Mr. Shawn Jennings July 23, 2010 E. H. & S. Specialist
P.O. Box 159 Grant Town, WV 26574

Subject: Utility MACT ICR Testing Quality Assurance Project Plan; American Bituminous Power Partners; Grant Town Station; Grant Town, West Virginia; Avogadro Environmental Corporation Project No. 10-7091

Dear Mr. Jennings:

Attached please find the Utility MACT ICR Testing Quality Assurance Project Plan for the proposed testing at the above referenced facility and source.

Avogadro looks forward to working with you during this project. Please feel free to contact me or Tom Mattei if there are any questions or comments.

Sincerely,

Janeen D. Maruskanic Air Quality Scientist

F:\2010 Projects\2010 projects\American Bituminous ICR MACT 10-7091\QAPP\final American Bituminous QAPP.docQUALITY ASSURANCE PROJECT PLAN
FOR
UTILITY MACT ICR TESTING OF THE AM ERICAN BITUMINOUS POWER PARTNERS
GRANT TOWN STATION COAL FIRED BOILERS

AMERICAN BITUMINOUS POWER PARTNERS
GRANT TOWN STATION GRANT TOWN, WEST VIRGINIA

Prepared for:
AMERICAN BITUMINOUS POWER PARTNERS
P.O. Box 159 Grant Town, WV 26574 Attn: Mr. Shawn Jennings

Prepared by:
AVOGADRO ENVIRONMEN TAL CORPORATION 1350 Sullivan Trail, Suite A Easton, PA 18040
Attn: Mr. Thomas Mattei

Avogadro Environmental Corporation Project No. 10-7091

July 23, 2010TABLE OF CONTENTS Page No.

1.0 PROJECT OVERVIEW / BACKGROUND INFORMATION 1
1.1 INTRODUCTION 1
1.2 PROGRAM RESPONSIBLE PARTIES 1
1.3 TENTATIVE TEST SCHEDULE 2
1.4 KEY PERSONNEL 3

2.0 SOURCE INFORMATION 4
2.1 FACILITY AND PROCESS DESCRIPTION 4
2.2 PROCESS DATA 4

3.0 SAMPLING LOCATIONS 5

4.0 TEST PROGRAM AND METHODS 6
4.1 TECHNICAL APPROACH 6
4.2 SUMMARY 6
4.3 VELOCITY AND VOLUMETRIC FLOW RATE MEASUREMENT 7 4.4 SULFUR DIOXIDE, CARBON DI OXIDE, CARBON MONOXIDE, OXYGEN, NITROGEN OXIDES, TOTAL HYDROCARBONS AND METHANE
MEASUREMENT 8 4.5 HYDROGEN CHLORIDE, HYDROGEN FLUORIDE, HYDROGEN CYANIDE
AND MOISTURE MEASUREMENT 11 4.6 PARTICULATE MATTER, MULTI-METALS AND MOISTURE
MEASUREMENT 14
4.7 MERCURY MEASUREMENT 17
4.8 PARTICULATE MATTER LESS THAN 2.5 MICRONS AND MOISTURE
MEASUREMENT 19
4.9 FORMALDEHYDE MEASUREMENT 22

5.0 QUALITY ASSURANCE / QUAL ITY CONTROL INFORMATION 25 5.1 TEST EQUIPMENT AND INSTRUMENTATION 25 5.2 CALIBRATION AND HANDLING OF TEST EQUIPMENT AND
INSTRUMENTATION 26
5.3 DATA COLLECTION AND MANAGEMENT 28

6.0 EMISSIONS TEST REPORT 33TABLES

TABLE 1: TENTATIVE SCHEDULE 2
TABLE 2: SAMPLING LOCATIONS SUMMARY 5
TABLE 3: TEST PARAMETERS AND METHODS 6
TABLE 4: REAL-TIME INSTRUMENTATION SUMMARY 9
TABLE 5: REFERENCE METHOD TRAVERSE POINT DETERMINATION CRITERIA 10 TABLE 6: REAL-TIME INSTRUMENTATION FIELD QA PROCEDURES SUMMARY 11
TABLE 7: SUMMARY OF MULTI-METALS DETECTION LIMITS 15

ATTACHMENTS

1 EXAMPLE CALCULATIONS
2 FIELD DATA SHEETS AND CHAIN OF CUSTODY FORM1

1.0 PROJECT OVERVIEW / BACKGROUND INFORMATION

1.1 INTRODUCTION

An emissions test program will be performed at the common outlet of the two coal fired
boilers at the AMERICAN BITUMINOUS POWE R PARTNERS, GRANT TOWN STATION (American Bituminous) facility in Grant Town, West Virginia. The purpose of this test program is to comply w ith the USEPA’s Electrical Utilities Maximum Achievable Control Technology (MACT) In formation Collection Request (ICR).

AVOGADRO ENVIRONMENTAL CORPORATION (Avogadro) has been retained by American Bituminous to perform the emission testing for the boilers. Avogadro has prepared this Quality Assurance Project Plan and will perform the emissions testing program in accordance with this document. Th is plan describes the source, the sampling locations, the technical approach, test me thods, quality assurance items and all other details pertaining to the evaluation.

1.2 PROGRAM RESPONSIBLE PARTIES

Site Address: Contact:
American Bituminous Power Partners Mr. Shawn Jennings
Grant Town Station Telephone: 304-278-6103 Grant Town, WV 26574

Corporate Address: Contact:
American Bituminous Power Partners Mr. Shawn Jennings P.O. Box 159 Telephone: 304-278-6103 Grant Town, WV 26574

Test Firm: Contact: Avogadro Environmental Corporation Mr. Thomas Mattei 1350 Sullivan Trail, Suite A Telephone: 610-559-8776 x 103 Easton, PA 18040 Fax: 610-559-89132

1.3 TENTATIVE TEST SCHEDULE

TABLE 1: TENTATIVE SCHEDULE

Day Weekday parameter Runs

0 Monday Set-up 1 Tuesday Particulate matter, metals and Hg 1&2 Particulate matter, metals and Hg 3 2 Wednesday SO 2 , NO X , and HCl/HF/HCN 1 3 Thursday SO 2 , NO X , and HCl/HF/HCN 2&3 4 Friday Demobilize31.4KEY PERSONNEL4

2.0 SOURCE INFORMATION

2.1 FACILITY AND PROCESS DESCRIPTION

American Bituminous operates a coal refuse fired power plant in Grant Town, West Virginia referred to as the Grant Town Station.

The Grant Town Station generates electri city with the steam supplied from two circulating fluidized bed combustion (CFB) boilers with a maximum rating of 551.9 MMBtu/hr each. The primary fuel is coal refuse supplemented with pond fines. Natural gas is used as a startup fuel.

Limestone is injected directly into the fu rnace combustor for control of sulfur dioxide emissions. High fluidization velocities promote circulation of solids which provides more efficient combustion, emissions control, and heat transfer. Employing limestone as the sorbent material in the fluidized bed removes sulfur dioxide (SO2) at an efficiency of 90
to 94.8%. The addition of limestone to the coal refuse at the combustion chamber is integral to the design and operation of the CFB boilers. Once the sulfurization process has occurred, the remaining calcium sulfate is removed from the boiler in the bottom ash and fly ash streams.

Gases and particulate matter (PM) produced from combustion then move through a hot cyclone where heavy particles and ash are sepa rated from the fine particulate hot exhaust gas. The hot exhaust gases then pass through a baghouse for capture of fine particulates. Both boiler units discharge through a common stack.

The CFB boiler technology produces lower leve ls of nitrogen oxides (NOx) than other combustion technologies. The CFB boilers operate at a relatively low temperature in the combustion zone producing less thermal NOx.

