Final Report 

Emissions Compliance Demonstration 

For System 13A, and the 

Deep Bed Carbon Scrubber 

(Class II Air Quality Operating Permit No. AP1041-0158.02 and 

the Nevada Mercury Control Program) 

Marigold Mining Company. 

Valmy, Nevada 

Prepared for: 

Marigold Mining Company 

P.O. Box 160 

Valmy, Nevada 89438

Prepared by: 

TRC Companies, Inc. 

6672 Boulder Highway, Suite 5 

Las Vegas, Nevada 89122

January 2008
TRC Project No. 153627 

January 2008 

Final Report 

Emissions Compliance Demonstration 

For System 13A, and the Deep Bed Carbon Scrubber 

(Class II Air Quality Operating Permit No. AP1041-0158.02 and the Nevada 

Mercury Control Program) 

Marigold Mining Company 

Valmy, Nevada 

Prepared for

Marigold Mining Company. 

P.O. Box 160 

Valmy, Nevada 89438 

Prepared by

TRC Companies, Inc. 

6672 Boulder Highway, Suite 5 

Las Vegas, Nevada 89122 

(702) 437-5800 

DISCLAIMER

This document is intended for use solely by Marigold Mining Company (Marigold) for the specific purposes described 

in the contractual documents between TRC Companies, Inc. (TRC) and Marigold. All professional services performed 

and reports generated by TRC have been prepared for Marigold's purposes as described in the contract. The information, 

statements and conclusions contained in the document have been prepared in accordance with the work statement and 

contract terms and conditions. The document may be subject to differing interpretations and/or may be misinterpreted 

by third persons or entities who were not involved in the investigative or consultation process. TRC therefore expressly 

disclaims any liability to persons other than Marigold who may use or rely upon this document in any way or for any 

purpose.
TABLE OF CONTENTS 

Section Page 

L2008-009 ii 

1.0 INTRODUCTION............................................................................................................. 1

1.1 OVERVIEW ................................................................................................................... 1 

1.2 SCOPE OF WORK......................................................................................................... 2 

2.0 SUMMARY AND DISCUSSION OF RESULTS .......................................................... 5

2.1 TEST PROGRAM OBJECTIVES.................................................................................. 5 

2.2 FIELD TEST CHANGES AND PROBLEMS............................................................... 5 

2.3 PRESENTATION OF RESULTS .................................................................................. 5 

2.3.1 System 13A Carbon Kiln Combustion Exhaust Stack - S2.012A .......................... 5 

2.3.2 System 13A Carbon Kiln Drum Exhaust Stack – S2.013A.................................... 5 

2.3.3 Deep Bed Carbon Scrubber Outlet Stack................................................................ 6 

3.0 PROCESS DESCRIPTION ........................................................................................... 10

3.1 INTRODUCTION ........................................................................................................ 10 

3.2 SAMPLING LOCATIONS .......................................................................................... 10 

3.2.1 System 13A........................................................................................................... 10 

3.2.2 Deep Bed Carbon Scrubber System...................................................................... 10 

4.0 SAMPLING PROCEDURES ........................................................................................ 12

4.1 OVERVIEW ................................................................................................................. 12

4.2 FIELD PROGRAM DESCRIPTION ........................................................................... 12 

4.3 PRESAMPLING ACTIVITIES.................................................................................... 13 

4.3.1 Equipment Calibration.......................................................................................... 13 

4.3.2 Glassware Preparation .......................................................................................... 14 

4.3.3 Sample Media Preparation.................................................................................... 15 

4.3.4 Continuous Emissions Monitoring ....................................................................... 15 

4.3.5 Interference Gas Test ............................................................................................ 17 

4.3.6 NO2 to NO Conversion Efficiency ....................................................................... 17 

4.4 ONSITE SAMPLING ACTIVITIES............................................................................ 18 

4.4.1 EPA Methods 1 and 2 for Velocity Measurements and Cyclonic Flow............... 18 

4.4.2 EPA Method 4 for Moisture Determination ......................................................... 18 

4.4.3 EPA Methods 5/202 for Particulate Matter (PM)/PM10 and Condensibles .......... 19 

4.4.4 Determination of the TCEM System Response Time........................................... 22 

4.4.5 Continuous Emissions Monitoring for O2, CO2, NOx, and CO ............................ 22 

4.4.6 EPA Method 9 for Opacity/Visible Emissions ..................................................... 23 

4.4.7 EPA Method 29 for Mercury Emissions............................................................... 23 

4.5 PROCESS MONITORING .......................................................................................... 25 

5.0 ANALYTICAL PROCEDURES AND CALCULATIONS ........................................ 26

5.1 ANALYTICAL PROCEDURES.................................................................................. 26 

5.1.1 Particulate Matter.................................................................................................. 26 

5.1.2 Mercury................................................................................................................. 27 

5.2 CALCULATIONS........................................................................................................ 27 

5.2.1 Flow Rates and Isokinetics ................................................................................... 27 
TABLE OF CONTENTS 

Section Page 

L2008-009 iii 

5.2.2 Grains Per Dry Standard Cubic Foot .................................................................... 30 

5.2.3 Pounds Per Hour ................................................................................................... 30 

5.2.3.1 Particulate Matter............................................................................................. 30 

5.2.3.2 Mercury............................................................................................................ 31 

5.2.3.3 NOx and CO ..................................................................................................... 31 

6.0 QUALITY ASSURANCE .............................................................................................. 32

6.1 OVERVIEW ................................................................................................................. 32

6.2 FIELD QUALITY CONTROL SUMMARY............................................................... 32 

6.2.1 Calibration Procedures.......................................................................................... 32 

6.2.2 Equipment Leak Checks ....................................................................................... 32 

6.2.3 Cyclonic Flow Check............................................................................................ 33 

6.2.4 Calibration Gases.................................................................................................. 33 

6.2.5 Instrument Calibrations......................................................................................... 33 

6.3 DATA REDUCTION, VALIDATION, AND REPORTING ...................................... 33 

6.3.1 Field Data Reduction ............................................................................................ 33 

6.3.2 Data Validation ..................................................................................................... 34 

6.3.3 Data Reporting...................................................................................................... 34 

6.4 EXCEPTIONS .............................................................................................................. 35 

Appendices 

A Field Sampling Data Sheets 

B Field Reduced Data 

C Facility Process Data 

D Laboratory Analytical Data 

E Equipment Calibration Sheets 

TABLES 

Number Page

1-1 Compliance Emissions Test Program Overview .................................................................3 

2-1 Summary of Results for System 13A, Source No. S2.012A ...............................................7 

2-2 Summary of Results for System 13A, Source No. S2.013A ...............................................8 

2-3 Summary of Mercury Emissions Test Results for the Deep Bed Carbon Scrubber ............9 

4-1 Calibration Gas Values and Instrument Ranges ................................................................16 

4-2 Performance Criteria..........................................................................................................17 
TABLE OF CONTENTS 

L2008-009 iv 

FIGURES 

Number Page

4-1 Schematic of EPA Method 5/202 Sampling Train ............................................................20 
L2008-009 1 

1.0 INTRODUCTION 

1.1 OVERVIEW 

Pursuant to the requirements of the Class II Air Quality Operating Permit (AP 1041-0158.02) 

and Nevada Mercury Control Program issued by the State of Nevada Department of 

Conservation and Natural Resources, Division of Environmental Protection (NDEP), Bureau of 

Air Pollution Control, Marigold Mining Company (Marigold) was required to perform emissions 

compliance testing for multiple sources at the Marigold mining facility located in Valmy, 

Nevada. 

