Report ICR Testing June 30, 2010 Kansas City Power & Light ii CEC Project 100-208 Sibley Generating Station TABLE OF CONTENTS Page

1.0 Project Summary ............................................................................................................... .. 1

1.1 Testing Approach ........................................................................................................ 1
1.2 Project Participants ..................................................................................................... 3
1.3 Sibley Generating Station ........................................................................................... 4

2.0 Data Summary .................................................................................................................. .. 5

2.1 Sampling Results for USEPA Method 29 Metals and Filterable Particulate Matter .. 5
2.2 Sampling Data for USEPA Method OTM 27/28 Filterable Particulate Matter Less Than 2.5 Microns and Condensib le Particulate Matter .............................................. 6
2.3 Sampling Data for Mercury ........................................................................................ 7

3.0 Test Approach and Sampling Methods ............................................................................... 9

3.1 Sampling Strategy ....................................................................................................... 9
3.2 Sampling and Analytical Procedures .......................................................................... 9
3.2.1 USEPA Method 1 ............................................................................................. 9
3.2.2 USEPA Method 2 ........................................................................................... 11
3.2.3 USEPA Method 3A......................................................................................... 12
3.2.4 USEPA Method 4 ........................................................................................... 15
3.2.5 USEPA Method 29 ......................................................................................... 15
3.2.6 USEPA Method 30B ....................................................................................... 17
3.2.7 USEPA Other Test Method (OTM) 27 ........................................................... 19
3.2.8 USEPA Other Test method (OTM) 28 ........................................................... 22
3.3 Fuel Sampling and Analysis ..................................................................................... 26
3.4 Process Monitoring and Operating Loads................................................................. 27

4.0 Quality Assurance and Quality Control ............................................................................ 28

4.1 Quality Assurance Criteria ........................................................................................ 28
4.2 Blank Sampling Trains ............................................................................................. 31
4.3 Quality Assurance Objectives ................................................................................... 32

APPENDICES

Appendix A – Field Data Forms Appendix B – Electronic Spread Sheets Appendix C – Example Calculations Appendix D – Analytical Data Enthalpy Analytical, OTM 27/28 Appendix E – Analytical Data Pace Labs, Method 29 Appendix F – Analytical Data Standard labs (fuel) Appendix G – Calibration Sh eets, Certifications Appendix H – Process DataReport ICR Testing June 30, 2010 Kansas City Power & Light 1 CEC Project 100-208 Sibley Generating Station 1.0 PROJECT SUMMARY

The United States Environmental Protection Ag ency’s (USEPA) Office of Air and Radiation (OAR) distributed a new Maximum Achievable Control Technology (MACT) Information Collection Request (ICR) to variet y of new and existing coal- and oi l-fired electric utilities. Under Part III of the ICR specific units are requ ired to conduct stack emissions tests and submit the test results to USEPA using EPA's Electroni c Reporting Tool (ERT) (Version 3). Kansas City Power & Light (KCP&L) operates four units th at were required to te st and report under the ICR. The facilities and the test s required to be conducted were:

• Hawthorn Unit 5A - Acid Gas HAP (Hazardous Air Pollutants); Mercury and non-Mercury Metallic HAPs; and N on-Dioxin/furan organic HAPs.

• La Cygne Unit 2 - Acid Gas HAP; Mercury and non-Mercury Metallic HAPs; and Non-Dioxin/furan organic HAPs.

• Sibley Units 1, 2 and 3 - Mercury and non-Mercury Me tallic HAPs. The Sibley units exhaust through a common stack and EP A has clarified the emissions testing will be conducted with all three units operating.

• Lake Road Unit 6 - Mercury and non-Merc ury Metallic HAPs.

Civil & Environmental Consultant s, Inc (CEC) was retained by KC P&L to provide the emissions testing services for the facilities listed in the I CR. This report discusses the sampling results for Sibley Generating Station Units 1, 2 and 3 located in Sibley, Missouri.

1.1 TESTING APPROACH

The first series of testing invol ved sampling the common stack for Units 1, 2 and 3 at the Sibley Generating Station. The testing program inco rporated standard USEPA sampling protocols based on USEPA’s requested protocols for coll ecting information on Mercury and Non-mercury Metal HAPs. As defined in the ICR request, sampling for Mercury and Non-mercury Metal HAP’s consisted of sampling for mercury (Hg), metals, total filterable particulate, and particulate matter less than 2.5 microns, cond ensible particulate, oxygen (O 2 ) and carbon dioxide (CO 2 ). The USEPA also specified minimum sampling times, minimum sampling volumes, and which test methods need to be performed simultane ously. Table 1 lists th e sampling protocols, minimum sampling times, and the units that the em issions data was reported in for the Mercury and Non mercury HAPs.Report ICR Testing June 30, 2010 Kansas City Power & Light 2 CEC Project 100-208 Sibley Generating Station *Also report scrubber recirculation liquid flow rate in liters/min and fuel feed rate in MMBTU/hr.

For this test program CEC and KCP&L used th e recommended method for the parameters listed in Table 1. Table 1 Summary of Coal Electric Utility Steam Generating Unit Test Methods for Mercury and Non-mercury Metallic HAP KCP&L ICR Sampling Sibley Generating Station

Pollutant Proposed Sampling Method Target Reported Units of
Measure Hg U.S. EPA Method 30B. Use a minimum sample time of 2 hours per run. lb/MMBtu

Metals U.S. EPA Method 29. Collect a minimum volume of 3.4 cubic meters and have a minimum sample time of 4 hours per run. Determine total filterable PM emissions according to §8.3.1.1. Use ICAP/MS for the analytical finish. lb/MMBtu

PM 2.5 (filterable) from stacks without entrained water droplets (e.g., not

from units with wet scrubbers) U.S. EPA Other Test Method 27 (OTM 27). Include cyclone catch as filterable PM. Collect a minimum volume of 3.4 cubic meters and have a minimum sample time of 4 hours per run. lb/MMBtu

PM 2.5 (condensable) U.S. EPA Other Test Method 28 (OTM 28). Collect a minimum volume of 3.4 cubic meters and have a minimum sample time of 4 hours per run. lb/MMBtu

O 2 /CO 2 * U.S. EPA Method 3A %

Moisture U.S. EPA Method 4 %Report ICR Testing June 30, 2010 Kansas City Power & Light 3 CEC Project 100-208 Sibley Generating Station 1.2 PROJECT PARTICIPANTS

The following personnel were involved in the execution of this project.

Table 2 Project Participants KCP&L ICR Sampling Sibley Generating Station

Participant Title Affiliation Contact

Steve Brooks Plant Engineer Sibley Kansas City Power & Light Telephone: Lake Road - 816-387-6266 and Sibley - 816-650-2931. Email: Steve.Brooks@kcpl.com

Christopher Dawdy Principal Civil & Environmental Consultants, Inc. Telephone: (314) 656-4566 Facsimile: (314) 656-4595 Email: CDawdy@cecinc.com

Franklin Stevens Project Manager Civil & Environmental Consultants, Inc. Telephone: (314) 656-4566 Cell Phone: (314) 540-4622 Facsimile: (314) 656-4595 Email: FStevens@cecinc.com

Dan Cusac Sr. Technician Civil & Environmental Consultants, Inc.

Nick Pichee Technician Civil & Environmental Consultants, Inc.

AJ Anderson Technician Civil & Environmental Consultants, Inc.

Joe Heilweck Sr. Technician Civil & Environmental Consultants, Inc.

