# 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 2008TRC 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 Mini ng Company (Marigold) for th e 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 documen t may be subject to differing interpreta tions and/or may be misinterpreted by third persons or entities who were not involved in the i nvestigative or consultation pro cess. 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 CHANGE S AND PROBLEMS............................................................... 5 2.3 PRESENTATION OF RESULTS .................................................................................. 5

2.3.1 System 13A Carbon Kiln Combus tion 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 NO 2 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 Part iculate Matter (PM)/PM 10 and Condensibles .......... 19 4.4.4 Determination of the TCEM System Response Time........................................... 22 4.4.5 Continuous Emissions Monitoring for O 2 , CO 2 , NO x , 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 PROCEDURE S AND CALCULATIONS ........................................ 26
5.1 ANALYTICAL PROCEDURES.................................................................................. 26

5.1.1 Particulate Matter.................................................................................................. 26 5.1.2 Mercury................................................................................................................. 2 7 5.2 CALCULATIONS........................................................................................................ 27

5.2.1 Flow Rates and Isokinetics ................................................................................... 27TABLE 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 NO x 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, VALIDAT ION, 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 Re sults for the Deep Bed Carbon Scrubber ............9 4-1 Calibration Gas Values and Instrument Ranges ................................................................16 4-2 Performance Criteria....................................................................................................... ...17TABLE OF CONTENTS

L2008-009 iv FIGURES

Number Page
4-1 Schematic of EPA Method 5/202 Sampling Train ............................................................20L2008-009 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 Resour ces, 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 pr ogram. TRC supported and managed the test program from the Las Vegas, Nevada office. TRC prepared and receiv ed 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 Comb ustion Exhaust Stack - S2.012A

- Determine the emission rate of nitrogen oxides (NO x ) and carbon monoxide (CO) in regards to limits in the operating permit; and

- Determine compliance with visible emission sta ndard 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 (PM 10 );

- Determine the emission rate of carbon monoxi de (CO) in regards to limits in the operating permit;

- Establish mercury emission rates for the source; and

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

Deep Bed Carbon Scrubber Outl et Stack (Control for; the retort, electrowinning cellsL2008-009 2 (3), pregnant and barren tanks, and the smelting furnace).

- Establish mercury emission rates for the sour ce individual sources (pregnant and barren tanks, electrowinning cells (3), retort, and sm elting furnace) controlled by the Deep Bed
Carbon Scrubber.

Sampling and analysis procedures described in this document we re 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 determin e 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 EMISSI ONS TEST PROGRAM OVERVIEW

Source Test Parameter Test Method Run Time (minutes) System 13A
Carbon Kiln Combustion Exhaust
S2.2012A NO x , 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/PM 10 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 96L2008-009 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 me thods 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/PM 10 · Method 7E - Oxides of Nitrogen · Method 9 - Visible Emissions/Opacity · Method 10- Carbon Monoxide · Method 29 - MercuryL2008-009 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 (NO x ) 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 aerodyna mic diameter of nominally 10 μm (PM 10 ); 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 Ca rbon Kiln Drum Exhaust and the Deep Bed Carbon Scrubber under five separate operating scenarios.

2.2 FIELD TEST CH ANGES 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 fo r nitrogen oxides (NO x ) and carbon monoxide (CO) in accordance with EPA Methods 7E and 10, respectively. In addition, triplicate
test runs were conducted for vi sible 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 conduc ted at the exhaust stack for PM/PM 10 , and mercury (Hg)L2008-009 6 in accordance with EPA Methods 5/202 , and 29, respectively. In addi tion, triplicate test runs were conducted for visible emissions (opacity) concurrent with the PM/PM 10 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 accordan ce with EPA Method 29. Testing was performed under the first operating scenario on November 6, 2007. Testi ng for operating scenarios 2 through 5 were conducted between November 12 and 15, 2007. A summ ary 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, 2007Source/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, 2007Scenario 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 ScrubberL2008-009 10 3.0 PROCESS DESCRIPTION

3.1 INTRODUCTION

Marigold Mining Company operates a gold produci ng mine on property located four miles south of I-80 (Exit 216) in Valmy, Nevada. There ar e several processing facilities located on the property which separate the gold from the ore. Pa rt 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 velo city 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 phot ographs 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 Compa ny, Ltd. Emission unit S2.012A represents the
carbon kiln combustion emissions which are uncont rolled and discharge to a horizontal stack
with an internal diameter of 15 inches. Emi ssion 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 inte rnal diameter of 7.5 inches.

