Date: September 30, 2011

Subject: National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for Coal- and Oil

Response to Comment Regarding 98 Facilities Lacking Part II Mercury 

Testing Data in the MACT Floor Analysis

From: Shelly Johnson, RTI International

To: William Maxwell

EPA/OAQPS/SPPD/ESG

Background

The EPA proposed National Emission Standards for 

Coal- and Oil-Fired Electric Utility Steam Generating EGUs on May 3, 2011. The public 

comment period ended on August 4, 2011. The company, CONSOL Energy, Inc., submitted 

comments on the proposed rule. CONSOL states

“EPA did not use all the data available to it in calculating the MACT floor. There are 98 

plants . . . that submitted Part II Hg emission data, but these plants are not in the list of 202 

plants (338 units) in the MACT floor spreadsheet. . . EPA has

exclude the data from 98 plants, nor discussed this data in any way. . . EPA failed to 

provide any reason for excluding these 98 plants. . . It is incumbent upon EPA to evaluate 

those data and explain why they were not used, and t

explanation if data were excluded for the other HAPs and HAP surrogates. . . The statue 

[sic] requires EPA to use all available emissions information. Since EPA cannot simply 

exclude those data without explanation, and sin

comment upon the Agency’s bases for that exclusion, EPA is obligated to provide that 

information and to take comment on it before it finalizes this rule.”

This memorandum addresses 

provided by the above-mentioned 98

Discussion

In order to process the large amount of emission test data submitted in response to the ICR, 

RTI developed a Microsoft Access 

and developed a series of database queries to calculate the emission factors (lb/MMBtu) 

necessary to conduct the MACT floor analysis. In the data analysis process (database 

queries), many stipulations were placed on the test data to ensure that the analysis included 

only those tests reports representing current EGU configurations. The five bullets listed 

, 2011

National Emission Standards for Hazardous Air Pollutants (NESHAP) 

and Oil-Fired Electric Utility Steam Generating EGUs

Response to Comment Regarding 98 Facilities Lacking Part II Mercury 

Testing Data in the MACT Floor Analysis

Shelly Johnson, RTI International

William Maxwell

OAQPS/SPPD/ESG

The EPA proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Fired Electric Utility Steam Generating EGUs on May 3, 2011. The public 

comment period ended on August 4, 2011. The company, CONSOL Energy, Inc., submitted 

comments on the proposed rule. CONSOL states, in part:

“EPA did not use all the data available to it in calculating the MACT floor. There are 98 

plants . . . that submitted Part II Hg emission data, but these plants are not in the list of 202 

units) in the MACT floor spreadsheet. . . EPA has not provided a reason to 

exclude the data from 98 plants, nor discussed this data in any way. . . EPA failed to 

provide any reason for excluding these 98 plants. . . It is incumbent upon EPA to evaluate 

those data and explain why they were not used, and to do similar analyses and provide 

explanation if data were excluded for the other HAPs and HAP surrogates. . . The statue 

[sic] requires EPA to use all available emissions information. Since EPA cannot simply 

exclude those data without explanation, and since the public is entitled to view and 

comment upon the Agency’s bases for that exclusion, EPA is obligated to provide that 

information and to take comment on it before it finalizes this rule.”

This memorandum addresses the reason(s) for exclusion of the mercury emission test data 

mentioned 98 facilities from the MACT floor analysis for mercury.

In order to process the large amount of emission test data submitted in response to the ICR, 

RTI developed a Microsoft Access database to store the raw data provided by the companies, 

and developed a series of database queries to calculate the emission factors (lb/MMBtu) 

necessary to conduct the MACT floor analysis. In the data analysis process (database 

ns were placed on the test data to ensure that the analysis included 

only those tests reports representing current EGU configurations. The five bullets listed 

National Emission Standards for Hazardous Air Pollutants (NESHAP) 

Fired Electric Utility Steam Generating EGUs -

Response to Comment Regarding 98 Facilities Lacking Part II Mercury 

Hazardous Air Pollutants (NESHAP) for 

Fired Electric Utility Steam Generating EGUs on May 3, 2011. The public 

comment period ended on August 4, 2011. The company, CONSOL Energy, Inc., submitted 