Bryan Tyler Air Sample Analysis Enthalpy Analytical, Inc. Telephone: 919/850-4392 x 250 Fax: 919/850-9012 Email: bryan.tyler@enthalpy.com

Steve Wilshire Coal Analysis Standard Laboratories Telephone: (618) 539-5836 ext. 115 Fax: (618) 539-5839 Email: swilshire@standardlabs.com

Scott Postma Observer USEPA Region 7 Telephone:
Fax: Email: postma.scott@epa.govReport ICR Testing June 30, 2010 Kansas City Power & Light 4 CEC Project 100-208 Sibley Generating Station 1.3 SIBLEY GENERATING STATION

Sibley Generating Station consists of three (3) Babcock & Wilcox cyclone boilers which are ducted to a common stack. Boiler #1 is a 1,300 PSIG, 950 °F/ 609.6 mmbtu/hr rated unit which serves Turbine #1 which has a gross 55 MW capac ity. The boiler and turbine was installed in 1960. Boiler #2 is the same as Boiler #1, except it was designed for a steam heat input of 627.3 mmbtu/hr and was installed in 1962. It serves Tu rbine #2 which has a gross capacity rating of 51 MW. Boiler #3 is a supercritical, 3,653 psig/1005 o F boiler with a design heat input of 4,094.1 mmbtu/hour. The boiler serves Turbine #3 whic h has a gross capacity of 419 MW. This boiler and turbine was installed in 1969. The boilers bur n a blend of coal typically 85% Powder River Basin (PRB) (sub bituminous) and 15% bituminous coal . Sibley #3 also burns tire derived fuel however normally this is less than 1% of the fuel being burned. Boile rs #1 and 2 have burned biofuel in the past as a test burn but are not currently permitted for burning biofuel.

Sibley Units 1 & 2 utilize electr ostatic precipitators (ESP) over fire air (OFA) and selective noncatalytic reduction/rich reagent injection (SNC R/RRI) as pollution control devices. Sibley #3 has an ESP, OFA and SCR for pollution control devices.Report ICR Testing June 30, 2010 Kansas City Power & Light 5 CEC Project 100-208 Sibley Generating Station 2.0 DATA SUMMARY

This section provides a summ ary of the te st results.

2.1 SAMPLING RESULTS FOR USEPA METHOD 29 METALS AND FILTERABLE PARTICULATE MATTER

Tables 3 and 4 present a summary of the total filterable particulate matter and the metals sampling for the Sibley Generating Station. Thr ee test runs were performed utilizing USEPA Method 29. The Method 29 sampling procedures are discussed in Section 3 of this report and the results of the QA/QC associated with the method are discussed in Sectio n 4 of this report.

Run1 has a smaller metals and particulate catch than runs 2 or 3. During Run 1, when moving the sampling train to the fourth port, it was noticed that the bottom of the last impinger had been broken. The run was stopped immediately and termin ated at that point. The damage was likely caused by the high moisture conditions, long samp le times and the resulting expansion of the silica gel. The run was accepted as a valid run si nce there was visible particulate catch on the filter. The results are consistent with the othe r runs. The final weight of the last impinger was estimated based on the moisture determinations of Runs 2 and 3, and the water catch in the first three impingers.

Table 3 Filterable Particulate Matter Data Sibley Generating Station

Run 1 Run 2 Run 3 Average

Total Filter Catch (mg) 35.6 77.0 68.0 60.20

Total Wash Catch (mg) 30.2 18.5 30.9 26.53
Total Catch (mg) 65.8 95.5 98.9 86.73 PM Emission Rate (lbs/mmbtu)

Run 1 Run 2 Run 3 Average

Filterable PM Emission Rate 0.0091 0.0093 0.0092 0.0092

Condensible PM Emission Rate* 0.0168 0.0203 0.0213 0.0195

Total PM** 0.0259 0.0296 0.0305 0.0287 *Condensible PM emissions determined by OTM-28 train and not corrected for blank values per discussions with ICR personnel **Total PM emission rate determined by combini ng filterable PM from M5/29 train and condensable PM from OTM-27/28 train

The results are very consistent validating the decision to accept the run as a valid run. To prevent this from happening on subsequent ru ns a small quantity of glass wool was placed beneath the silica gel to provide sp ace for expansion should it occur.Report ICR Testing June 30, 2010 Kansas City Power & Light 6 CEC Project 100-208 Sibley Generating Station Table 4 USEPA Method 29 Metals Data Sibley Generating Station

Meta l Total Catch (ug)* Run 1 Run 2 Run 3 Average Antimony (Sb) 1.48 2.81 2.70 2.33 Arsenic (As) 11.57 20.00 19.46 17.01 Beryllium (Be) 0.33 0.54 0.55 0.47 Cadmium (Cd) 0.49 1.15 0.93 0.86 Chromium (Cr) 14.29 23.03 20.85 19.39 Cobalt (Co) 3.56 7.38 7.84 6.26 Lead (Pb) 12.62 23.40 25.36 20.46 Manganese (Mn) 15.85 23.74 24.74 21.44 Nickel (Ni) 15.86 28.72 22.83 22.47 Selenium (Se) 33.97 70.63 79.04 61.21

Metal Metals Emission Rate (lbs/mmbtu) Run 1 Run 2 Run 3 Average Antimony (Sb) 2.05E-07 2.74E-07 2.51E-07 2.43E-07 Arsenic (As) 1.60E-06 1.95E-06 1.81E-06 1.79E-06 Beryllium (Be) 4.58E-08 5.27E-08 5.11E-08 4.99E-08 Cadmium (Cd) 6.80E-08 1.12E-07 8.64E-08 8.89E-08 Chromium (Cr) 1.98E-06 2.25E-06 1.94E-06 2.06E-06 Cobalt (Co) 4.94E-07 7.20E-07 7.29E-07 6.47E-07 Lead (Pb) 1.75E-06 2.28E-06 2.36E-06 2.13E-06 Manganese (Mn) 2.20E-06 2.32E-06 2.30E-06 2.27E-06 Nickel (Ni) 2.20E-06 2.80E-06 2.12E-06 2.37E-06 Selenium (Se) 4.71E-06 6.89E-06 7.35E-06 6.32E-06 *Individual front and back half catch values can be found in appendices.

2.2 SAMPLING DATA FOR USEPA METHOD OTM 27/28 FILTERABLE PARTICULATE MATTER LESS THAN 2.5 MICRONS AND CONDENSIBLE PARTICULATE MATTER

To determine the emission rates for Filterable Particulate Matter less than 2.5 Microns in diameter (PM2.5) and Condensible Particulate Matter, three runs using USEPA Other Test Method (OTM) 27 and 28 were run simultane ously with USEPA Method 29. OTM 28 was combined with the OTM 27 sampling train. The procedure for operating the sampling train is discussed in Section 3 of this report, and the results of the QA/QC asso ciated with the method are discussed in Section 4 of this report.Report ICR Testing June 30, 2010 Kansas City Power & Light 7 CEC Project 100-208 Sibley Generating Station Table 5 Filterable Particulate Matter Less Than 2.5 Microns in Diameter (PM2.5) and Condensible Particulate Matter Results Sibley Generating Station

Filterable PM

Filterable PM Catch Run 1 Run 2 Run 3 Average PM 2.5 Filter Catch (mg) 11.0 13.6 12.2 12.27 PM 2.5 Wash Catch (mg) 0.8 1.5 1.1 1.13 Total PM 2.5 Catch (mg) 11.8 15.1 13.3 13.40 Total PM Catch (mg) 21.5 25.1 22.6 23.07

Filterable PM Emission Rate PM 2.5 Emission Rate (lbs/mmbtu) 0.0033 0.0043 0.0037 0.0038 PM Emission Rate (lbs/mmbtu) 0.0061 0.0072 0.0063 0.0065
Condensible PM Condensible PM Catch (mg) Net organic Catch (mg) 3.50 4.90 5.70 4.70 Corrected Inorganic Catch (mg) * 55.80 66.40 70.60 64.27
Condensible Particulat e Matter** 59.30 71.30 76.30 68.97 Corrected Condensible Particulate Matter* 57.40 69.30 74.30 67.00

Emission Rate Condensible PM
Condensible Particul ate Matter Emission Rate (lbs/mmbtu)** 0.0168 0.0203 0.0213 0.0195 Corrected Condensible Particulate Matter Emission Rate (lbs/mmbtu)* 0.0163 0.0197 0.0207 0.0189 Total PM Emission Rate (lbs/mmbtu)***

Total PM ** 0.0229 0.0275 0.0276 0.0260

Corrected Total PM* 0.0224 0.0269 0.0270 0.0254 *Corrected based on the method and the results from the blank sampling train **Condensible PM not corrected for blank values per discussions with ICR personnel ***Total PM emission rate determined by OTM27/28

2.3 SAMPLING DATA FOR MERCURY

Mercury was collected on paired Ohio Lumex high moisture carbon traps with a 100 ng spike on one tube per USEPA Method 30B. Three runs were completed usi ng an Apex Instruments Merc 6000 system for extracting the samp le through paired carbo n traps. One trap was spiked with 100 ng of elemental mercury and the second trap was unspiked. The samples were collected over a 2 hour period and then analyzed on an Ohio Lumex 915+ with a thermal desorption device for removing the mercury from the carbon traps. The sample was collected from 12 sampling points, 3 per port, at a constant sa mpling rate of approximately 500 ml/minute.Report ICR Testing June 30, 2010 Kansas City Power & Light 8 CEC Project 100-208 Sibley Generating Station Table 6 lists the tube identifications and the na nogram (ng) catch on each sorbent trap pair. Table 7 lists the mass emission rate in ng/l and lb/mmBtu for each tube and the average for the pair of tubes. The results of the QA/QC associ ate with the traps (percen t recovery, breakthrough, tube agreement etc) are listed in Section 4 of this report. The detail description of the sampling approach can be found in section 3 of this report.