2.2 PROCESS OPERATING DATA

During a 30 day period that will include emissions testing and fuel analysis reporting, the following process information will be collected: total heat input; feed rate (if available); steam output; gross electric output; net electric output; emissions control devices in use during the test; control device operating or monitoring parameters (including, as appropriate to the control device, flue gas flow rate, pressure drop, scrubber liquor pH, scrubber liquor flow rate, sorbent type and sorbent injection rate), and process parameters (such as oxygen). These data will be averaged daily and included in the final report.5

3.0 SAMPLING LOCATIONS

Sample locations will be verified in the field to conform to USEPA Method 1. Acceptable cyclonic flow conditions will be confirmed prior to testing using USEPA Method 1, Section 11.4.

TABLE 2: SAMPLING LOCATIONS SUMMARY

Distance from nearest flow disturbance Sampling
Location Stack ID Downstream
EPA “B” Upstream
EPA “A” Number of
Traverse Points

Outlet 139.5
inches >93 feet (>8 duct diameters) >23.25 feet (>2 duct diameters) Twelve (three per port)6

4.0 TEST PROGRAM AND METHODS

4.1 TECHNICAL APPROACH

The facility will correct daily averages from 30 days of CEM data in lieu of conducting a
NOx and SO 2 stack test. In order to correlate these emissions with other stack test emissions, a portion of the CEMS data will contain emissions data collected during this ICR test. The CEM meets the requirements of Title 40, Code of Federal Regulations, Part 60, (40 CFR 60), Appendix B, Performa nce Specification 2 and ongoing QA/QC requirements of 40 CFR Part 75.

4.2 SUMMARY

The proposed emissions test program will be performed for the parameters specified in Table 4. Three, test runs for the listed pa rameters will be conducted. All test methods proposed for this compliance program conform to 40 CFR 60, Appendix A test procedures or those specified by the USEPA.

TABLE 3: TEST PARAMETERS AND METHODS

Parameters USEPA Test Method Duration (minutes) Reporting Units In-Stack Detection Limit

acfm ---

scfm --- Velocity / Volumetric Flowrate USEPA Methods 1 & 2 60-240

dscfm ---
Carbon Dioxide (CO 2 ) / Oxygen (O 2 ) USEPA Method 3A 60-240 %, dry basis 0.1

Moisture USEPA Method 4 60-240 % 0.02

ppmvd ---
ppmvd @ 7% O 2 --- Sulfur Dioxide (SO 2 ) Plant CEMS 60

lb/MMBTU
--- ppmvd --- ppmvd @ 7% O 2 --- Nitrogen Oxides (NO
x ) Plant CEMS 60

lb/MMBTU
--- ppmvd 1.0 ppmvd @ 7% O 2 0.001 Carbon Monoxide (CO) USEPA Method 10 120

lb/MMBTU 1.1 ppmvd 0.4 ppmvd @ 7% O 2 0.4 Total Hydrocarbons (THC) as

propane USEPA Method 25A 120

lb/MMBTU 0.00077

TABLE 3: TEST PARAMETERS AND METHODS (CONTINUED)

Parameters USEPA Test Method Duration (minutes) Reporting Units In-Stack Detection Limit
ppmvd 1.7 ppmvd @ 7% O 2 1.9 Methane USEPA Method 18 120

lb/MMBTU 0.001 lb/MMBTU (HCl) 0.0005 lb/MMBTU (HCN) 0.0001 Hydrogen Chloride (HCl), Hydrogen Cyanide (HCN) and Hydrogen Fluoride (HF) USEPA Method 26A / CTM-033 60 lb/MMBTU (HF) 0.0003 Suspended Particulate Matter / Multi-Metals USEPA Method 29 240 lb/MMBTU See Section 4.6

lb/MMBTU (filterable) 0.00006 Particulate Matter less than 2.5 Microns (PM 2.5 )) USEPA OTM27 and USEPA OTM-028 240 lb/MMBTU (condensable) 0.0005

Mercury (Hg) USEPA Method 30B 120 lb/MMBTU 2.20E-09

ppmvd @ 7% O 2 3.2 Formaldehyde USEPA Method 320 120 lb/MMBTU 0.006

4.3 VELOCITY AND VOLUMETRIC FLOW RATE MEASUREMENT

SUMMARY: The outlet volumetric flow rate for each test run will be determined in
accordance with USEPA Methods 1 and 2. Simultaneously, USEPA Methods 3A and 4 will be conducted to quantify the oxygen, carbon dioxide and moisture content of the exhaust gas.

CALIBRATION: Pitot tubes will be calibrated in accordance with USEPA Method 2. All new pitot tubes or those meeting the di mensions of USEPA Method 2, section 6.1, are assigned a baseline coefficient of 0.84, per section 10.1 of this method. All other pitot tubes are calibrated to establish the specific co efficient. A pitot tube coefficient of 0.99 is assigned to each standard pitot tube.

DETECTION LIMITS: The lower detection limit for the pitot tube/manometer measurement system is 0.01 inches of water.

OPERATING RANGE: The water manometer has a ra nge up to 10 inches with 0.01
increments.8

PRINCIPLE OF OPERATION : The total stack or duct pr essure is a combination of the static and the velocity pressure. The velo city pressure is also referred to as the delta P, which is equal to the total pressure minus the static pressure.

When a type S-pitot tube is connected to a wa ter manometer, the total pressure and the static pressure are measured to yield the velocity pr essure. The volumetric ga s flow in a stack or duct is equal to the area times the velocity.

4.4 CARBON DIOXIDE, CARBON MONOXIDE, OXYGEN, TOTAL
HYDROCARBONS AND METHANE MEASUREMENT

SUMMARY: Stack concentrations of carbon monoxide (CO), carbon dioxide (CO 2 ), oxygen (O 2 ) and total hydrocarbons (THC as methan e), will be continuously sampled and analyzed with Avogadro’s real-time monito ring system (RTMS). Methane will sampled using Tedlar bags and analyzed via USEPA Method 18.

SAMPLE SYSTEM DESCRIPTION: The RTMS is fully extractive, conforms to USEPA Method 7E and consists of a sampli ng interface system (SIS), an instrument control panel, and instruments. The SIS consists of a stainless steel probe with a calibration tee, a heated sampling line, a calibration gas line, a heated sample pump/filter and a semi-non-contact thermoelectric sample conditioner.

The SIS will be used to cool, dry, filter, convey and distribute sample gas to the analytical instruments, which will be housed in one of Avogadro’s mobile laboratories. For total hydrocarbons, a portion of the uncond itioned sample stream will be diverted through heated sample passages directly to the analytical instrument for continuous analysis. All sampling components leading to the analyzer will be heated to ≥ 110 °C (220 °F). Actual temperatures will be recorded at 10-minute intervals during each test run.

All instrument output signals will be record ed every 20-30 seconds simultaneously with a data logger and a personal computer. Each data point logged will be date/time stamped.

Instruments, operating ranges and calibration gas concentrations that will be used for this test program are summarized in Table 4. Pe r Method 7E, the average concentration for each test run will be 20-100% of the chosen sp an. For THC, the analyzer range will be
1.5 to 2.5 times the stack concentration and no less than 25 ppm. All monitors conform to the design and performance criteria outlined in 40 CFR 60 Appendix A.9

Calibration gases will be USEPA Protocol.