“EPA did not use all the data available to it in calculating the MACT floor. There are 98 

plants . . . that submitted Part II Hg emission data, but these plants are not in the list of 202 

not provided a reason to 

exclude the data from 98 plants, nor discussed this data in any way. . . EPA failed to 

provide any reason for excluding these 98 plants. . . It is incumbent upon EPA to evaluate 

o do similar analyses and provide 

explanation if data were excluded for the other HAPs and HAP surrogates. . . The statue 

[sic] requires EPA to use all available emissions information. Since EPA cannot simply 

ce the public is entitled to view and 

comment upon the Agency’s bases for that exclusion, EPA is obligated to provide that 

rcury emission test data 

facilities from the MACT floor analysis for mercury.

In order to process the large amount of emission test data submitted in response to the ICR, 

database to store the raw data provided by the companies, 

and developed a series of database queries to calculate the emission factors (lb/MMBtu) 

necessary to conduct the MACT floor analysis. In the data analysis process (database 

ns were placed on the test data to ensure that the analysis included 

only those tests reports representing current EGU configurations. The five bullets listed 
2

below describe the criteria by which some emission tests were excluded from the MACT 

floor analysis spreadsheets.

There are instances, noted below, where some data were not included in the MACT floor 

output for the EGU proposal, but are included in the current MACT floor output for the 

promulgated rule. The database queries used to develop the emission factors have been 

refined to include additional emission tests, as appropriate.

 Emission rate, but no process data.

An emission test was excluded if the pollutant emissions were provided in units of an 

emission rate (e.g., pounds per hour), but the necessary process information was not 

provided to calculate an emission factor. Either the unit load (MW) during testing or the 

fuel flow rate (lb/hour) and fuel heating value (Btu/lb) during testing were needed in 

addition to the emission rate.

 Concentration, but insufficient flue gas parameters.

An emission test was excluded if the pollutant emissions were provided in units of 

concentration, but not enough sampling run data was provided to calculate an emission 

factor. The equations contained in EPA Method 19 were used to convert concentrations 

to emission factors. The additional pieces of data necessary to make the conversion 

included fuel type, concentration units that could be converted to pounds per dry standard 

cubic foot, percent oxygen or percent carbon dioxide, and moisture content of the flue 

gas.

Additionally, facilities that burned exactly a 50/50 split of the fuels during testing were 

excluded, as the automated process was developed to consider just one primary fuel.

 Test data prior to installation of current emission controls.

An emission test was excluded if the test report end date was not provided by the 

company. In order to accurately represent the emissions from EGUs as they are currently 

configured and operating, any emission tests that were completed prior to the latest air 

pollution control device installation date were excluded. For example, if a company

provided emission test reports from March 2006 and March 2009, and installed an 

activated carbon injection system in 2008, then only the March 2009 test would appear in 

the MACT floor output.

In the process for the February output, the test date was chosen from one field in the ICR 

database. If this field was not populated, then the test report was excluded. Since the 

February output, the process has been modified to include more reports by pulling in 

dates from more fields (there are several fields from which the test date can be 

determined). As a result, additional tests are now included in the MACT floor output.
3

Additionally, for the February output, for facilities that have no add-on emission control 

devices, there is no control installation date, so these reports were excluded. Since the 

February output, the output queries have been modified to include these reports. 

Since the February output was created, another change to the database has been to denote 

future controls as any control with a start date of 1/1/2010 or later. These controls were 

not considered in determining the latest configuration control date. 

 Sampling port not after last control.

Multiple sampling ports could have been selected for a test; however, results from only

one sampling port were selected. The sampling port selected had to be located after the 

last emission control device and had to be the last port for which data were provided. For 

example, if a company provided test results for the inlet to their wet scrubber (the last 

control in their configuration), a sampling port at the bottom of the stack, and a sampling 

port at the top of their stack, then only the test results from the sampling port at the top of 

their stack would be used.

