United States        Office of Air Quality
Environmental Protection   Rannlng and Standards
Agency          Research Triangle Park, NC 27711
EMB Report 03-UTL-2
May 1003
Air
 Electric Utility
 Combined Cycle Gas-Fired
 Gas Turbine
 Emission Test Report
Houston Lighting and Power Company
T.H. Wharton Electric Generating Station
Houston, Texas

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                    FINAL  REPORT
COMBINED CYCLE GAS-FIRED GAS TURBINE EMISSIONS TEST

         HOUSTON  LIGHTING AND  POWER  COMPANY
    T.  H.  WHARTON  ELECTRIC  GENERATING  STATION
                   HOUSTON,  TEXAS
             EPA Contract No. 68D20163
              Work  Assignment No.  1-34
                    Prepared by:

                 Research Division
                   Entropy,  Inc.
               Post Office Box 12291
   Research Triangle Park, North Carolina  27709
                   Prepared for:

                      Lori  Lay
       U. S. Environmental Protection Agency
            Emissions Measurement Branch
    Research Triangle Park,  North Carolina 27711
                    May 27,  1994

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                                 DISCLAIMER
     This document  was prepared  by  Entropy,  Inc.  under EPA  Contract No.
68D20163, Work Assignment No. 1-34.  This document has been reviewed by the
U.S. Environmental Protection Agency (EPA).

     The opinions,  conclusions,   and  recommendations expressed  herein are
those of the authors, and do not necessarily represent those of EPA.

     Mention of specific trade names  or  products within this report does not
constitute endorsement by EPA or Entropy, Inc.

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                             TABLE OF CONTENTS
1.0  INTRODUCTION 	    1
     1.1  BACKGROUND	    1
     1.2  DESCRIPTION OF THE PROJECT	    1
     1.3  PROJECT ORGANIZATION  	    3

2.0  PROCESS DESCRIPTION AND SAMPLE POINT LOCATIONS 	    4
     2.1  PROCESS DESCRIPTION 	    4
     2.2  CONTROL EQUIPMENT DESCRIPTION 	    6
          2.2.1  Nitrogen Oxides (NOX)  Control   	    6
          2.2.2  Sulfur Dioxide (S02)  Control  	    6
          2.2.3  Particulate Control  	    6
     2.3  SAMPLE POINT LOCATIONS  	    6
          2.3.1  Turbine Outlet (HRSG Inlet)  	 .  	    6
          2.3.2  Stack (HRSG Outlet)  	    7

3.0  SUMMARY AND DISCUSSION OF RESULTS	10
     3.1  OBJECTIVES AND TEST MATRIX	10
     3.2  FIELD TEST CHANGES AND PROBLEMS	12
     3.3  SUMMARY OF RESULTS	12
          3.3.1  FTIR Results	12
               3.3.1.1   Gas Phase Results  	   12
               3.3.1.2   Sample Concentration Spectra 	   13
          3.3.3  Process Operation During Testing 	   31
               3.3.3.1  Process Results 	   31
               3.3.3.2  Problems and/or Variations during Testing ...   31

4.0  SAMPLING AND ANALYTICAL PROCEDURES 	   36
     4.1  EXTRACTIVE SYSTEM FOR DIRECT GAS PHASE ANALYSIS  	   36
          4.1.1  Sampling System	36
          4.1.2  Analytical System  	   37
          4.1.3  Sample Collection Procedure  	   37
     4.2  SAMPLE CONCENTRATION  	   40
          4.2.1  Sampling System	40
          4.2.2  Analytical System  	   40
          4.2.3  Sample Collection Procedure  	   40
     4.3  CONTINUOUS EMISSIONS MONITORING 	   43
     4.4  FLOW DETERMINATIONS	44
     4.5  PROCESS OBSERVATIONS  	   46
     4.6  ANALYTICAL PROCEDURES 	   46
          4.6.1  Description of K-Matrix Analyses 	   46
          4.6.2  Preparation of Analysis Programs 	   47
          4.6.3  Error Analysis of data	48
          4.6.4  Concentration Correction Factors 	   50
          4.6.5  Analysis of Sample Concentration Spectra  	   51
                                     n

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                                (Continued)
5.0  QUALITY ASSURANCE/QUALITY CONTROL ACTIVITIES 	  52
     5.1  QC PROCEDURES FOR MANUAL FLUE GAS TEST METHODS	52
          5.1.1  Pitot Tube QC Procedures	52
          5.1.2  Sample Concentration Sampling QC Procedures  	  53
          5.1.3  Manual Sampling Equipment Calibration Procedures ...  53
               5.1.3.1  Type-S Pitot Tube Calibration 	  53
               5.1.3.2  Temperature Measuring Device Calibration  ...  53
               5.1.3.3  Dry Gas Meter Calibration 	  54
     5.2  QC PROCEDURES FOR INSTRUMENTAL METHODS  	  54
     5.3  QA/QC CHECKS FOR DATA REDUCTION, VALIDATION, AND REPORTING   .  55
          5.3.1  Sample Concentration 	  55
          5.3.2  Gas Phase Analysis	56
          5.3.3  FTIR Spectra . .  .	56
     5.4  CORRECTIVE ACTIONS  . .  .	57

6.0  CONCLUSIONS AND DISCUSSION 	  58

7.0  REFERENCES	61

APPENDICES

     A - Results and Calculations
     B - Raw Field Data and Calibration Data Sheets
     C - Analytical Data
     D - EPA Methods and Protocol
                                    m

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                             1.0  INTRODUCTION

1.1  BACKGROUND

     The U. S. Environmental Protection  Agency  (EPA)  Office of Air Quality
Planning and Standards  (OAQPS), Industrial Studies Branch (ISB), and Emission
Measurement Branch (EMB) directed Entropy, Inc.  to conduct an emission test
at  Houston Lighting  and Power  Company's  (HLPC)  T.  H. Wharton  Electric
Generating Station combined-cycle gas-fired  gas  turbine in  Houston,  Texas.
The test was conducted on May 17  and  18,  1993.  The purpose of this test was
to identify which hazardous air pollutants (HAPs) listed in the Clean Air Act
Amendments of 1990 are  emitted from this source.   The measurement method used
Fourier transform  infrared (FTIR) technology, which  had been developed for
detecting and quantifying many organic HAPs  in  a flue gas stream.   Besides
developing emission  factors  (for this source  category), the data  will  be
included in an EPA report to Congress.

     Before this test  program, Entropy conducted screening  tests using the
FTIR method at facilities representing several  source categories, including
a coal-fired  boiler.   These screening tests were part  of  the  FTIR Method
Development  project   sponsored   by  EPA  to  evaluate   the performance  and
suitability of FTIR spectrometry  for  HAP  emission measurements.  These tests
helped determine sampling and  analytical limitations, provided qualitative
information on emission  stream composition,  and allowed estimation  of the
mass emission rates for a number  of HAPs  detected at many process locations.
The evaluation demonstrated that  gas phase analysis using FTIR can detect and
quantify many HAPs at concentrations  in the low part per  million (ppm) range
and higher, and a sample concentration technique was able to detect HAPs at
sub-ppm levels.

     Following the screening tests,  Entropy conducted  a field  validation
study at a coal-fired steam generation facility to assess the effectiveness
of the FTIR method for measuring  HAPs,  on a compound by compound basis.  The
flue  gas  stream  was  spiked with  HAPs   at  known  concentrations  so  that
calculated concentrations, provided by the FTIR analysis, could be compared
with actual concentrations in the gas stream.  The analyte spiking procedures
of EPA Method 301 were adapted  for experiments with 47 HAPs.  The analytical
procedures of Method 301 were used to evaluate the accuracy and precision of
the results.   Separate procedures  were  performed to  validate  a  direct gas
phase analysis technique and a  sample concentration  technique of  the FTIR
method.  A complete  report,  describing the  results  of the field validation
test, has been submitted to EPA.1

     This  report was  prepared  by  Entropy,   Inc.  under EPA Contract  No.
68D20163,  Work Assignment  No.   1-34.    Research  Triangle  Institute  (RTI)
provided the process information given in Sections 2.1 and 3.3.3.

1.2  DESCRIPTION OF THE  PROJECT

     The FTIR-based method uses two different sampling  techniques: (1) direct
analysis of the extracted gas stream  (hereafter referred  to as the gas phase
technique or  gas  phase analysis) and (2) sample concentration  followed by
thermal  desorption.   Gas phase  analysis involves extracting gas  from the

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sample point  location  and transporting the  gas  through sample  lines  to a
mobile laboratory where sample conditioning and FTIR analyses are performed.
The sample  concentration  system employs  10  g  of Tenax  sorbent,  which can
remove organic compounds from a flue gas stream.  Organic compounds adsorbed
by Tenax  are  then thermally desorbed  into  the  smaller  volume  of the  FTIR
absorption cell; this  technique  allows detection  of  some compounds down to
the ppb level  in the original sample.   For this test, approximately 850 dry
liters  of  flue  gas  were  sampled  during  each  run  using  the  sample
concentration system.  Section 4.0 describes the sampling systems.

     Entropy  operated   a  mobile  laboratory  (FTIR  truck)  containing  the
instrumentation and sampling equipment.  The  truck was driven to the site at
T. H. Wharton,  and  parked next to the sampling location.   Three test  runs
were performed over a two-day period.

     Entropy tested the exhaust gases from one of the gas turbines operated
by T.H.  Wharton  to generate electricity.  The turbine  burns  natural  gas.  Hot
gases from the combustion  of  the natural gas drive the turbine.  Gases (about
1000°F)  exiting  the turbine pass through  an exhaust duct to a heat recovery
steam generator  (HRSG).   Heat  is  recovered  in  the HRSG to  produce steam,
which in turn is used  to  drive  a steam turbine.   The cooled gases exit the
HRSG to be  exhausted through a short  stack.   The only  control  device  is a
water injection  system used to minimize  NOX emissions.   Entropy  installed
sampling  equipment  in  ports  available  on  the  gas  turbine exhaust  duct
upstream  of  the  heat  recovery  steam generator.   Section  2.0  contains
descriptions of the process and the sampling point locations.

     Direct gas  phase  analysis was used  to  measure carbon  monoxide  (CO),
carbon dioxide  (C02),  sulfur  dioxide  (S02),  nitrogen oxides (NOX), and ppm
levels of other species.  EPA instrumental test methods were used to provide
concentrations  of  CO,   C02,  02,  and  hydrocarbons  (HC).    The  sample
concentration technique was  used to measure  HAPs at ppb  levels.   Entropy
conducted three 4-hour  sample concentration and gas phase runs at the turbine
exhaust duct  upstream  of the HRSG.   In  addition, a single  sample concen-
tration run was also conducted at the HRSG stack simultaneous with Run  2 at
the inlet of the HRSG.   Combustion gas volumetric  flows were calculated from
fuel data provided by T. H. Wharton.  Section 3.1 gives the test schedule.

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1.3  PROJECT ORGANIZATION

     The test program was funded and administered by the Industrial Studies
Branch (ISB) and the Emissions Measurement Branch (EMB) of the U.S. EPA.  A
representative from RTI collected process data.  The following list presents
the organizations and personnel  involved in coordinating and performing this
project.
HLPC Corporate Contact:
Mr. Derek Furstenwerth     (713) 897-8603
T. H. Wharton Plant
Contacts:
Mr. Ron Jernigan
Mr. Edward Wong
(713)  897-2609
EMB Work Assignment
Managers:
Ms. Lori Lay
Mr. Dennis Holzschuh
(919)  541-4825
(919)  541-5239
Industrial Studies Branch
(ISB) Contacts:
Mr. Kenneth Durkee
Mr. William Maxwell
(919) 541-5425
(919) 541-5430
Entropy Project Manager:
Dr. Thomas Geyer
(919)  781-3551
Entropy Test Personnel:
Mr. Scott Shanklin
Ms. Lisa Grosshandler
Dr. Laura Kinner
Mr. Greg Blanschan
Mr. Mike Worthy
RTI Representative:
Mr. Jeffrey Cole
(919) 990-8606

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            2.0  PROCESS DESCRIPTION AND SAMPLE POINT LOCATIONS

     The process  information  was supplied  by the T.H.  Wharton Generating
Station.