TABLE 4: REAL-TIME INSTRUMENTATION SUMMARY

Parameter Analyzer Operating Principle Expected Average
Concentrations (client to verify) Calibration gases
(% of span)

CO TECO 48, 48s,
or 48i Non-dispersive,
infrared 15-20 ppm 0, 40-60, 100

THC JUM VE7 or
TECO 51 Flame
ionizationdetection very low 0, 25-35, 45-55, 80-90

O 2 Infrared
instruments or
Servomex Electro-chemical 7.5-8 % 0, 40-60, 100

CO 2 Summit or Fuji

ZRH Non-dispersive,
infrared 11-12% 0, 40-60, 100

PROCEDURE: Table 6 summarizes the quality assurance procedures to which the RTMS will be subjected in the field. Prior to the testing or during the first test run, a stratification test will be conducted for oxygen, as a surrogate for all gaseous test parameters, in accordance with USEPA Method 7E, Section 8.1.2. Stratification and trav erse points will be determined using the criteria in Table 5. In lieu of stratification testing, all gaseous samples may be drawn from 12 traverse points chosen in accordance with EPA Method 1.10

TABLE 5: REFERENCE METHOD TRAVERSE POINT DETERMINATION
CRITERIA

Number of stratification check points Criteria for all point Number of sample traverse points

|D| ≤ 0.05A (NOx, CO, SO 2 , O 2 , CO 2 ) or |D| ≤ 0.5 ppmv (NOx, CO, SO 2 ) or 3 or 12 |D| ≤ 0.3 %v/v (O 2 , CO 2 ) 1 (most representative of average)

0.05A ≤ |D| ≤ 0.1A (NOx, CO, SO 2 , O 2 , CO 2 ) or 0.5 ppmv ≤ |D| ≤ 1.0 ppmv (NOx, CO, SO 2 ) or 3

0.3 %v/v ≤ |D| ≤ 0.5 %v/v (O 2 , CO 2 ) 3 at 16.7%, 50.0%, and 83.3% of diameter

0.05A ≤ |D| ≤ 0.1A (NOx, CO, SO 2 , O 2 , CO 2 ) or 3 on the line with the highest concentration, located at:
0.5 ppmv ≤ |D| ≤ 1.0 ppmv (NOx, CO, SO 2 ) or 16.7%, 50.0%, and 83.3% of diameter (stack diameter <7.8 feet) 12

0.3 %v/v ≤ |D| ≤ 0.5 %v/v (O 2 , CO 2 ) 16”, 39” and 79” from stack wall (stack diameter >7.8 feet) |D| ≥ 0.1A (NOx, CO, SO 2 , O 2 , CO 2 ) or |D| ≥ 1.0 ppmv (NOx, CO, SO 2 ) or 3 or 12 |D| ≥ 0.5 %v/v (O 2 , CO 2 ) 12 located per EPA Method 1

|D| = difference between concentration at trav erse point and total concentration average 0.05A = 5% of the average concentration 0.1A = 10% of the average concentration ppmv = parts per million by volume %v/v = percent volume

With the exception of total hydrocarbons, calib ration gas will be introduced directly to the instruments during the calibration/linearity error check. First, the instrument will be zeroed on the zero gas. The zero gas for all re ference method analyzers will be <0.25% of span, except for THC, which will be <0.1 ppm (a s methane). Then the instrument will be calibrated against the high-concentration calibration gas. The lower-concentration calibration gas(es) will then be used to ch eck the instrument’s linearity, without making any adjustments to the instrument’s calibration.

Excluding the sample probe, calibration gas will be introduced to the entire sample system during the bias check and the calib ration/linearity error check of the total hydrocarbon analyzer.11

Per EPA Method 25A, this eliminates the n eed for a separate bias check for total hydrocarbons. Whenever possible, the upscal e gas used for the bias check and the
calibration/zero drift checks will be the one closest to the measured average stack concentration. A post-test zero/calibration drif t check may also serve as the bias check
for the next test run.

Instrument response to each calibration gas challenge will be documented on the strip chart recorder. Final run averages for all re ference method analyzers will be calculated in
accordance with Section 12.6 of USEPA Method 7E.

TABLE 6: REAL-TIME INSTRUMENTATION FIELD QA PROCEDURES SUMMARY

Check Frequency Limit

Instrument calibration/linearity

error • Beginning of each test day

• Range change

• After excessive calibration drift ± 2% of span (except THC)

± 5% of gas value (THC)

Sample system bias Before and after each test run ± 5% of span

Calibration/zero drift After each test run. ± 3% of span

SAMPLE RATES AND DETECTION LIMIT: The in-stack detection limits outlined in Table 3 are based on an analytical detection limit of 1.0 parts per million by volume, dry (ppmvd).

During each total hydrocarbon test run, a por tion of the conditioned sample will be
collected at a constant rate from the RTMS in a Tedlar gas bag. Each gas bag will then be analyzed via USEPA Method 18 for methan e within 48 hours of the completion of sampling. Methane analysis (samples and standards) will be conducted in triplicate.

4.5 HYDROGEN CHLORIDE, HYDR OGEN FLUORIDE, HYDROGEN
CYANIDE AND MOISTURE MEASUREMENT

SUMMARY: Outlet hydrogen chloride, hydrogen fluoride and hydrogen cyanide emissions will be sampled isokinetically using a modified USEPA Method 26A. Hydrogen chloride and hydrogen fluoride emissi ons will be analyzed in accordance with USEPA Method 26A. Hydrogen cyanide emissions will be analyzed in accordance with
Method CTM-033.

The primary components of the sampling train include a heated probe, a heated filter, three impingers containing sodium hydroxide (NaOH) and an impinger containing silica gel.12

Hydrogen cyanide present in the stack gas stream reacts with the NaOH to form a cyanide ion, which is retained in th e alkaline solution until analyzed by ion chromatography (IC). Hydrogen chloride a nd hydrogen fluoride present in the stack gas
stream reacts with the NaOH to form chloride and fluoride ions, which are retained in the alkaline solution until analyzed by ion chromatography (IC).

PREPARATION OF COLLECTION TRAIN: The entire sampling train is washed with detergent, rinsed with tap water, and finally rinsed with distilled/deionized water followed by acetone and allowed to air dry.

The main components of the sample train are the stainless steel nozzle, the probe sheath and probe liner, the heated filter holder box, the filter holder itself, the type S pitot tube, the moisture or impinger train, the differen tial pressure gauge, and the metering system (vacuum gauge, leak-free vacuum pump and th ermometers). The nozzle is connected to the probe sheath via a gas-tight connection to the inner (sampling) probe liner.

The impinger train will consist of four unrestricted Greenburg-Smith impingers
immersed in an ice bath and connected in series with glass crossovers. In order to maintain a pH at or above 12.0 as required by Method CTM-033, the first three impingers may contain up to 250 ml of up to 10N NaOH per impinger. The last impinger will contain approximately 200 grams of silica gel. The last impinger is connected to a positive displacement pump and a calibrated dry gas meter. The objective is for the last two reagent impingers to have a pH greater than 12.0. Alizarin yellow indicator will be added to the impingers . If the indicator shows that the impinger pH is starting to approach 12, additional caus tic may be added to the impingers to raise the pH. The pH of the last reagent impinge r will be checked at the end of the run to ensure that the pH is above 12.0. If the pH is found to be below 12.0, the run will be repeated.

SAMPLE TRAIN OPERATION : A single train traversing the stack cross sectional
area will be used for the entire test run.

The temperature of the gas stream in the sample train is maintained at a minimum temperature of 248 o F to prevent condensation from o ccurring. This includes the probe and filter box temperatures. The filter and filter housing are connected to the impinger
train.

During testing, a sample rate is maintained su ch that it is within 10 percent of the true isokinetic. First, the manometer is leveled and zeroed. The sample train is assembled and leak ch ecked. The initial dry gas meter volume is recorded, and the sampling train is placed at the first sampling point in the stack.13

At this point, the stack gas velocity, the stack temperature and initial gas meter volume are all recorded in order to establish the proper sample rate.

At each traverse point in the stack, the following data are recorded:

• the temperature of the stack gas;

• the meter system temperatures;

• the probe and filter holder temperatures;

• the exit impinger temperature;

• the sampling rate. This procedure is repeated until the end of the test run.