TRC Companies, Inc. (TRC) was retained by Marigold to provide sampling and analytical 

support for the emissions compliance test program. TRC supported and managed the test 

program from the Las Vegas, Nevada office. TRC prepared and received approval from NDEP 

for a testing protocol to satisfy the testing requirements stipulated in the operating permit. The 

purpose of the testing was to: 

System 13A – Carbon Kiln Combustion Exhaust Stack - S2.012A 

- Determine the emission rate of nitrogen oxides (NOx) and carbon monoxide (CO) in 

regards to limits in the operating permit; and

- Determine compliance with visible emission standard limitations of the operating permit. 

System 13A – Carbon Kiln Drum Exhaust Stack – S2.013A 

- Determine the emission rate of particulate matter (PM) and particulate matter equal to or 

less than an aerodynamic diameter of nominally 10 μm (PM10); 

- Determine the emission rate of carbon monoxide (CO) in regards to limits in the 

operating permit; 

- Establish mercury emission rates for the source; and 

- Determine compliance with visible emission standard limitations of the operating permit. 

Deep Bed Carbon Scrubber Outlet Stack (Control for; the retort, electrowinning cells 
L2008-009 2 

(3), pregnant and barren tanks, and the smelting furnace). 

- Establish mercury emission rates for the source individual sources (pregnant and barren 

tanks, electrowinning cells (3), retort, and smelting furnace) controlled by the Deep Bed 

Carbon Scrubber. 

Sampling and analysis procedures described in this document were conducted using procedures 

deemed acceptable by the NDEP. TRC was responsible for the collection and analysis of all flue 

gas samples. 

1.2 SCOPE OF WORK 

The purpose of the test program was to determine the emission rates and visible emissions for 

each parameter included in the operating permit for the identified emission units. Triplicate test 

runs were conducted for all parameters. Table 1-1 presents a summary of the test parameters, 

test methods and run times. 
L2008-009 3 

TABLE 1-1. COMPLIANCE EMISSIONS TEST PROGRAM OVERVIEW 

Source Test Parameter Test Method 

Run Time 

(minutes) 

System 13A 

Carbon Kiln Combustion Exhaust 

S2.2012A 

NOx, and CO EPA Methods 7E and 10 60 

 Opacity EPA Method 9 6 

System 13A 

Carbon Kiln Drum Exhaust 

 S2.013A 

Flows and Moisture EPA Methods 1 – 4 

 PM/PM10 EPA Method 5/202 96 

 CO EPA Method 10 60 

 Opacity EPA Method 9 6 

 Mercury EPA Method 29 96 

Deep Bed Carbon 

Scrubber Outlet Stack 

(5-scenarios)

Mercury EPA Method 29 96 

Scenario 1 – Electrowinning 

Cells (2), pregnant and barren 

tanks. 

Mercury EPA Method 29 96 

Scenario 2 - Electrowinning 

Cells (2), pregnant and barren 

tanks, and retort. 

Mercury EPA Method 29 96 

Scenario 3 – Electrowinning 

Cells (2), pregnant and barren 

tanks, and smelting furnace. 

Mercury EPA Method 29 96 

Scenario 4 – Electrowinning 

Cells (3), pregnant and barren 

tanks, retort and smelting 

furnace. 

Mercury EPA Method 29 96 
L2008-009 4 

Source Test Parameter Test Method

Run Time 

(minutes)

Scenario 5 – Electrowinning 

Cells (3), pregnant and barren 

tanks. 

Mercury EPA Method 29 96 

The required measurement parameters and test methods to accomplish these test objectives were 

as follows: 

• 40 CFR Part 60, Appendix A, EPA Methods 

· Methods 1 & 2 - Velocity and Flow Rate 

· Method 3/3A - Oxygen and Carbon Dioxide 

· Method 4 - Moisture 

· Method 5 /202 - PM/PM10

· Method 7E - Oxides of Nitrogen 

· Method 9 - Visible Emissions/Opacity 

· Method 10- Carbon Monoxide 

· Method 29 - Mercury 
L2008-009 5 

2.0 SUMMARY AND DISCUSSION OF RESULTS 

2.1 TEST PROGRAM OBJECTIVES 

The purpose of the test program was the following: 

• Demonstrate compliance with the emission rates of nitrogen oxides (NOx) and carbon 

monoxide (CO) listed in the operating permit for the Carbon Kiln Combustion Exhaust 

Stack; 

• Demonstrate compliance with the emission rate of particulate matter (PM) and particulate 

matter equal to or less than an aerodynamic diameter of nominally 10 μm (PM10); and 

carbon monoxide (CO) listed in the Operating Permit for the Carbon Kiln Drum Exhaust; 

• Demonstrate compliance with the visible emission limits in the operating permit for both 

the Carbon Kiln Combustion Exhaust and the Carbon Kiln Drum Exhaust Stack; 

• Establish mercury emission rates for the Carbon Kiln Drum Exhaust and the Deep Bed 

Carbon Scrubber under five separate operating scenarios. 

2.2 FIELD TEST CHANGES AND PROBLEMS 

No problems were encountered, and no field test changes were required during the sampling 

program. 

2.3 PRESENTATION OF RESULTS 

2.3.1 System 13A Carbon Kiln Combustion Exhaust Stack - S2.012A 

Testing of System 13A, Emission Unit S2.012A was conducted on November 14, 2007. 

Triplicate test runs were conducted at the exhaust stack for nitrogen oxides (NOx) and carbon 

monoxide (CO) in accordance with EPA Methods 7E and 10, respectively. In addition, triplicate 

test runs were conducted for visible emissions (opacity) in accordance with EPA Method 9. A 

summary of the test results is presented in Table 2-1. 

2.3.2 System 13A Carbon Kiln Drum Exhaust Stack – S2.013A 

Testing of System 13A, Emission Unit S2.013A was conducted between November 7 and 8, 

2007. Triplicate test runs were conducted at the exhaust stack for PM/PM10, and mercury (Hg) 
L2008-009 6 

in accordance with EPA Methods 5/202, and 29, respectively. In addition, triplicate test runs 

were conducted for visible emissions (opacity) concurrent with the PM/PM10 testing. Triplicate 

test runs for carbon monoxide (CO) were conducted concurrent with the Hg sampling. A 

summary of the test results is presented in Table 2-2. 