2.1  PROCESS DESCRIPTION

     Houston Lighting  & Power Company's  (HLPC)  T.H.  Wharton  Unit  Four is
located in  Houston, Texas.  Unit Four began operation  in  1974 and consists of
four combined cycle gas  turbines, numbered 41, 42, 43,  and 44.   Each combined
cycle gas turbine consists  of a General  Electric MS-7000  simple  cycle gas
turbine and  a  heat recovery steam generator  (HRSG).  These  components are
described below.  The four combined cycle gas turbines and their associated
steam turbine  are collectively  referred to as a  General  Electric  Stag 300
system (Figure  2-1).   Gas turbine No. 41  (GT 41)  was used for testing.  One
or more of these GT's normally  operate  during peak  usage times, which vary
depending on need.  There is a 2-week planned  outage for  each GT once a year
for an annual inspection. The primary fuel  source for GT 41 is natural gas.
GT 41 can also burn  No. 2 fuel  oil.  Only  natural gas  was used during the
test period.

     Each General Electric  MS-7000  gas  turbine  is  a 49 MW,   single-shaft,
three-bearing machine connected  to its own generator.  The hot  gases exiting
the combustion  chambers drive the gas turbines, which in turn develop power
to drive the axial compressor  and to produce useful shaft output for driving
the generator.

     The exhaust from all  four GT's  is used in the combined-cycle mode as the
heat energy input to  produce steam from HRSG feedwater.   Each gas turbine has
its own HRSG.   The saturated  steam  in each HRSG  drum is superheated by gas
turbine exhaust. This superheated steam is collected from all four HRSGs and
used to turn a  102.5 MW steam turMne generator.

     The gas turbine is  equipped with  a set of dampers which  allow the
turbine to  operate in simple-cycle or combined-cycle mode.  The  bypass damper
controls flow  through  the bypass or  simple-cycle stack, and  the isolation
damper  controls flow  through the  HRSG.    During start-up operations the
isolation damper is  closed, preventing  flue gas  flow through  the HRSG, and
the  bypass  damper  is open,  allowing flue  gas  to exit  through  the bypass
stack.  This is referred to  as simple-cycle operation.  Once the turbine has
completed start-up procedures the isolation damper is opened and the bypass
damper is closed redirecting  flue gas flow through  the  HRSG.   The hot flue
gas  heats  boiler feed water  to  produce steam, which, once it has reached
sufficient  quality,  is  used to drive  a  steam turbine  to   produce  more
electricity.  This is referred to as combined-cycle operation.

     GT 41  can  produce  48 to 62 MW depending on the time  of  year.  In winter,
the  inlet  air  is  colder and denser,  allowing  more fuel  to  flow  to the
turbines producing greater  output.   The  opposite occurs during the summer
when the inlet  air is less dense.  Unit Four  is nominally rated at 300 MW.

     GT 41  can produce  210,000  Ib/hr of  steam from  its  HRSG  for the steam
turbine generator.   All four GT's  in Unit Four  are capable of a combined
840,000 Ib/hr  of steam.

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 GT44    Natural
          Gas
Combustion
 System
 GT43    Natural  Exhaust
          Gas
                                                                         3.5' \Deaerator/
                                                                            Condenser

                                                                             Makeup
                                                                            — W&ter
                                                                            (it necessary)
Legend
Air & Gas - -
Fuel —
Water & Steam

- - •
- —
	
 Figure 2-1.  Houston Lighting & Power Co. - T. H. Wharton Electric Utility
      Generating Station - Unit Four (General Electric Stag 300 System)

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2.2  CONTROL EQUIPMENT DESCRIPTION

2.2.1  Nitrogen Oxides (NOJ  Control
                         -xJ
     A water injection system for NOX control  is incorporated in the design
of GT 41.  The water injection system operates using demineralized water from
the  station  feedwater treatment  system.    Water is  vaporized  when  it  is
injected into the combustion air  stream.   The  vaporization process removes
some of the heat from the combustion  chamber,  thus  lowering the peak flame
temperature.   The  result of  this temperature  reduction  is to  reduce  the
formation of thermal  NOX.

2.2.2  Sulfur Dioxide (SO;)  Control

     Emissions of S02 are considered negligible for natural  gas firing.  When
using the alternate fuel  (No.  2  distillate), S02 emissions are controlled by
the use of  low  sulfur content oil.   The maximum  sulfur content acceptable
under current permit specifications is 0.5 percent sulfur by weight.

2.2.3  Particulate  Control

     Particulate and visible emissions are  limited  by using natural gas as
the primary fuel and  No.  2 distillate  oil as an alternate fuel.  In addition
to  the  low ash  characteristics  of  No.  2  fuel  oil,  each gas  turbine  is
equipped with a swirl  plate to impart a swirl to the  combustion air to ensure
a thorough mixing of air and fuel so that complete combustion occurs.


2.3  SAMPLE POINT LOCATIONS

     There were two options for a sampling location,  at the turbine outlet
(HRSG inlet) or the stack (outlet of the HRSG).  The turbine outlet location
was  selected  for testing because of  concern  that vents near  the emission
point on the  stack would  allow  ambient air to dilute  to sample stream.   A
second sampling train was available,  and one sample concentration run of the
system was performed  at  the  stack concurrently with sample concentration Run
2 at the turbine outlet.

2.3.1  Turbine Outlet (HRSG Inlet)

     Figure 2-2 depicts the turbine outlet location.  Six sample ports were
available across the top of the 22.5-foot  wide,  7.25-foot  deep gas turbine
exhaust duct.   The ports  were located 13  feet  down-stream of  a damper and
3.25 feet upstream  of a widening in the duct (diffuser) that led  to the HRSG.
The separate sample probes were  installed in the two  middle  ports  (see Figure
2-2).   A pitot  probe was  installed  in  the  port  adjacent to  the sample
concentration probe  to  provide   indications of changes in  the  exhaust  gas
flow.  These ports were the only  ports used during  the test.   The flue gas
conditions  prohibited  sample  and   pitot   probe  traverses  to  check  for
stratification in the gas stream, and determine flue gas volumetric flow.

     According to  HLPC  personnel, gas stratification  was  unlikely at this
location on the process.  A sample point traverse across the duct through a

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single  port  was  performed  using  the  gas  phase  probe  to  check  for
stratification and the results of the 02 traverse indicated the  stream was not
stratified (see Section 3.3.2).   The sample concentration and the gas phase
probe tips were both inserted to a depth of 3 ft.

     Flue gas  conditions  at the sample point location were 990°F and about 20
inches of water  positive  pressure.   Due to these extreme  conditions,  as a
safety concern,  the  facility did not fire the turbine during the installation
of the  sampling probes,   but  fired  the turbine once  Entropy was  ready to
proceed with the test.

2.3.2  Stack (HRSG Outlet)

     Dimensions of the stack location are  shown in  Figure  2-3.   The sample
port was  1-foot  below  the top of the  stack which was open.  The  gas  flow
presumably prohibited mixing between flue gas and  air at the test point, but
there were no CEM,  Orsat or gas phase FTIR measurements performed to verify
this.  Horizontal vents around the stack just below the level  of the sample
port were  closed during  the  test  run,  so there should  have been  no air
leakage from this source.  Although this location did not meet EPA Method 1
criteria, EPA believed  the composition  of the stack outlet to be of interest
so a single sample concentration run was performed.

     The sample concentration probe  extended through  the port several  feet
into the opening at  the top of the stack. The gas  stream was between 290 and
300°F during the test run.  This  allowed Entropy to set up the apparatus and
insert the probe while  the process was operating.

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 Gas-Fired
Gas Turbine
    A Gas Phase Sample Port
    B Sample Concentration Sample Port
    C Pitot and Thermocouple
                        Damper
                                       Diffuser •
                                  TOD View
                                                               Stack














Gas-Fired
Gas Turbine










1 J'
k )





Bypass
s— Damper




7-3"
T







— f>»

Stack

Ctn/«U
Transition
HRSG
1

/









                                 Side View
Figure 2-2.  Houston Lighting and Power, T.H. Wharton Generating Station.

                                     8

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 Gas-Fired
Gas Turbine
22'-6"
                                Damper
                        IX
                                                       Diffuser
                                          TOD View
                                                                        Stack

                                                                       i-n'-l
                                                                        Stack
                                                                      Transition
                                                                       Sample
                                                                        Port
                                       Steam Generator
                                         Elbow Module
                                          End View
Figure 2-3. Houston Lighting and Power, T.H. Wharton Generating Station stack test location.

                                              9

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                   3.0   SUMMARY AND DISCUSSION OF  RESULTS
3.1  OBJECTIVES AND TEST MATRIX

     The purpose  of the test program  was  to obtain  information  that will
enable EPA to develop emission factors (for as many HAPs as possible) which
will apply to electric utilities  employing gas-fired gas turbines.  EPA will
use these results to prepare a report for Congress.

     The specific objectives were:

          •    Measure  HAP  emissions  (employing  methods  based  on  FTIR
               spectrometry) in two concentration ranges,  above 1 ppm using
               gas  phase  analysis,  and  to  sub-ppm  levels  using  sample
               concentration/thermal desorption.

          •    Determine maximum possible concentrations for undetected HAPs
               based on  detection  limits of instrumental  configuration and
               limitations imposed by composition of flue gas matrix.

          •    Measure 02,  C02, CO,  and hydrocarbons  using gas analyzers.

          •    Perform simultaneous testing  at  the  inlet  and  outlet  of the
               HRSG and analyze data to assess effect (if any) of the HRSG on
               HAP emissions.

          •    Obtain  process  information  from  T.  H.   Wharton.    This
               information includes the rate of power production during the
               testing periods.
     Table 3-1  presents the  testing  schedule that  was  followed at  T.  H.
Wharton.
                                     10

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                                        TABLE 3-1.

               FTIR TESTING SCHEDULE AT T.H. WHARTON GAS FIRED GAS TURBINE
SAMPLING PERIODS
Date
5/17/93
5/17/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
Run#a
Amb
1
2


3

Amb
Amb
Locb
I
I
S
I
I
I
I
I
S
Sample0
Conditioning

H/W

H/W
COND
P/P
H/W


Gas Phase
Analysis

1804-1939

1140-1208
1226-1431
1521-1624
1635-1652


Sample
Cone.
1005-1105
1445-1845
1057-1407
1100-1500

1555-1955

2030-2130
1530-1645
CEM
Analyzers

1449-1940

1039-1208
1209-1431
1432-1624
1625-1654


Thermal Desorption
Date
5/18
5/18
5/19
5/19

5/19

5/18
5/18
Time
2226-2040
2328-2349
0026-0049
2349-0014

0053-0118

2246-2259
2304-2318
(a)   Amb denotes an ambient sample.
(b)   Location designations; I = Gas Turbine outlet (HRSG Inlet), S = Stack (HRSG Outlet).
(c)   H/W = Hot/Wet Sample; COND = Condenser Sample; P/P = Perma Pure Sample.
                                           11

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3.2  FIELD TEST CHANGES AND PROBLEMS

     On the initial test day  Entropy  experienced  difficulties aligning the
FTIR cell.  It was  important  to  achieve  satisfactory alignment of the cell
because this determined the intensity  of the  signal  reaching the detector,
which in turn influenced the  signal to noise  ratio  (S/N)  of the data.  The
sensitivity of the  instrument depends,  in  part,  on S/N.    The problem was
corrected but not  before  set-up of the  sample  concentration apparatus was
complete and the plant was operating under conditions suitable for testing.
It was decided to begin sample concentration Run 1  and begin  direct gas phase
testing as soon as possible during Run 1.  As a result there are direct gas
phase  and  CEM  data  covering  only  a  portion of  Run 1.    This  was  deemed
acceptable because there was  ample  opportunity  to obtain  gas phase data on
the second test day.

     The second change was  introduced  to permit the completion of two test
runs in a single day.  Initially, the plan called for the completion of two
4-hour sample concentration runs with concurrent gas phase runs performed
over the entirety of the two 4-hour periods.  Instead, sample concentration
Run 1 commenced  as  soon as the system was  ready and the turbine was operating
at full capacity.   Direct gas  phase  testing  commenced about  40 minutes after
the beginning of Run 2.  Gas phase analysis  continued through the end of Run
2 and into Run 3 but was stopped before Run 3 was completed.  This plan was
the best way to  accomplish the test objectives and  complete the test runs
within the originally scheduled  time.  Also, it was not necessary for the gas
phase analysis to run for  the entire  4 hours  of each Run  to collect enough
data to characterize the flue gas stream.