LEAK-CHECK PROCEDURES: A leak-check of the entire sample train will be performed prior to and after each test run. Leak checking is performed by plugging the nozzle and pulling a controlled vacuum in the sa mple train equal to or greater than the highest sample vacuum obtained during the test run. If the leakage rate is measured to be less than 0.02 cubic feet per minute (cfm), then it is acceptable. If the leak rate is higher, the tester shall, at the discretion of the regulatory personnel, either record the leakage rate and correct the sample volume, or void the test run.

SAMPLE VOLUMES AND DETECTION LIMITS: The in-stack detection limits listed in Table 3 are based upon an anal ytical detection limit of 0.434 ug/ml for hydrogen chloride, 0.217 ug/ml for hydroge n fluoride and 0.104 ug/ml for hydrogen cyanide, an estimated impinger reagent sa mple volume of 1,000 ml and a gas sample
volume of 30 cubic feet. Each test run will be one hour in duration.

Large amounts of NaOH will likely be needed in order to keep the impinger pH above 12, because the high stack CO 2 consumes the NaOH during sampling. The additional
NaOH does not affect the detection limit for HCN and is not expected to change the
detection limit for HCl and HF.

SAMPLE RECOVERY: The recovery of each sample train is conducted onsite. The sampling train is transferred to an area th at is clean and protected from external conditions. The impingers will be disassembled and wiped free of any water or ice. The impinger contents are weighed (to the nearest tenth of a gram) for moisture determination. The contents of the impingers along with NaOH impinger rinses will be
added to container #1. The filter will be discarded after the test run.

A reagent blank of NaOH will be collected based upon the concentration used during the

runs.14

Samples will be transported from the test site to Avogadro Environmental’s lab for assignment of chain-of-custody and transfer to Enthalpy Analytical, Inc. for analysis.

ANALYSIS: The impinger samples and blanks will be analyzed by ion chromatography by Enthalpy Analytical, Inc.

4.6 PARTICULATE MATTER, MULTI-METALS AND MOISTURE
MEASUREMENT

SUMMARY: Stack gas will be sampled isokinetically for suspended (filterable) particulate and metal emissions in accordance with USEPA Method 29. Suspended particulate in the sampled gas will be collected in the sample train on a heated glass fiber filter. Metals in the sampled gas will be coll ected in the sample train on a filter and in acidic impinger reagents. Recovered samples will first be analyzed gravimetrically for particulate in accordance with EPA Method 29. Then the samples will be digested and analyzed for antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), total chromium (Cr), cobalt (Co), lead (Pb), mangane se (Mn), nickel (Ni) and selenium (Se),
in accordance with Method 29.

Key sample train components will include:

• a sized, tapered –edge, glass “button-hook” sample nozzle,

• a stainless steel sample probe with a heated glass liner, S-type pitot tube and thermocouple

• a heated glass filter holder with a low- metals quartz fiber filter supported by a
Teflon frit

• a condenser system consisting of Greenbur g-Smith glass impingers and connecting pieces

• a sample control/metering system consis ting of a vacuum pump, dry gas meter, sample flow controls, sample rate ma nometer, stack gas velocity manometer, temperature indicator and heat controllers.

PREPARATION OF SAMPLING TRAIN: Sampling glassware and samplecontainers will be cleaned prior to sampling. A soap and water wash followed by a fourhour soak in 10% HNO 3 (plastic ware will be rinsed only) and triplicate rinse with distilled, deionized water and an acetone rinse (probe and nozzle only) will be used to clean the glassware.

The condenser will consist of four impinge rs. All impingers except the third will be Greenburg-Smith modified with unrestricte d impinger tubes. Impinger 3 will be a standard Greenburg-Smith impinger.15

Each impinger will be charged for sampling as follows:

• Impinger 1, moisture knock-out

• Impingers 2 & 3, 100ml 5% HNO 3 / 10% H 2 O 2

.

• Impinger 4, silica gel.

All impingers will be weighed prio r to sampling. Solutions of 5% HNO 3 /10% H 2 O 2 will be used within 24 hours of preparation.

LEAK-CHECK PROCEDURES: A leak-check will be performed prior to and after each test by creating a vacuum in the sample train equal to or greater than the highest sample vacuum obtained during the test. A leakage rate found to be no greater than 0.02 cubic feet per minute is acceptable. If a highe r leakage rate is obtained, the tester shall at the discretion of the regulatory personnel, either record the leakage rate and correct the sample volume, or void the test run.

SAMPLE VOLUMES AND DETECTION LIMITS : Detection limit for particulate
matter summarized in Table 3 are based on an analytical detection limit of 0.0002 grams and a sample volume of 3.4 cubic meters. Each test run will be a minimum of four hours
in duration.

Detection limits for the metals are summari zed in Table 7 and are based on a sample
volume of 3.4 cubic meters. Each test run will be a minimum of four hours in duration.

TABLE 7: SUMMARY OF MULTI-METALS DETECTION LIMITS

Detection Limit Analytical, μ g/sample In-stack, Pounds/MMBTU Metal Front Half Back Half Front Half Back Half Antimony 0.4 0.2 1.20E-07 6.01E-08

Arsenic 0.4 0.2 1.20E-07 6.01E-08 Beryllium 0.1 0.05 3.00E-08 1.50E-08
Cadmium 0.1 0.05 3.00E-08 1.50E-08
Chromium 0.3 0.15 9.01E-08 4.51E-08

Cobalt 0.1 0.05 3.00E-08 1.50E-08
Lead 0.2 0.1 6.01E-08 3.00E-08 Manganese 0.75 0.25 2.25E-07 7.51E-08
Nickel 0.5 0.25 1.50E-07 7.51E-08
Selenium 1 0.5 3.00E-08 1.50E-0716

SAMPLE TRAIN OPERATION : A single train traversing the affected stack cross
sectional area shall be used for the entire te st. The sampling system will consist of a sized tapered edge nozzle constructed of gla ss. The nozzle is connected to a stainless steel support tube via a gas-tight connection to a glass inner sampling probe. The gas stream will enter a four inch diameter glass fiber filter supported by a quartz glass frit. The gas stream temperature will be 250° F (+ 25° F).

During testing, a sample rate is maintained su ch that it is within 10 percent of the true isokinetic. First, the manometer is leveled and zeroed. The sample train is assembled and leak checked. The initial dry gas meter volume is recorded, and the sampling train is placed at the first sampling point in the stac k. At this point, the stack gas velocity, the stack temperature and initial gas meter volume ar e all recorded in order to establish the proper sample rate.

At each subsequent traverse point in the stack, the following data are recorded:

• the temperature of the stack gas;

• the meter system temperatures;

• the probe and filter holder temperatures;

• the exit impinger temperature;

• the sampling rate This procedure is repeated until the end of the test run.

SAMPLE RECOVERY: Sample recovery will occur onsite in the mobile CEM lab or in an adequately clean environment.

The filter is placed into a petri dish (containe r 1) and sealed to prevent sample loss. The probe, nozzle, liner, and the front half of the filter will be washed and brushed with acetone into one container (container 2) until the rinse shows no visible particles. The
amount of acetone used to rinse the front-hal f sample train components will be at least 200 milliliters or 30 milliliters per foot of pr obe length, whichever is greater. The impingers will be disassembled and wiped free of any water or ice, and the volume is weighed to the nearest gram to determine moisture content.

The probe and nozzle will be rinsed three times with a total of 100 ml of 0.1N HNO 3 into a high-density polyethylene (HDPE) sa mple jar (container 3). Impingers 1, 2 & 3 contents will be transferred to a HDPE sample jar (container 4).

Impingers 1, 2 & 3 and connecting glassware will then be rinsed three times with a total
of 100 ml 0.1N HNO 3 into container 4.17

A sample blank of acetone, equivalent to th at used for the probe and nozzle rinse for each run, will be collected and submitted for analysis. An HDPE jar containing 100 ml
0.1N HNO 3 will be recovered as a front-half ri nse blank. A HDPE jar containing 200 ml
5% HNO 3 /10% H 2 SO 4 and 100 ml 0.1 N HNO 3 will be recovered as a back-half blank.

