Tucson Electric Power 

H. Wilson Sundt 

Irvington Generating Station 

Unit #4 

Compliance/CEMS Test Report 

Test Dates: 06/08-09/11 

By: 

Ed Wadington 

Rafael Guillen, Team Leader 

Energy & Environmental Measurement Corporation (EEMC) 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 

3730 N. Pellegrino Drive, Tucson, Arizona 85749 

Phone: (520) 749-2167 Fax: (520) 749-3582 

1744 Mullowney Lane, Billings, Montana 59101 

Phone: ( 406) 252-4450 Fax: ( 406) 252-6350 
Field Observation Checklist 

Test Discussion !_ncluding: 

Introduction 

Test Chronolog 

CEM Data/Description 

Test Procedures 

Units of Reporting 

Results 

References 

Tabulated: 

Summary Section: 

TABLE OF CONTENTS 

Compliance Statement /Relative Accuracy Summary I Permit Excerpts /Relative 

Accuracy Data Summaries I Data Summaries /Review Certification 

Stack Parameters 

Field Data & Calculations: 

Mid Load: Gas Flow RA; 02/C02 Logger 

Low Load: SOzfNOx/02/C02/Gas Flow/H20 RA; Logger 

High Load: Particulate Emissions I Gas Flow RA; 02/C02 Logger 

CEM Data 

Equipment Calibration 

Instrument Specifications 

Q. C. Outlines 

Test Methods & Train Schematics 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 
Test Dates: 

Plant Name: 

Plant Address: 

Source Tested: 

TEP Contacts: 

FIELD OBSERVATION CHECKLIST 

06/08-09/11 

Tucson Electric Power (TEP) 

H. Wilson Sundt 

Irvington Generating Station 

Unit #4 

3950 East Irvington Road 

Tucson, Arizona 

Unit #4 Emissions Compliance 

Unit #4 CEMS Relative Accuracy Test Audit (RATA) 

Richard Willett 

(520) 237-5947 

RWillett@tep.com 

Mirna Leon -Galligan 

(520) 745-7114 

mgalligan@tep.com 

Observers & Affiliation: Richard Willett - TEP 

Mirna Leon-Galligan - TEP 

EEMC Field Team: 

Dustin Fitzpatrick, Environmental Specialist, 

Pima County DEQ 

Team Leaders: Rafael Guillen 

Robert Carper 

Bret Gray 

George Wilson 

Other Members: 

Energy & Environmental Measurement Corporation (EEMC) 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 

3730 N. Pellegrino Drive, Tucson, Arizona 85749 

Phone: (520) 749-2167 Fax: (520) 749-3582 

1744 Mullowney Lane, Billings, Montana 59101 

Phone: (406) 252-4450 Fax:(406) 252-6350 
INTRODUCTION 

Tucson Electric Power contracted with Energy & Environmental Measurement Corporation (EEMC) 

to conduct a series of compliance emission tests and relative accuracy emission monitor system 

certifications (CEMS) on Tucson Electric Power (TEP) H. Wilson Sundt Irvington Generating 

__ Station Unit #4. The purpose of this report is to outline the sampling and analytical methods 

employed, report field/laboratory data and provide test results. 

TEST CHRONOLOG 

Date/Time Run # 

06L08Lll 

09:41-1 2:01 1-GF thru 9-GF 

09:40-1 2:09 1-H20 thru 2-H20 

09:40-1 2:05 1-9 C0i02 

23:39-23:45 lOGF 

23:37-23:57 1 (3) H20 

23:38-23:58 1 S0202C02NOX 

06L09L11 

00:1 9-04:35 1 1-1 8 GF 

00:16-04:58 2-10 (4-1 1) H20 

00:1 7-04:49 2-9 S0202C02N0x 

16:25-21 :43 1 2PT-1 4PT 

16:25-1 9:16 1-9 GF 

16:26-21 :45 1-5 C02/02 

CEM DATA 

Location 

Unit #4 - Mid Load 

Unit #4- Mid Load 

Unit #4- Mid Load 

Unit #4 - Low Load 

Unit #4 - Low Load 

Unit #4- Low Load 

Unit #4 - Low Load 

Unit #4 - Low Load 

Unit #4 - Low Load 

Unit #4 - High Load 

Unit #4 - High Load 

Unit #4 - High Load 

Test Description(s) 

EPA Methods #1-4 

EPA Method #4 

EPA Method #3A 

EPA Methods #1-4 

EPA Method #4 

EPA Methods #3A,6 C,7E 

EPA Methods #1-4 

EPA Method #4 

EPA Methods #3A,6 C, 7E 

EPA Methods #1-5 

EPA Methods #1-4 

EPA Method #3A 

CEM data for relative accuracy testing was provided by TEP personnel and is included as 

tabulated. 

CEMS Description 

Unit #4 

Manufacturer 

Monitor Labs 

Monitor Labs 

Monitor Labs 

Kurz 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 

Model/Serial # 

9841 AS/M3546-M276 

Chemiluminescence 

9820/01 41 5D/327 8 

Infrared Radiation 

422/01 4200/327 8 

Paramagnetic 

4500 

Species Range 

NOX 0- 500 ppm v /v Dry 

C02 0-25% v/v Dry 

02 0-25% v/v Dry 

Gas Flow wscfh 
Text Page Two 

TEST PROCEDURES 

Tests were conducted at three loads. At the low load, tests were conducted to certify monitors 

for NO,, S02, 02, C02, and Gas Flow. NOx and S02 emissions compliances were also evaluated 

at low load. At the mid load a gas monitor certification was conducted. At the high load, gas 

flow monitor certification was done as well as particulate emissions compliance testing. 