 

2.3.3 Deep Bed Carbon Scrubber Outlet Stack 

Testing of Deep Bed Carbon Scrubber Outlet was conducted under five separate operating 

scenarios, described in Table 1-1 above. Triplicate test runs were conducted at the exhaust stack 

for mercury (Hg) in accordance with EPA Method 29. Testing was performed under the first 

operating scenario on November 6, 2007. Testing for operating scenarios 2 through 5 were 

conducted between November 12 and 15, 2007. A summary of the test results is presented in 

Table 2-3. 
Source/Test Parameters Results Units Emission Limit

(Average of three test runs)

Carbon Kiln Combustion Exhaust

NOx 0.24 lb/hr 0.73

1.06 tpy 3.18

CO 0.062 lb/hr 0.099

0.27 tpy 0.43

Opacity 0 % 20

Marigold Mining Company

Valmy, Nevada

Table 2-1

Summary of Results

System 13A, Source No. S2.012A

November 14, 2007
Source/Test Parameters Results Units Emission Limit

(Average of three test runs)

Carbon Kiln Drum Outlet

PM/PM10 0.042 lb/hr 0.095

0.18 tpy 0.42

CO 0.66 lb/hr 1.53

2.90 tpy 6.68

Opacity 0 % 20

Mercury (Hg)

Hg (particle bound) 0.83 ug

8.05E-07 lb/hr NA

Hg (gaseous) 8.62 ug

8.32E-06 lb/hr NA

Hg (Total) 9.45 ug

9.13E-06 lb/hr NA

Marigold Mining Company

Valmy, Nevada

Table 2-2

Summary of Results

System 13A, Source No. S2.013A

November 7, 2007

November 8, 2007
Scenario No./Date Parameters Results Units

(Average of three test runs)

Scenario 1 (Condition 0) Mercury (Hg)

November 6, 2007 Hg (particle bound) 2.23 ug

3.34E-06 lb/hr

Hg (gaseous) 8.72 ug

1.33E-05 lb/hr

Hg (Total) 10.9 ug

1.66E-05 lb/hr

Scenario 2 (Condition 1) Mercury (Hg)

November 12, 2007 Hg (particle bound) 0.48 ug

6.97E-07 lb/hr

Hg (gaseous) 7.45 ug

1.09E-05 lb/hr

Hg (Total) 7.93 ug

1.16E-05 lb/hr

Scenario 3 (Condition 2) Mercury (Hg)

November 13, 2007 Hg (particle bound) 12.50 ug

3.95E-05 lb/hr

Hg (gaseous) 59.75 ug

1.90E-04 lb/hr

Hg (Total) 72.25 ug

2.29E-04 lb/hr

Scenario 4 (Condition 3) Mercury (Hg)

November 14, 2007 Hg (particle bound) 17.93 ug

5.43E-05 lb/hr

Hg (gaseous) 62.88 ug

1.91E-04 lb/hr

Hg (Total) 80.82 ug

2.45E-04 lb/hr

Scenario 5 (Condition 4) Mercury (Hg)

November 15, 2007 Hg (particle bound) 0.73 ug

1.07E-06 lb/hr

Hg (gaseous) 7.79 ug

1.14E-05 lb/hr

Hg (Total) 8.52 ug

1.25E-05 lb/hr

Marigold Mining Company

Valmy, Nevada

Table 2-3

Summary of Mercury Emissions Test Results

Deep Bed Carbon Scrubber
L2008-009 10 

3.0 PROCESS DESCRIPTION 

3.1 INTRODUCTION 

Marigold Mining Company operates a gold producing mine on property located four miles south 

of I-80 (Exit 216) in Valmy, Nevada. There are several processing facilities located on the 

property which separate the gold from the ore. Part of this mining process utilizes Systems 2, 3, 

13A, and the Deep Bed Carbon Scrubber.

3.2 SAMPLING LOCATIONS 

The procedures specified by EPA Method 1, "Sample and Velocity Traverses for Stationary 

Sources", were followed to determine the number and location of traverse points to be used for 

the stratification testing and velocity traverses. The number of straight run stack diameters 

(equivalent diameters) upstream and downstream from the sample ports were used to determine 

the minimum number of traverse points required. 

Additional detail is provided for each system in Appendix A of this Final Report, including 

diameters upstream and downstream, internal diameters of each exhaust stream, sampling point 

locations and distances, and photographs of sampling locations. 

3.2.1 System 13A 

System 13A includes two separate stacks for the carbon kiln system which is a Lockheed 

Haggerty Engineering and Manufacturing Company, Ltd. Emission unit S2.012A represents the 

carbon kiln combustion emissions which are uncontrolled and discharge to a horizontal stack 

with an internal diameter of 15 inches. Emission unit S2.013A represents the carbon kiln drum 

emissions which are controlled with a Venturi scrubber/carbon scrubber system and discharge to 

a horizontal stack with an internal diameter of 7.5 inches. 

3.2.2 Deep Bed Carbon Scrubber System 

The Deep Bed Carbon Scrubber System includes one deep bed carbon scrubber outlet that 
L2008-009 11 

controls emissions from several thermal units. The outlet stack is vertical with an internal 

diameter of 9.5 inches. 
L2008-009 12 

4.0 SAMPLING PROCEDURES 

4.1 OVERVIEW 

This section describes the procedures that TRC followed during the field sampling program. 

Throughout the program TRC followed EPA Methods 40 CFR Part 60 Appendix A sampling 

procedures. 

The remainder of this section is divided into several subsections: Field Program Description; 

Pre-sampling Activities; and Onsite Sampling Activities. 

4.2 FIELD PROGRAM DESCRIPTION 

The field sampling program was conducted by TRC over a two week period. On the first day 

equipment was set up and preliminary measurements were made. On the following days, TRC 

collected samples for the parameters listed below on the permitted units: 

O2, CO2, NOx, CO, PM, PM10

Velocity and Percent Moisture 

Mercury 

Visible Emissions 

TRC personnel used the following EPA Methods as listed in 40 CFR Part 60, Appendix A. 

• EPA Method 1 Sample Velocity Traverse for Stationary Sources 

• EPA Method 2 Determination of Stack Gas Velocity and Volumetric Flow 

 Rate (Type S pitot tube) 

• EPA Method 3/3A Determination of Oxygen and Carbon Dioxide 

 Concentrations in Emissions from Stationary Sources 

 (Instrumental Analyzer Procedure) 

• EPA Method 4 Determination of Moisture Content in Stack Gases 

• EPA Methods 5/202 Determination of PM10 and Condensible Particulate 

 Emissions Particulate Emissions from Stationary 

 Sources
L2008-009 13 

• EPA Method 7E Determination of Nitrogen Oxides Emissions from 

 Stationary Sources (Instrumental Analyzer Procedure) 

• EPA Method 9 Visual Determination of the Opacity of Emissions from 

 Stationary Sources 

• EPA Method 10 Determination of Carbon Dioxide Emissions from 

 Stationary Sources (Instrumental Analyzer Procedure) 

• EPA Method 29 Determination of Metals Emissions from 

 Stationary Sources 

4.3 PRESAMPLING ACTIVITIES 

Presampling activities included equipment calibration, precleaning of the sample train glassware, 

and other miscellaneous tasks. Each of these activities are described or referenced in the 

following subsections. Other presampling activities included team meetings, equipment packing, 

and finalization of all details leading up to the coordinated initiation of the sampling program. 