ANALYTICAL PROCEDURES: All sample containers will be sealed, labeled and marked for fluid level prior to shipment. Samples will be transported or shipped from the site by Avogadro personnel. Each sample will be logged on a chain of custody form that will accompany the samples to Maxxam Analy tics. Prior to shipment, the filters are desiccated to constant weight for quan tifying the weight gain at the Avogadro laboratory.

At Maxxam Analytics, the acetone rinse will be dried, desiccated and the residue quantified as particulate. The acetone rins e residue will then be combined with the remaining front-half sample fractions. Front-half and back-half fractions will be analyzed separately via Method 29. Induc tively coupled plasma mass spectrometry (ICP/MS) analysis for all metals will utilize SW-846-6020.

4.7 MERCURY MEASUREMENT

MERCURY MEASUREMENT

SUMMARY: Mercury will be measured in accord ance with USEPA Method 30B. The analytical procedure for USEPA 30B incorporates the use of solid-sorbent traps filled with two segments of iodinated charcoal. Mercury collected onto each segment is then desorbed and analyzed separately by thermal decomposition (700°C) outfitted to an AA Spectrometric detector. This procedure is referred to as the “thermal procedure” in
USEPA Method 30B. A sampling train using paired sorbent traps will be used to collect samples from the outlet.

Samples are quantified utilizing a calibration cu rve. The calibration curve is determined on the day of analysis by analyzing a minimum of three standards in order to provide a minimum of three calibration points. At the end of each set of anal ysis a post calibration
is conducted.

SAMPLING TRAIN: The sorbent traps will be appr oximately 12 inches long for high moisture sources and have two chambers. Both chambers will be carbon impregnated and will capture vapor phase Hg.18

The sampling train consists of two sorbent traps mounted at the end of one sampling probe in a manner that allows for the gas st ream to enter the traps directly. The probe will be heated in order to prevent moisture condensation in the probe. After exiting the probe, the sample gas stream will pass through a condenser to remove moisture prior to entering the metering system. The metering system will consist of either a dry gas meter or a mass-flow sensor and a sample pump. If a mass flow sensor is used to measure sample volumes, its accuracy will be checked against a second standard in the field while sampling stack gas as described in section 10.2.2.5 of Method 30B.

SAMPLE VOLUMES AND DETECTION LIMITS : The detection limits for mercury summarized in Table 3 are based on an analytical detection limit of 0.36 nanograms and a sample volume of 167 liters. Each test run will be a minimum of two
hours in duration.

FIELD RECOVERY PAIRED SAMPLE TESTS: For each pair of traps sampled during each test run, one will be spiked with 50 ng of Hg onto the front section of the trap and the second trap will be un-sp iked. Because of the special handling considerations for internal spiking and to enhance quality assurance this procedure will be performed at Ohio Lumex.

Both the spiked and un-spiked traps will be analyzed in the same batch and in the same manner. Once the amount of mercury found in the spiked trap is corrected for the spike, it will be compared to the amount of mercury in the un-spiked trap to see if the amounts found agree as specified in Section 8.2.6.2 of Method 30B.

SAMPLE TRAIN OPERATION: Before sampling, a leak check will be performed with the sorbent traps in place. A vacuum will be drawn through the probe and adjusted to approximately 15”Hg. Using the gas meter, a leak rate will be determined and must not exceed 4% of the target sampling rate. Once the leak check passes the criteria, the vacuum will be carefully released and the sorb ent trap inlet will be sealed until the probe is ready for insertion.

After performing the leak check, the sample collection is accomplished by removing the plug from each end of the traps and inserting the probe through the port, turning on the pump, and sampling at the target rate. The sa mple rate will remain constant (+/- 10%) through both sample traps throughout each test run. The sampling train will be leakchecked a second time after each test run has been completed, at the highest pressure drop encountered during the test run. The train is returned to atmospheric pressure and the sorbent traps will be carefully removed.19

SAMPLE RECOVERY AND ANALYSIS: After the traps have been removed from the probe, both ends will be sealed and the traps will be wiped clean and placed in a clean storage container to be sent to Ohio Lumex for analysis.

4.8 PARTICULATE MATTER LESS THAN 2.5 MICRONS (PM 2.5 ) AND
MOISTURE MEASUREMENT

SUMMARY : Stack gas will be sampled for PM 2.5 emissions in accordance with
USEPA Other Test Method 27 and Other Test Method 28.

Suspended (filterable) and condensable pa rticulate matter (CPM) with an aerodynamic particle size of 2.5 microns or less will be se parated from the sampled gas with an instack cyclone and collected on a glass fiber filter and in water.

The CPM is collected in the water dropout impinger, the modified Greenburg Smith impinger and a CPM filter of the sampling tr ain. The organic and aqueous fractions will then be taken to dryness and the residues wei ghed. The total of both fractions represents
the CPM.

Recovered samples will then be analyzed gr avimetrically for particulate in accordance
with Method OTM-27 and OTM-28.

Key sample train components will include:

• An in-stack, stainless-steel cyclone and sa mple nozzle meeting the specifications of
EPA Other Test Method 27 for PM 2.5 sampling;

• A stainless-steel sample probe with a heated glass liner, S-type pitot tube, probe extension and thermocouple;

• Condenser followed by a dropout impinger;

• CPM filter holder;

• A sample control/metering system consisting of a vacuum pump, dry gas meter, sample flow controls, sample-rate manometer, stack gas velocity manometer, temperature indicator, and heat controllers.

PREPARATIONS: The cyclone will be cleaned with acetone prior to sampling. The glassware portion of the sampling train is wash ed with soap and water, rinsed with tap water, rinsed with distilled/deionized water, rinsed with acetone and finally rinsed with
MeCl 2 . After cleaning, the glassware will be baked at 300  ̊ C for 6 hours prior to each source type sampled.20

Prior to each test run, the glassware used to collect CPM must be rinsed thoroughly with deionized, distilled ultra-filtered water that conforms to ASTM D1193-06, Type 1.

ONSITE LEAK-CHECK PROCEDURES: A leak-check will be performed prior to and after each test by plugging the nozzle and creating a vacuum in the sample train equal to or greater than the highest sample vacuum obtained during the test. A leakage rate no greater than 0.02 cubic feet per minut e (cfm) is acceptable. If a higher leakage rate than 0.02 cfm is obtained post run, the tester shall, at the discretion of the regulatory personnel, either record the leakage rate and correct the sample volume, or void the test

run.

SAMPLE VOLUMES AND DETECTION LIMITS: The in-stack detection limits outlined in Table 3 are based on an analytical detection limit of 0.0002 grams for filterable PM, 0.0015 for condensable PM and a sample volume of 3.4 cubic meters. Each test run will be up to six hours in duration.

SAMPLE TRAIN OPERATION : Completion of each test run will include the following key procedures:

• Proper sample rate and nozzle size will be selected in accordance with Sections 8.5 through 8.5.5 of Method OTM-27.

• A pre-test leak check of the entire sample train will be conducted.

• Sample time at each sample point will be va ried for local delta P in accordance with Equations 22 and 23 of Method OTM-27.

• Probe heat will be maintained to prevent internal moisture condensation. Ice will be maintained in the impinger ice bath. The CPM filter temperature will be maintained

at < 85  ̊ F. The moisture train exit temperature will be maintained at < 68  ̊ F.

• A post-test leak check will be performed on the entire sample train without the instack cyclone at a vacuum equal or greater than the highest vacuum achieved during
the test run.

• All necessary data for each sample point a nd test run will be recorded on appropriate
data forms.