3.3  SUMMARY OF RESULTS

3.3.1  FTIR Results

     Gas phase and sample concentration data were analyzed  for the presence
of  HAPs  and  other  species.     All  spectra  were  visually  inspected  and
absorbance bands were identified.  Then spectra were  analyzed, using analysis
procedures developed by Entropy, to determine concentrations of any species
detected.   These  results  are  presented in Table  3-2.    Maximum possible
concentrations were determined  for undetected  HAPs.   These  results  are
presented in Tables 3-3 to 3-5.

3.3.1.1   Gas Phase  Results  Each  gas phase FTIR  spectrum was separately
analyzed for the  presence  of  HAPs or  other species.  The spectra revealed
that the gas phase samples were composed primarily of;

     •    water vapor
     •    C02
     •    Smaller amounts  of NO  (an  average of about 15 ppm)  and CO were also
          detected.
     •    N02 was  detected  but not quantified because quantitative reference
          spectra are not currently available.

     Calculated concentrations of NO for  each  spectrum will  be  included in a


                                     12

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table with the  final  report.   No S02 or HC1 was detected  in  the gas phase
spectra.   The  spectra  were  analyzed  for  the  presence of  HAPs  that  are
currently represented in the  quantitative  reference  spectra  library.  None
were detected.  Previously, Entropy  developed  analysis programs to analyze
for HAPs in FTIR spectra of samples extracted from a coal-fired boiler stack.
Statistical  analyses showed that  the programs  were  successful  in measuring
some HAPs in hot/wet and condenser samples.1  The major interferant species
detected at the coal-fired boiler  are  very similar  to  those  that have been
identified at the gas-fired gas turbine (with the exception that  S02 was not
detected in the gas-fired exhaust).  Therefore, the same programs were used
to analyze the data obtained in this test.  The results of the analyses are
presented in Appendix C.

     A  set  of  subtracted  spectra was generated  so that  maximum possible
(minimum detectible) concentrations  could  be calculated for  HAPs that were
not identified in  the sample stream.  Reference spectra of water vapor and C02
were scaled and subtracted  from each of the field  spectra.   The remaining
base  lines  were   then  analyzed  for  every compound   represented   in  the
quantitative   spectral   library   to   determine   the  maximum  possible
concentrations of HAPs that were undetected.  The  calculations were performed
according to the procedures described in  Section  4.6.3.  Results  for hot/wet
and  dry  (treated with  the  condenser  or  PermaPure  dryers)  spectra  are
presented in Tables 3-3 and 3-4  respectively.  The  results are averages of
the calculated values for all  of the spectra over the 3 sample runs.

     The hot/wet gas phase  spectra are  the  most difficult to analyze because
there is strong interference from water vapor.  Even  so, in results from the
hot/wet gas phase data,  92 compounds gave minimum detectible concentrations
below 10 ppm, and of these, 77 are below 5 ppm, and 26 are 1 ppm or lower.

     The results  represent upper  limits  for in-stack concentrations of the
HAPs listed.   This means that,  for a HAP to be present in the gas  stream, its
concentration must have been  below the calculated  maximum possible concen-
tration.

3.3.1.2   Sample  Concentration Spectra   The sample  concentration spectra
represent integrated samples taken over each 4-hour run.

     •    Ammonia  (NH3)  was detected in  samples  from all  three runs at the
          turbine outlet and  in the  sample taken from  the  HRS6 outlet.   It
          was also present  in  the ambient samples  collected  at each location.

     •    HC1 was detected in the  sample from  Run  1  and in  both ambient
          samples at the turbine outlet.

     •    Evidence of hexane Was observed in samples  from both locations and
          the  ambient  samples.   Absorbances similar  to  hexane  are often
          observed in spectra  of desorbed samples.  These features may be due
          to a mixture of alkane hydrocarbons,  including hexane, the sum of
          whose spectra gives absorbances which appear similar to hexane.

     •    A siloxane compound was detected that Entropy first identified in
          spectra of samples taken at the coal-fired boiler  validation test.1


                                     13

-------
          This compound was shown to be a product of a reaction between HC1
          or water  vapor  in  the gas  stream and  materials  in the  filter
          housing of the Method  5 box.  Entropy took steps to eliminate this
          problem and the  siloxane,  if it is a  contaminant,  is  present at
          very low levels relative to validation data.

     •    Nitrous acid (HN02)  was detected in spectra from Runs 1  and 2 and
          from  the  HRSG  outlet.   This   compound  was  probably  formed  by
          reaction of the NOX  in the gas  stream with the water condensed in
          the collection tube.

     Table 3-2  shows  calculated concentrations of HC1,  NH3,  and  hexane in
samples where these  species were detected.  In-stack concentrations are also
given  for  the same  species.    In-stack  concentrations were  determined by
dividing the in-cell concentration by the concentration factor (see Section
4.6.4).  The in-stack concentrations are  based on the volume of gas sampled
and do  not  account  for effects  of  the sampling system  or  the adsorption/
desorption efficiencies of HC1 and NH3.  Therefore, the values in Table 3-2
represent lower limits on the concentrations for these species.  Upper limits
are provided by the  values given  in the gas phase data  (Tables 3-3 and 3-4).e
gas stream.  Table  3-5  gives  minimum detectible concentrations for species
not detected using Tenax and the maximum in-stack concentrations are based on
the amount of gas sampled (See Section 4.6.5)

     Other  absorbance   bands   were  also  observed   which   still   remain
unidentified.  None  of these bands were attributed  to HAPs for which Entropy
currently has reference  spectra.   When these  bands  are  identified, it should
become  clear  whether they  are  due  to emissions  from the process  or were
formed by conditions unrelated to the process  (i.e.  by contamination).  These
bands  do  not  consistently  appear in every sample  so  it is  possible that
concentrations of some species varied during  the test Runs.

     Spectral analysis programs  were also  developed for sample concentration
spectra.    The   analysis   programs   were used   to   evaluate  the  sample
concentration data  for  HAPs.    The  results,  presented in Appendix  C, give
calculated concentrations only  for  those  HAPs  that Entropy  has proven in a
field validation study can be measured using  Tenax.
                                     14

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             TABLE 3-2.  CONCENTRATIONS CALCULATED FOR SOME COMPOUNDS
                       DETECTED IN SPECTRA OF CONCENTRATED SAMPLES EXTRACTED
                       FROM THE UNIT 4 STACK AT WHARTON GAS-FIRED TURBINE.
Spectra


TINL125B
TINL204B
TINL302B
TINLAMB1
TINLAMB2
TOUT109B
TOUTAMB1
Nitric Oxide (a)
In-Cell Flue Gas
(ppm) (c) (ppm) (d)
52.72
59.60
48.21
3.42
-0.34
54.81
5.20
0.3258
0.5575
0.2705
0.0230
-0.0023
0.3980
0.0377
Ammonia
In-Cell Flue Gas
(ppm) (ppm)
0.07
-0.22
0.01
-0.48
-0.81
16.68
1.73
0.0004
-0.0021
0.0001
-0.0032
-0.0055
0.1212
0.01 26
Hydrochloric Acid
In-Cell Flue Gas
(ppm) (ppm)
7.29
2.20
-120.66
23.22
2.70
4.22
2.95
0.0451
0.0206
-0.6771
0.1561
0.0182
0.0307
0.0215
Hexane (b)
In-Cell Flue Gas
(ppm) (ppm)
1.42
0.50
-14.91
3.09
0.71
4.33
1.42
0.0088
0.0046
-0.0837
0.0208
0.0048
0.0314
0.0103
(a) Compounds for which Entropy has obtained quantitative reference spectra.
(b) Probably a mixture of alkane hydrocarbons which may include hexane and together
   give absorbancs similar to hexane.
(c) Concentration of detected compound in FTIR cell calculated using MCOMP analytical routine.
(d) Concentration of detected compound in flue gas calculated by dividing in-cell concentration by
   the concentration factor (see Section 4.6.5).

-------
TABLE 3-3. CALCULATED MAXIMUM (MINIMUM DETECT1BLE) CONCENTRATIONS:
         HAP SPECIES NOT DETECTED IN SPECTRA OF HOT/WET SAMPLES. UNIT 4 GAS-FIRED
         GAS TURBINE OUTLET.
Location
Compound (a)
Acetonrtrile (e)
Acrolein
Acrylonrtrile
Ally! Chloride
Benzene
Bromoform
1 ,3-Butadiene
Carbonyl Sutfide
Chlorobenzene
Ethyl Benzene
Ethyl Chloride
Ethylene Dibromide
n-Hexane
Methyl Bromide
Methyl Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methyl Methacrylate
Methylene Chloride
2-Nrtropropane
Propylene Oichloride
Styrene
Tetrachloroethylene
Toluene
1,1 ,2-Trichloroethane
Trichloroethylene
2,2,4-Trimethylpentane
Vinyl Acetate
Vinyl Bromide
Analytical Region (wn) (b)
1039.90 - 1064.00
2636.11 - 2875.59
922.19 - 997.82
893.51 - 1002.22
3020.15 - 3124.44
1134.18 - 1159.39
870.00 - 1052.64
2029.21 - 2075.69
1012.42 - 1036.64
2854.28 - 3122.12
2916.56 - 3041.03
1167.96 - 1208.92
2835.27 - 3005.43
2938.47 - 3002.81
2928.38 - 3099.97
1140.70 - 1222.63
2872.05 - 2994.95
1137.50 - 1232.04
1241.32 - 1290.95
831.47 - 868.50
2927.59 - 3031.58
886.32 - 931.22
899.20 - 925.20
2862.00 - 2924.00
909.41 - 960.62
826.25 - 860.91
2861.57 - 3009.23
832.23 - 906.69
939.59 - 944.72
Inlet
Max. Con.
RMS (c) (ppm) (d)
4.03E-03
1.91E-03
4.57E-03
5.13E-03
9.02E-03
3.78E-03
6.06E-03
1.98E-02
6.16E-03
8.00E-03
6.62E-03
5.84E-03
4.41 E-03
4.81 E-03
6.85E-03
5.76E-03
4.36E-03
7.50E-03
2.11E-02
3.24E-03
6.16E-03
2.26E-03
2.17E-03
1.99E-03
4.43E-03
3.41 E-03
4.78E-03
2.92E-03
4.90E-03
55.17
2.50
3.76
4.19
4.83
0.67
6.35
1.13
5.67
8.34
4.92
4.16
0.64
6.38
14.42
4.25
1.84
0.84
11.47
3.57
5.88
1.71
0.20
3.15
4.61
0.53
0.58
1.80
1.57
                                    16

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TABLE 3-3.  (Continued)
Location
Compound (a)
Vinyl Chloride
Vinylidene Chloride
O-xylene
P-xylene
Carbon Disulfide
Carbon Tetrachloride
Chloroform
Cumene
1 ,2-Epoxy Butane
Ethylene Oxide
Methanol
Methyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
Propyiene Oxide
M-xylene
Acetone
Acetaldehyde
Acetophenone
Acrylic Acid
Aniline
Benzotrichloride
Benzyl Chloride
Bis(chloromethyl)ether
Chloroacetic acid
2-Chloroacteophenone
Chloromethyl methyl ether
Chloroprene
o-Cresol
Analytical Region (wn) (b)
852.81 - 1056.06
1059.44 - 1113.01
2859.84 - 3095.04
2854.43 - 3083.14
2188.79 - 2196.47
758.21 - 804.29
1210.20 - 1229.00
2871.26 - 3095.39
902.37 - 919.70
866.90 - 875.00
2807.91 - 3029.40
710.05 - 736.84
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2846.93 - 3090.79
1182.00 - 1255.03
3006.20 - 3009.20
1140.40 - 1286.06
758.79 - 1378.25
1102.90 - 1123.63
3069.50 - 3088.80
3070.16 - 3085.53
1218.65 - 1260.78
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 - 1146.08
971.60 - 975.80
1092.80 - 1114.07
Inlet
Max. Cone.
RMS (c) (ppm) (d)
6.01 E-03
6.29E-03
7.20E-03
7.30E-03
2.74E-03
6.41 E-02
1 .32E-02
7.25E-03
2.01 E-03
1.60E-03
5.54E-03
5.84E-01
1.12E-03
3.54E-03
7.33E-03
7.27E-03
8.46E-03
2.54E-03
1.00E-02
1.67E-01
5.15E-03
6.30E-03
6.42E-03
1.05E-02
4.93E-03
8.38E-03
4.44E-03
3.56E-03
4.65E-03
6.14
1.68
4.56
3.99
2.18
2.96
3.01
18.16
1.46
0.38
4.46
37.19
1.01
0.56
4.64
7.00
3.67
6.04
1.29
83.84
1.64
5.12
10.35
3.91
1.05
1.54
0.64
1.88
1.93
                                     17