3.2.2 Deep Bed Carbon Scrubber System

The Deep Bed Carbon Scrubber System include s one deep bed carbon scrubber outlet thatL2008-009 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 Me thods 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 T RC over a two week period. On the first day equipment was set up and preliminary measuremen ts were made. On the following days, TRC collected samples for the parameters listed below on the permitted units:

O 2 , CO 2 , NO x , CO, PM, PM 10 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 Tr averse 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 PM 10 and Condensible Particulate Emissions Particulate Emissions from Stationary SourcesL2008-009 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 Ca rbon 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 eq uipment calibration, precleaning of the sample train glassware,
and other miscellaneous tasks. Each of these activities are described or referenced in the following subsections. Other pres ampling activities included team meetings, equipment packing,
and finalization of all details l eading up to the coordi nated initiation of the sampling program.

4.3.1 Equipment Calibration

TRC follows an orderly program of positive acti ons to prevent the failure of equipment or instruments during use. This preventative main tenance and careful calibration helps to ensure accurate measurements from field and laboratory instruments.

Once the equipment had gone throug h the cleaning and repair proce ss 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 st ep in ensuring the successful completion of the field effort. All equipment was inspected for proper operation and durability prior to calibration. Calibra tion 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 calib rations 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 th e nozzle; difference between high and low

 0.1 mm. Recalibrated, reshaped and sh arpened when nozzle became nicked, dented or corroded.

• Pitot tubes (QA Handbook Vol III, S ection 3.1.2, pp. 1-13) - measured for appropriate spacing and dimensions or cal ibrated 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, Me thod 5, Section 5.3) - calibrated against a wet test meter. Acceptance criteria - pretest Y i = Y = + 0.02; post test Y = + 0.05 Y i .

• Orifice meter calibrated ag ainst 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 manuf acturer 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-dr ying. 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 th e EPA Method 29 sampling trains was precleanedL2008-009 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 wa s 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 monitori ng 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 th e EPA Publication 340/1-83-016 regarding setup and operation of its Transpor table Continuous Emissions Mo nitoring System (TCEMS).

The TCEMS consisted of three subsystems: sa mple acquisition/conditioning, sample analysis, and a data acquisition system. Sample acqui sition/conditioning is designed to deliver a representative sample of the gas stream to the sa mple analysis subsystem. Since the stream must be clean and dry for O 2 , CO 2 , NO x , and CO analyzers, a gla ss fiber filter and noncontact moisture condenser were used for particulate an d moisture removal. The sample line was heat traced to eliminate inline condensation prior to the condenser.

In each case, accurate interpretati on of analyzer response required the systematic calibration of the instrument against gases of known concentrations.

The data acquisition subsystem consisted of a dig ital data logger design ed to receive and log instrument signals (raw voltages) at user-defin ed 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 portL2008-009 16 at the sampling location.

Prior to insertion of the probe into the sampling location, the samp le/acquisition system was leak checked by the following procedure:

a. plugged probe; b. observed that flow in ro tameter 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 met hods requires calibration of all involved monitors. At the beginning of each day, system instrument calibrations for zero and upscale gases were performed prior to initiat ion of testing by system calibration gas injection. System calibrations were performed both prior to and followi ng 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. Fo llowing completion of the required runs, final system calibrations were performed. These proce dures allowed for determination of initial and final system calibration error, as well as syst em drift. Typical ca libration gas values and instrument range settings are listed in Table 4-1.

Calibration gases used were EPA Protocol 1, traceab le to the National Institute of Standards and Technology (NIST). The measurement system perf ormance specifications as stated in 40 CFR 60 Appendix A, for Methods 3A, 7E, and 10 are lis ted in Table 4-2 and were the performance criteria for this program.

TABLE 4-1. CALIBRATION GA S VALUES AND INSTRUMENT RANGES

Analyzer Range Conc. High Mid Low Zero
NO x 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

CO 2 0 – 20 % 18.17 9.95 N/A nitrogen
O 2 0 - 25 % 22.15 10.02 N/A nitrogenL2008-009 17 TABLE 4-2. PERFORMANCE CRITERIA

Procedure Performance Criteria
O 2 /CO 2

M3A NO x 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
NO 2 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 NO x 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 analyz er were made if the performance specifications

were not met.