Table 6 USEPA 30B Mercury Results (ng) Sibley Generating Station

No Description Tube ID Tube A/B Catch

ng Spiked (100 ng) STD Volume (l)
1 Run 1 A 68707 FH 68707 A 117 no 58.278
2 Run 1 A 68707 BH 1.7 3 Run 1 B 68534 FH Spike 68534 B 216 yes 56.695
4 Run 1 B 68534 BH 1.4
5 Run 2 A 68739 FH 68739 A 100 no 58.315
6 Run 2 A 68739 BH 0.3 7 Run 2 B 68542 FH Spike 68542 B 186 yes 56.707
8 Run 2 B 68542 BH 0.7
9 Run 3 A 68709 FH 68709 A 102 no 57.739
10 Run 3 A 68709 BH 0 11 Run 3 B 65430 FH Spike 65430 B 191 yes 56.489
12 Run 3 B 65430 BH 1.2

Table 7 USEPA 30B Concentrations and Mass Emission Rates Sibley Generating Station

Run Concentration Tube A

ng/l Concentration
Tube B

ng/l Average Concentration (ng/l) Tube A Emission
Rate (lbs/mmBtu) Tube B Emission
Rate (lbs/mmBtu) Average Emission
Rate (lbs/mmBtu)
1 2.04 2.07 2.05 1.48E-06 1.51E-06 1.49E-06
2 1.72 1.52 1.62 1.25E-06 1.11E-06 1.18E-06
3 1.77 1.61 1.69 1.27E-06 1.19E-06 1.23E-06 Average 1.84 1.73 1.79 1.34E-06 1.27E-06 1.30E-06Report ICR Testing June 30, 2010 Kansas City Power & Light 9 CEC Project 100-208 Sibley Generating Station 3.0 TEST APPROACH AND SAMPLING METHODS

This section describes the samp ling strategy, samplin g and analytical me thods, and quality assurance/quality control procedur es that were implem ented during this pr oject. The project involved performing three (3) test runs for the parameters listed in Table 1 of this document at Sibley Generating Station in Si bley, Missouri. Sampling occurr ed on March 16 and 17, 2010.

3.1 SAMPLING STRATEGY

The USEPA methods that were utilized in this sampling program are:

• Method 1 for the location of sa mpling ports and points, and de termination of cyclonic flow;

• Method 2 for velocity and volume tric flow rate determination;

• Method 3A for the determin ation of dry molecular weig ht of the stack gas;

• Method 4 for the determ ination of moisture in the stack gas;

• Method 29 was used to determine concentrations and emission rates of non-mercury metals (antimony (Sb), arsenic (As), beryllium (Be) , cadmium (Cd), chromi um (Cr), cobalt (Co), lead (Pb), manganese (Mn), nick el (Ni), and selenium (Se)) an d filterable particulate matter;

• Method 30B was used for the determina tion of mercury (Hg) emissions;

• Other Test Methods (OTM) 27 and 28 was used to determine filterabl e particulate matter less than 2.5 microns in diam eter and condensible particul ate matter, respectively.

All methods were performed simult aneously during each test run. Th ese test methods are available in the Code of Federal Regulatio ns Volume 40, Part 60, US EP A’s web site www.epa.gov/ttn/emc/ or by request from CEC.

3.2 SAMPLING AND ANALY TICAL PROCEDURES

A sampling and analysis synopsis fo r these methods is discussed briefl y in the following sections.

3.2.1 USEPA Method 1

USEPA Method 1 was used for this test program to determine the appropriateness of the existing ports as sampling locations and to determine the number of sampling points to be used when sampling at these locations.

The duct diameters upstream and downstream from the sampling ports were determined based on the sampling port location. For particulate and flow traverses, Method 1 specifies that a minimum number of 12 traverse points can be used for stacks greater than 24 inches in diameter if the ports are located >8 stack diameters downstream and >2 stack diameters upstream from any flow disturbances and 24 traverse points when locat ed >2 diameters downstream and >0.5 diameters upstream. These exact distances up and downstream from disturbanc es were determin ed during the initial set-up day at the site and the ratio of the distances to the diam eter of the stack were used in conjunction with Figure 1 to determine the number of sampling points to be used during the testing.Report ICR Testing June 30, 2010 Kansas City Power & Light 10 CEC Project 100-208 Sibley Generating Station At Sibley generating station both the upstream and downstream dist ances from the port location was greater than 8 stack diameters which meant that the minimum of 12 samplin g points (3 per port) could be used at the sampling location. The co upling length was 7 inches and the sampling points were located at 14.1, 30.7 and 55 inches into the port from the outside edge of the po rt coupling.

Figure 1: Sampling Point Determinations

After determining the number of sa mpling points, a Type “S” pitot tube such as the one defined in USEPA Method 2 was used to de termine if cycl onic flow conditions ex isted at the sampling location. If the flow conditions at a sampling lo cation are parallel or near parallel to the stack walls (< ± 20 o ) then the location can be used to determine pollutant concentrations using isokinetic sampling methods.

CEC leveled and zeroed the manom eter and connected a Type “S ” pitot and leak-checked the system. The pitot tube was positione d at each traverse point , in succession, so th at the planes of the face openings of the pitot tube we re perpendicular to the stack cros s-sectional plane. This position was referred to as the"0 o reference point." The differential pressure ( Δ p) reading at each traverse point was recorded. If a zero reading was obtain ed the angle of flow was recorded as 0 o . If the pitot 50

40

30

20

10

0.5 1.0 1.5 2.0 2.5

0

2 3 4 5 6 7 8 9 10 B A Disturbance

Measurement
Site

Disturbance

Duct Diameters Downstream from Flow Disturbance * (Distance B) Stack Diameter = 0.30 to 0.61 m (12 - 24 in.) Duct Diameters Upstream from Flow Disturbance (Distance A)

a Higher Number is for Rectangular Stack or Ducts

16

12

8 or 9 a

* From Point of Any Type of Disturbance (Bend, Expansion, Contraction, etc.) Stack Diameter > 0.61 m (24 in.)Minimum Number of Traverse Points

20 24Report ICR Testing June 30, 2010 Kansas City Power & Light 11 CEC Project 100-208 Sibley Generating Station reading was not zero, the pitot tube was rotated un til a null reading was obta ined. The va lue of the rotation angle was determin ed to the nearest degree using a digital angle finde r. After this technique had been applied at each traver se point, the average of the ab solute value of the angles was determined. The average angle was ≤ 20 o and the overall flow condition in the stack was found to be acceptable. This procedure was conducte d in conjunction with the preliminary flow determinations using USEPA Method 2 whic h is discussed in the next section.

3.2.2 USEPA Method 2

After determining the appropriate number of sampling points an d conducting the cyclonic flow check, USEPA Method 2 was used to perform velocity measurements of the fl ue gas in the stack. Preliminary velocity measurements were made to determine the appropriate nozzle size to use to maintain isokinetic sampling ra tes during the sampling. Velocity measurements were performed concurrently, while collecting the sa mples, to ensure the samples we re collected isok inetically and to determine the pollutant concentrations and mass emission rates.

The stack gas velocity was determined from th e measurement of the velocity head at each traverse point with a calibrated Type "S" pitot tube connected to an inclined manometer (Figure 2). Measurement of the stack gas temperature was made with a calibrated Type "K" thermocouple, and determination of the stack gas composition was made using USEPA Method 3A (Section 3.2.3).