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TABLE 3-3.  (Continued)
Location
Compound (a)
m-Cresol
p-Cresol
,2-Dibromo-3-chloropropane
1 ,4-Dichlorobenzene
Dichloroethyl ether
1 ,3-Dichloropropene
Dichlorvos
N,N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1 -Dimethyl hydrazine
Dimethyl phthalate
1 ,4-Dioxane
Epichlorohydrin
Ethyl Acrylate
Ethylene Dichloride
Ethylidene dichloride
Formaldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
Hexachloroethane
Hexamethylphosphoramide
Hydrochloric Acid
Isophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
N-Nitrosodimethylene
Analytical Region (wn) (b)
915.55 - 939.18
1245.80 - 1265.40
2959.13 - 2985.82
995.96 - 1031.06
2662.14 - 3089.07
768.00 - 791.00
835.77 - 876.95
2655.32 - 3156.07
889.55 - 917.52
2824.80 - 2873.60
856.12 - 974.09
1157.86 - 1254.16
2967.40 - 2970.30
943.52 - 981.73
1181.93 - 1210.00
2965.00 - 2999.00
2792.57 - 3132.83
2788.33 - 2842.20
976.90 - 997.70
1227.02 - 1240.42
785.50 - 793.00
949.42 - 1019.53
2817.35 - 2823.26
2681.20 - 3130.60
838.45 - 841.30
2683.00 - 3061.78
779.31 - 783.55
841.70 - 861.39
928.00 - 1085.28
Inlet
Max. Cone.
RMS (c) (ppm) (d)
2.64E-03
9.24E-03
5.33E-03
2.64E-03
7.06E-03
1 .66E-02
3.16E-03
8.71 E-03
1.81E-03
1.34E-03
3.92E-03
7.95E-03
1.91 E-03
4.61 E-03
5.12E-03
5.66E-03
8.64E-03
1.75E-03
3.73E-03
3.96E-03
3.17E-02
3.86E-03
8.23E-04
8.59E-03
1.90E-03
6.32E-03
2.40E-03
3.48E-03
6.44E-03
1.63
1.50
8.97
1.13
8.64
3.31
0.36
4.96
0.45
0.83
3.17
4.12
0.57
3.69
0.26
8.32
36.73
1.72
0.51
0.29
1.38
0.51
0.79
5.34
0.19
6.77
0.23
1.34
1.95
                                   18

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      TABLE 3-3. (Continued)
Location
Compound (a)
N-Nitrosomorpholine
Phenol
Deta-Propiolactone
Propionaldehyde
1 ,2-Propylenimine
Quioline
Styrene Oxide
1 ,1 ,2,2-Tetrachloroethane
2,4-Toluene diisocyanate
o Toluidine
1 ,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Ammonia
Analytical Region (wn) (b)
1024.64 - 1258.17
2494.80 - 2530.90
860.13 - 957.64
2546.18 - 3114.35
817.57 - 821.31
800.19 - 803.73
861.39 - 903.93
794.92 - 824.07
885.61 - 905.31
2729.50 - 2758.80
1009.00 - 1198.39
1178.04 - 1204.16
856.27 - 863.36
2756.62 - 2839.34
893.10 - 926.00
Inlet
Max. Cone.
RMS (c) (ppm) (d)
7.05E-03
1.17E-03
3.73E-03
7.44E-03
1 .39E-03
3.92E-03
2.46E-03
5.49E-03
1 .21 E-03
1.48E-03
5.98E-03
5.27E-03
1.84E-03
1.83E-03
2.07E-03
2.94
19.25
0.76
7.82
0.59
0.57
1.70
1.22
0.86
16.13
3.99
1.58
0.43
0.76
1.23
(a) HAP's for which Entropy has obtained quantitative reference spectra.
(b) Region, in wavenumbers (1/cm) chosen for the analysis.
(c) Calculated root mean square deviation over the analytical region in spectra that were generated by
    subtracting reference spectra of interferant species from the sample spectra.
(d) Maximum Concentration of undetected compound calculated according to procedures discussed in
    Section 4.6.3.
(e) For explanation and discussion of Max. Con. result see section 3.3.1.
                                             19

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TABLE 3-4. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTJBLE) CONCENTRATIONS:
     HAP SPECIES NOT DETECTED IN SPECTRA OF CONDENSER SAMPLES
     UNIT 4 GAS-FIRED GAS TURBINE OUTLET.
Location
Compound (a)
Acetonrtrile (e)
Acrolein
Acrylonrtrile
Ally! Chloride
Benzene
Bromoform
1 ,3-Butadiene
Carbonyl Sulfide
Chlorobenzene
Ethyl Benzene
Ethyl Chloride
Ethylene Dibromide
n-Hexane
Methyl Bromide
Methyl Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methyl Methacrylate
Methylene Chloride
2-Nitropropane
Propylene Dichloride
Styrene
Tetrachloroethylene
Toluene
1 ,1 ,2-Trichloroethane
Trichloroethylene
2,2,4-Trimethylpentane
Vinyl Acetate
Vinyl Bromide
Analytical Region (wn) (b)
1039.90 - 1064.00
2636.11 - 2875.59
922.19 - 997.82
893.51 - 1002.22
3020.15 - 3124.44
1134.18 - 1159.39
870.00 - 1052.64
2029.21 - 2075.69
1012.42 - 1036.64
2854.28 - 3122.12
2916.56 - 3041.03
1167.96 - 1208.92
2835.27 - 3005.43
2938.47 - 3002.81
2928.38 - 3099.97
1140.70 - 1222.63
2872.05 - 2994.95
1137.50 - 1232.04
1241.32 - 1290.95
831.47 - 868.50
2927.59 - 3031.58
886.32 - 931.22
899.20 - 925.20
3018.19 - 3054.70
909.41 - 960.62
826.25 - 860.91
2861.57 - 3009.23
832.23 - 906.69
939.59 - 944.72
Inlet
Max. Con.
RMS (c) (ppm) (d)
1.95E-03
9.12E-04
2.33E-03
2.07E-03
3.89E-03
1.33E-03
2.93E-03
9.61 E-03
4.89E-03
3.54E-03
3.15E-03
1.56E-03
2.19E-03
1.68E-03
3.10E-03
1.71 E-03
1.96E-03
2.06E-03
5.02E-03
1.40E-03
2.67E-03
1.46E-03
1.22E-03
3.24E-03
2.10E-03
1.78E-03
2.10E-03
1.67E-03
1.71 E-03
26.72
1.19
1.92
1.69
2.08
0.24
3.07
0.55
4.50
3.70
Z34
1.11
0.32
Z23
6.52
1.26
0.82
0.23
2.73
1.55
2.55
1.11
0.11
1.54
2.19
0.28
0.25
1.03
0.55
                               20

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TABLE 3-4. (Continued)
Location
Compound (a)
Vinyl Chloride
Vinylidene Chloride
O-xylene
P-xyiene
Carbon Oisulfide
Carbon Tetrachloride
Chloroform
Cumene
1,2-Epoxy Butane
Ethylene Oxide
Methanol
Methyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
3ropylene Oxide
M-xylene
Acetone
Acetaldehyde
Acetophenone
Acrylic Acid
Aniline
Benzotrichloride
Benzyl Chloride
Bis(chloromethyl) ether
Chloroacetic acid
2-Chloroacteophenone
Chloromethyl methyl ether
Chloroprene
o-Cresol
Analytical Region (wn) (b)
852.81 - 1056.06
1059.44 - 1113.01
2859.84 - 3095.04
2854.43 - 3083.14
1545.78 - 1549.33
758.21 - 804.29
1210.20 - 1229.00
2871.26 - 3095.39
902.37 - 919.70
866.90 - 875.00
2807.91 - 3029.40
710.05 - 736.84
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2846.93 - 3090.79
1182.00 - 1255.03
3006.20 - 3009.20
1140.40 - 1286.06
758.79 - 1378.25
1102.90 - 1123.63
3069.50 - 3088.80
1262.23 - 1277.98
1218.65 - 1260.78
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 - 1146.08
971.60 - 975.80
1092.80 - 1114.07
Inlet
Max. Con.
RMS (c) (ppm) (d)
2.85E-03
2.62E-03
3.23E-03
3.21 E-03
4.44E-02
2.27E-02
3.13E-03
3.30E-03
1.15E-03
6.99E-04
2.41 E-03
5.30E-01
4.53E-04
1.25E-03
3.38E-03
3.15E-03
2.30E-03
1.17E-03
3.12E-03
1.73E-02
1.57E-03
2.53E-03
5.79E-03
2.93E-03
1.53E-03
2.60E-03
1.72E-03
7.95E-04
1 .39E-03
2.91
0.70
2.04
1.75
1.13
1.05
0.71
8.27
0.83
0.17
1.94
33.72
0.41
0.20
2.14
. 3.04
1.00
2.80
0.40
8.69
0.50
2.05
3.48
1.09
0.33
0.48
0.25
0.42
0.58
                                         21

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TABLE 3-4. (Continued)
Location
Compound (a)
m-Cresol
p-Cresol
,2-Dibromo-3-chloropropane
1 ,4-Dichlorobenzene
Dichloroethyl ether
1 ,3-Dichloropropene
Dichlorvos
N,N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1 -Dimethyl hydrazine
Dimethyl phthalate
1 ,4-Dioxane
Epichlorohydrin
Ethyl Acrylate
Ethylene Dichloride
Ethylidene dichloride
rormaldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
Hexachloroethane
Hexamethylphosphoramide
Hydrochloric Acid
Isophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
N-Nitrosodimethylene
Analytical Region (wn) (b)
915.55 - 939.18
1245.80 - 1265.40
2959.13 - 2985.82
995.96 - 1031.06
2662.14 - 3089.07
768.00 - 791.00
835.77 - 876.95
2655.32 - 3156.07
889.55 - 917.52
2824.80 - 2873.60
856.12 - 974.09
1157.86 - 1254.16
2967.40 - 2970.30
943.52 - 981.73
1181.93 - 1210.00
2965.00 - 2999.00
2792.57 - 3132.83
2788.33 - 2842.20
976.90 - 997.70
1227.02 - 1240.42
785.50 - 793.00
949.42 - 1019.53
2817.35 - 2823.26
2681.20 - 3130.60
838.45 - 841.30
2683.00 - 3061.78
779.31 - 783.55
841.70 - 861.39
928.00 - 1085.28
Inlet
Max. Con.
RMS (c) (ppm) (d)
1.62E-03
3.46E-03
1.68E-03
1 .43E-03
2.46E-03
8.46E-03
1 .35E-03
2.95E-03
1.17E-03
9.16E-04
2.10E-03
2.39E-03
4.87E-04
2.50E-03
1 .43E-03
1.95E-03
3.33E-03
8.29E-04
1.55E-03
1.13E-03
3.42E-02
2.17E-03
6.55E-04
2.93E-03
4.78E-04
2.29E-03
1 .62E-03
1.60E-03
3.72E-03
1.00
0.56
2.82
0.62
3.01
1.69
0.15
1.68
0.29
0.57
1.70
1.24
0.15
2.00
0.07
2.86
14.16
0.82
0.21
0.08
1.49
0.29
0.63
1.82
0.05
2.46
0.15
0.62
1.13
                                        22