4.3.6 NO 2 to NO Conversion Efficiency

Before mobilizing for the field portion of this program, the NO 2 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 outle t 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 exha ust velocities from the sampling location. An attached Type-K thermocouple with remote digita l 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 require d number of velocity measurements points for each sampling location was determined following EPA Method 1.

Cyclonic flow checks were conducted at each sa mpling 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 perp endicular to the stack cross-sectional plane. Th is position is called the "0 ° reference". The velocity pressure ( Δ P)
measurement was noted. If the Δ P reading was zero, the cycloni c angle was recorded as 0 ° . If
the Δ P reading was not zero, the pitot tube was ro tated clockwise or counter clockwise until the
Δ P reading became zero. This angle was then measur ed 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 orL2008-009 19 gravimetrically. Sampling was conducted in co njunction with the particulate matter and/or mercury emissions sampling test runs.

4.4.3 EPA Methods 5/202 for Particulate Matter (PM)/PM 10 and Condensibles

Particulate matter (PM) and particulate matter e qual to or less than an aerodynamic diameter of nominally 10 μm (PM 10 ) 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 wa s 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 contai ning 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 thr ough 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 empt y. The fourth impinger contained a preweighed amount of silica gel. The impingers were follo wed 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 sampli ng train were performed before and after each sampling run. All leak checks and leakage rates we re 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 Met hod 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, pr obe, and front-half filter housing were brushrinsed with acetone into an ambe r 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 gla ss 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 (MeCl 2 ) into a separate amber glass container with a Teflon ® -lined cap.

● The silica gel was returned to its origin al 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 produ ced the following samples:

● Container No. 1 - Filter

● Container No. 2 - Front-Half Acetone RinseL2008-009 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 conducte d one time starting at a high span calibration value and switching to the effluent.

4.4.5 Continuous Emissions Monitoring for O 2 , CO 2 , NO x , and CO

TRC conducted a series of three 1-hour test runs using EPA Me thods. Emissions testing was conducted for oxygen (EPA Method 3A), carbon di oxide (EPA Method 3A), oxides of nitrogen (EPA Method 7E), and carbon dioxide (EPA Met hod 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 stainles s-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 particulat e 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 atmos pheric by-pass rotometer. The O 2 , CO 2 , NO x , and CO analyzers withdrew samples from this manifold.

All CEMS data was recorded as averages by a di gital data logger design ed to receive and log instrument signals. The result s were expressed in ppm for NO x and CO and in percent for O 2 and CO 2 .L2008-009 23 4.4.6 EPA Method 9 for Opac ity/Visible Emissions

Three 6-minute runs were conducted on each appli cable source for visible emissions utilizing EPA Method 9, “Visual Determination of the Opacity of Emissions from Stationary Sources.”
Visible emissions tests were conduc ted concurrent with the PM/PM 10 test runs.

The applicable sources test ed included the following:

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

A certified Method 9 observer c onducted 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 test ed included the following:

• Carbon Kiln Drum System; and

• Deep Bed Carbon Scrubber

The sampling train utilized the EPA Method 29 sa mpling configuration and consisted of a quartz button-hook nozzle, quartz lined heated probe, a nd 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 fi lter 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 mois ture and the gaseous mercury species. The first and second impingers each contained 100 mL of a 5% HNO 3 /10% H 2 O 2 solution. The third impinger was empty to separate the two chemical solutions. The fourth and fifth impingers each
contained 100 mL of a 4% KMnO 4 /10% H 2 SO 4 solution. The sixth impinger contained 200 -L2008-009 24 400 grams of silica gel. All fille d 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 Gr eenburg 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 sampli ng train were performed before and after each sampling run. All leak checks and leakage rates we re 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, th e 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 an d 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 colo r, silica gel color, etc.).

• Container No. 1 - Disassembled th e filter housing and transfered th e 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 trai n, 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 containe r was sealed and labeled.

• Container No. 3 - The contents of the two 5% HNO 3 /10% H 2 O 2 impingers were weighed. The filter support, backhalf of the filter holde r and connecting glassware were rinsed three times with 100 mL of 0.1N HNO 3 into a glass amber container with a Teflon ® lined cap.L2008-009 25 The impingers and connecting glassware were rinsed with 0.1N HNO 3 . The container was sealed and labeled.