CEC made measurements of the face opening ali gnments, external tubing diameter, and base-toopening plane distances of the pito t tubes prior to coming to site These measurements meet the design criteria in USEPA Method 2 for an Type “S” pitot tube, therefore a baseline coefficient value of 0.84 inches was assigned to the pitot tube. Verificati on of these measurements were recorded onto a pitot tube calibration worksh eet and presented in Appendix G. Once the measurements of the pitot tube were complete d, the method 2 train was assembled and leak checked prior to conducting velocity measurements.Report ICR Testing June 30, 2010 Kansas City Power & Light 12 CEC Project 100-208 Sibley Generating Station Figure 2: Velocity Measurements System

In addition to the velocity head measuremen ts, USEPA Method 3A (Section 3.2.3) was used to determine O 2 and CO 2 concentrations in the flue gas in order to calculate the flue gas molecular weight. The measurement was made in order to complete the preliminary velocity calculations necessary to establish the sampling conditions for the actual pollutant measurements.

3.2.3 USEPA Method 3A

Method 3A was used for determining O 2 and CO 2 concentrations and dry molecular weight of a sample from the outlet of the boiler system. CEC used a California Analytical Model 600P
O 2 /CO 2 paramagnetic and non-dispersive infrared analyzer with a range of 0-25 percent for O 2 and CO 2

.
Due to the magnetic properties of O 2 , the analyzer utilizes the phen omenon of Para -magnetism to
measure O 2 in the sample stream and gene rates a proportional electrical cu rrent. The sensor consists of two sealed spheres at each en d of a bar forming a dumbbell. The dumbbell is suspended in a symmetrical non-uniform magnetic field. Being slightly diamagnetic, the spheres are pushed away from the most intense part of th e magnetic field. Wh en the gas surrounding the spheres contains O 2 , the spheres are pushed further out of the field by the relati vely stronger paramagnetic O 2

.
The transducer incorporates a st rong metal band suspension mechan ism mounted to the dumbbell. In the zero position (O 2 free gas) light is reflected from an attached mirror to a photocell. In the feedback loop, when O 2 is present, a current was sent thro ugh the suspension system creating an electromagnetic counter torque. This torque restores the mirror to a position so that the photocell 7.62 cm (3 in.)* Temperature Sensor 1.90 - 2.54 cm* (0.75 - 1.0 in.)

Type S Pitot Tube

Leak-Free Connections Manometer

* Suggested (Interference Free) Pitot tube/Thermocouple SpacingReport ICR Testing June 30, 2010 Kansas City Power & Light 13 CEC Project 100-208 Sibley Generating Station again detects the light. Th e amount of restoration requi red is related to the O 2 concentration. The current simultaneously generates an output signal of 0-10 volts (V) which corresponds to 0-25% O 2 that was recorded by th e data acquisition system.

The CO 2 concentration in the effluent was measured by a non-dispersive in frared (NDIR) micro flow detector to measure CO 2 in the sample stream a nd generates a proportional electrical current. A single infrared light beam is modulated by a chopper and pa ssed through a sa mple cell of predetermined length containing th e gas sample to be analyzed. As the beam passes through the cell, the sample gas abso rbs some of its energy.

The attenuated beam emerges from th e cell and is introduced to the front chamber of a two-chamber infrared detector. The detector wa s filled with the component of in terest and consequently the beam experiences further energy absorptio n. The absorption process increases the pressure in both of the chambers. The differential pressure between the fr ont and rear chambers of the detector causes a slight gas flow between the two chambers. The flow is det ected by a mass-flow sensor and is converted into an AC electrical signal. This is amplified and rectified into a DC voltage signal which was recorded by the data ac quisition system in a percent rang e of 0 to 10V. The electrical output signal was directly proportional to the concentration of the sample gas.

The collected sample is split by the analyzer using critical orifices and passed through the appropriate analyzer. This configuration prevents the system from being pressurized and biasing the sample results. Figure 3 presents a di agram of the Method 3A sampling system.

An analyzer calibration error test was run, prior to sampling using a high-, mid-, and low-level gases
O 2 /CO 2 certified gas mixture with a balance of nitroge n. After the system had been calibrated, the mid-level cal gas was delivered to the probe tip and transported to the an alyzer to determine the response time for the analyzer system configuratio n and to determine if the system had any biases that would affect the sample results.

The electrical output response si gnal from the analyzer was r ecorded with a STRATA Version 2.01 data acquisition system. The gas sample wa s continuously extracted from the stack and transported to the analyzers via a heated Teflon® sample line. The effluent gas sample from the stack flowed through the Teflon® tubing to a c ondenser where the water vapor was removed. The gas sample was transported to the analyzer’s in let at a constant flow rate and pressure. The system response time was determined and recorded.

An analyzer calibration error test was performed on the O 2 analyzer by introducing a zero, mid and high-range calibration gas to the gas analyzer inlet. No adjustments were made to the analyzer. A zero gas (nitrogen) concentration of less than 0.25% of spa n, a certified Protocol-1 mid range gas (40-60% of span) and a certified Protocol-1 high-range ga s (100% of span) was used for the O 2 analyzer calibration error test.Report ICR Testing June 30, 2010 Kansas City Power & Light 14 CEC Project 100-208 Sibley Generating Station A sample system bias check was also performe d on the analyzer sampli ng system by introducing a zero and a mid-range calibration ga s at the calibration valve that is installed on the end of the sampling probe. The sampling system was operated at the normal sampling rate and no adjustments were made to the measurement system.

The acceptance criteria for the analyzer used in this test program was as follows:

• Calibration Error - Less than +2% of Calibra tion Span for the zero, mid, and high cal

gases.

• System Bias - Less than +5% of Calibration Span for the zero, mi d, and high cal gases.

• Zero Drift - Less than +3% of Calibration Span over the period of each test run.

• Calibration Drift - Less than +3% of Calibrati on Span over the period of each test run.

Figure 3 presents a basic diagram of a method 3A sampling system.

Figure 3: USEPA Method 3A Sampling System

The CEM sampling was conducted concurrently with the other pollutant measurements for an equal amount of time at the point of average velocity during each test run fr om a single test port. Heated filter

Sam p le manifol d

Calibration Gases Sample Pump Bypass

Heated Line Sample line Stack System Calibration / Bias Line O 2 CO 2 DAS Computer Heated probe

Universal Sample Conditioner Atmospheric DumpReport ICR Testing June 30, 2010 Kansas City Power & Light 15 CEC Project 100-208 Sibley Generating Station 3.2.4 USEPA Method 4

The Method 4 sampling train was incorporated in to the Method 29 sampling train for this test program. The moisture content of the sample gas stream was determin ed by extracting the gas sample at a known and regulated rate through a gl ass condenser train cons isting of four glass impingers connected in series with leak-free glass u-tube connectors. The gas sample was extracted through the impinger train maintained be low 68 degrees Fahrenheit (°F) in an ice bath with a vacuum pump. The volume of gas sampled wa s measured with a calib rated dry gas meter. The volume of moisture collected was measured gr avimetrically with an analytical balance with a tolerance of 0.1 gram (g) and the volume of gas drawn, was corrected to dry standard conditions (528 oR, 29.92 in. Hg).

3.2.5 USEPA Method 29

Emissions testing fo r antimony (Sb), ar senic (As), beryllium (Be), ca dmium (Cd), chromium (Cr), cobalt (Co), lead (Pb), manganese (Mn), nickel (Ni), and selenium (Se) and filterable particulate matter were performed according to US EPA Me thod 29. Since mercury (Hg) was sampled and analyzed using a separate procedure (Method 30B), the impingers containing potassium permanganate, 5 th and 6 th impingers were not used for this test program, per Section 6.1.5 of USEPA Method 29. For the meta l sampling per Method 29 the minimum sample volume was 3.4 cubic meters and a minimum sampli ng time of four (4) hours wa s used for each sampling run.