-------
TABLE 3-4. (Continued)
Location
Compound (a)
N-Nitrosomorpholine
'henol
beta-Propiolactone
Propionaldehyde
1,2-Propylenimine
Quioline
Styrene Oxide
1 ,1 ,2,2-Tetrachloroethane
2,4-Toluene diisocyanate
o Toluidine
1 ,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Ammonia
Analytical Region (wn) (b)
1024.64 - 1258.17
2494.80 - 2530.90
860.13 - 957.64
2546.18 - 3114.35
817.57 - 821.31
800.19 - 803.73
861.39 - 903.93
794.92 - 824.07
885.61 - 905.31
2729.50 - 2758.80
1009.00 - 1198.39
1178.04 - 1204.16
856.27 - 863.36
2756.62 - 2839.34
893.10 - 926.00
Inlet
Max. Con.
RMS (c) (ppm) (d)
3.61 E-03
7.68E-04
1.95E-03
2.41 E-03
8.74E-04
1.67E-03
1 .35E-03
2. 11 E-03
1.09E-03
7.17E-04
3.52E-03
1.50E-03
9.60E-04
8.16E-04
1 .23E-03
1.51
12.67
0.40
2.54
0.37
0.24
0.93
0.47
0.77
7.81
2.34
0.45
0.22
0.34
0.73
 (a) HAP's for which Entropy has obtained quantitative reference spectra.
 (b) Region, in wavenumbers (1/cm) chosen for the analysis.
 (c) Calculated root mean square deviation over the analytical region in spectra that were generated by
     subtracting reference spectra of interferant species from the sample spectra.
 (d) Maximum Concentration of undetected compound calculated according to procedures discussed in
     Section 4.6.3.
 (e) For explanation and discussion of Max. Con. result see section 3.3.1.
                                           23

-------
TABLE 3-5. CALCULATED MAXIMUM (MINIMUM DETECTJBLE) CONCENTRATIONS:
         HAP SPECIES NOT DETECTED IN SAMPLE CONCENTRATION SPECTRA,
         UNIT 4 GAS-FIRED GAS TURBINE
Locaoon
Compound (a)
&cetonKrile (f)
i\crolein
Acrylonrtrile
Allyl Chloride
Jenzene
Jromoform
1,3-Butadieoa
Carbonyl Sulfide
Chlorobenzene
Ethyl Benzene
Ethyl Chloride
ithylene Otbromide
Methyl Bromide
Methyl Chloride
ulethyl Ethyl Ketone
vtethyl Isobutyl Ketone
vtethyl Methacrylate
Vlethyteoe Chloride
2-Nitropropane
'ropylene Oichloride
Styrene
Tetrachloroethylene
Toluene
1 . 1 .2-Trichloroethane
Trichloroethylene
2,2,4-Trimethylpentane
i/lnyl Acetate
/myl Bromide
Analytical Region (wn) (b)
1039.90 - 1064.00
913.70 - 1000.35
922.19 • 997.82
893.51 - 1002.22
1010.22 - 1063.18
1134.18 - 1159.39
870.00 • 1052.64
2029.21 • 2075.69
1012.42 - 1036.64
2854.28 • 3122.12
943.43 • 1000.16
1167.96 - 1208.92
2938.47 - 3002.81
2928.38 - 3099.97
1140.70 - 1222.63
2872.05 • 2994.95
915.64 • 962.12
1241.32 - 1290.95
831.47 • 868.50
996.86 - 1038.00
886.32 • 931.22
899.20 - 925.20
2862.00 - 2924.00
909.41 • 960.62
919.70 - 959.88
2861.57 • 3009.23
919.53 • 1046.33
939.59 - 944.72
Turbine Outlet
Max. In-Cell
RMS (c) Cone, (pom) (d)
3.04E-O3
3.87E-03
3.94E-03
4.02E-03
5.40E-03
7.20E-03
7.69E-03
4.21 E-02
5.95E-03
6.18E-02
3.78E-O3
1.45E-02
1.24E-02
2.20E-02
1.79E-02
1.13E-02
3.57E-03
1.75E-01
1.37E-02
5.38E-03
3.88E-03
3.75E-03
3.20E-03
3.64E-03
3.63E-03
1.30E-02
5.25E-03
1.38E-03
41.66
2.46
3.24
3.29
13.19
1.28
8.05
2.40
5.48
64.51
5.27
10.30
16.45
46.27
13.20
4.76
1.81
95.32
15.08
6.33
2.94
0.34
5.05
3.79
0.70
1.57
2.63
0.44
Max Outlet
Cone, (ppm) (•
0.280
0.017
0.022
0.022
0.089
0.009
0.054
0.016
0.037
0.433
0.035
0.069
0.110
0.311
0.089
0.032
0.012
0.640
0.101
0.043
0.020
0.002
0.034
0.025
0.005
0.011
0.018
0.003
Stack
Max.kt-C««
RMS Cone, (ppm)
1.94E-02
4.91 E-02
5.05E-02
4.63E-02
1.83E-02
1.60E-02
3.79E-02
1.31 E-02
1.58E-02
6.25E-O3
4.B6E-02
1.19E-02
4.57E-03
6.60E-03
1.42E-02
4.48E-03
4.10E-02
2.92E-02
Z01E-02
1.50E-02
3.39E-02
1.3SE-02
2.16E-03
4.03E-02
3.96E-02
4.26E-03
4.27E-02
1.37E-O3
268.10
31.13
41.56
37.78
44.89
its
39.65
0.75
14.51
6.52
67.76
8.46
6.06
13.90
10.44
1.88
20.74
15.89
2Z20
17.68
25.68
1.23
-3.41
41.99
7.61
0.51
21.37
0.44
Max. Stack
Cone, (ppm)
1.932
0.226
0.302
0.274
0.324
0.021
0.288
0.005
0.105
0.047
0.492
0.061
0.044
0.101
0.076
0.014
0.151
0.115
0.161
0.128
0.186
0.009
0.025
0.305
0.055
0.004
0.155
0.003
                               24

-------
TABLE 3-5. (Continued)
Location
Compound (a)
tfnyl Chloride
tfnyltdene Chloride
0-xylene
'-xylene
Carbon Oisulfide
Carbon Tetrachloride
Chloroform
Cumene
1.2-Epoxy Butane
Ethylene Oxide
Methanol
Methyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
'ropylene Oxide
«4-xylene
Acetone
iVcetaldehyde
toetophenone
ton/lie Acid
Aniline
3enzotrichloride
3enzvl Chloride
3is(chloromethvl)ether
Chloroacetic acid
2-Chloroacteophenone
Chloromethvl methyl ether
Chloroprene
a-Cresol
Analytical Region (wn) (b)
852.81 • 1056.06
1059.44 - 1113.01
2859.84 - 3095.04
770.61 - 819.06
2188.79 - 2196.47
758.21 - 804.29
758.21 - 781.25
2871.26 - 3095.39
9O2.37 - 919.70
866.90 - 875.00
2807.91 - 3029.40
710.05 - 736.84
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2846.93 - 3090.79
1182.00 - 1255.03
3006.20 - 3009.20
1140.40 - 1286.06
758.79 - 1378.25
1102.90 - 1123.63
866.50 - 877.90
3070.16 - 3085.53
1218.65 - 1260.78
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 • 1146.08
971.60 - 975.80
1092.80 - 1114.07
Turbine Outlet
Max. In-Cell Max. Outlet
RMS (c) Cone, (ppm) (d) Cone, (ppm) (e
1.09E-02
7.41 E-03
2.10E-02
1.41E-02
1.64E-02
1.34E-02
6.59E-03
2.08E-02
3.73E-03
2.91 E-03
1.66E-02
2.90E-02
1.36E-03
6.24E-03
2.13E-02
2.10E-02
2.33E-02
3.66E-03
8.23E-02
3.01 E-01
6.07E-03
3.07E-03
2.13E-02
2.94E-02
5.91 E-03
1.78E-02
8.26E-03
1.53E-03
5. 11 E-03
11.14
1.98
13.30
8.05
13.03
0.62
0.33
52.18
2.71
0.70
13.34
1.85
1.23
0.98
13.44
20.25
10.13
8.73
10.60
150.90
1.93
0.56
34.32
10.96
1.25
3.26
1.19
0.81
2.13
0.075
0.013
0.089
0.054
0.088
0.004
0.002
0.350
0.018
0.005
0.090
0.012
0.008
0.007
0.090
0.136
0.068
0.059
0.071
1.013
0.013
0.004
0.230
0.074
0.008
0.022
0.008
0.005
0.014
Stack
Max. In-Cell Max. Stack
RMS Cone, (ppm) Cone, (ppm)
3.71 E-02
2.46E-02
6.15E-03
1.35E-02
2.49E-02
1.07E-02
6.01 E-03
6.28E-03
1.41 E-02
1.98E-02
3.93E-03
4.26E-02
1.25E-03
5.97E-03
6.33E-03
6.05E-03
1.68E-02
1.63E-03
2.00E-02
2.27E-01
2.38E-02
1.82E-02
4.74E-03
1.74E-02
2.12E-02
1.20E-02
1.77E-02
3.25E-03
1.78E-02
37.90
6.55
3.90
7.70
19.75
0.49
0.30
15.72
10.25
4.77
3.16
2.71
1.13
0.94
4.00
5.82
7.29
3.89
2.58
114.06
7.56
3.33
7.64
6.50
4.49
2.20
2.55
1.72
7.41
0.275
0.048
0.028
0.056
0.143
0.004
0.002
0.114
0.074
0.035
0.023
0.020
0.008
0.007
0.029
0.042
0.053
0.028
0.019
0.828
0.055
0.024
0.055
0.047
0.033
0.016
0.019
0.012
0.054
                                                25

-------
TABLE 3-5. (Continued)
location
Compound (a)
n-Cresol
>-C(eso!
.2-Oibromo-3-chloropropane
1 ,4-Dichlorobenzene
Oichloroethvl ether
1 ,3-Dichloropropene
lichlorvos
N.N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1-Dimethvl hydrazine
Dimethyl phthalate
1.4-Dioxane
zpichlorohydrin
Ethyl Acrylate
ithylene Oichloride
Ethylidene dichloride
:orm aldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
Hexachloroethane
Hexamethvlphosphoramide
Isophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
N-Nitrosodimethylene
Analytical Region  (b)
915.55 - 939.18
2865.70 - 2893.00
2959.13 - 2985.82
995.96 - 1031.06
2662.14 - 3089.07
768.00 - 791.00
967.79 - 1000.25
2655.32 - 3156.07
889.S5 - 917.52
2824.80 - 2873.60
856.12 - 974.09
1157.86 - 1254.16
2967.40 - 2970.30
943.52 - 981.73
1181.93 • 1210.00
712.00 - 736.00
930.35 - 1126.16
2788.33 - 2842.20
976.90 - 997.70
1227.02 - 1240.42
785.50 - 793.00
949.42 - 1019.53
2681.20 - 3130.60
338.45 - 841.30
2683.00 - 3061.78
779.31 - 783.55
841.70 • 861.39
928.00 - 1085.28
Turbine Outlet
Max In-Cell Max Outlet
RMS (c) Cone, (ppm) (d) Cone, (ppm) (e
3.84E-03
1.57E-03
9.67E-03
3.22E-03
2.58E-02
1.04E-02
2.11E-03
5.30E-02
3.21 E-03
1.57E-03
8.81 E-03
2.25E-02
3.17E-03
4.23E-03
9.24E-03
2.99E-02
9.68E-03
2.04E-03
1.39E-03
5.82E-03
1.01E-02
4.04E-03
5.41 E-02
4.39E-03
2.24E-02
3.39E-03
1.73E-02
8.52E-03
2.37
2.81
16.26
1.38
31.60
2.08
0.29
30.20
0.79
0.97
7.11
11.66
0.95
3.38
0.46
5.25
13.29
2.01
0.19
0.43
0.44
0.54
33.60
0.43
24.04
0.32
6.67
2.58
0.016
0.019
0.109
0.009
0.212
0.014
0.002
0.203
0.005
0.007
0.048
0.078
0.006
0.023
0.003
0.035
0.089
0.014
0.001
0.003
0.003
0.004
0.226
0.003
0.161
0.002
0.045
0.017
Stack
Max. In-Cell Max Stack
RMS Cone, (ppm) Cone, (ppm)
4.93E-02
1.04E-03
4.82E-03
1.27E-02
4.77E-03
9.97E-03
2.39E-02
5.31 E-03
1.38E-02
1.04E-03
4.25E-02
1.69E-02
1.18E-03
5.69E-02
1.02E-02
4.44E-02
3.88E-02
1.14E-03
1.58E-02
4.91 E-03
9.61 E-03
4.36E-02
5.35E-03
2.35E-03
4.24E-03
5.70E-03
1.96E-02
4.32E-02
30.32
1.86
8.11
5.46
5.83
1.99
3.33
3.03
3.39
0.64
34.29
8.75
0.35
45.53
0.51
7.81
53.25
1.12
2.16
0.36
0.42
5.82
3.32
0.23
4.54
0.55
7.57
13.10
0.220
0.014
0.059
0.040
0.042
0.014
0.024
0.022
. 0.025
0.005
0.249
0.064
0.003
0.331
0.004
0.057
0.387
0.008
0.016
0.003
0.003
0.042
0.024
0.002
0.033
0.004
0.055
0.095
                                              26