An emission test was excluded if the sampling port chosen for the test was not part of the 

configuration chosen for the test (i.e., the sampling port was not included in the “current” 

configuration for the unit). In the electronic ICR, there was a mandatory field for the 

sampling port to be selected and an optional field for the configuration to be selected for 

each test. In tests from a few facilities, the company did not select a sampling port that 

was part of the configuration they selected. These test results were excluded.

 Yellowstone Energy (specific facility cited by commenter).

The Yellowstone Energy LP facility (ORIS Code 50931) results are, in fact, included in 

the MACT floor analysis. The data are included in the petroleum coke spreadsheet 

because the primary fuel during testing was reported to be petroleum coke. 

Conclusion

Table 1 presents a summary of the reasons emissions tests were excluded from the MACT 

floor analysis at proposal, and provides counts of facilities excluded for each reason. Table 1 

also presents the number of previously excluded facilities that have been added to the MACT 

floor analysis for promulgation due to refinements in the database queries.

The attached Table A-1 (in Attachment 1) lists the 98 facilities that were excluded from the 

mercury MACT floor analysis at proposal. Table A-1 includes the reason each of these 

emission tests was excluded from the MACT floor analysis at proposal. An additional 

column identifies the emission tests that are now included in the MACT floor analysis due to 

refinements in the database queries since proposal.
4

Table 1: MACT Floor Facility Exclusion Summary

Reason

Facilities excluded in

February output

Facilities that are now 

included

Emission rate, but no 

process data 11

Concentration, but 

insufficient flue gas 

parameters

58

Test data prior to 

installation of current 

emission controls

33 13

Test data from old 

configuration, or not at

the stack

1

Yellowstone Energy 1

**The sum of facilities excluded is 104, instead of 98, because 6 

facilities fall under multiple reasons.
5

Attachment 1
Table A-1. Excluded Test Reports

6

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

207 HgTest_06_2006_AppK x

207 HgTest_06_2006_OH x

207 HgTest_06_2006_SCEM x

508 3 x

594

Unit 3 - 100% Bituminous Test -

Trace Metals x

594

Unit 3 60% PRB Test - Trace 

Metals x

703 Unit 3 Scrubber Mercury testing x

856 1 x x

856 10 x x

856 11 x x

856 2 x x

856 3 x x

856 4 x x

856 5 x x

856 6 x x

856 7 x x

856 8 x x

856 9 x x

861 1 x x

863 1 x

863 2 x

863 3 x

876 2009Hg x x

898 14 x

898 16 x

976 1 x

976 10 x

976 11 x

976 12 x

976 13 x
Table A-1. Excluded Test Reports

7

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

976 14 x

976 15 x

976 16 x

976 17 x

976 18 x

976 19 x

976 2 x

976 20 x

976 21 x

976 22 x

976 23 x

976 24 x

976 25 x

976 26 x

976 27 x

976 28 x

976 29 x

976 3 x

976 30 x

976 31 x

976 32 x

976 33 x