• Container No. 4 - The contents of the third im pinger 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 c ontainer. The container was sealed and labeled.

• Container No. 5 (Impingers 4 and 5, H 2 SO 4 /KMnO 4 Impinger Contents and Rinses) - Dry the exterior surfaces of Impinge rs 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 H 2 SO 4 -KMnO 4 impingers into a glass sample, Container 5. Rinsed the impingers and connecting glassware three times with a tota l of 100 mL of fresh H 2 SO 4 /KMnO 4 solution and poured into Container 5. Similarly, rinsed the impingers and connecting glasswar e three times with 100 mL of DI water. Added these rinses to Cont ainer 5. The container wa s sealed and labeled.

• Container No. 6 - Rinsed the contents of im pingers 4 and 5 and conn ecting 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 prope r sealing, proper labeli ng, 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 HNO 3 Rinse

• Container No. 3 - Impingers 1 and 2 - 5% HNO 3 /10% H 2 O 2 Impingers Catch & Rinse

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

• Container No. 5 - Impingers 4 and 5 - H 2 SO 4 /KMnO 4 Impingers Catch & Rinse

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

4.5 PROCESS MONITORING

Marigold facility person nel monitored and recorded all throughput and cont rol data specified in Operating Permit (AP 1041-0158.02) duri ng each test run.L2008-009 26 5.0 ANALYTICAL PROCEDURE S 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 concentra tions equal to or less than an aerodynamic diameter of nominally 10 μm (PM 10 ) sampling were accomplished by following the procedures
in EPA Method 5/202. Particulate ma tter analysis was conducted by TRC.

The glass fiber filters were desiccated to a consta nt 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 desic cated 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 us ed to calculate the concentration of filterable particulate matter. The net weights for the f ilterable particulate fraction were reported as concentrations in grains per dry standard c ubic foot (gr/dscf) and pounds per hour (lbs/hr).

The back-half DI water reagent and the back-half MeCl 2 rinses were combined and extracted
with MeCl 2 to separate the organic a nd inorganic fractions. The or ganic and inorganic fractions were desiccated and weighed to a constant weig ht. 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 f ilterable and condensable particulat e fractions was reported as the
total PM 10 .L2008-009 27 5.1.2 Mercury

At the conclusion of the field effort TRC p ackaged 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, ft 3 = VM Pitot ∆ P, in. H 2 O = ∆ P Orifice ∆ H, in. H 2 O = PM Dry Gas Temp In, oF = TMI Dry Gas Temp Out, oF = TMO Stack Static Pressure, in. H 2 O = 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, ft 3
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. H 2 O 13.6L2008-009 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 H 2 O silica gel + gm impinger H 2 O

Note: If ml H 2 O is measured - (ml Η 0.9982 gm/ml)
9. Volume of water vapor at standard conditions, scf b

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 valu e at given stack temperature.
12. Molecular weight of dry stack gas
MWD = (% CO 2 × 0.44) + (% O 2 × 0.32) + [(% CO + % N 2 ) × 0.28]

12a. % Excess Air
%EA = [(% O 2 ) - 0.5 × (% CO)] × 100 [(0.264) × (% N 2 )] - (% O 2 ) + 0.5 × (% CO)
13. Molecular Weight of wet stack gas
MW = (MWD × MD) + 18 × (1 - MD)
14. AS = Stack Area, square inchesL2008-009 29 Circular = π 2
2 diameter stack ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

Rectangular = Length Η Width
15. PS = Stack Pressure, absolute, inches Hg = PB ± Avg PST
PST = Stack static pressure

PST = PST in. H 2 O 13.6

PS = PB ± Average PST

16. TS avg = Average Stack Temperature

17. SDE avg = 

# ( ) 460 TS P avg + × Δ avg 18. Stack gas velocity at stack conditions, afpm

VS = 2 / 1

avg c MW PS 1 SDE Cp 5130 ⎥ ⎦ ⎤ ⎢ ⎣ ⎡

× × × × Cp = pitot tube coefficient
19. Stack gas volumetric flow rate at stack conditions, acfm d

Q a = VS × AS 144
20. Stack gas volumetric flow rate at standard conditions, dscfm e
Q s = Q a × 528 × MD × PS (29.92) × (TS avg + 460)