4.3.1 Equipment Calibration 

TRC follows an orderly program of positive actions to prevent the failure of equipment or 

instruments during use. This preventative maintenance and careful calibration helps to ensure 

accurate measurements from field and laboratory instruments. 

Once the equipment had gone through the cleaning and repair process it was then calibrated. All 

equipment that was scheduled for field use was cleaned and checked prior to calibration. Once 

the equipment had been calibrated, it was packed and stored to ensure the integrity of the 

equipment. 

Inspection and calibration of the equipment is a crucial step in ensuring the successful 

completion of the field effort. All equipment was inspected for proper operation and durability 

prior to calibration. Calibration of the following equipment was conducted in accordance with 

the procedures outlined in EPA documents entitled "Quality Assurance Handbook for Air 

Pollution Measurement Systems; Volume III - Stationary Source Specific Methods" (EPA-600/4-
L2008-009 14 

77-027b) and 40 CFR Part 60 Appendix A. All calibrations were performed prior to the test 

program. 

• Probe Nozzles (QA Handbook, Vol III, Section 3.4.2, pp. 19) - average three 

internal diameter measurements of the nozzle; difference between high and low 

0.1 mm. Recalibrated, reshaped and sharpened when nozzle became nicked, 

dented or corroded. 

• Pitot tubes (QA Handbook Vol III, Section 3.1.2, pp. 1-13) - measured for 

appropriate spacing and dimensions or calibrated in a wind tunnel. Rejection 

criteria is given on the calibration sheet. A post-test check inspected for damage. 

• Thermocouples (QA Handbook, Vol III, Section 3.4.2, pp. 12-18) – verified 

 against a mercury-in-glass thermometer at three points including the anticipated 

 measurement range. Acceptance limits - impinger + 2oF; DGM + 5.4oF; stack +

1.5 percent of stack temperature. 

• Dry gas meters (EPA 40 CFR Part 60, Method 5, Section 5.3) - calibrated against 

 a wet test meter. Acceptance criteria - pretest Yi = Y = + 0.02; post test Y = + 

 0.05 Yi. 

• Orifice meter calibrated against a wet test meter. Acceptance criteria is ∆H@i = 

+ 0.2 from the average value. 

• Field barometer (QA Handbook, Vol III, Section 3.4.2, pp. 18-19) – compared 

 against a mercury-in-glass barometer or use Airport Station BP and corrected for 

 elevation. Acceptance criteria -  0.02 in. Hg; post-test check was the same. 

• Analytical balances (QA Handbook, Vol III, Section 3.4.2, pp. 19) – Acceptance 

 criteria - calibrated with Standard Class-S weights within 0.5 mg of stated value. 

 Corrective action: Have manufacturer recalibrate or adjust. 

4.3.2 Glassware Preparation 

Sample train glassware required specialized precleaning to avoid contamination of the sample 

from the collection container or devices. The sample train glassware necessary for the EPA 

Methods 5/202 sampling trains was precleaned using an Alconox® soap and water wash. 

Acetone was used for rinsing followed by air-drying. The glassware was then rinsed with 

methylene chloride followed again by air-drying. The glassware was then sealed with Parafilm®. 

 

The sample train glassware necessary for the EPA Method 29 sampling trains was precleaned 
L2008-009 15 

using an Alconox® soap and water wash. Deionized water was used for rinsing followed by airdrying. The glassware was then soaked in nitric acid bath (10% nitric acid) followed again by a 

deionized water rinse followed by air-drying. The glassware was then sealed with Parafilm®. 

4.3.3 Sample Media Preparation 

All reagents were checked in accordance with the TRC’s existing QC Program to minimize the 

probability of using contaminated solvents. This included the use of spectro-grade solvents from 

the same lot and the collection and analysis of the appropriate blanks. All filters were desiccated 

and weighed to the nearest 0.5 mg constant weight. 

4.3.4 Continuous Emissions Monitoring 

TRC conducted continuous emissions monitoring for oxygen (EPA Method 3A), carbon dioxide 

(EPA Method 3A), oxides of nitrogen (EPA Method 7E), and carbon monoxide (EPA Method 

10). TRC followed procedures outlined in the EPA Publication 340/1-83-016 regarding setup 

and operation of its Transportable Continuous Emissions Monitoring System (TCEMS). 

The TCEMS consisted of three subsystems: sample acquisition/conditioning, sample analysis, 

and a data acquisition system. Sample acquisition/conditioning is designed to deliver a 

representative sample of the gas stream to the sample analysis subsystem. Since the stream must 

be clean and dry for O2, CO2, NOx, and CO analyzers, a glass fiber filter and noncontact 

moisture condenser were used for particulate and moisture removal. The sample line was heat 

traced to eliminate inline condensation prior to the condenser. 

In each case, accurate interpretation of analyzer response required the systematic calibration of 

the instrument against gases of known concentrations. 

The data acquisition subsystem consisted of a digital data logger designed to receive and log 

instrument signals (raw voltages) at user-defined intervals. Once the system was set up, the 

TCEM was connected to a power source and brought online. Sample line and signal wires were 

strung between the sampling and TCEM locations, and the probe was placed in the sampling port 
L2008-009 16 

at the sampling location. 

Prior to insertion of the probe into the sampling location, the sample/acquisition system was leak 

checked by the following procedure: 

a. plugged probe; 

b. observed that flow in rotameter reached zero lpm; 

c. observed vacuum; and 

d. confirmed that sample vacuum during sampling did not exceed vacuum 

attained during leak check. 

The initial phase of instrumental analysis methods requires calibration of all involved monitors. 

At the beginning of each day, system instrument calibrations for zero and upscale gases were 

performed prior to initiation of testing by system calibration gas injection. System calibrations 

were performed both prior to and following each run using a zero and one upscale gas 

concentration. This was accomplished by directing calibration gas through the sample line and 

conditioning system to assess system bias. Following completion of the required runs, final 

system calibrations were performed. These procedures allowed for determination of initial and 

final system calibration error, as well as system drift. Typical calibration gas values and 

instrument range settings are listed in Table 4-1. 

Calibration gases used were EPA Protocol 1, traceable to the National Institute of Standards and 

Technology (NIST). The measurement system performance specifications as stated in 40 CFR 

60 Appendix A, for Methods 3A, 7E, and 10 are listed in Table 4-2 and were the performance 

criteria for this program. 