976 34 x

976 35 x

976 36 x

976 37 x

976 38 x

976 39 x

976 4 x

976 40 x

976 41 x

976 42 x

976 43 x
Table A-1. Excluded Test Reports

8

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

976 44 x

976 45 x

976 5 x

976 6 x

976 7 x

976 8 x

976 9 x

1008 U2091409-BAGOUT x

1008 U2091409-BASE x

1122 3 x x

1122 4 x x

1122 5 x x

1122 6 x x

1122 7 x x

1217 2007 Stack (Hg) x x

1217 2009 Stack (Hg) x x

1239 2 x

1239 4 x

1381 Baseline Mercury Test Study x

1382 Baseline Mercury Test Study x

1382

Baseline Mercury Test Study 2007 

H1 x

1382

Baseline Mercury Test Study 2007 

H2 x

1383 Baseline Mercury Test Study x

1552 1 x

1552 10 x

1552 11 x

1552 12 x

1552 13 x

1552 14 x

1552 2 x

1552 3 x
Table A-1. Excluded Test Reports

9

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

1552 4 x

1552 5 x

1552 6 x

1552 7 x

1552 8 x

1552 9 x

1554 1 x

1554 10 x

1554 11 x

1554 12 x

1554 13 x

1554 14 x

1554 15 x

1554 2 x

1554 3 x

1554 4 x

1554 5 x

1554 6 x

1554 7 x

1554 8 x

1554 9 x

1571 E1 Hg 1qtr 09 x x

1571 E1 HG 2QTR 08 x

1571 E1 Hg 2qtr 09 x x

1571 E1 HG 3QTR 07 x

1571 E1 Hg 3qtr 08 x

1571 E1 HG 4QTR 07 x

1571 E1 Hg 4qtr 08 x

1571 E2 HG 1QTR 08 x

1571 E2 HG 2qtr 08 x

1571 E2 Hg 2qtr 09 x x

1571 E2 HG 3QTR 07 x

1571 E2 Hg 3qtr 08 x
Table A-1. Excluded Test Reports

10

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

1571 E2 HG 4QTR 07 x

1571 E2 Hg 4qtr 08 x

1572 D1 HG 1QTR 08 x

1572 D1 Hg 1qtr 09 x

1572 D1 Hg 2qtr 08 x

1572 D1 Hg 2qtr 09 x

1572 D1 HG 3QTR 07 x

1572 D1 Hg 3qtr 08 x

1572 D1 HG 4QTR 07 x

1572 D1 Hg 4qtr 08 x

1572 D2 HG 1QTR 08 x

1572 D2 Hg 2qtr 08 x

1572 D2 Hg 2qtr 09 x

1572 D2 HG 3QTR 07 x

1572 D2 Hg 3qtr 08 x

1572 D2 HG 4QTR 07 x

1572 D2 Hg 4qtr 08 x

1572 D3 HG 1QTR 08 x

1572 D3 Hg 1qtr 09 x

1572 D3 Hg 2qtr 08 x

1572 D3 Hg 2qtr 09 x

1572 D3 HG 3QTR 07 x

1572 D3 Hg 3qtr 08 x

1572 D3 HG 4QTR 07 x

1572 D3 Hg 4qtr 08 x

1573 F1 HG 1QTR 08 x

1573 F1 Hg 1qtr 09 x

1573 F1 Hg 2qtr 08 x

1573 F1 Hg 2qtr 09 x

1573 F1 HG 3QTR 07 x

1573 F1 Hg 3qtr 08 x

1573 F1 HG 4QTR 07 x

1573 F1 Hg 4qtr 08 x
Table A-1. Excluded Test Reports

11

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

1573 F2 HG 1QTR 08 x

1573 F2 Hg 1qtr 09 x

1573 F2 Hg 2qtr 08 x

1573 F2 Hg 2qtr 09 x

1573 F2 HG 3QTR 07 x

1573 F2 Hg 3qtr 08 x

1573 F2 HG 4QTR 07 x

1573 F2 Hg 4qtr 08 x

1606 Hg CEM certification 2008 x

1606 Hg CEMS certification 2009 x x

1606 Hg emissions 2006 x

1606 Hg emissions Jan. 2007 x

1606 Hg emissions Sept 2007 x

1606

Jan 2008 initial Hg CEMS 

certification x

1606 Turbosorp - initial compliance test x

1619 2007FebHg x

1619 2007OctHg x

1695 BCC4 - Hg CEMs Performance x

1695

BCC5 - Hg CEMs Performance 

Guarentee x

1702

DEK1 - Hg Cems Performance 

Test x

1702

DEK2 - Hg CEMs performance 

guarantee x

1720

JCW78 - Hg CEMs Performance 

Test x

1769 PIPP-TracePM-F7-05.2009 x

1831 Hg-1--7/05 x x

1831 Hg-2-7/05 x x

1831 Hg-3-7/05 x x

1831 Hg-4-7/05 x x

1891 GE-Hg-7-2009 x