POST TEST NITROGEN PURGE: After the post-test leak check, a nitrogen purge of the impinger train will be conducted. Duri ng the purge, the temperature at the exit of the silica gel impinger will be monitored and maintained below 68  ̊ F. The temperature
at the exit of the CPM filter will be monitored and maintained below 85  ̊ F. If no water was collected before the CPM filter, then the nitrogen purge will be omitted.21

During the purge, a stem will be inserted into the dropout impinger. The impinger tip length will extend below the water level in th e impinger catch. If insufficient water was collected, then a measured amount of dega ssed deionized, distilled ultra-filtered ASTM D1193-06, type 1 or equivalent, water will be added until the impinger tip is at least 1
cm below the surface of the water. The am ount of water added to the dropout impinger
to correct the moisture content of the effl uent gas will be recorded. The train will be purged using nitrogen for one hour using zero-grade ultra-high purity nitrogen.

SAMPLE RECOVERY : Sample recovery will be perfor med in the field in a suitable area that is clean and protected from external conditions. Each impinger will be weighed to 0.1 gram for moisture determination.

OTHER TEST METHOD 27:

The particulate filter and loose particulate will be transferred to a plastic petri dish. The

PM 2.5 exit tube and filter holder front-half will be brushed and rinsed with acetone into an amber glass bottle.

A sample blank of acetone will be collected in a separate amber glass container, adding a volume of acetone equal to the volume used for sample cleanup.

OTHER TEST METHOD 28:

Tweezers and/or clean disposable gloves will be used to remove the CPM filter from the
CPM filter holder. The contents of th e CPM impingers (impinger catch) will be transferred to a clean sample container (glass or plastic).

A distilled water rinse of the probe, pr obe extension, condenser, CPM impingers, impinger connectors, CPM filter front-half and particulate filter-holder back-half will be completed twice, and the rinse will be added to a clean sample container. Next, an acetone rinse of these same components will be performed, followed by duplicate methylene chloride rinses. The acetone and me thylene chloride rinses will be combined into a clean sample container.

Blanks will be recovered as follows:

Sample blanks of distilled water, acetone a nd methylene chloride will be collected in clean sample containers, adding volumes equal to the volume used for sample cleanup.22

FIELD TRAIN BLANK: One field train blank will be recovered for the test program. The sampling train will be assembled as described above, except 100 mL of water will be added to the first impinger. The field tr ain blank will be purged and recovered in the same manner as the test run samples, as described above.

SAMPLE SHIPMENT AND STORAGE: Samples will be labeled according to scenario and test run number. All samples will be transported from the test site to Avogadro’s offices for a final quality assuran ce check prior to analysis at Avogadro and Maxxam Analytical. The samples will be stored in their recovery containers until analysis.

SAMPLE ANALYSIS: PM 2.5 analysis will be performe d in accordance with Section
11.0 of OTM-27. Filters will be dried and de siccated to a constant weight. After measuring the quantity of acetone in container 2, its contents will be transferred to a dry, desiccated and tared evaporation vessel. After evaporating the acetone, the vessel will be dried, desiccated, and re-weighed to a constant weight.

The CPM samples will be processed accord ing to Figure 6 of Method OTM-28 at Maxxam Analytical.

4.9 FORMALDEHYDE MEASUREMENT

Formaldehyde emissions will be measured at the outlet stack in accordance with USEPA Method 316, “Sampling and analysis for fo rmaldehyde emissions from stationary sources in the mineral wool and wool fiberglass industries”.

PRINCIPLE AND APPLICABILITY: Gaseous and particulate pollutants are withdrawn isokinetically from the source and are collected in distilled/deionized (DI) water. The DI water is then analyzed using the modified pararosaniline method.

The main components of the sample train are the stainless steel nozzle, the probe sheath and glass probe liner, the type-S pitot tube, the moisture or impinger train, the differential pressure gauge, and the metering system (vacuum gauge, leak-free vacuum pump and thermometers).

PREPARATION OF SAMPLING TRAIN: The glassware portion of the sampling train is washed with soap and water, rinsed with tap water and rinsed with
distilled/deionized water. For each test r un, the first two impingers are filled with approximately 100 grams of DI water. Th e third impinger is empty, and the fourth impinger is charged with approximately 200 grams of silica gel.23

LEAK-CHECK PROCEDURES: A leak-check of the entire sample train will be performed prior to and after each test run. Leak checking is performed by plugging the nozzle and pulling a controlled vacuum in the sa mple train equal to or greater than the highest sample vacuum obtained during the test run. If the leakage rate is measured to be less than 0.02 cubic feet per minute (cfm), then it is acceptable. If the leak rate is higher, the tester shall, at the discretion of the regulatory personnel, either record the leakage rate and correct the sample volume or void the test.

SAMPLE VOLUMES AND DETECTION LIMITS: The in-stack detection limits outlined in Table 3 are based on an analy tical detection limit of 5 ug and a sample
volume of 30 cubic feet. Each test run will be a minimum of two hours in duration.

SAMPLE TRAIN OPERATION : During testing, a sample rate is maintained such that it is within 10 percent of the true isokinetic. First, the manometer is leveled and zeroed. The formaldehyde sample train is a ssembled and leak checked. The initial dry gas meter volume is recorded, and the sampling train is placed at the first sampling point in the stack. At this point, the stack gas velocity, the stack temperature and initial gas meter volume are all recorded in order to establish the proper sample rate.

At each subsequent traverse point in the stack, the following data are recorded:

• the temperature of the stack gas;

• the meter system temperatures;

• the probe and filter holder temperatures;

• the exit impinger temperature;

• the sampling rate This procedure is repeated until the end of the test run.

The temperature of the probe is maintained at approximately 248°F +/- 25°F to prevent condensation from occurring. The impinger temperatures are maintained to allow proper condensation to occur. At no time will the last (exit) impinger temperature
exceed 68 o F. Accordingly, ice and/or cold water is added, as necessary.

SAMPLE RECOVERY: The recovery of the formaldehyde sample train is conducted onsite. The sampling train is transferred to an area that is clean and protected from external conditions. The impingers will be disassembled and wiped free of any water or ice. The impinger contents are weighed (to the nearest tenth of a gram) for moisture determination. The probe nozzle, probe fitting and the glass liner are washed and
brushed with DI into one container at least three times and until the rinse shows no visible particles.24

Empty the contents of the first three impingers into the same sample bottle. The first three impingers and the connecting glassware are rinsed three times with DI water and added to same sample container.

A sample blank of DI water is collected in a separate polyethylene bottle adding a volume of water equal to the volume used for sample cleanup. [less than or equal to 100 milliliters (ml)]

SAMPLE TRANSPORTATION AND STORAGE: Each sample is given a sample number and corresponding label for identificati on purposes. Each sample container is sealed and taped to prevent leakage, contamin ation, or loss. Immediately after recovery, samples will be stored cold. Samples are tr ansported from the test site to Avogadro’s offices for a final quality assurance check pr ior to analysis. All samples will be shipped cold to the laboratory.

ANALYTICAL PROCEDURES: Each water sample and the water blank will be analyzed by the modified pararosaniline method.25

5.0 QUALITY ASSURANCE / QUALIT Y CONTROL INFORMATION

5.1 TEST EQUIPMENT AND INSTRUMENTATION

Avogadro has access to all items of sampling, m easurement, and test equipment required for the correct performance of the tests, or calib rations, or both (including sampling, preparation of test and/or calibration items, processing and analysis of test and/or calibration data). Avogadro’s equipment and software used for te sting, calibration, and sampling is capable of achieving the required accuracy and complies with specifications relevant to the tests and/or calibrations concerned. Avogadro ensures that be fore being placed into service, equipment (including that used for sampling) is calibrated or checked to establish that it meets Avogadro’s specification requirements and complies with the relevant standard specifications. Additionally, Avogadro ensures that equipment is operated by trained and authorized personnel.