Method 29 was used to collect gaseous and particul ate pollutants isokinetically from the emission source and collect them in a multi- component sampling train. Particul ate matter was collected on a tared quartz fiber filter. The gaseous com ponents were then aspirated through a measured volume of 5% nitric acid/10% hydrogen peroxide to determine the moistu re and multiple metal content of the emission source. The principal co mponents of the sampling system are:

1. Pitot Tube Assembly

a. Nozzle --Borosilicate glass with a sharp, tapered leading edge. b. Probe --Stainless steel sheath with a 5/8-inch di ameter quartz glass in sert wrapped with nichrome wire; electronically controlled a nd capable of maintaining 248 ± 25 oF with calibrated Type "K" thermocouple. c. Pitot --Calibrated stainless steel Type "S" pito t tube constructed and attached to probe according to specifications outlined in USEPA Method 2, 40 CFR 60. d. Thermocouple --Calibrated Type "K" thermocouple attached to the sample probe such that the tip has no contact with metal and doe s not interfere with the pitot tube face openings and the sample nozzle. e. Glass filter housing --with a Teflon frit filter suppor t with a quartz fiber filter.

2. Impingers

Four impingers connected in series with glass ball/socket joint fit tings and placed in an ice bath were used for these tests. The second impinger was a Greenburg-Smith design with a standardReport ICR Testing June 30, 2010 Kansas City Power & Light 16 CEC Project 100-208 Sibley Generating Station orifice tip. The first, third a nd fourth impingers were the m odified Greenburg-Smith design. Final gas exit temperature was measured with a calibrated Type "K" thermocouple immersed in the gas stream.

3. Control Box

This control box is a module containing vac uum gauge, external leak-free pump, and thermocouple capable of measuring temperature within ±5 ° F, and dry gas meter with a minimum of 2 percent accuracy, valves and rela ted equipment to determine sample gas volume. Figure 4 presents the standard Method 29 sampli ng train with the mercury impingers and an extra knockout impinger up front that were not used during the sampling at Sibley.

Figure 4: USEPA Standard Method 29 Sampling Train

The sampling train was assembled, as previously described, ice was added to the impinger portion of the train, and the probe and hot box was heat ed to 248 ± 25 oF. Once the train was heated, the system was leak checked. A leak rate less than 0.02 cubic feet per minute (cfm) was determined and considered acceptable as outlined in 40 CFR 60. Once the sampling train passed the leak check, it was placed in the stack for sampling.

The train was run for the mi nimum of 4 hours. Afte r each test run, the f ilter, which collected the particulate sample, was carefully re moved from the Teflon filter suppor t and sealed in a petri dish. The nozzle, probe liner, and front filt er-half of the filter assembly we re rinsed with 0.1N nitric acid into a 500 milliliter amber glas s storage container.Report ICR Testing June 30, 2010 Kansas City Power & Light 17 CEC Project 100-208 Sibley Generating Station The liquid in the first tw o impingers were measur ed to the nearest tent h of a milligram. The collected sample was stored in a one liter amber glass storage containe r along with three 0.1N nitric acid rinse of the impingers and co nnecting glassware. The containe r was sealed and the liquid level marked. The contents of the thir d impinger were measur ed to the nearest te nth of a gram. The collected sample along with a 10 0 milliliter 0.1N nitric acid rinse of the impi nger was stored in a 250 ml amber glass storage container. The contai ner was sealed and the liquid level marked. The volume of the moisture collected by the silica gel in the fourth impinger was determined to the nearest 0.1 gram per Method 4. Collected condensate measuremen ts were recorded on the Method 29 moisture determinatio n data analysis form.

These samples and filters were shipped to the laboratory, along with the appropriate chain of custody documentation. Samples, method blanks and spiked sa mples were weighed, digested, prepared and analyzed according to EPA Method 29 protocol. Samples were analyzed for metals on a PerkinElmer ELAN 6100 inductively coupled argon plasma emission spectroscopy/mass spectrometry (ICP-MS) or similar instrument. The metals analysis was performed by Pace Analytical located in Minneapolis, MN.

3.2.6 USEPA Method 30B

Method 30B is a self validating sampling proce dure for measuring total vapor phase mercury (Hg) emissions from coal-fired combustion sour ces using sorbent trap sampling and subsequent analysis using thermal desorption. This method is designed to measure the mass concentration of total vapor phase Hg in flue gas, including elemental Hg (Hg o ) and oxidized forms of Hg (Hg +2 ), in micrograms per dry standard cubic meter. Kn own volumes of flue gas are extracted from the stack through paired, in stack sorbent media traps at a cons tant flow rate. By collecting the mercury on the sorbent media in the stack, poten tial loss of mercury during transport through a probe/sample line is eliminated.

For each test run, paired train sampling was performed to allow for the determination of measurement precision and verify acceptability of the measured emissions data. A field recovery test was performed with each run to determine measurement bias and to verify data acceptability.

The Method 30B sampling tubes were 6mm, 2-se ction sorbent traps c ontaining halogenated carbon. CEC used sorbet traps supplied by Ohio Lumex which contained an iodated carbon for the mercury sampling at Sibley. For quality-assurance purposes, the back section of one of the paired sorbent traps was spiked with Hg o by Ohio Lumex. This section was analyzed separately and a specified percentage of the spike must be recovered fo r the method to be valid. All three runs meet the spike recove ry criteria in the method.

As part of the Method 30B QA/ QC, CEC performed a Bias Test on the mercury analyzer prior to sampling on site. The Method 30B Bias Test is requ ired in order to show that the analytical instrument is able to measure both elemental an d oxidized mercury withoutbias. During the bias test three sorbent traps are spiked with elemental mercury at each of two levels (three low levels and three high levels between which actual samples are expected to fall). The sampling tubes are analyzed to demonstrate instrument accuracy in quantifying elemental mercury. Then, two setsReport ICR Testing June 30, 2010 Kansas City Power & Light 18 CEC Project 100-208 Sibley Generating Station of three standards are made with aqueous mercur y solutions and analyzed at the same mercury levels as the sorbent traps. As the water evap orates during analysis, for a short instance, the mercury exists as a mercury salt (oxidized mercury) until it is then broken down thermally and measured.

The USEPA has established mini mum sample run times for th e Method 30B sa mpling to be performed under the ICR. For the Hg sampling pe r Method 30B the minimu m sample time of two (2) hours was used for each sa mpling run. The Method 30B sampling train consisted of:

• A heated sampling probes capable of hol ding paired Method 30B sorbent traps;

• A heated umbilical;

• A moisture knockout;

• An umbilical to connect the control c onsole to the knockout and probe assembly;

• Control console containing heater controls, ma ss flow controllers, thermocouple readouts, heater controls for the heated umbilical and probe, dry gas meter and data acquisition system. Figure 5 presents a flow diagram for the USEPA Method 30B sampling system.

Figure 5: USEPA 30 B Sampling System Diagram

Paired Method 30B sorbent traps were loaded into the sample probes, leak checked and placed in the stack. One sorbent trap was spiked and th e other unspiked. Flue ga s was pulled through the paired sampling tubes for 2 hours at a sampling ra te of ~500 ml/minute. At the completion of sampling, the probe was removed from the stac k and a post leak check was performed. The tubes were removed, capped and taken to the mobile lab for analysis.Report ICR Testing June 30, 2010 Kansas City Power & Light 19 CEC Project 100-208 Sibley Generating Station An Ohio Lumex RA 915+ mercur y analyzer with a RP-M324 ther mal desorption attachment was used to analyze the carbon sorb ent traps. The 915+ uses di fferential atomic absorption spectrometry to determine the mercury that is th ermally desorbed from the sampling tubes. The system was calibrated usi ng the following procedure:

• The furnace is powered on and operated on Profile 1 mode which sets and holds the temperature at 680 o C. The sample flow is set at 2 lit er/minute. The lamp is ignited and the system was given 1 hour to warm–up and stabilize.

• The system was then calibrated using the thr ee calibration points which were determined based on the anticipated mercury catch. The r 2 was determined for the calibration curve and when it met method criteria and the standards were within ±10% of their true value, the samples were analyzed.

The samples will be analyzed as follows:

• Two layers of clean aluminum foil were placed on top of a clean sheet of white copier paper. A quartz ladle was placed on top of the second layer of aluminum foil. A second piece of aluminum foil was laid beside the ladle for wrapping the glass wool plug from the first layer of the trap.

• A blank sample was the first sample analyzed on the instrument to establish a background Hg level.

• The samples were prepared for analysis afte r the blank, by removing the first glass wool plug which is wrapped in aluminum foil and pl aced in the ladle on top of the carbon from the first section of the sorbent tube which was poured into the ladle. A final inspection of the tube was performed to ensure that there were no visible signs of carbon remaining in the first section of the sorbent tub. Carbon th at is deposited on the aluminum foil as a result of sample preparation is carefully poured into the ladle.