TABLE 4-1. CALIBRATION GAS VALUES AND INSTRUMENT RANGES 

Analyzer Range Conc. High Mid Low Zero

NOx 0 - 120 ppm 111.0 51.9 N/A nitrogen 

CO 0 – 100 

0 - 500 

ppm 

ppm 

85.6 

472.00 

40.00 

249.00 N/A nitrogen 

CO2 0 – 20 % 18.17 9.95 N/A nitrogen 

O2 0 - 25 % 22.15 10.02 N/A nitrogen 
L2008-009 17 

TABLE 4-2. PERFORMANCE CRITERIA 

Procedure Performance Criteria 

O2/CO2

M3A

NOx

M7E

CO 

M10

Zero Drift, % of range < ± 3 < ± 3 < ± 3 

Calibration Drift, % of 

range 

< ± 3 < ± 3 < ± 3 

Response time, seconds 60 60 60 

Interference Response, % of 

range 

< ± 2 < ± 2 < ± 2 

NO2 to NO Converter, % 

efficiency NA > 98 NA 

Calibration Error, % of cal 

gas 

< ± 2 < ± 2 < ± 2 

4.3.5 Interference Gas Test 

Before mobilizing for the field portion of this program, the NOx analyzer was checked for 

interference using the following gases: 

Gas Concentration

Carbon monoxide 500 ± 50 ppm 

Oxygen 20.9 ± 1 percent 

 Carbon Dioxide 10 ± 1 percent 

Sulfur Dioxide 200 ± 20 ppm 

Corrections to the measurement system or analyzer were made if the performance specifications 

were not met. 

4.3.6 NO2 to NO Conversion Efficiency 

Before mobilizing for the field portion of this program, the NO2 to NO converter was checked in 

accordance with the procedures of section 8.2.4 of EPA Method 7E. 
L2008-009 18 

4.4 ONSITE SAMPLING ACTIVITIES 

Onsite sampling activities included the emissions testing of the previously mentioned outlet 

stacks and collection of operational data. 

4.4.1 EPA Methods 1 and 2 for Velocity Measurements and Cyclonic Flow 

Velocity traverses were conducted on the outlet stacks with an S-type pitot assembly in 

accordance with EPA Reference Methods 1 and 2. An S-type pitot tube with an attached 

inclined manometer was used to measure the exhaust velocities from the sampling location. An 

attached Type-K thermocouple with remote digital display was used to determine the flue gas 

temperature. During the test program, velocity measurements were conducted during each EPA 

Methods 201A/202 sampling test run. The required number of velocity measurements points for 

each sampling location was determined following EPA Method 1. 

Cyclonic flow checks were conducted at each sampling location in accordance with Section 2.4 

of EPA Method 1. This procedure is referred to as the nulling technique. An S-type pitot tube 

connected to an inclined manometer was used in this method. The pitot tube was positioned at 

each traverse point so that the face openings of the pitot tube were perpendicular to the stack 

cross-sectional plane. This position is called the "0° reference". The velocity pressure (ΔP) 

measurement was noted. If the ΔP reading was zero, the cyclonic angle was recorded as 0°. If 

the ΔP reading was not zero, the pitot tube was rotated clockwise or counter clockwise until the 

ΔP reading became zero. This angle was then measured with a leveled protractor and reported to 

the nearest degree. After this null technique was applied at each traverse point, the average of 

the cyclonic angles was calculated. If this average was less than 20°, the flow condition is 

acceptable to test. 

4.4.2 EPA Method 4 for Moisture Determination 

Moisture was determined for each test run according to EPA Reference Method 4, 

"Determination of Moisture Content in Stack Gases". The principle of this method is to remove 

the moisture from the sample stream and determine moisture either volumetrically or 
L2008-009 19 

gravimetrically. Sampling was conducted in conjunction with the particulate matter and/or 

mercury emissions sampling test runs. 

4.4.3 EPA Methods 5/202 for Particulate Matter (PM)/PM10 and Condensibles 

Particulate matter (PM) and particulate matter equal to or less than an aerodynamic diameter of 

nominally 10 μm (PM10) was determined according to EPA Method 5, "Determination of 

Particulate Emissions from Stationary Sources" (40 CFR Part 60 Appendix A) and Method 202 

(40 CFR Part 61, Appendix M). Sampling was conducted for three 96 minute test runs. 

The sampling train consisted of a probe, quartz-liner, and a quartz or stainless steel button-hook 

nozzle. A thermocouple and S-type pitot tube were attached to the probe for the measurement of 

gas temperature and velocity. The sample gas passed through the probe assembly to a heated 

glass filter holder assembly containing a quartz fiber filter and a Teflon® frit support. The filter 

holder was maintained at 248oF ± 25oF throughout each test run. Downstream of the heated 

filter, the sample gas passed through a series of four ice-cooled impingers kept below 68oF to 

enable condensation of entrained moisture. The first two impingers contained 100 mL of 

deionized water. The third impinger was empty. The fourth impinger contained a preweighed 

amount of silica gel. The impingers were followed by a dry gas meter, pump, and a calibrated 

orifice meter. 

Sampling will be isokinetic (± 10 percent) with readings of flue gas parameters recorded at every 

sampling point during the traverse. 

Leak checks of the entire Method 5/202 sampling train were performed before and after each 

sampling run. All leak checks and leakage rates were documented on the relevant field test data 

sheets. The acceptance criterion for the Method 5/202 train was a leak rate of ≤ 0.02 cfm at the 

highest vacuum obtained during the test run. 

L2008-009 21 

Following the completion of each test run, the Method 5/202 train was transported to a recovery 

area onsite. The impinger contents were purged with nitrogen to remove dissolved sulfur 

dioxide and the recovery sequence proceeded as follows: 

● Removed the sampling train to the recovery area. 

● Noted the condition of the train (i.e., filter condition, impinger contents color, 

silica gel color, etc.). 

● Disassembled the filter housing and transferred the filter to its original petri dish. 

Sealed the container with Teflon® tape and labeled it with the appropriate sample 

information. 

● The front half of the train, nozzle, probe, and front-half filter housing were brushrinsed with acetone into an amber glass container with a Teflon®-lined cap. The 

rinse procedure was performed three times after which the container was sealed 

and labeled. 

● The impinger contents were purged with nitrogen and afterwards, the contents of 

the first three impingers were measured for volume and the contents were 

collected in an amber glass container with a Teflon®-lined cap. 

● The back-half of the filter holder, probe, impingers, and connecting glassware 

were rinsed three times with methylene chloride (MeCl2) into a separate amber 

glass container with a Teflon®-lined cap. 

● The silica gel was returned to its original container and weighed to obtain a final 

weight. 

● All containers were checked to ensure proper sealing, proper labeling, and that all 

liquid levels were marked. 

● All samples were logged onto a chain-of-custody form. 

The filter, front, and back-half rinses were used to determine PM concentrations. The impinger 

catches (impingers 1 thru 4) were also used to determine moisture and condensable material. 

The Method 5/202 train produced the following samples: 

● Container No. 1 - Filter 

● Container No. 2 - Front-Half Acetone Rinse 
L2008-009 22 

● Container No. 3 - Impinger Catches 

● Container No. 4 - Back-Half Methylene Chloride Rinse 

4.4.4 Determination of the TCEM System Response Time 

After the TCEM system was set up, the response time was determined. Zero gas was introduced 

at the TCEM system calibration gas valve assembly until a stable zero response was achieved. 