Avogadro assigns a unique identifier to each item of sampling, measurement, and test equipment that requires traceability, routine and/or scheduled maintenance, requires routine and/or scheduled calibrations and/or has a specific lifespan. The unique identifier is prominently and indelibly applied to the item and assignments are documented in the inventory management system.

This equipment is maintained in good operating order and calibrated at regular intervals in accordance with the test procedures for wh ich it is used. Additionally, documentation substantiating service dates and calibration and maintenance histories is maintained. Avogadro uses data sheets and maintains logbooks to capture this information.

Copies of equipment manuals and calibration reco rds are kept in the Avogadro office so that the information is readily available to users and observers. Additionally, each piece of test equipment is sent to the field with a reasonabl e inventory of field-replaceable spare parts.

Field teams are capable of performing minor se rvice and repairs in the field. Unless the service action requires the use of spare parts, the service or maintenance action is not recorded. When equipment cannot be serviced in the field, it is tagged and removed from service until it is repaired. Service actions that require the use of spare parts, originate from field tagging, or are performed by third parties are reviewed to determine when the service requirement may have affected test results for ot her test programs. In the event test results for other programs are affected, clients are notified and follow-up actions are completed.26

Avogadro will rent or lease test equipment when there is insufficient equipment in-house to adequately service jobs, when owned equipmen t is being repaired, or when specialized equipment is required. Avogadro ensures that when it uses equipment outside its permanent control, all requirements of ASTM D 7036 are met. Providers of rental equipment are required to furnish documentation indicating accep table performance of the equipment at the time it is shipped. Rented equipment, wh ile not subject to Avogadro’s maintenance program, is subject to the calibration require ments of the test method. For this reason, Avogadro performs appropriate pre- and post-te st calibrations of rented test equipment. Test equipment and instrumentation is often used in the field in an industrial environment. Whenever possible and practical, test equipment and instrumentation is used within a mobile laboratory that provides a satisfactory opera ting environment for the equipment; however, some projects require that test equipment a nd instrumentation be operated in uncontrolled environments. In these instances, environmen tal factors and their potential impacts will be recorded in calibration logs or on data sheets and reported in the test report.

5.2 CALIBRATION AND HANDLING OF TEST EQUIPMENT AND
INSTRUMENTATION

All equipment used for tests, or calibrations , or both, including equipment for subsidiary measurements (for example, for environmenta l conditions) having a significant effect on the accuracy or validity of the result of the test , calibration or sampling will be calibrated by Avogadro before being put into service. Where possible, Avogadro will use reference
materials traceable to certified reference materi als. Checks needed to maintain Avogadro’s
confidence in the calibration status of referen ce, primary, transfer or working standards and reference materials will be carried out, as far as technically and economically practicable, in accordance with defined procedures and schedules.

Avogadro has established calibration program s for key quantities or values of the instruments where these properties have a signifi cant effect on the results. For example, the test equipment manufacturer specifies speci fic maintenance requirements and Avogadro adheres to these requirements. Additionall y, calibration requirements are set forth in individual test methods and Volume III of the Quality Assurance Handbook for Air Pollution Measurement Systems: Stationary Source Specific Methods . Avogadro calibration procedures conform to the requirements set fo rth in these documents. Where appropriate, maintenance and calibration procedures are desc ribed or referenced in standard operating procedures (SOPs). Where applicable, these calibration procedures are traceable to National Institutes of Standards and Technology (NIST) reference materials. While Avogadro performs most maintenance and calibration activities in-house, Avogadro relies on a vendor for annual calibration of mass flow controllers used in dilution systems.27

Avogadro checks the calibration of analytical balances on each day of use with mass standards that bracket the range of use, ch ecks the function and calibration of top loading balances monthly and either (i) replaces the ba lances annually or (ii) performs maintenance service and recalibrations annually. These daily calibrations are recorded in the log book. Thermometers and other temperature measurem ent equipment are checked periodically, and at least annually (quarterly in the case of di al thermometers), against a NIST traceable thermometer and appropriate correction factors are developed and applied.

Copies of calibration data, along with the iden tification number for the calibrated equipment, are stored in either the logbook or requisite proj ect file, and when appropriate, kept with the equipment.

Test equipment, instrumentation, and related ca libration standards are handled and stored in manners that ensure their integrity, prolong th eir useful service lives and that provide adequate protection to personnel, facilities, equi pment, and the environment. Equipment is labeled with regard to calibration status and tagged and removed from service if it requires repair. Equipment is stored in protected and secure areas. Equipment is properly discarded
at the end of their useful service life.

All sampling equipment and instrumentation to be used for this test program are calibrated per the applicable test method. Copi es of all pre-test and post-test calibration data will be included in the final test report. The information presented below addresses specific quality assurance items not menti oned in the sections above. Additional calibration information may include but is not limited to the following:

• Dry Gas Meters: Dry gas meters are calibrated prior to use in accordance with USEPA Method 5, section 10.3 using a dry gas meter as described in section 16.1. Dry gas meter calibrations will be verifi ed in the field in accordance with Alternate Method 009, unless data is not available, then post-test calibration checks will be performed as per section 10.3.2 of USEPA Method 5.

• Span Gas Certifications: Each gas supplier provides span gas certifications, and copies will be included in the final test report.

• Thermocouples: Stack temperature thermocouple calibrations are checked after
each field use in accordance USEPA Alternative Method 2 (ALT-011) by comparing the thermocouple to an ASTM mercury-in-glass thermometer at a single, convenient temperature. The thermocouple reading must agree within + 2 o F of the thermometer reading.28

Stack temperature thermocouple measuremen t system continuity will be checked in the field prior to sampling in accordance with ALT-011 by observing that the temperature reading changes as expected upon insertion or withdrawal of the thermocouple from the stack.

• Heated Sample Lines: Heated sample lines temperature will be visually observed and recorded at 15 minute intervals during each test run.

• Nozzles: Copies of calibration data for all glass and/or stainless steel nozzles used during the test program will be included in the final report.

5.3 DATA COLLECTION AND MANAGEMENT

Insofar as is feasible, recorded information is created using standardized electronic media and software. These activities are performe d using personal computers (PCs) with or without Local Area Network (LAN). The LAN is backed-up on a daily basis and data are stored for ten years. Standardized directory fo rmats are used for the storage of client and Avogadro administrative files.

Avogadro is able to provide documentation or otherwise demonstrate on request that it complies with the relevant and appropriate federal, state, and local requirements for conducting testing procedures under its scope , including compliance with ASTM D 7036. Additionally, Avogadro is able to provide documentation or otherwise demonstrate on request that it complies with applicable lo cal, state, and federal requirements governing health and safety, transportation, shipping, and other relevant requirements.

Avogadro has established and maintains procedur es for handling, control and storage of all documents (including quality and technical record s) that form part of its quality system (internally generated or from external sour ces). Quality records include reports from customer and regulatory authority feedback, inte rnal audits and management reviews as well as records of corrective and preventive actions. All records will be (1) legible, (2) stored in facilities that provide a suitable environment to prevent damage or deterioration and to prevent loss, and (3) retained in such a way that they are readily retrievable. All records in possession of Avogadro are secure and held in confidence in accordance with established record retention periods. Avogadro has proce dures to protect and back-up records stored electronically and to prevent unauthorized access to or amendment of these records. At the end of the designated retention period, records are destroyed or returned to the client.29

Avogadro retains records of original observations , derived data and sufficient information to establish an audit trail, calibration records, staff records and a copy of each test report or calibration certificate issued, for a defined peri od. The records for each test or calibration contain sufficient information to facilitate, if po ssible, identification of factors affecting the uncertainty and to enable the test or results, or calibration to be repeated under conditions as close as possible to the original. The record s include the identity of personnel responsible for the sampling performance of each test, or calibration, or both.