Table A-1. Excluded Test Reports

12

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

1891 Platt_HG-6-2008 x

2008

Results of Unit 4 Compliance 

Testing #902546 (Hg) x

2168 Catalyst Mercury Test x

2168 Catalyst Mercury Test U2 x

2168 Catalyst Mercury Test U3 x

2187 Dec2005Hg x

2187 June2008Hg x

2187 Nov2007Hg x

2187 Sept2008Hg x

2367 sr-4-037-Hg-2 x

2367 SR-4-07-037-Hg-1 x

2367 SR4-07-037-Hg-3 x

2367 SR4--07-037-Hg-4 x

2367 SR4-07-037-Hg-5 x

2367 SR4-07-123-M30B x

2367 SR4-08-030-M29 x

2367 SR4-08-093-M29 x

2367 SR4-08-093-M30B x

2367 SR4-09-038-M29 x

2367 SR4-09-042-M29 x

2367 SR5-Startup Testing x

2367 SR6-08-124-Test Burn x

2549 Stack-Hg-0609 x

2549 Stack-Hg-0707 x

2549 Stack-Hg-0708 x

2554 Hg-06/08-1 x

2554 Hg-06/08-2 x

2554 Hg-06/09-1 x

2554 Hg-06/09-2 x

2554 Hg-06/09-3 x

2554 Hg-06/09-4 x

2554 Hg-07/07-1 x
Table A-1. Excluded Test Reports

13

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

2554 Hg-07/07-2 x

2554 Hg-07/07-3 x

2554 Hg-07/07-4 x

2554 Hg-07/08-3 x

2554 Hg-07/08-4 x

2720 BLR5(9/12/07) x

2720 BLR9(3/5/08) x

2720 BLR9(8/11/09) x

2721 UNIT2(10/3/07) x

2721 UNIT4(10/2/07) x

2721 UNIT5(9/16/08) x

2723 UNIT2(9/14/07) x

2727 CS001011008 x

2727 CS001011108 x

2727 CS001080409 x

2727 U3011608 x

2727 U3011608RemovalIN x

2727 U3011608RemovalOUT x

2727 U3011708 x

2727 U3012208 x

2727 U3080309 x

2727 U4012308 x

2727 U4012408 x

2727 U4012508 x

2727 U4080509 x

2823 2008 HG Testing x

2835 Hg Testing (June 2006) x

2838 Unit 18 Hg Testing (Jun 2006) x

2850 MS4WEngineerHg x

2864 Unit 8 Hg Testing (Dec 2005) x

2866 Unit 4 Hg Testing (July 2005) x

2866 Unit 5 Hg Testing (July 2005) x

2866 Unit 6 Hg Testing (July 2005) x
Table A-1. Excluded Test Reports

14

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

2878 Unit 1 Hg Testing (Sept 2006) x

2878 Unit 2 Hg Testing (Sept 2006) x

2878 Unit 3 Hg Testing (Sept 2006) x

2878 Unit 4 Hg Testing (Sept 2006) x

3131 SH-181 x

3131 SH-181A x

3131 SH-181B x

3131 Unit 1 Baseline HG x

3131 Unit 1 Boiler performance x

3131 Unit 2 Baseline Hg x

3131 Unit 2 Boiler Performance x

3131 Unit 3-4 Baseline Hg x

3136 K179 x

3136 K1792 x

3298 Hg-03/09 x x

3298 Hg-11/05 x x

3298 Hg-12/08 x x

3298 Hg-12/09 x x

3298 PM-HCL-HF-Hg-06/06 x x

3317 G1LME2008 x x

3317 G2LME2008 x x

3319 J3LME2008 x x

3319 J4LME2008 x x

3497

14-Mercury Measurements at Unit 

1 x

3497

5-The Effect of ACI on Mercury 

Control at Unit 1 x

3497

7-Field Testing of ACI Options for 

Mercury Control x

3644 CRB1 Mercury CEM Certification x

3644 CRB2 Mercury CEM Certification x

3944 9 x

3982 Mercury Diagnostic Test 2006 x x
Table A-1. Excluded Test Reports

15

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

4050 EDG3-HG-20071003 x

4050 EDG4-Hg-20071101 x

4050 EDG4-Hg-20080730 x

4050 EDG4-Hg-20080731 x

4050 EDG5-Hg-20060907 x

4050 EDG5-HgPM-20080226 x

4050 EDG5-HgPM-20080306 x

4050 EDG5-Metals-20060615 x

4054 ND1-Inlet-Metals-20050222 x