-------
  TABLE 3-5.  (Continued)
Location
Compound (a)
il-Nitrosomorpholine
'henol
leta-Propiolactone
'ropionaldehyde
1 ,2-Propylenimine
Quioline
Styrene Oxide
1 . 1 ,2.2-Tetrachloroetnane
2.4-Toluene diisocvanate
a-Toluidine
1 .2.4-Trichlorobenzene
2.4.5-Trichlorophenol
2.4,6-Trichlorophenol
Criethylamine
Analytical Region 
-------
3.3.2  Instrumental and Manual Test Results

     In accordance with  standard  turbine  emission test requirements (i.e.,
Subpart GG  and  EPA  Method 20),  a preliminary  02 traverse  was conducted
immediately prior to  initiating Run 1 to determine an appropriate measurement
point location.  Other probes were installed and could not be removed while
the turbine was in operation, therefore, only three of the six sample ports
were  traversed  during  this  check.    The  traverse   point   locations  and
corresponding 02 measurements are presented in  Figure 3-1.   These results
indicated no change in the 02 levels across the duct;  therefore, the probes
were positioned at a depth of 3 ft. within the duct for the testing.

     Table 3-6 summarizes the results of the EPA Methods 3A and 10 tests as
described in Section 4.3.  All CEM results  in the table were determined from
the average gas  concentration measured  during  the run and adjusted for the
pre- and post-test run calibration check results  (Equation 6C-1 presented in
EPA Method 6C,  Section 8).  Although not required by Method 10, the same data
reduction procedures as that in Method 3A were used for the CO determinations
to improve the quality of the  data.  All measurement system calibration bias
and  calibration  drift  checks  for  each  test  run  met  the  applicable
specifications contained in the test methods.

     No  HC  data  were  available  from  the  test  because  the  analyzer
malfunctioned during the first test run.  Each  test run CO emission rate was
computed using the averaged concentration measurement for the test run, the
flue gas volumetric flow rate, and the  appropriate conversion factors.

     The turbine  exhaust gas  flow rates used  to compute  mass emissions in
units  of  Ib/hr  were  determined  using EPA  Method 19  procedures  and  the
measured flue gas 02.  An on-line process gas chromatograph  analyzes a natural
gas  sample  every  hour at the Wharton facility.   The fuel  analysis  data
supplied  by  the  source are  included   in  Appendix B.   The  analysis  data
collected for  each test  period  were averaged.   This information  and the
amount of fuel  fired  by the turbine were used to compute the heat consumption
and Fd-factor needed  to compute the dry  exhaust gas volumetric flow rate (in
units of dry standard  cubic feet  per minute,  dscfm)  for  each test run (see
Table 3-7).  Wet basis flow rates (wscfm) were computed based on 13% H20 in
the flue gas.

     As a quality assurance  check of  the  02  and C02  data,  F0 factors were
calculated for each test run.  The calculated  F0 results presented in Table
3-8 are within the range of acceptable  values.
                                     28

-------
O 2 Measurements

Depth
r
2
3
4'
5
e

A
15.2
15.2
15.2
15.2
15.2
15.2
Port
B
15.1
15.2
15.2
15.2
15.2
15.2

C
15.1
15.1
15.1
15.1
15.1
15.1
T/Cand Sample
Pitot Conc-
F E| D
1
2
3
4
5
6
n rtfti f


1
C B A
i n n n


























                                                                                      r-3"
                                                 Section K-K
                          Unit 41
                        Gas-Fired
                       Gas Turbine
                                         Damper
                                                                Diffuser
                                              Stack
501049/93
Figure 3-1. C>2 traverse data; HRSG Inlet.

                 29

-------
TABLE 3-6.   SUMMARY OF CEM  TEST RESULTS FROM T.H. WHARTON UNIT 41 HRSG INLET
DATE
5/17/93
5/18/93

5/18/93

RUN
#
1
2

3

SAMPLE
TIME
1804-1939
1140-1208
1226-1431
1521-1624
1635-1654
SAMPLING
SYSTEM
to FTIR
Hot/Wet
Hot/Wet
Condenser
Perma Pure
Hot/Wet
02
(%d)
15.1
15.1
15.1
15.1
15.1
C02
(%d)
3.3
3.3
3.3
3.4
3.4
CO"
Ppmd
1.8
2.3
1.9
2.4
2.7
Ib/hr
2.8
3.7
3.0
3.9
4.4
FLOW
RATE
(wscfm)
413,521
418,557

433,541

FLOW
RATE
(dscfm)
359,763
364,145

377,181

          The  CO   emissions  rates  were   calculated  using   dry  basis
          concentrations and flow rate data.
    TABLE  3-7.   TURBINE  EXHAUST  GAS  VOLUMETRIC  FLOW  RATE  DETERMINATIONS.


RUN
NO.
1
2
3


GCV
(Btu/ft3)
1010.15
1009.91
1026.83

AVG. FUEL
FLOW
(mmftVday)
16.5
16.7
17.0

HEAT
CONSUMPTION
(mmBtu/hr)
694.48
702.73
727.34


Fd
(dscf/mmBtu)
8625.6
8628.2
8634.7


02
(%d)
15.1
15.1
15.1
FLUE
GAS
FLOW
(dscfm)
359,763
364,145
377,181
           TABLE 3-8.  VALIDATION OF 0, AND CO, MEASUREMENT DATA
RUN NO.
1
2
3
02
(%d)
15.1
15.1
15.1
C02
(%d)
3.3
3.3
3.4
CALCULATED
F0
1.76
1.76
1.71
Calculated F0 = (20.9-%02) / %C02
EPA Method 3 acceptance criteria,
F0 range: 1.64 - 1.88 for natural gas
                                     30

-------
3.3.3  Process Operation During Testing

3.3.3.1  Process  Results  Table 3-9 and Figures 3-2,  3-3,  and 3-4 present the
process results and can be found immediately following this section.

3.3.3.2  Problems and/or Variations during Testing  During Run 1 (2:45 p.m.
to 6:45 p.m.,  5/17/93), there were no process operations that would interfere
with testing.

     During Run  2  (11:00  a.m.  to  3:23  p.m.,  5/18/93),  a  piece  of test
equipment overheated  and  was  replaced  with a reserve  unit.   The  Run was
stopped during  the down  time, then  restarted.   The  Run was  extended  to
achieve a total Run time of 4-hours.

     During Run 3 (3:55 p.m. to 7:55 p.m., 5/18/93), the turbine's megawatt
output increased.  This increase was due to a thunderstorm that passed over
the plant.  GT 41  obtains  its combustion air  from  ambient air outside the
unit.  As the  temperature  dropped,  the air density  increased  and  the mass
flow  through   the  turbine  also  increased,  although  fuel   flow  stayed
essentially the same.  This  increased mass  flow  provided more power to the
turbine and, thus,  greater megawatt generation.
                                     31

-------
                            TABLE 3-9.
Process Data Sheet: Houston Lighting and Power Co., T. H. wharton, Unit 4

Date
Testl
5/17/93
5/17/93

Time

MW
Operating capacity

2:45 PMl 52.0
3:01 PMl 52.0
5/17/93 i 3:16 PMl 52.0
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93
5/17/93

Test 2
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
3:31 PMl 52.0
3:45 PMl 52.0
4:00 PMl 52.0
4:15 PMl 52.0
4:30 PMl 52.0
4:45 PMl 52.0
5:00 PM
5:15 PM
52.0
52.0
5:30 PM| 52.0
5:45 PMl 52.0
6:00 PM
6:15 PM
52.0
52.0
6:30 PMl 52.0
6:45 PMl 52.0


11:00 AMI 53.0
11:15 AM| 52.2
11:30 AM
11:45 AM
12:00 PM
12:15 PM
12:30 PM
12:45 PM
1:00 PM
1:15 PM
1:30 PM
52.1
52.1
52.5
52.1
52.1
52.1
52.1
52.1
52.1
1:45 PM| 52.1
5/1 8/93 1 2:00 PMl 52.1
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93

TcstS
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
5/18/93
2:15 PM| 52.1
2:30 PMl 52.5
2:45 PMl 52.7
3:00 PMl 53.0
3:23 PM


3:55 PM
4:10 PM
4:25 PM
4.40 PM
4:55 PM
5:10 PM
53.0


54.0
55.0
55.2
55.7
55.7
55.0
5:25 PMl 55.0
5:40 PM| 55.0
5:55 PM
6: 10PM
6:25 PM
55.0
55.0
55.5
6:40 PM| 55.4
6:55 PMl 55.7
7:10 PMJ 55.6
5/18/93! 7:25 PMl 55.8.
5/18/931 7:40 PMl 56.0
5/18/931 7:55 PMl 56.0
DegF
Turbine gas exit temp.

989
989
989
990
990
990
990
990
990
990
990
990
990
990
990
990
990


989
989
989
990
989
990
990
990
990
990
990
989
989
989
989
989
990
985


985
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
DcgF
Stack gas exit temp

300
300
299
299
299
299
299
298
299
299
299
299
299
299
299
299
298


297
290
291
293
296
295
295
295
2%
297
297
297
295
295
295
295
295
295


295
298
298
295
295
298
298
298
298
298
299
298
299
298
299
299
299
Million cubic feet/day
Natural Gas Flow

16.5
16.6
16.6
16.6
16.5
16.5
16.5
16.4
16.4
16.5
16.5
16.6
16.6
16.5
16.5
16.6
16.6


16.8
16.8
16.8
16.8
16.7
16.7
16.7
16.6
16.6
16.6
16.6
16.6
16.6 '
16.6
16.8
16.8
16.7
16.7


16.9
17.0
17.0
17.1
17.0
17.0
16.9
16.9
17.0
16.9
17.0
17.0
17.0
17.0
17.0
17.1
17.0
                                 32

-------
         54
                                                                                     994
OJ
GJ
         53
         52
         51
         50
           2:45 p m.   3:18 p.m.   3:45 p.m.   4:15 p m.    4:45 p.m.   5:15 p.m.   5.45 p m.   6:15 p.m.   6:45 p.m.
               3.01 p m.   3:31 p.m.   4.00 p m.    4:30 p.m.   5:00 p.m.   5:30 p m.   6 00 p.m.   6:30 p m.
Generator Output, Megawatts
           17


         16.8


         16.6


         16.4


         16.2


           16
             2:45 p m.   3:16 p.m.   3:45 p.m.   4.15 pm   4 45 p m.   5:15 p m.    5 45 p m.   6:15 pm   6:45 p m
                 3O1 p.m.   3.31 p.m.   4:00 pm.    430p.m.   5.OOpm   S30pm    6OOpm   6:30 p.m.
                                Natural Gas Flow (MCFD)
                                  MCFD = miHion cubic feet /day

                                                                                     992
                                                      990
                                                                                     988
                                                                                     986
                                                          2:45 p m.  3:16 p.m.   3:45 p m.   4:15 p m.   4.45 p.m.   5:15 p.m.   5:45 p m.   A.I 5 p m    6 45 p n>
                                                             301 p m.   3.31 p m.  4:00 p m.   4:30 p.m.   5.00p.m.   5 30 p m.   6 00 p m   6 30 p m
                                                                                                           Turbine gas exit temp. (F)

                                                                                    310
                                                      305
                                                      300
                                                      295
                                                     290
                                                                                       2:45 p m.   316pm   3:45 p.m.   4:IS p.m.   4:45 p.m.   5:15pm.   5:45 p m.   6:15 p m   6 
-------
oo
         54
         53
         52
         51
         50
           1l:00rm.  11:30«m.   12:00p.m.  12:30pm.   1:00pm.   1:30p.m,   2:00pm.  2:30p.m.   3:00p.fn.
               11:ISi.m.  Il45tm  1215pm   1245pm.  115pm   MS p.m.   215pm   245pm.   J23pr
                              Generator Output, Megawatts

         17.2


           17


         16.8


         16.6


         16.4
         16.2
             11.00a.m.   I130«m.  1200pm  1230pm  lOOpm    130pm.   200pm   230pm   300p.m.
                11:1Sim.  11:4Sim   12:15 pm   12:45 pm.   1.15pm   1:45 pm   2:15 pm   245pm   323 pn
                                Natural Gas Flow (MCFD)
                                  MCFO = million cubic feet / day
                                                                                    992
                                                                                    990
 988
                                                                                    986
                                                                                    984
    11:00 «m  11:30im  1200pm  1230pm   100pm.   1.30pm.   200pm.   230pm   300pm
        I1:l5i. m.  ll:4S«m  1215pm   12:45 pm  1:15pm.  1:4Spm   215pm  245pm  323pm
                       Turbine gas exit temp. (F)
                                                                                   305
300
295
290
285
                                                                                      1l:00i m  1130«m  1200pm   12:30 p.m.  t.OOpm.   1:30p.m.  2:00 pm   2:30 pm   300pm
                                                                                          1l:15«.m   11:45 «m  12.15pm  1245pm.   1:l5pm   1:45p.m.   2:15pm   245pm  323pm
                                                                                                           Stack gas exit temp. (F)

                                                                         Figure 3-3.