• The carbon and aluminum foil containing the gl ass wool plug was placed in the ladle and covered with sodium carbonate and placed in the furnace for analysis. The analysis was initiated as the ladle was placed in the furnace.

• The aluminum foil covering the sample prep aration area was removed along with the plain white paper and a new set placed down for each section of the traps. The carbon and glass wool from the second layer was remove d and placed in the ladle as previously described and analyzed.

• Each subsequent sample was handled following the same procedure.

• A calibration check sample, using a secondary standard, was prepared and analyzed before and after the samples to verify the system performance.

3.2.7 USEPA Other Test Method (OTM) 27

The USEPA OTM 27 was used to measure particulate matter emissions equal to or less than a nominal aerodynamic diameter of 2.5 micrometer (PM 2.5 ). USEPA’s concern under the current ICR was the determination of PM2.5 emissions. To facilitate the sampling during this testReport ICR Testing June 30, 2010 Kansas City Power & Light 20 CEC Project 100-208 Sibley Generating Station program, the OTM 27 sampling train was run without the PM 10 cyclone. This approach is allowed under the method (see Section 2.1).

The USEPA has established minimum sample volumes and run times for the PM 2.5 sampling to be performed under the ICR. For the PM 2.5 sampling per OTM 27, the minimum sample volume is 3.4 cubic meters and a minimum sampling time of four (4) hours for each sampling run. The nominal sampling time was used to as the primary driver. Based on historical PM data it was determined that 4 hours would meet EPA’s primary goal of ensuring an adequate catch to ensure the methods accuracy.

The sampling train consists of:

• Stainless steel (316 or equivalent) or Teflon ® -coated stainless steel nozzles with a sharp tapered leading edge;

• A PM 2.5 sizing devices that meets the design spec ifications shown in Figures 3, 4, 5, and 6 of Section 17 of Method OTM 27;

• A stainless steel (316 or equivalent) or Teflon ® -coated stainless steel, in-stack filter holder, 47 mm in diameter;

• Stainless steel pitot tube attached to the probe with stainless steel fittings per the specifications in Section 6.1.1.3 of Method 5;

• A glass lined stainless steel probe; A meteri ng system capable of maintaining a semiisokinetic samp ling rate and accurately determining the sample volume according to specifications in APTD-0581.

Figure 6 presents a schematic of the standard OTM 27 sampling train. For this test program the sampling train back half was replaced with the OTM 28 back half and the PM 2.5 sampling head was used without the PM 10 sampling head. The sampling trai n was assembled per the method with the noted exceptions and the system leak checked. The entire assembled sample system was leak-checked by plugging the inlet to the pr obe nozzle and pulling a vacuum of at least 15 in. Hg. A leak rate less than 0.02 cubic feet per minute (cfm) was determined and considered acceptable as outlined in 40 CFR 60.Report ICR Testing June 30, 2010 Kansas City Power & Light 21 CEC Project 100-208 Sibley Generating Station Figure 6: USEPA OTM 27 Sampling Train

The PM 2.5 sampling head was wrapped with a heat strip to preheat the sampling head to a temperature close to the stack temperature to prevent the formation of condensation when the sampling head was placed in the hot flue gas. The sampling was performed per the method and at the completion of the test run the sampling head was removed from the stack, the system post leak checked (without the PM 2.5 sampling head) and the nozzle was covered with Teflon to prevent the loss of particulate matter. The h ead was delivered to the sampling trailer for

recovery.

Once in the sampling trailer, rec overy of the sample began. R ecovery involves the quantitative transfer of particles > 2.5 micrometers; and ≤ 2.5 micrometers. A Nylon or Teflon ® brush and an acetone rinse are used to recover the sample head.

• Tweezers and/or clean disposable surgical glove s were used to remove the filter from the filter holder. The filter was placed in the petri dish that was identified as Container #1. Using a dry Nylon bristle brush, any particulate matter and/or filter fibers that adhere to the filter holder gasket or filter support screen were transferred to the petri dish and the container was sealed.

• The particulate matter from the cyclone cup and acetone rinses (and brush cleaning) of the cyclone cup, internal surf ace of the nozzle, and cyclone internal surfaces, including the outside surface of the down comer line were quantitatively recovered. The particulate from the cyclone cup and the acetone (and brus h cleaning) rinses of the cyclone cup were placed into Container #2. The container was sealed and the liquid level was marked on the outside. This container hol ds the particulate matter > 2.5 micrometers. This container was archived since the filterable PM is be ing determined with the Method 29 sampling train.Report ICR Testing June 30, 2010 Kansas City Power & Light 22 CEC Project 100-208 Sibley Generating Station • Acetone rinse (and brush cleaning) of the internal portion of the exit tube of PM 2.5 cyclone and the front half of the filter holder was placed into in container #3. The container was sealed and the liquid level wa s marked on the outside of the container.

• An acetone blank (100 ml) was placed into container #4.

The samples were shipped to the laboratory for analysis after the completion of sampling. The samples were analyzed using gravimetric analysis to determine the particulate mass for each PM size fraction based on the method. The recovery of the sample probe and back half of the sampling train are discussed with USEPA OT M 28, in section 3.2.8 of this document.

3.2.8 USEPA Other Test method (OTM) 28

USEPA OTM 28 was utilized to measure condensabl e particulate matter (CPM) emissions in the flue gas. This method includes procedures for me asuring both organic and inorganic CPM. CPM is measured in the flue gas afte r passing through a filter , or in this case af ter passing through the cyclone and in-stack filter. The OTM 28 samp ling train was the back half of the OTM 27 sampling train.

The OTM 28 sampling train consisted of:

• Method 23 type condenser and a condensate dropout impinger withou t bubbler tube after the final out-of-stack hot filter assembly;

• The dropout impinger is followed by a modified Greenburg Smith impinger with no taper ;

• A filter holder with a Teflon® filter meeting th e requirements in Section 6.1.2 will be placed immediately following the modified Greenburg-Smith impinger. The connection between the CPM filter and the moisture trap impinger includes a thermocouple fitting that provides a leak-free seal between the thermocouple and the stack gas;

• A Greenburg Smith impinger containing 100 ml of water followed by an impinger containing silica gel to collect moisture that passes through the CPM filter.

A pretest leak-check was performed and a leak rate of not more than 0.02 actual cubic feet per minute (acfm) or 4 percent of the average sample flow during the test run, whichever is less was considered acceptable per the method. The leak-check was performed at a vacuum equal to or greater than the vacuum anticipated during the test run. The first two impingers of the sampling train were maintained separately from the back two impingers. The first two impingers were kept in a dry compartment at a temperature less than 85 o F. The second 2 impingers (after the CPM filter) were maintained at a temperature of less than 68 o F. Figure 7 present a diagram of the OTM 28 sampling train.Report ICR Testing June 30, 2010 Kansas City Power & Light 23 CEC Project 100-208 Sibley Generating Station Figure 7: USEPA Method OTM 28 Sampling Train

Once the run was completed the sampling train was leak checked from the probe back. The leakcheck was performed and a leak rate of not more than 0.02 actual cubic feet per minute (ACFM) or 4 percent of the average sample flow during the test run, whichever is less was considered acceptable per the method. The leak-check was performed at a vacuum equal to or greater than the highest vacuum measured during the test run.

Once the leak check was completed the probe, any cyclones, and in-stack or hot filters were detached from the condenser and impinger train. The short stem impinger was emptied into a modified Greenberg Smith impinger which was inse rted in front of the short impinger. The impinger tip length extended below the wa ter level in the impinger catch.

The purge line was attached to a purged inline fi lter with no flow of gas through the clean purge line and fittings. The filter outle t was connected to the inlet of the impinger train. The nitrogen gas flow was started slowly while simultaneous ly opening the meter box pump valve(s). The pump bypass was adjusted and the nitrogen delivery rate ch anged to obtain the following conditions: (1) 20 liters/min or Δ H@, and (2) a positive overflow rate through the rotameter of less than 2 liters/min. The conde nser operation and recirculating water was continued during the purge to maintain a temperature less than 85 o F at the exit of the CPM f ilter. Ice was left in the water bath for the last two impingers to prevent removal of moisture during the purge and to maintain the gas temperature measured at the ex it of the silica gel impi nger below 20°C (68°F) until the sample recovery began.Report ICR Testing June 30, 2010 Kansas City Power & Light 24 CEC Project 100-208 Sibley Generating Station The purge was continued for a period of one hour checking the rotameter and Δ H@ periodically to ensure the purge rate had not changed. After 1 hour the pump and the purge gas were stopped simultaneously.