Schematics of the sampling trains are included in the Test Methods section. 

Particulate Emissions Evaluation 

EPA Methods #1 -5!11 were employed for determination of stack flue gas particulate emissions at 

high load. 

The sample train consisted of a stainless steel button-hook nozzle followed by a heated SS pitobe 

assembly (S-type pitot tube and a Type K thermocouple) leading to a heated EPA Type A glass 

fiber filter ( -248 ± 25 °F). The filtered gases were pulled through four Greenberg-Smith 

impingers (1 &2 1 50 ml H20, 3 -empty, 4-silica gel). The filtered and dried gases were then 

pulled, via an umbilical cord, to an RAC type meter box for gas volume metering. 

Upon completion of each test run, moisture percent was determined via gravimetric analysis of 

the impinger liquid gain (moisture determination). Resultant particulate samples were washed 

from the train on site, and removed to the EEMC Tucson, Arizona laboratory for analysis and 

reporting. The first test (run 1 2-PT) exceeded ninety minutes, but the other two tests (runs 13-

PT, 1 4-PT) were sixty-minute tests when it was determined that Method #202 would not be 

employed. 

S02 / NOx I 02 / C02 Relative Accuracy Monitor Certification 

A total of nine twenty-one minute reference tests were conducted at the Unit #4 Exhaust Stack at 

low load. EPA Methods #3A, 6C and 7 EPl standard procedures were employed as outlined 

below. Data was evaluated via EPA Specification 40CFR7 5. The nine twenty-one minute 

reference tests were combined to make three compliance runs to determine S02 and NO, 

emissions compliance. 

NO, Emissions 

EPA Method #7 E was employed for determination of NO, emissions. The stack gases were 

extracted from the gas stream and conveyed to a California Analytical Instruments (CAl) Model 

400 Chemiluminescent Analyzer. A diagram of the sample train is included in the Test Methods 

Section. The monitor was calibrated with NO in N2 Protocol 1 span gases as per the method. 

Results were recorded via an integrating computer/logger on a one-minute basis. A full span 

range of 0 -522.0 ppm v/v was utilized for Unit #4. 

S02 Emissions 

EPA Method #6 C was employed for determination of SO" emissions. An Ametek 7 21 A TM 

Analyzer was utilized for SO" concentration determination. The monitor was calibrated with SO:: 

in N2 Protocol 1 span gases. Results were recorded via an integrating logger on a one-minute 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 
Text Page Three 

TEST PROCEDURES - continued 

S02 Emissions - continued 

basis. A span of 0 -524.0 ppm vlv S02 was utilized. 

C02_LQ2 Emissions 

EPA Method #3Afll was employed for determination of stack gas C02 I 02 concentrations. The 

stack gases were extracted from the stream, and conveyed to Servomex 1 440 Carbon Dioxide 

and Servomex 1 400 Oxygen analyzers. Protocol calibration gases were utilized for instrument 

span checks. Zero was checked with zero N2 gas. Results were recorded via an 

integrating/computer logger on a one-minute basis. A full span of 0 -1 8.6 5% C02 and 0 -20.94% 

02 was utilized. 

Gas Flow - Relative Accuracy Certification 

EPA Methods #1 -4 were employed for determination of reference gas flow (wscfh). Nine 

reference tests were conducted on Unit #4 at all three load levels (high, mid, and low). 

UNITS OF REPORTING 

The data is reported with the following units: 

1) Particulates 

gr/dscf- grains per dry standard* cubic foot (*@29.92 "Hg and 68 °F) 

PPH - pounds per hour 

2) NOX / S02 

ppm vlv dry - parts per million on a volume basis without moisture 

lb/M MBtu - pounds per million British Thermal Units on a 02 basis 

PPH - pounds per hour 

3) co 

ppm vjv dry - parts per million on a volume basis without moisture 

4) C02 I 02 -% vlv - percent on a volume basis 

5) Gas Stream Characteristics 

FPS - feet per second 

A WCFM - actual wet cubic feet per minute 

DSCFH - dry standard* cubic feet per hour 

(*@ 68 °F & 29.92 "Hg) 

5) Gas Stream Characteristics - continued 

SCFH - wet standard* cubic feet per hour 

(*@ 68 °F & 29.92 "Hg) 

Temperature - "F - degrees Fahrenheit 

Moisture - %H20 v/v - percent moisture on a volume basis 

6) Fd - scfiMMBtu (From Plant Data, 02 basis for natural gas) 

7) Gas Flow - scfh- wet standard* cubic foot per hour 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11 
UNITS OF REPORTING - continued 

8) BAF - Bias Adjustment Factor 

Text Page Four 

The resultant data was evaluated via EPA Specificationlll40CFR7 5 and 40CFR60 Specification 

#4A. 

RESULTS 

This report contains summarizations of all pertinent sampling and analytical results. Field and 

laboratory data is included as tabulated or indexed. 

REFERENCES 

ftJ Federal Register, 40CFR6 0, App. A, Methods #1 -5, 3A, 6 C, 7E, 1 9, 

EPA Specifications 40CFR75 App. A, 7/1 /1 0. 

TEP Irvington Unit #4 CEMS, Cmp. 6-8,9-11