             Houston Lighting & Power Co., T. H. Wharton, Unit Four, Test #2, (5/18/93,11:00 a.m.-3:23 p.m.)

-------
OJ
on
          56.5

           56

          55.5

           55

          54.5

           54
          53.5 ^
              3:55 p.m.   4:25 p.m.   4:55 p.m.   5.25 p.m.   5 55 p.m.   6:25 p m.   6.55 p.m.   7:25 p.m.    7:55 p.m.
                  4:1 Op.m.   4:40 p m.   5:1 Op m.   5:40p.m.   6:10 p m.   6:40 p.m.   7:10p.m.   7:40p.m.
                                Generator Output, Megawatts

          17.4

          17.2

            17

          16.8

          16.6
              355 p m.    425 pm.   455 p m.   525 p m.    5.55 pm    625 p.m.   6:55 p m.   725p.m.   7:55 pm
                  4:10 p.m.    4:40 p m.   5:10 pm.   5:40 p.m.    6:10 pm.   6:40 p m   7:10 p.m.   7:40 p.m.
                                  Natural Gas Flow (MCFD)
                                   MCFD = million cubic feet / day
 994
 993
 992
 991
 990
 989
 988
 987
 986
 985
 984
     3:55 p m.   4:25 p m.   4:55 p.m.   5:25 p.m.   5.55 p m.   6:25 p.m.   6:55 p m   7.25 p m.   7 55 p m
        4:10 p m.   4:40p.m.   5:1 Op.m.   5:40p m.   6:1 Op.m.   6:40p m.   7:10p m   7 40p m
                        Turbine gas exit temp. (F)
                                                                                      305
300
295
290
285
                                                                                         3.55 p.m.   4:25 p.m.   4:55 p.m   5:25 p.m.   5:55 p.m.   6:25 p.m.   6 55 p m.   7:25 p m.   7 55 p m
                                                                                             4:10 p m.   4:40 p.m.    5:10 p m   5:40 pm.   6:10 p.m.   6:40 p m.   7:1 Opm.   7 40 p m
                                                                                                               Stack gas exit temp. (F)
                                                                           Figure 3-4.

               Houston Lighting &  Power Co., T. H. Wharton, Unit Four, Test #3, (5/18/93, 3:55 p.m.-7:55  p.m.)

-------
                  4.0  SAMPLING AND ANALYTICAL PROCEDURES

     The FTIR analysis is done using two different experimental techniques.
The first, referred to as direct  gas  phase analysis,  involves transporting
the gas  stream  to the sample  manifold so it  can  be sent  directly  to the
infrared cell.  This technique  provides  a sample similar in composition to
the flue  gas  stream at the sample  point location.  Some  compounds  may be
affected because of contact  with the sampling system components or reactions
with other species  in  the gas.   A second  technique, referred to as sample
concentration, involves concentrating the  sample by passing  a measured volume
through an absorbing material  (Tenax) packed into a U-shaped stainless steel
collection tube.  After sampling,  the tube is heated to desorb any collected
compounds  into  the FTIR cell.   The desorbed  sample is then  diluted  with
nitrogen to one atmosphere  total  pressure.  Concentrations of any species
detected in the absorption  cell are related to  flue gas concentrations by
comparing  the volume  of  gas  collected  to the  volume  of the  FTIR  cell.
Desorption  into  the  smaller  FTIR  cell  volume  provides  a  volumetric
concentration related  to  the  volume  sampled.    This,  in  turn,  provides  a
corresponding increase in sensitivity for the detection of species that can
measured  using  Tenax.   Sample  concentration  makes it possible  to achieve
lower detection limits for some HAPs.

     Infrared absorbance spectra of gas phase and concentrated samples were
recorded  and  analyzed.   In  conjunction  with  the  FTIR  sample  analyses,
measurements of (HC),  (CO), (02), and (C02) were obtained using gas analyzers.
Components of the emission  test  systems  used  by  Entropy  for this testing
program are described below.


4.1  EXTRACTIVE SYSTEM FOR DIRECT GAS PHASE ANALYSIS

     An extractive system, depicted in  Figure 4-1,  was used  to transport the
gas stream from the turbine  exhaust duct directly to the infrared cell.

4.1.1  Sampling System

     Flue gas was extracted through a stainless steel probe.   In order to
protect the Teflon® sampling system components, a thermocouple was installed
at the outlet of  the probe  to  verify  that the  sample  gas  temperatures had
been lowered  to  approximately  350°F  before  entering  the  heated line.   A
Balston® particulate filter  rated  at 1  micron was installed at the outlet of
the sample probe.  A 100-foot length of heated 3/8-inch O.D. Teflon® sample
line connected the probe to the  heated sample pump (KNF Neuberger,  Inc. model
number N010 ST.Ill) located  inside the mobile laboratory.  The temperature of
the  sampling  system  components was  maintained at  about   300°F.   Digital
temperature controllers were used to control  and monitor the temperature of
the transport lines.   All connections  were wrapped with  electric heat tape
and  insulated to ensure that  there were  no  "cold spots"  in  the sampling
system where  condensation might occur.  All components of the sample system
were constructed  of Type 316 stainless steel  or Teflon®.   The heated sample
flow manifold,  located in the  FTIR truck, included a secondary particulate
filter and valves that allowed  the  operator  to send sample gas directly to
the absorption cell or through  a gas conditioning system.


                                    36

-------
     The  extractive system  can  deliver  three  types  of  samples  to  the
absorption  cell.    Sample  sent  directly  to  the FTIR  cell  is  considered
unconditioned,  or   "hot/wet."     This  sample  is  thought   to   be   most
representative of  the  actual  effluent  composition.   The removal  of  water
vapor from the gas stream before analysis was sometimes desirable; therefore,
a second type of  sample  was  provided by directing gas  through a  condenser
system.  The  condenser employed a  standard  Peltier  dryer  to  cool  the gas
stream to approximately 38°F.  The resulting condensate was  collected in two
traps and removed  from  the  conditioning  system with peristaltic pumps.   This
technique  is  known  to leave the  concentrations of  inorganic and  highly
volatile compounds  very  near to the  (dry-basis) stack concentrations.   A
third type of sample was  obtained by passing the  gas stream  through a series
of  PermaPure® dryers.    This  system utilized  a network  of semi-permeable
membranes.    Water  vapor  was   drawn   through   the  membrane  walls  by  a
concentration gradient, which was established by a counter  flow of dry air
along  the  outside of  the  membrane  walls.    In  addition  to protecting the
absorption cell,  water removal relieved spectral interferences, which  could
limit the effectiveness of the FTIR analysis for particular compounds.

4.1.2  Analytical  System

     The FTIR equipment  used  in this test consists of  a  medium-resolution
interferometer,  heated infrared  absorption  cell,  liquid  nitrogen  cooled
mercury cadmium telluride  (MCT)  broad  band infrared detector, and computer
(see Figure 4-2).  The  interferometer, detector,  and computer were purchased
from KVB/Analect,   Inc.,  and  comprise  their base Model  RFX-40 system.   The
nominal spectral resolution of the system is one  wavenumber (1  cm ).  Samples
were contained in a model 5-22H infrared  absorption cell  manufactured  by
Infrared Analysis, Inc. The inside walls and mirror housing  of the cell were
Teflon® coated.  Cell temperature was maintained at 240°F  using  heated jackets
and temperature controllers.   The absorption path length of  the cell was set
at 22 meters.

4.1.3  Sample Collection Procedure
                                                                   t
     During operation of the  gas turbine, the  flue gas temperatures of  990°F
and a positive pressure of about 20  inches  of water at the sampling location
presented  a safety  concern.   Therefore,  according  to  agreement with the
plant, the turbine was  not operated until installation of the sampling probes
was completed. Once installation was completed,  the plant fired the turbine
and the test proceeded.

     During all  three test runs, direct gas phase analysis was performed at
the stack concurrent with the sample concentration testing.  Over each 4-hour
test run,  flue  gas  continuously flowed through the  heated  system to the
sample manifold in the  FTIR truck.   A portion of  the gas stream was diverted
to a secondary manifold located near the inlet of the FTIR  absorption  cell.
The cell was  filled with  sample to ambient pressure and  the FTIR spectrum
recorded.  After analysis,  the cell was evacuated so that a subsequent sample
could be introduced.   The  process of collecting  and  analyzing a sample and
then evacuating the cell  to  prepare for the sample required  less  than  10
minutes.  During  each run, about 12 gas phase samples were  analyzed.
                                     37

-------
OJ
oo
                                                           Vent
               In-Stack
              Paniculate
                 Filter
                                                                   Heated
                                                                  Transport
                                                                    Lines
Extractive
  Probe
                                                       Heated
                                                        Pump
                                                                                                                      Heated
                                                                                                                     Manifold




FTIR
Cell
                                                                                                                  02
                                                                                                               Analyzer
                                                                                                                              J.
                                                                                                 CO
                                                                                              Analyzer
    50104 9/93
                   Figure 4-1. Direct extraction gas handling system.

-------
OJ
IO
                                                                                To       To
                                                                              Vacuum     Vent
                                                                               Pump
                                                                                                                                Preheated
                                                                                                                                   N2
50104 9/93
Figure 4-2. Top view of FTIR measurement system.

-------
4.2  SAMPLE CONCENTRATION

     Sample concentration was performed using the adsorbent material Tenax,
followed by thermal  desorption  into the FTIR cell.   The sample collection
system employed equipment  similar  to that of the Modified  Method  5 sample
train.

4.2.1  Sampling System

     Figure 4-3 depicts the apparatus used  in this test program.  Components
of the sampling train included a heated  stainless steel probe, heated filter
and  glass  casing,  stainless  steel  air-cooled  condenser,  stainless  steel
adsorbent trap in an  ice bath,  followed by two  water-filled impingers, one
knockout impinger, an impinger filled with silica gel, a sample pump,  and a
dry gas meter.  All  heated  components were  kept  at a  temperature above  120°C
to ensure no  condensation  of  water vapor within the  system.  The stainless
steel condenser coil was used to pre-cool  the  sample gas before it entered
the  adsorbent  trap.   The trap was  a  specially  designed  stainless  steel Li-
shaped collection tube filled  with  10 grams of Tenax and plugged  at both ends
with  glass  wool.    Stainless  steel  was used for  the construction of the
adsorbent tubes  because it gives  a more  uniform  and more efficient  heat
transfer than glass.