After the purge was complete, recove ry of the sample train began:

• CPM Container #1, Aqueous Liquid Impinger Cont ents. Quantitatively transferred liquid from the dropout and the impinger prior to the CPM filter into a clean glass sample bottle;

• Rinsed the probe extension, condenser, each impinger and the connecting glassware, and the front half of the CPM filter housing twice with water. Recovered the rinse water, and added it to the same sample bottle. Mark ed the liquid level on the bottle. CPM Container #1 held the water sol uble CPM captured in the impingers;

• CPM Container #2, Organic Rinses. Followed the water rinses of the probe extension, condenser, each impinger and all of the conn ecting glassware and fr ont half of the CPM filter with an acetone rinse. Then repeated the entire procedure with two rinses of MeCl 2 , and saved both solvents in a separate gla ss container identified as CPM Container #2. Marked the liquid level on the jars;

• CPM Container #3, CPM filter sample. Used tweezers and clean disposable surgical gloves to remove the filter from the CPM filter holder. Placed the filter in the petri dish identified as CPM Container #3;

• The non CPM impinger water and the silica gel impinger were weighed in the field and discarded.

The samples were sent to the laboratory for pro cessing and analysis. The lab analysis procedure followed the flow diagram in Figure 8.Report ICR Testing June 30, 2010 Kansas City Power & Light 25 CEC Project 100-208 Sibley Generating Station Figure 8: Analytical Flow diagram for OTM 28

The OTM 27/28 analysis was performed by Enth alpy Analytical located in Durham, NC.Report ICR Testing June 30, 2010 Kansas City Power & Light 26 CEC Project 100-208 Sibley Generating Station 3.3 FUEL SAMPLING AND ANALYSIS

The fuel sampling requirements were defined in the discussion in the Supporting Statement Part B of the ICR. The fuel sampling requirements for this test are listed in Table 8 below. Each fuel sample was a composite sample which consisted of three samples collected at approximately equal intervals during the f our hour testing period.

Table 8 ICR Required Fuel Analyses KCP&L ICR Sampling Sibley Generating Station

Mercury and

non-mercury metallic HAP antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, selenium, chlorine, and provide the HHV and proximate/ultimate analyses of the coal being utilized during the test

The fuel sampling at Sibley was performed from the feeders on the three boiler units exhausting into the common stack. The sampling was performed utilizing procedures similar to those in ASTM D2234/D2234M. Unit 3 at Sibley has ei ght sampling points on the feeder and Units 1 and 2 have four sampling points each. The sa mpling locations are on the bottom of the coal chute for each of the coal feeders. Each samp ling location consisted of a ball valve with a two inch diameter pipe nipple. The valve was opened, purged for 1 minute and a 2 pound (lb) coal sample collected at each location. This procedure was conduted three times over equally spaced intervals during each four hour emissions test, resulting in a total of 96 lbs of coal being collected during each flue gas emi ssion test run. The 96 lb sample was composited into a single sample for analysis at the lab based on the procedures in ASTM D2013/D2013M which addresses reducing and dividing the gross samp le into a mass suitable for the laboratory.

Table 9 outlines the approved analytical methods for analyzing fuel samples. The laboratory being utilized for the fuel analysis used the methods presented in Table 9 or an equivalent method.Report ICR Testing June 30, 2010 Kansas City Power & Light 27 CEC Project 100-208 Sibley Generating Station Table 9 Fuel Analysis Methods KCP&L ICR Sampling Sibley Generating Stations

Analyte Fuel Type Method Target Reported Units of
Measure Sample Preparation - Lab Coal ASTM D2013 Sample prep Higher Heating Value Coal ASTM D5865–04, Btu/lb Moisture Coal ASTM-D3173-03/3303 % Mercury Concentration Coal ASTM D6722-01 Ppm

Total Selected Metals Concentration Coal ASTM D6357-04 for arsenic, beryllium, cadmium, chromium, lead, manganese, and nickel in coal ASTM D4606-03 for Se ppm

Chlorine Concentration Coal ASTM D6721-01 ppm

All fuel analysis was performed by Standard Laboratories Freeburg Lab - Illinois Division Office located in Freeburg, IL.

3.4 PROCESS MONITORING AND OPERATING LOADS

Coal fired utilities are expected to operate at ninety (90 %) of maximum capacity for the testing required under the ICR. The facility provided operating data on the Unit Load (MW), net generation during each test run (MWh net), fuel feed rate and steam load of each run.Report ICR Testing June 30, 2010 Kansas City Power & Light 28 CEC Project 100-208 Sibley Generating Station 4.0 QUALITY ASSURANCE A ND QUALITY CONTROL

4.1 QUALITY ASSURANCE CRITERIA

CEC has established quality assuranc e and quality control (QA/QC) gu idelines for providing quality sampling and analytical data from source tests. These QA/QC procedures were implemented to ensure the acceptabilit y and reliability of the data generated.

For the measurement of O 2 /CO 2 utilizing a continuous emission monitor there are four primary criteria used to determine the methods performance:

• Zero Drift - Less than ±3 percent of the span value

• Calibration Drift - Less than ±3 percent of span value

• Calibration Error - Less than ±5 pe rcent of the calibration gas value

• System Bias Check - Less than ±5 percent of the calibration gas value

Table 10 Calibration Error Test O2/CO2 Sibley Generating Station

Date/Time 3/16/2010 7:20:41 Analyte O2 CO2 Units % % Zero Ref Cyl 0 0 Zero Avg -0.009 0.001
Zero Error% 0 0 Low Ref Cyl 5.486 5.469 Low Avg 5.437 5.431
Low Error% 0.2 0.1 Mid Ref Cyl 14.99 14.9 Mid Avg 14.969 14.917 Mid Error% 0.1 0.1 High Ref Cyl 21.92 21.73 High Avg 22.127 22.082 High Error% 0.8 1.2Report ICR Testing June 30, 2010 Kansas City Power & Light 29 CEC Project 100-208 Sibley Generating Station All calibration error and bias test met the method criteria.

For the particulate matter measurements of part iculate matter less than 2.5 microns there are a number of the method performance criteria the me thod must meet to be considered valid. These include:

Post Meter Calibration 1 0.05 Isokinetics 100 ±20% Pre and post meter box leak checks < 0.020 cu. Ft.
D 50 2.5μ ± 0.25μ Table 11 Final System Bias Check O2/CO2 Analyzers

Run 1 Run 2 Run 3
Date/Time 3/16/2010 14:10:04 3/16/ 2010 20:18:12 3/17/2010 2:03:35 Analyte O2 CO2 O2 CO2 O2 CO2 Units % % % % % % Zero Ref Cyl 0 0 0 0 0 0
Zero Cal -0.009 0.001 -0.009 0.001 -0.009 0.001 Zero Avg 0.028 0.138 -0.001 0.169 0 0.134 Zero Bias% 0.1 0.5 0 0.6 0 0.4 Zero Drift% 0.1 0.1 -0.1 0.1 0 -0.1 Span Ref Cyl 5.486 5.469 5.486 5.469 5.486 5.469 Span Cal 5.437 5.431 5.437 5.431 5.437 5.431 Span Avg 5.382 5.393 5.404 5.526 5.408 5.505 Span Bias% 0.2 0.1 0.1 0.3 0.1 0.2 Span Drift% -0.1 -0.2 0.1 0.4 0 -0.1 Ini Zero Avg -0.003 0.107 0.028 0.138 -0.001 0.169 Ini Span Avg 5.395 5.445 5.382 5.393 5.404 5.526 Run Avg 3.3 15.592 3.316 15.737 3.287 15.833
Co 0.012 0.122 0.013 0.153 0 0.152
Cm 5.389 5.419 5.393 5.46 5.406 5.515 Correct Avg 3.355 15.972 3.368 16.061 3.335 15.99Report ICR Testing June 30, 2010 Kansas City Power & Light 30 CEC Project 100-208 Sibley Generating Station Table 12 QA/QC for USEPA Method OTM27/28 Sibley Generating Station

Parameter Run 1 Run 2 Run 3 Average Results % Isokinetic (80-120%) 94.48 92.26 95.90 94.22 Pass

Δ P range ( 3.80 to 9.12) passed passed passed passed Pass Cunningham Correction Factor ( C ) 1.0909 1.0896 1.0921 1.09 Pass
μmeter - D50 for Cyclone IV (2.25-2.75) 2.39 2.43 2.37 2.40 Pass

All pre and post leak ch ecks met method criteria.

