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 SO2, NOX, and 

flow RATAs performed at the above referenced unit. Based on our review the SO2, NOX, and flow 

RATAs should be rejected for the following reasons and repeated at the earliest opportunity. 

1. The SO2 calibration gases used in the RATA were not representative of the entire range of SO2

concentrations measured in the stack. Average SO2 concentrations recorded during the runs were 

consistently observed at levels around 810 ppm. However, the highest concentration of SO2

calibration gas used in the reference system calibration was only 489 ppm. Consequently, the 

reference SO2 analyzer was measuring SO2 concentrations well beyond its calibrated range and 

the SO2 RATA is therefore deemed invalid. 

2. The upscale post-run calibration checks for bias and drift during the NOx 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 NOx

concentrations recorded from the stack during the runs were usually between 360 ppm and 

370 ppm, the 384 ppm NOx calibration gas should have been used as the upscale gas instead of 

the 241 ppm NOx 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 NOX 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 raw 
Mr. Lynn Haynes 

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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 report 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