21. Percent Isokinetics

%ISO = 1039 f × (TS avg + 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 = 

## ( ) ( ) ( )( ) min sec/ 60 O H in. R Hg in. mole

- lb/lb

sec ft 85.5

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 × ft 2 × π × 100

5.2.2 Grains Per Dry Standard Cubic Foot

Particulate matter rates in terms of grains per dr y 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 = 

## ( ) ( ) ( ) ( ) ⎥ ⎦ ⎤ ⎢ ⎣ ⎡ ⎭ ⎬ ⎫ ⎩ ⎨ ⎧

+ × + × × × ÷ × 460 TM 29.92 PM PB VM Y 528 mg 0.0154

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, ft 3 PB = Barometric Pressure, inches Hg PM = Average Orifice Pressure Drop, inches Hg (Avg. Δ H inches H 2 O ) 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 th e particulate matter rate in terms of grains per dry standard cubic feet (g r/dscf), flowrate - dscfm (Qs), 60 minutes/hour, divided by 7,000 grains per pound (gr/lb).

lbs/hr = gr/dscf × Qs × 60 7000L2008-009 31 5.2.3.2 Mercury

Total mercury is defined by the method as the su m of the particulate bound mercury and gaseous mercury as shown in the following equation:

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

The following equation was used for each species:

lb/hr = μ g/dscf mercury species x Qs dscfm x 60 min/hour 453.59 x 10 6 μ g/lb

5.2.3.3 NO x and CO

Emission rates in terms of pounds per hour (lbs/hr) for NO x 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 (M W), 60 minutes/hour, divided by 385.3 × 10 6 dscf/lb-mole @ 68oF (20oC).

lbs/hr = ppm × Qs × MW × 60 385.3 × 10 6

where:

NO x molecular weight = 46 CO molecular weight = 28L2008-009 32 6.0 QUALITY ASSURANCE

6.1 OVERVIEW

TRC management is fully committed to an effect ive 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, sa mpling and analysis ac tivities, engineering assessments, and the analysis of gathered data for planning purposes. The Quality Assurance Program works to provide complete, precise, accurat e, 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 pe rformed prior to the field sampling effort. Copies of the calibration sheets were submitted to th e field team leader to take onsite and for the project file. Calibrations were performed as describe d in the EPA publications " Quality Assurance Handbook for Air Pollution Measuremen t Systems; Volume III - Stationary Source Specific Methods " (EPA-600/4-77-027b) and EPA 40 CFR Pa rt 60 Appendix A. Equipment to be calibrated included the sample metering system, thermocouples, and pitot tubes. All calibrations were available for review during th e test program. Copies of the equipment calibration forms are found in Appendix E.

6.2.2 Equipment Leak Checks

Prior to sampling, each Met hod 5/202 and EPA Method 29 sampli ng trains were leak checked according to the procedures outlined in EPA Refere nce Method 5. During the course of a test run, a leak check was conducted before and afte r every test, or if replacement of a component became necessary. Final leak checks were perfor med 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 theL2008-009 33 appropriate field data sheet.

6.2.3 Cyclonic Flow Check

The absence of cyclonic flow within the sampli ng 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 performan ce criteria defined in 40 CFR 60 Appendix A, Methods 3A, 7E, and 10. Any test not meeting these criteria was consid ered questionable and the test run repeated.

6.3 DATA REDUCTION, VALI DATION, 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 reco rd field sampling data ar e presented in Appendix
A. The data collected were reviewed in the fiel d by the Field Team Leader and at least one other field crew member. Errors or discrepa ncies were noted in the field book.L2008-009 34 6.3.2 Data Validation

TRC supervisory and QC personnel use validation me thods and criteria appropr iate to the type of data and the purpose of the measurement. Record s of all data were maintained, including that judged to be an "outlying" or s purious value. The persons who va lidated 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 a nd 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 co mputer 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. O 2 , percent b. CO 2 , percent
c. NO x , ppm, and lbs/hr d. CO, ppm, and lb/hr

e. Hg, lbs/hr f. PM and PM 10 , gr/dscf, and lbs/hr g. Opacity, %

6.4 EXCEPTIONS

Any deviations from this test plan were ap proved by the NDEP and documented in this final report.