For the filterable particulate and the multi meta ls train (Method 29) the sampling system must

meet:

Post Meter Calibration 1 0.05 Isokinetics 100 ±10% Pre and post meter box leak checks < 0.020 cu. Ft.

Table 13 QA/QC Method 5/29 Sibley Generating Station

Method Criteria Run 1 Run 2 Run 3 Average Test Series

Unit # 2 - Condition 1

Isokinetics 100 + 10 % 95.45 95.75 98.75 96.65 Pass

Post Leak Checks - System < 0.020 cu. ft./min 0.000 0.000 0.017 0.001 Pass

Post Leak Checks - Pitot stable for at least
15 secs 0.0 0.0 0.0 0.0 Pass

Alt-009 Results ± 5 % of original Y -3.39 -2.87 -2.82 -3.03 Pass

In addition the metals analysis at the lab must achieve laboratory spike recoveries that meet the 75% to 125% recovery criteria. The laboratory met all spike rec overy criteria for the method.

Mercury analysis per Method 30B’s quality assurance criteria are:

Tube agreement ± 10% Spike recoveries 100% ± 15% Break through <10% Spike level ± 50% of the sample catchReport ICR Testing June 30, 2010 Kansas City Power & Light 31 CEC Project 100-208 Sibley Generating Station For this test sequence all three runs meet the QA/QC criteria for determining the validity of the test. Table 14 below presents the QA/QC data for the test sequence at Sibley Generating Station.

Table 14 QC/QA Data for USEPA Method 30B Sibley Generating Station

No Description Tube ID C, ng/g RD (Tube Agreement) B % Recovery %
1 Run 1 A 68707 FH A 68707 117 0.83%
2 Run 1 A 68707 BH A 1.7 1.45% 101.9%

3 Run 1 B 68534 FH Spike B 68534 216
4 Run 1 B 68534 BH B 1.4 0.65%
5 Run 2 A 68739 FH A 68739 100 6.28%
6 Run 2 A 68739 BH A 0.3 0.30% 89.2%

7 Run 2 B 68542 FH Spike B 68542 186
8 Run 2 B 68542 BH B 0.7 0.38%
9 Run 3 A 68709 FH A 68709 102 4.61%
10 Run 3 A 68709 BH A 0 0.00% 92.4%

11 Run 3 B 65430 FH Spike B 65430 191
12 Run 3 B 65430 BH B 1.2 0.63%

Average Spike = 100 ng 3.91% 0.57% 94.50%

The metals analysis at the lab must achieve labo ratory spike recoveries that meet the 75% to 125% recovery criteria. The laboratory met a ll spike recovery criteria for the method. The results on a per metal basis can be found in Appendix E.

4.2 BLANK SAMPLING TRAINS

For each of the sampling trains a blank train was collected by recharging the first sampling train with reagents, assembling the train, leak checking the train at the sample location and recovering the sample train.

For the metals train (Method 29) chromium, manga nese, nickel, arsenic and lead were found in the blank train front half section at 1.82 ug, 3.8 ug, 0.59 ug, 0.63 ug and 0.27 ug, respectively. All of the target metals were det ected in the backhalf of the samp ling train at levels at or below the laboratory reporting limits, w ith the exception of chromium and nickel which were found at 1.03 ug and 1.19 ug, respectively. The trace levels detected are mi nimal and have a negigible impact on the final results.

The OTM27/28 blank sampling train for Filterable PM was at the method detection limit of 0.5 mg for the filter and front half rinse. The to tal blank level was 0.9 mg which is nsignificantReport ICR Testing June 30, 2010 Kansas City Power & Light 32 CEC Project 100-208 Sibley Generating Station compared to the concentration detected in the samples. The condensible portion of the sampling train had blank train values of 2.9 (organic) an d 1.8 (inorganic) ug for a total correction of 4.7 mg. This correction is higher than the he method allowed 2 mg correction. The results indicate that there may be a slight positive bias in th e final condensible result s of approximately 2%.

4.3 QUALITY ASSURANCE OBJECTIVES

Data Quality Indicators (DQIs) are a simplisti c way of referring to da ta characteristics by consideration of commonly used measures of environmental quality. The most commonly used DQIs are precision, bias (accuracy), and completene ss. Accuracy is the degree of agreement of a measurement (or average of measurements) with an accepted reference or true value. Precision is a measure of mutual agreement of replicate measurements. Completeness is a measure of the amount of valid data compared to the amount th at was expected to be obtained under correct operating conditions.

Precision is typically determined by calculating the range percent (RP) when the number of data points is less than four but more than 2. RP is typically calculat ed using the equation:

ܴܲ ൌ 100 ൈ ሺܺ ௠௔௫ െ ܺ ௠௜௡ ሻ ܺ ௔௩௚ ൘

Table 5 lists the expected (typical) precision of the sampling methods, based on the above listed calculation.

Accuracy is the extent of the agreement between an observed valu e (sample result) and the true value of the parameter being measured. Accu racy/Bias as an indicator of measurement confidence, percent accuracy will be calculated ba sed on analytical results of spiked samples of known chemical concentrations for the metals anal ysis. Accuracy for an analytical method is typically calculated as:

%ܴ ൌ 100 ൈ ܥ ௠ ܥ ௦௥௠ ൗ

Where: C m = measured concentra tion of a standard
C srm = actual concentration of the SRM

when laboratory control spikes ar e used in the analysis. Accuracy of the other manual sampling methods typically cannot be measured. Table 15 lists the expected accuracy of the sampling methods based on the calibration procedure.Report ICR Testing June 30, 2010 Kansas City Power & Light 33 CEC Project 100-208 Sibley Generating Station Table 15 Precision and Accuracy for Emission Test Methods KCP&L ICR Sampling Sibley Road Generating Stations Parameter Method Traceability or Audit Device Expected Precision Expected Accuracy Achieved

Gas Velocity Method 2 EPA Design Specifications ± 18% Not measured Not measured Gas Volume Method 4, 29, OTM 27/28 Wet test meter reference ± 2% ± 2% ± 0.3%

Stack /Filter Temperature Thermocouple Mercury in glass ± 1 % ± 1.5 % ± 1.5%

Barometric
Pressure Aneroid
Barometer Calibrated Barometer ± 4 % ± 4 % ± 4 %

Particulate weights Electronic Balance Class S weights ± 0.5 mg ± 0.5 mg ± 0.5 mg

Gas Composition O 2 /CO 2 EPA Method 3A NIST Traceable Cylinder gas ± 25% ± 20% ± 10%

Particle size weight Electronic balance Class S weights ± 0.2 mg ± 0.5 mg ± 0.5 mg

Multimetals EPA Method 29/ICAP Audit sample ± 20% ± 10% N/A

Particulate emissions EPA Method 5 Filterable PM All the above ± 12.1% N/A 2.2%

Completeness is a measure of the amount of va lid data compared to the amount that was expected to be obtai ned. Completeness is calculated using:

%ܥ ൌ 100 ൈ ܸ ܶ ൗ Where V = the number of valid samples T = total number of planned samples

For this testing program the pe rcent completeness was 100%.

### APPENDIX A

FIELD DATA FORMS

### APPENDIX B

ELECTRONIC SPREAD SHEETS

### APPENDIX C

EXAMPLE CALCULATIONS

### APPENDIX D

ANALYTICAL DATA ENTHALPY ANALYTICAL, OTM 27/28

### APPENDIX E

ANALYTICAL DATA PACE LABS, METHOD 29

### APPENDIX F

ANALYTICAL DATA STANDARD LABS, FUEL

### APPENDIX G

CALIBRATION SHEETS, CERTIFICATIONS

### APPENDIX H

PROCESS DATA