Once achieved, the calibration gas valve at the probe was switched to the effluent. Time of the 

response to a stable effluent response was recorded. This upscale response was conducted one 

time. A downscale response time was also conducted one time starting at a high span calibration 

value and switching to the effluent.

4.4.5 Continuous Emissions Monitoring for O2, CO2, NOx, and CO 

TRC conducted a series of three 1-hour test runs using EPA Methods. Emissions testing was 

conducted for oxygen (EPA Method 3A), carbon dioxide (EPA Method 3A), oxides of nitrogen 

(EPA Method 7E), and carbon dioxide (EPA Method 10) for the applicable Systems. Single 

point sampling was conducted. 

 

The CEM system sampling was conducted at a single point located at the centroid of the stack. 

The CEMS sampling train started with a stainless-steel sampling probe. The sample stream was 

then drawn through a glass fiber filter, heated (248°F ± 25°F) Teflon® sample line, and a sample 

conditioner to remove the moisture and particulate from the gas stream. The sample was then 

drawn through Teflon® tubing by a leak-free Teflon® double diaphragm pump to a stainless-steel 

sample manifold with and atmospheric by-pass rotometer. The O2, CO2, NOx, and CO analyzers 

withdrew samples from this manifold. 

All CEMS data was recorded as averages by a digital data logger designed to receive and log 

instrument signals. The results were expressed in ppm for NOx and CO and in percent for O2

and CO2. 
L2008-009 23 

4.4.6 EPA Method 9 for Opacity/Visible Emissions 

Three 6-minute runs were conducted on each applicable source for visible emissions utilizing 

EPA Method 9, “Visual Determination of the Opacity of Emissions from Stationary Sources.” 

Visible emissions tests were conducted concurrent with the PM/PM10 test runs. 

The applicable sources tested included the following: 

• System 13A – Carbon Kiln System (2 stacks) 

A certified Method 9 observer conducted these tests during the compliance testing. Opacity 

determination took place concurrently with the particulate matter testing. 

4.4.7 EPA Method 29 for Mercury Emissions 

Mercury (Hg) was determined via EPA Method 29 “Metals Emissions from Stationary Sources”. 

 

The applicable sources tested included the following: 

• Carbon Kiln Drum System; and 

• Deep Bed Carbon Scrubber 

The sampling train utilized the EPA Method 29 sampling configuration and consisted of a quartz 

button-hook nozzle, quartz lined heated probe, and heated filter housing. A thermocouple and Stype pitot tube were attached to the probe for the measurement of gas temperature and velocity. 

The sample gases passed through the probe and filter assembly which were connected to an 

impinger train. The impinger train consisted of a series of six-ice bath cooled impingers, kept 

below 68°F to enable condensation of entrained moisture and the gaseous mercury species. The 

first and second impingers each contained 100 mL of a 5% HNO3/10% H2O2 solution. The third 

impinger was empty to separate the two chemical solutions. The fourth and fifth impingers each 

contained 100 mL of a 4% KMnO4/10% H2SO4 solution. The sixth impinger contained 200 - 
L2008-009 24 

400 grams of silica gel. All filled impingers were weighed prior to placing the impingers in the 

train. The impingers were followed by a leak free pump, dry gas meter, and calibrated orifice 

meter. The second impinger was the standard Greenburg design. The first, third, fourth, fifth 

and sixth impingers were modified Greenburg Smith impingers. No silicone grease was used in 

the train. No silicone grease was used in the train. 

TRC conducted three EPA Method 29 test runs on each source, with each test run having 

duration of 96 minutes. Sampling was isokinetic (±10%) with all stacks and train operating 

parameters recorded at each sampling point. 

Leak checks of the entire EPA Method 29 sampling train were performed before and after each 

sampling run. All leak checks and leakage rates were documented on the relevant field test data 

sheets. The acceptance criterion was a post run leak rate of ≤ 0.02 cfm at the highest vacuum 

obtained during the test run. The pre run leak check criterion was ≤ 0.02 cfm at 15 in Hg. 

Following the completion of each test run, the EPA Method 29 train was transported to a 

recovery area onsite. The sample recovery sequence was as follows: 

• All openings on the probe, inlet to cyclone/or filter holder and impingers were sealed with 

Teflon® tape. 

• The sampling train was removed to the recovery area. 

• The condition of the train was noted (i.e., filter, impinger contents color, silica gel color, 

etc.). 

• Container No. 1 - Disassembled the filter housing and transfered the filter to its original glass 

petri dish. Sealed the petri dish with Teflon® tape and labeled it with the appropriate sample 

information. Any filter fibers adhering to the support gasket were transferred to the petri 

dish. 

• Container No. 2 - The front half of the train, nozzle, probe, and front-half filter housing, 

cyclone and flask were brush-rinsed with 100 mL of 0.1N nitric acid into an amber glass 

container with a Teflon®-lined cap. The container was sealed and labeled. 

• Container No. 3 - The contents of the two 5% HNO3/10% H2O2 impingers were weighed. 

The filter support, backhalf of the filter holder and connecting glassware were rinsed three 

times with 100 mL of 0.1N HNO3 into a glass amber container with a Teflon® lined cap. 
L2008-009 25 

The impingers and connecting glassware were rinsed with 0.1N HNO3. The container was 

sealed and labeled. 

• Container No. 4 - The contents of the third impinger were weighed and transferred to a glass 

amber container with a Teflon®-lined cap. The impinger and U-tubes were rinsed three 

times with a 100 mL portion of 0.1N nitric acid into a sample container. The container was 

sealed and labeled. 

• Container No. 5 (Impingers 4 and 5, H2SO4/KMnO4 Impinger Contents and Rinses) - Dry 

the exterior surfaces of Impingers 4 and 5, then weighed and recorded the weight of each 

impinger (to the nearest 0.5 g). Poured all of the liquid from the two H2SO4-KMnO4

impingers into a glass sample, Container 5. Rinsed the impingers and connecting glassware 

three times with a total of 100 mL of fresh H2SO4/KMnO4 solution and poured into 

Container 5. Similarly, rinsed the impingers and connecting glassware three times with 100 

mL of DI water. Added these rinses to Container 5. The container was sealed and labeled. 

• Container No. 6 - Rinsed the contents of impingers 4 and 5 and connecting glassware with 

25 mL of 8N HCl and transferred the rinsate into Container 6 filled with 200 mL of DI 

water. The container was sealed and labeled. 

• The silica gel impinger was weighed to obtain a final weight. 

• All containers were checked to ensure proper sealing, proper labeling, and that all liquid 

levels were marked. All samples were logged onto a chain-of-custody record. 