Other records include but are not limited to quality records, results of internal and external audits, training and qualification records for personnel, performance feedback, gas certifications, and chain-of-custody records. Observations, data and calculations are recorded at the time they are made and are iden tifiable to the specific task. When mistakes occur in records, each mistake is crossed out, not erased, made illegible or deleted, and the correct value entered alongside. Such alterati ons to records are dated and signed or initialed by the person making the correction. In case of records stored electronically, equivalent measures are taken to avoid loss or change of original data.

SPREADSHEETS

Spreadsheets are an essential tool for the reduc tion and management of emission testing data and Avogadro relies on a number of standard spreadsheets for routine work. When spreadsheets are initially developed, they are checked against a known data set or by hand calculations. Once the accuracy and reliability of the spreadsheet have been established, the master version is password protected to preven t overwriting. Only the master version is to be used for project work. This is accomplished by opening the master version, acknowledging that it is a read-only version and then saving it with a new name. Once the document has been saved with a new name, data can be entered and saved.

Attachment 1 contains example calculations relevant to the proposed testing.

HANDWRITTEN DATA AND RECORDS

Field data are often recorded by hand. Handwritte n field data must be recorded in indelible ink. When corrections are made, they are made such that the original entry is not obliterated (i.e., a single line is drawn through the erroneous entry). Each correction is initialed and
dated.30

It is often necessary to transfer handwritten data to spreadsheets for data reduction purposes and the accuracy of the transfer must be verifi ed by either the person making the transfer or by another individual. Once data transfer acc uracy has been verified, the spreadsheet is printed, initialed and dated by the verifier.

Occasionally, it may be necessary to modify qua lity system or project documents (e.g., test plans, SOPs, data summaries, etc.) by hand. In cases where it is necessary to amend a document by hand, the document will be formally re-issued as soon as practicable. Original signature and initials are maintained in appropriate company files.

Attached 3 contains sample field data sheets relevant to the proposed testing and a blank chain of custody form.

TEST REPORTS

The results of each test, calibration or series of tests or calibrations carried out by Avogadro will be reported accurately, clearly, unambiguous ly and objectively, and in accordance with any specific instructions in the test or calibra tion methods. Avogadro test reports adhere to a standard format that is determined by the sc ope of work. Each report bears a unique project number and each page in the report is numbe red. The report includes all information requested by the client and relevant regulatory authority and necessary for the interpretation of the test or calibration results and all information required by the method used. Each test report or calibration certificate includes at le ast the following information, unless Avogadro has valid, documented reasons for not including it:

• A title,

• The name and address of Avogadro and the testing location,

• Unique identification of the test report and on each page an identification in order to ensure that the page is recognized as a part of the test report, and a clear identification of the end of the test report,

• The name and address of the client,

• Unambiguous identification of the substance, material or product sampled,

• The location of sampling, including any diagrams, sketches or photographs,

• Detailed process description and process operations for each test run,

• Identification of the method(s) used,

• A description and unambiguous identification of the item(s) tested,

• The date(s) of performance of the test,

• Reference to the test plan and procedures used by Avogadro,

• The test results with, where appropriate, the units of measurement,

• Deviations from, additions to, exclusions from the test protocol, test methods, Avogadro’s quality manual, or this practice,31

• Information on specific test conditions, such as environmental conditions,

• A discussion of test results including the un certainty associated with the test and discussion of possible errors or limiting conditions,

• Calibration certificates for all equipment significant to the testing performed,

• Documentation and sufficient raw data to verify and reproduce all report calculations,

• The name(s), function(s) and signature(s) or equivalent identification of person(s) authorizing the test report, and

• A signed statement by a responsible official that Avogadro operates in conformance with the requirements of this practice during the test project.

Technical Coordinators, with assistance from other Avogadro personnel, prepare individual report components and work product intermediates. The components and work product intermediates are compiled into a complete dr aft by Air Quality Scientists. The Project Manager, with support from the Quality Manage r or Technical Director, then performs a review and revision of the report. The Project Manager signs all project reports. If the work is subject to ASTM D 7036, then the report w ill also be signed by the Qualified Individual overseeing the project.

Project specific quality control data including calib ration data, and audit, spike, and replicate sample results are all reviewed by the Quality Manager using acceptance criteria established in test methods, regulatory agencies, or project plans. When quality control data do not meet established acceptance criteria, the Quality Mana ger must review the data, investigate the cause for outliers, and provide a written descrip tion of the impact on reported source data. The written description must be incorporated into the final report.

Corrective actions can result in the requirement to re-issue a test report. When it is necessary to re-issue a test report, the original report identification number is retained and the suffix “Revised Day-Month-Year” is added. A Foreword is added to describe the reasons for revising the report. Revised data and suppor ting documentation are included in appropriate sections of the report. Other corrective actions can result in the requirement to add or append information to an existing test report. In these instances, appropriate correspondence and documentation is prepared and submitted to the c lient. Amended reports or data that amendsor supplements a report will include the statement “Supplement to Test Report dated DateMonth-Year” along with a reference to the orig inal report. Amendments, corrections, or replacements will conform to the requirements of this section and ASTM D 7036.32

RECORDS MANAGEMENT

Avogadro maintains project and quality system reco rds for at least ten years from the date of origination. Hardcopy documents are controlled in secure areas where they are protected from reasonably foreseeable exposure to damage or theft. Additionally, hardcopy documents
are scanned for electronic archival. Access to stored records is documented with “file out” cards and logbooks. Electronic records are back ed-up daily. Weekly, the back-up drives are changed and are stored offsite.

In the event Avogadro is sold, the records will be transferred to the new owner. In the event, Avogadro ceases business operations, appropriate arrangements will be made for either (i) the return of project files to clients, (ii) th e proper destruction and disposal of records that have been retained for more than 10 years, or (iii) continued storage of records until the 10- year period has elapsed.

CONFIDENTIALITY

The nature of Company work requires confiden tiality to prevent the unauthorized release of confidential, sensitive, or proprietary busine ss data to third parties. Avogadro does not release project summaries or client lists without approval from the clients.33

6.0 EMISSIONS TEST REPORT

The raw field data will be combined into sp readsheets to calculate the applicable test results. All field data sheets, emissions calculation spreadsheets, analytical data, calibration data and analyzer data summaries will be included in the final report. Test results will be presented in the reporting units as listed in Table 3.

Avogadro will issue a draft comprehensive emi ssions test report to American Bituminous within 45 days of completion of testing. The final report will be signed by a licensed Certified Industrial Hygienist (CIH) or a Pr ofessional Engineer (PE) licensed in the Commonwealth of Pennsylvania. It will documen t all results of the testing program, and it will include all of the support data to inde pendently calculate the test results. Other than the title and certification pages, the main components of the report will be as
follows:

1. Introduction, which includes an overview and a summary of purpose and scope;
2. A summary and discussion of results, which includes comparison to permit standards, as well as a summary of test dates and times;
3. Summary of sampling locations;
4. Sampling / analysis procedures as well as any departures from USEPA test methods;

5. Appendices.

The appendices may include but are not limited to raw field data, notes, process/production data, laboratory reports and chains of custody, calibration certificates, results summaries, calculations and spreadsheet s, example calculations using actual field data, quality assurance data, diagrams and a copy of the approved test protocol and related correspondence.

Protocol submitted by: Reviewed by:

Janeen D. Maruskanic Thomas F. Mattei Air Quality Scientist Qua lity Assurance Manager / Technical Director

F:\2010 Projects\2010 projects\American Bituminous ICR MACT 10-7091\QAPP\final American Bituminous QAPP.docAttachment 1

Example CalculationsAttachment 2

Field Data Sheets and Chain of Custody Form**This is the last page of the plan**

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