 2 calibration gases used in the RATA were not representative of the entire range of SO 2 concentrations measured in the stack. Average SO 2 concentrations recorded during the runs were consistently observed at levels around 810 ppm. However, the highest concentration of SO 2 calibration gas used in the reference system calibration was only 489 ppm. Consequently, the

reference SO 2 analyzer was measuring SO 2 concentrations well beyond its calibrated range and

the SO 2 RATA is therefore deemed invalid.

2. The upscale post-run calibration checks for bias and drift during the NO

x runs were performed with the incorrect calibration gas. Method 7E refers to the Method 6C measurement system perfomance test procedures. As such, section 6.4 of the method requires that in conducting the sampling system bias check, the “zero gas and either the mid-range or high-range gas, whichever most closely approximates the effluent concentrations, shall be used...”. Since the NO

x concentrations recorded from the stack during the runs were usually between 360 ppm and 370 ppm, the 384 ppm NO

x calibration gas should have been used as the upscale gas instead of the 241 ppm NO

x calibration gas. Since the run to run calibration bias and drift data used to correct the gas concentration for analyzer drift was performed incorrectly, the NO X RATA test is

deemed invalid.

3. No calculations of the reference system bias or drift were included in the report. Although the raw data for the calibrations appear in the report, no span values were provided for the analyzers used to perform Methods 3A, 6C and 7E. This made it impossible to determine from the rawMr. Lynn Haynes Page Two

calibration data whether the system calibration bias and drift for the tests were within the applicable specifications.

4. The number of the sampling points as determined in Method 1 are not consistent within the report. Though the data appears to have been collected using 12 traverse points (6 points on each stack diameter), the locations of these points are shown to have been calculated using the criteria for 16 traverse points (8 points on each stack diameter). This inconsistency leaves questions as to whether or not the traverse points were properly positioned within the stack (See page 97 of the report and Table 1-2 in Method 1). Since, the re port does not clearly demonstrate that the points were properly selected in accordance with the procedures of EPA Method 1, the flow RATA is

deemed invalid.

5. Calibration data for the meter box was not included in the report. This makes it impossible to verify the validity of the gamma factor used to adjust the meter box readings. Also, missing from the report is the raw data for the pre and post run impinger weights. This omission makes it impossible to verify the calculation of moisture collected in the impingers. Furthermore, no calibration data/dimensional verification data was included for the pitot tube. The pitot tube’s dimensional specifications are needed to verify the pitot tube’s ability to meet the default 0.84

calibration factor. Since the calibration information and data listed above were omitted from the report, no assurance of data quality can be made and therefore the flow RATA is again deemed

invalid.

If you have any questions, please call either Matthew Boze at 850/921-9514, Dave Pocengal at 850/921-9577, or write to me.

Sincerely,

M. D. Harley, P.E., D.E.E.

P.E. Administrator Emissions Monitoring Section Bureau of Air Monitoring

and Mobile Sources

MDH/dp/mgb

cc: David McNeal, EPA Wayne Tutt, Jax RESD George Rizk, JEA