The EPA Method 29 train produced the following samples: 

• Container No. 1 - Filter 

• Container No. 2 - Front-Half 0.1N HNO3 Rinse 

• Container No. 3 - Impingers 1 and 2 - 5% HNO3/10% H2O2 Impingers Catch & Rinse 

• Container No. 4 - Impinger 3 - Impinger Catch & Rinse 

• Container No. 5 - Impingers 4 and 5 - H2SO4/KMnO4 Impingers Catch & Rinse 

• Container No. 6 - Impingers 4 and 5 - 8N HCl Rinse 

4.5 PROCESS MONITORING 

 

Marigold facility personnel monitored and recorded all throughput and control data specified in 

Operating Permit (AP 1041-0158.02) during each test run. 
L2008-009 26 

5.0 ANALYTICAL PROCEDURES AND CALCULATIONS 

This section delineates the analytical procedures and calculations that were used by TRC during 

the Compliance Test Program. 

5.1 ANALYTICAL PROCEDURES 

5.1.1 Particulate Matter 

Particulate matter and particulate matter concentrations equal to or less than an aerodynamic 

diameter of nominally 10 μm (PM10) sampling were accomplished by following the procedures 

in EPA Method 5/202. Particulate matter analysis was conducted by TRC. 

The glass fiber filters were desiccated to a constant weight and placed in glass petri dishes and 

sealed with Teflon® tape prior to testing. An identification label was placed on the petri dish. 

The beakers used for the dry down of the acetone rinse were cleaned and dried in and an oven at 

225oF. The beakers were desiccated to a constant weight. 

The front-half acetone rinse was air dried in a tared container and then desiccated and weighed to 

a constant weight. The filter was desiccated and weighed to constant weight. The sum of the net 

weights for the probe wash and filter catch was used to calculate the concentration of filterable 

particulate matter. The net weights for the filterable particulate fraction were reported as 

concentrations in grains per dry standard cubic foot (gr/dscf) and pounds per hour (lbs/hr). 

The back-half DI water reagent and the back-half MeCl2 rinses were combined and extracted 

with MeCl2 to separate the organic and inorganic fractions. The organic and inorganic fractions 

were desiccated and weighed to a constant weight. The organic and inorganic fractions were 

reported as concentrations in grains per dry standard cubic foot (gr/dscf) and pounds per hour 

(lbs/hr). The sum of the organic and inorganic fractions was reported as the total condensable 

particulate. The sum of the filterable and condensable particulate fractions was reported as the 

total PM10. 
L2008-009 27 

5.1.2 Mercury 

At the conclusion of the field effort TRC packaged the mercury (EPA Method 29) emission 

samples and provided delivery to the analytical laboratory. TRC utilized Test America located 

in West Sacramento, California as the laboratory for this program. 

5.2 CALCULATIONS 

5.2.1 Flow Rates and Isokinetics 

Time = T 

Dry Gas Meter, ft3

 = VM 

Pitot ∆P, in. H2O = ∆P 

Orifice ∆H, in. H2O = PM 

Dry Gas Temp In, oF = TMI 

Dry Gas Temp Out, oF = TMO 

Stack Static Pressure, in. H2O = PST 

Stack Temp, oF = TS 

1. DN = Nozzle Diameter, inches 

2. PB = Barometric Pressure, inches Hg 

3. TT = Net Sampling Time, minutes 

4. VM = VM final - VM initial = Sample Gas Volume, ft3

4A. VML = Use only if any final or intermediate leak check rate is over 0.02 cfm 

LI = Leak rate after any given sampling period, cfm 

TLI = Total time of sample period in which leak occurred, minutes 

VML = VM - [(L1 - 0.02) TLI + (L2 - 0.02) TL2 + (L3 - 0.02) TL3 + (L4 - 0.02) TL4] 

5. Average Dry Gas Temperature at meter, oF 

TM = Average TMI + Average TMO

 2 

6. Average Orifice Pressure Drop, inches Hg 

PM = Average ∆H, in. H2O 

 13.6 
L2008-009 28 

7. Volume of dry gas sampled at standard conditions, dscf a

VMSTD = 528 × (Y) × (VM) × (PB + PM)

 29.92 × (TM + 460) 

Y = dry gas meter calibration factor 

8. Total Water Collected 

VW = gm H2O silica gel + gm impinger H2O 

Note: If ml H2O is measured - (ml Η 0.9982 gm/ml) 

9. Volume of water vapor at standard conditions, scfb

VW gas = 0.04715 x VW 

10. Percent moisture in stack gas 

 100 × VW gas 

% M = VMSTD + VW gas 

11. Mole Fraction of dry gas (dimensionless) 

 100 - %M 

MD = 100 

Note: The proper %M must be used in this calculation. The % vapor moisture can never 

be greater than the saturation value at given stack temperature. 

12. Molecular weight of dry stack gas 

MWD = (% CO2 × 0.44) + (% O2 × 0.32) + [(% CO + % N2) × 0.28] 

12a. % Excess Air 

%EA = [(% O2) - 0.5 × (% CO)] × 100 

[(0.264) × (% N2)] - (% O2) + 0.5 × (% CO) 

13. Molecular Weight of wet stack gas 

MW = (MWD × MD) + 18 × (1 - MD) 

14. AS = Stack Area, square inches 
L2008-009 29 

Circular = π

2

2

stack diameter⎟

⎠

⎞ ⎜

⎝

⎛

Rectangular = Length Η Width 

15. PS = Stack Pressure, absolute, inches Hg = PB ± Avg PST 

PST = Stack static pressure 

PST = PST in. H2O

 13.6 

PS = PB ± Average PST 

16. TSavg = Average Stack Temperature 

 

17. SDEavg = ( ΔP) avg

× TSavg + 460

18. Stack gas velocity at stack conditions, afpm 

 VS = 

1/ 2

avg

c

PS MW

1 5130 Cp SDE ⎥

⎦

⎤ ⎢

⎣

⎡

×

× × ×

Cp = pitot tube coefficient 

19. Stack gas volumetric flow rate at stack conditions, acfmd

Qa = VS × AS

 144 

20. Stack gas volumetric flow rate at standard conditions, dscfme

 

Qs = Qa × 528 × MD × PS 

(29.92) × (TSavg + 460) 

21. Percent Isokinetics 

%ISO = 1039f

 × (TSavg + 460) × VMSTD

 VS × TT × PS × MD × (DN)2

a

 = Dry standard cubic feet at 68oF (528oR) and 29.92 in. Hg 

b

 = Standard conditions at 68oF (528oR) and 29.92 in.Hg 

c

 = 5130 = ( ) ( )

( )( ) 60sec/ min

R in.H O

lb/lb - mole in.Hg

sec

85.5 ft

2

⎥ ×

⎦

⎤ ⎢

⎣

⎡

° ×

× 
L2008-009 30 

d

 = Actual cubic feet per minute 

e

 = Dry standard cubic feet per minute at 68oF (528oR) and 29.92 in.Hg 

f

 = 1039 = 29.92 in. Hg 144 in.2 4 

 528oR × ft2 × π × 100 

5.2.2 Grains Per Dry Standard Cubic Foot 

Particulate matter rates in terms of grains per dry standard cubic feet (gr/dscf) were calculated 

using the pollutant rate in terms of milligrams (mg) divided by the volume of gas collected 