4054 ND1-Outlet-Metals-20050222 x

4054 ND2-Hg-20071101 x

4054 ND2-Inlet-Metals-20050224 x

4054 ND2-Outlet-Metals-20050224 x

4140 3 x x

4140 4 x

4143 5 x

4158

BW41 Mercury CEM Certification 

Testing x

4158

BW42 Mercury CEM Certification 

Testing x

4158

BW43 Mercury CEM Certification 

Testing x

4158

BW44 Mercury CEM Certification 

Testing x

4162 Mercury CEM Certification Testing x

4162 Mercury CEM RATA Testing Unit 3 x

4162

Mercury CEM RATA Testing Units 

1&2 x

4271 5 x

4941 2006-Hg x

6031 Hg Test 2007 Stack x

6031 Hg Test 2008 Port 1 x

6065 MercuryCEMSRATA2009 x
Table A-1. Excluded Test Reports

16

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

6068 MERC 0709/3 x

6073

Hg Control using Sorbent Injection 

2005 x

6089 5 x

6089 8 x

6089 9 x

6094 Unit 1 Hg Certification (Nov 2008) x

6094 Unit 1 Hg Testing (May 2007) x

6094 Unit 2 Hg Certification (Nov 2008) x

6094 Unit 2 Hg Certification (Nov 2009) x

6094

Unit 3 Hg Certification 1 (Nov 

2008) x

6094

Unit 3 Hg Certification 2 (Nov 

2008) x

6094 Unit 3 Hg Testing (Jul 2005) x

6101

Mercury CEM Certification Testing 

2008 x

6101 Mercury CEM RATA Testing 2009 x

6136 1 x

6146

13b-Multi-Method Hg 

Speciation\Acid Gas for Unit 2 x x

6146

4-Optimizing ACI for Mercury 

Emission Control x x

6165 PST2008HGU1 x

6165 PST2009HGU3 x

6165 PST2009HHU2 x

6170 PPPP-Hg-U1-01.2007 x

6170 PPPP-Hg-U2-5.2007 x

6178 Stack- 6/06 x

6178 Stack-8/08 x

6193

Sorbent Injection for Mercury 

Control x

6194 Sorbent Injection for Mercury x
Table A-1. Excluded Test Reports

17

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

Control at Tolk Sta

6195 Hg Emissions\181-015 x

6204 Pre-Sorbent Injection Evaluation 1 x

6204 Pre-Sorbent Injection Evaluation 2 x

6204 U2 Mercury Emissions Report x

6204 U3 Mercury Test Report x

6249 W1LME2008 x x

6249 W2LME2008 x x

6249 W3LME2008 x x

6249 W4LME2008 x x

6257

30B and Ontario Hydro Single 

Point Test Results x

6257

Mercury Emission Results Unit 2; 

Jan 2009 x

6257

Unit 3 Baghouse Performance (Hg 

only) x

6288 001 x

6481 Hg CEM Acceptance Test x

6772 Hg-2005 x

6823 Baseline Mercury Test Study x

8002 NT-x9-113-PM x

8042 UNIT1(8/24/09) x

8042 UNIT1(9/11/08) x

8042 UNIT1(9/12/08) x

8042 UNIT2(10/21/08) x

8042 UNIT2(8/26/09) x

8042 UNIT2(9/10/08) x

8042 UNIT2(9/9/08) x

8069 U1 Mercury CEM Certification Test x

8069

Unit 2 Mercury CEMS Certification 

Test x

8222 Mercury Emission Test x

8226 CH-63 x
Table A-1. Excluded Test Reports

18

Facility ID 

(ORIS 

Code)

Report ID Provided by 

Respondent

Emission 

rate w/o 

process 

data

Concentration 

w/o flue gas 

parameters

Test data prior 

current 

emission 

controls

Included in 

current output

Test data from 

old 

configuration

Yellowstone 

Energy

10113 2009 Hg 1 x

10113 2009 Hg 2 x

10675 4 x x

10675 5 x x

10675 6 x x

10784 2008 RATA x

10784 2009 RATA x

50039 1 x

50039 3 x

50879 StackTest-1 x

50879 StackTest-2 x

50931 2/15/05 to 2/17/05 testing x

54626 6 x x