(dscf). 

gr/dscf = ( ) ( ) ( )

( ) ⎥

⎦

⎤ ⎢

⎣

⎡

⎭

⎬

⎫

⎩

⎨

⎧

× +

× × × +

× ÷

29.92 TM 460

528 Y VM PB PM 0.0154 mg 

where: 

dscf = Dry standard cubic feet at 68oF (528oR) and 29.92 inches Hg 

 0.0154 = 0.0154 grains per milligram 

Y = Dry gas meter calibration factor 

VM = Volume metered, ft3

PB = Barometric Pressure, inches Hg 

PM = Average Orifice Pressure Drop, inches Hg (Avg. ΔH inches H2O ) 13.6) 

TM = Average Dry Gas Temperature at Meter, oF 

5.2.3 Pounds Per Hour 

5.2.3.1 Particulate Matter 

Rates in terms of pounds per hour (lbs/hr) were calculated using the particulate matter rate in 

terms of grains per dry standard cubic feet (gr/dscf), flowrate - dscfm (Qs), 60 minutes/hour, 

divided by 7,000 grains per pound (gr/lb). 

lbs/hr = gr/dscf × Qs × 60

 7000 
L2008-009 31 

5.2.3.2 Mercury 

Total mercury is defined by the method as the sum of the particulate bound mercury and gaseous 

mercury as shown in the following equation: 

Hg (total), μg/dscm = Hg (particle bound) + Hg (gaseous) 

The following equation was used for each species: 

lb/hr = μg/dscf mercury species x Qs dscfm x 60 min/hour

453.59 x 106 μg/lb 

5.2.3.3 NOx and CO 

Emission rates in terms of pounds per hour (lbs/hr) for NOx and CO were calculated using the 

pollutant emission rate in terms of parts per million (ppm/dry volume), flowrate - dscfm (Qs), 

molecular weight of the pollutant (MW), 60 minutes/hour, divided by 385.3 × 106

 dscf/lb-mole 

@ 68oF (20oC). 

lbs/hr = ppm × Qs × MW × 60

 385.3 × 106

where: 

NOx molecular weight = 46 CO molecular weight = 28 

 
L2008-009 32 

6.0 QUALITY ASSURANCE 

6.1 OVERVIEW 

TRC management is fully committed to an effective Quality Assurance/Quality Control Program 

whose objective is the delivery of a quality product. For much of TRC's work, that product is 

data resulting from field measurements, sampling and analysis activities, engineering 

assessments, and the analysis of gathered data for planning purposes. The Quality Assurance 

Program works to provide complete, precise, accurate, representative data in a timely manner for 

each project, considering both the project's needs and budget constraints. 

This section highlights the specific QA/QC procedures followed for this Test Program. 

6.2 FIELD QUALITY CONTROL SUMMARY 

6.2.1 Calibration Procedures 

Calibration of the field sampling equipment was performed prior to the field sampling effort. 

Copies of the calibration sheets were submitted to the field team leader to take onsite and for the 

project file. Calibrations were performed as described in the EPA publications "Quality 

Assurance Handbook for Air Pollution Measurement Systems; Volume III - Stationary Source 

Specific Methods" (EPA-600/4-77-027b) and EPA 40 CFR Part 60 Appendix A. Equipment to 

be calibrated included the sample metering system, thermocouples, and pitot tubes. All 

calibrations were available for review during the test program. Copies of the equipment 

calibration forms are found in Appendix E. 

6.2.2 Equipment Leak Checks 

Prior to sampling, each Method 5/202 and EPA Method 29 sampling trains were leak checked 

according to the procedures outlined in EPA Reference Method 5. During the course of a test 

run, a leak check was conducted before and after every test, or if replacement of a component 

became necessary. Final leak checks were performed to ensure that no leaks developed in the 

train during the course of the test run. All leakage rates, if any found, were recorded on the 
L2008-009 33 

appropriate field data sheet. 

6.2.3 Cyclonic Flow Check 

The absence of cyclonic flow within the sampling location was verified prior to sampling in 

accordance with Section 2.4 of EPA Method 1. 

6.2.4 Calibration Gases 

All calibration gases used to conduct instrument calibrations were prepared in accordance with 

the EPA Protocol 1, and are traceable to NIST. 

6.2.5 Instrument Calibrations 

All instrument calibrations met the performance criteria defined in 40 CFR 60 Appendix A, 

Methods 3A, 7E, and 10. Any test not meeting these criteria was considered questionable and 

the test run repeated. 

6.3 DATA REDUCTION, VALIDATION, AND REPORTING 

Specific QC measures were used to ensure the generation of reliable data from sampling 

activities. Proper collection and organization of accurate information followed by clear and 

concise reporting of the data is a primary goal in all projects. 

6.3.1 Field Data Reduction 

The standardized forms that were used to record field sampling data are presented in Appendix 

A. The data collected were reviewed in the field by the Field Team Leader and at least one other 

field crew member. Errors or discrepancies were noted in the field book. 
L2008-009 34 

6.3.2 Data Validation 

TRC supervisory and QC personnel use validation methods and criteria appropriate to the type of 

data and the purpose of the measurement. Records of all data were maintained, including that 

judged to be an "outlying" or spurious value. The persons who validated the data have sufficient 

knowledge of the technical work to identify questionable values. 

Field sampling data were validated by the Field Team Leader and/or the QC Coordinator based 

on their review of the adherence to an approved sampling protocol and written sample collection 

procedure. 

The following criteria were used to evaluate the field sampling data: 

● Use of approved test procedures; 

● Proper operation of the process being tested; 

● Use of properly operating and calibrated equipment; 

● Leak checks conducted before and after tests; 

● Proper chain-of-custody maintained. 

The criteria listed below were used to evaluate the analytical data: 

● Use of approved analytical procedures; 

● Use of properly operating and calibrated instrumentation; 

● Acceptable results from analyses of QC samples (i.e., the reported values should 

fall within the 95 percent confidence interval for these samples). 

6.3.3 Data Reporting 

All data has been reported in standard units depending on the measurement and the ultimate use 

of the data. The bulk of the data was computer processed and reported as follows: 
L2008-009 35 

• Exhaust Gas Stream 

- Gas Properties: 

a. Moisture, dscf and percent by volume 

b. Flow rate, dscfm and acfm 

c. Pressure, mm of Hg 

d. Temperature, °F 

- Gas Diluents and Pollutants 

a. O2, percent 

b. CO2, percent 

c. NOx, ppm, and lbs/hr 

d. CO, ppm, and lb/hr 

e. Hg, lbs/hr 

f. PM and PM10, gr/dscf, and lbs/hr 

g. Opacity, % 

6.4 EXCEPTIONS 

Any deviations from this test plan were approved by the NDEP and documented in this final 

report.