     Each sampling run  was  4-hours at approximately  0.12 to 0.13 1pm for a
total sampled  volume of about 30 to 40  dcf.   The sampling rate depended on
the sampling train used and was  close to the maximum  that could  be achieved.
Collection times provided a volumetric concentration that  was proportional to
the total volume sampled.  The resulting increase in sensitivity  should allow
detection to concentrations below  1 ppm for some HAPs.

4.2.2  Analytical System

     Before analysis condensed  water vapor was  removed  from the collection
tubes using a dry nitrogen  purge for about  15 minutes.  Sample analyses were
performed using thermal desorption-FTIR., The  sample  tubes were  wrapped with
heat  tape  and placed  in  an  insulated  chamber.  One end  of the  tube was
connected to the inlet  of the evacuated FTIR absorption cell.   The same end
of the  tube  that served as  the inlet during the sample concentration run
served as the outlet for the  thermal desorption.  Gas samples were desorbed
by heating the Tenax to 250°C.  A preheated stream of UPC grade  nitrogen was
passed  through the  adsorbent and  into  the FTIR  absorption cell.   About
7 liters of nitrogen  (at 240°F)  carried  the desorbed gases  to the  cell and
brought  the  total  pressure of  the  FTIR sample to   ambient  pressure.   The
infrared absorption  spectrum was  then  recorded.   The purging  process was
repeated until no evidence of additional sample desorption was  noted in the
infrared spectrum.

4.2.3  Sample Collection Procedure

     During each 4-hour run,  sample concentration  testing was  conducted at
the turbine outlet.   During Run  2 a sample  was also collected simultaneously
at the  stack.  The  sample  concentration test apparatus was  set up at the
location after Entropy performed leak checks of the system.    Sample flow,


                                     40

-------
temperature of the heated box, and the tube outlet temperature were monitored
continuously and recorded at 10-minute  intervals.   At  the end of each run,
sampling was interrupted and the collection tube was removed.  The open ends
were tightly capped  and  the  tube was stored on ice  until  it was analyzed.  In
most cases,  the  tubes were  analyzed within  several hours after the sample
run.
                                     41

-------
        Heated
       Filter Box
                     J
                              Probe
                                    Duct Wall
                                       Gas
                                       Flow
                                                Thermocouples
                                                                    Heated
                                                                    Teflon
                                                                     Line
                                                                Air-Cooled
                                                                Condenser
                                                                   Coil
T ) Thermocouple
                                                                  Bypass
                                                                  Valve
ft?
Vacuum Line ^
Main Valve
50104 9/93
                                               Figure 4-3. Sample concentration sampling system.

-------
4.3  CONTINUOUS EMISSIONS MONITORING

     Entropy's extractive measurement system and the sampling and analytical
procedures used for the determinations of HC, CO, 02, and C02 conform with the
requirements of EPA Test  Methods 25A, 10, and 3A,  respectively,  of 40 CFR 60,
Appendix B.  A heated extractive sampling system and a set of gas analyzers
were used to analyze  flue gas  samples extracted at the turbine outlet sample
point location.  The analyzers received gas samples delivered from the same
sampling system that  supplied  the FTIR cell with condenser sample.  These gas
analyzers require that the flue gas  be conditioned to eliminate any possible
interference  (i.e.,  particulate matter and/or water  vapor)  before  being
transported and analyzed. All components of the sampling  system that contact
the gas sample were Type 316 stainless steel and Teflon®.

     A gas flow distribution  manifold downstream  of  the  heated sample pump
was used to control the flow of sample gas to each analyzer.  A refrigerated
condenser  removed  water  vapor from  the sample  gas analyzed  by all  the
analyzers  except   for  the HC  analyzer   (Method  25A requires  a wet  basis
analysis).  The condenser was  operated at approximately 38°F.  The condensate
was continuously  removed from the  traps within  the condenser  to  minimize
contact between the gas sample and the condensate.

     The  sampling  system  included  a  calibration  gas  injection  point
immediately upstream of  the analyzers for  the calibration error checks and
also at the outlet of the probe for  the  sampling system bias and calibration
drift checks.  The mid-  and high-range  calibration  gases were certified by
the vendor according to  EPA Protocol  1  specifications.   Methane in air was
used to calibrate  the HC analyzer.

     A  computer-based  data  acquisition system  was  used  to  provide  an
instantaneous  display  of the  analyzer  responses, as  well as  compile the
measurement data collected each second, calculate data averages over selected
time periods, calculate emission rates,  and document the measurement system
calibrations.

     Table 4-1 presents a list of the analyzers that Entropy used during the
test  program.    Figure  4-1 presents a  simplified  schematic  of  Entropy's
reference measurement system.

     The  test  run values  were determined  from  the average concentration
measurements displayed by the gas analyzers during the run and are adjusted
based on the zero  and  upscale sampling  system bias  check results using the
equation presented in Section  8 of Method 6C.  The CEM data are presented in
Appendix A.
                                     43

-------
          TABLE  4-1.   GAS ANALYZERS USED DURING THE TEST  PROGRAM
PARAMETER (RANGE)
HC (0-10 ppmj
CO (0-100 ppmd)
C02 (0-20%d)
02 (0-25%d)
ANALYZER
Ratfisch Model RS255CA
Thermo Environmental
Model 48
Fuji Model 3300
Teledyne 320P-4
ANALYTICAL TECHNIQUE
Flame ionization
detector (FID)
Infrared gas filter
correlation (GFC)
Non-dispersive infrared
(NDIR)
Micro-fuel cell
4.4  FLOW DETERMINATIONS

     Because of the high flue gas temperature and pressure conditions, it was
not possible to perform velocity  traverses  at  point locations according to
EPA Method  1  specifications.    In lieu  of pitot  measurements,   flue  gas
volumetric flow was determined using mass balance calculations based on the
natural  gas  fuel  usage  rate,  fuel  composition,  exhaust  gas  diluent
concentrations, and an F-factor as outlined in EPA Method 19 (40 CFR 60).

     The  natural  gas  feed  rate  to the  turbine was  a process  parameter
recorded by the RTI representative during the test program.  The rates were
recorded at 15-minute intervals and then averaged for each test run period.
The Wharton facility operates  an  on-line  gas  chromatograph that analyzes a
natural gas sample every  hour.   This analysis data was  supplied  to EPA so
that the gross calorific value  (GCV,  in units of Btu/ft3) and Fd-factor (in
units of dry standard cubic  feet of combustion gas generated per million Btu
of heat input, dscf/MM-Btu) could  be  determined  for the computation of the
flue gas volumetric flow rates.

     A  pitot  tube was positioned  adjacent to  the  point where the sample
concentration probe was inserted.  Single point AP values were  recorded at 10
minute intervals to verify that flow characteristics, at the sampling point,
were not changing significantly during the test.

Heat consumption of the turbine was calculated from the fuel data:
                        HC = GCV x FQT x 3600E'6
                                                       (1)
    where:

      HC  =
     GCV  =

     FQT  =
Heat Consumption (mmBtu/hr)
Gross Calorific  Value  of Fuel  (Btu/ft3)  from  fuel  analysis
data provided by Wharton.
Fuel Flow Rate (mmft3/day)  provided by Wharton.
                                    44

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The dry exhaust gas  flow rate was calculated using EPA Method 19 procedures:
                     DSCFH  = F          °9
                                    20.9-%02J
where:
     Fd   =    Dry basis F-factor (dscf/mmBtu) determined from fuel analysis,
   %02d   =    dry basis concentration measurement from EPA Method 3A
                                    45

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4.5  PROCESS OBSERVATIONS

     During  the  testing,   an   RTI  representative  monitored  the  process
operations  so  that emissions  test  data could  be correlated  with  process
conditions.  The process observations are presented in Section 3.3.3.


4.6  ANALYTICAL PROCEDURES

4.6.1  Description of K-Matrix Analyses

     K-type  calibration  matrices  were   used   to  relate  absorbance  to
concentration.    Several  descriptions  of  this analytical  technique  can be
found in  the  literature2.   The  discussion presented here  follows  that of
Haaland, Easterling, and Vopicka3.

     For a  set  of m absorbance reference  spectra  of  q  different compounds
over  n  data  points  (corresponding to  the  discrete  infrared  wavenumber
positions chosen as the analytical  region) at a fixed absorption pathlength
b, Beer's law can be written in matrix form as
                                   = KC+E
                                                             (3)
where:
     K =
     C =
The n  x m  matrix representing  the absorbance  values of  the  m
reference  spectra over  the n  wavenumber  positions,  containing
contributions from all or some of the q components;

The n by q  matrix representing the relationship between absorbance
and concentration for the compounds  in  the wavenumber region(s) of
interest,  as  represented in the  reference  spectra.   The matrix
element   K,,,,  =  banq, where  anq  is  the  absorptivity  of  the  qth
compound at the nth wavenumber position;

The q x m matrix containing the concentrations of the q compounds
in the m reference spectra;
     E =
                                        "errors"
The n x m matrix representing the random
the analysis; these  errors  are not actually
Beer's   law,   but   actually   arise   from
misrepresentation  (instrumental   distortion)
   in Beer's law for
due to a  failure  of
 factors   such   as
 of  the  absorbance
          values of the reference spectra,
          spectrum concentrations.
                                 or inaccuracies in the reference
     The  quantity  which is  sought  in the  design  of this  analysis  is the
matrix K,  since if an  approximation  to  this matrix, denoted  by  K,  can be
found, the concentrations in a sample spectrum can  also  be estimated.  Using
the  vector A*  to  represent  the n measured absorbance  values  of a sample
                                     46

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spectrum over  the  wavenumber region(s)  of interest,  and  the vector  C  to
represent the  j  estimated concentrations  of  the compounds  comprising the
sample, C can be calculated from A* and  K from the  relation
                            £= [^Sr'K'A* .                         (4)
Here the superscript t represents  the transpose of the indicated matrix, and
the superscript -1 represents the matrix inverse.
                               ; = ACfc[CCfc ]
                                            "1
     The standard method for obtaining the best estimate K is to minimize the
square of the error terms represented by the matrix E.  The equation
represents the estimate K which minimizes the analysis error.

     Reference spectra for the K-matrix concentration determinations were de-
resolved to 1.0  cm"1  resolution  from  existing 0.25  cm"1 resolution reference
spectra.  This was accomplished by truncating and re-apodizing4 the interfer-
ograms  of  single beam reference spectra  and their  associated  background
interferograms.   The  processed single  beam spectra  were recombined  and
converted to absorbance (see Section 4.3).

4.6.2  Preparation of Analysis Programs

     To provide  accurate quantitative  results,Hv^matrix input  must include
absorbance values from a set  of reference  spectra  which,  added together,
qualitatively  resemble the  appearance of  the  sample  spectra.    For  this
reason,  all   of  the  Multicomponent  analysis   files  included  spectra
representing interferant species and  criteria pollutants present  in the flue
gas.

     Several factors affect the detection and analysis of .an analyte in the
stack  gas  matrix.   One is the  composition of the  stack gas.   The  major
spectral interferant in the gas-fired boiler effluent are water and C02.  At
C02 concentrations of about 10 percent and higher, weak absorbance bands that
are normally not visible begin to emerge.  Some portions of the FTIR spectrum
were not available for analysis because of extreme  absorbance from water and
C02, but most  compounds exhibit at least one absorbance band that  is suitable
for analysis.   Significant amounts of  NO,  and N02  were also  present in the
samples  and  these  species  needed to  be  accounted  for  in any  analytical
program.  A second factor affecting analyses is the number of analytes that
are to be detected because the program becomes more  limited in distinguishing
overlapping bands as the number of species  in  the sample increases.  A third
factor  depends  on how  well  the sample spectra  can be modeled.   The  best
analysis can be made when reference spectra are  available to account for all
of  the species  detected  in  the  sample.    When  reference spectra  are  not


                                     47

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available for  a  compound which has  been  identified, then  it  becomes more
difficult to quantify other species.

     A  set  of Multicomp program  files  had  been  previously  prepared  for
analysis  of data  collected at  a coal-fired  utility  for  the  purpose  of
performing  statistical  validation testing of  the  FTIR methods.   Separate
programs were  prepared  to measure  47  different compounds.   Four baseline
subtraction points were specified in each analytical region, identifying an
upper and a lower baseline averaging  range.   The absorbance  data  in each
range were  averaged,  a  straight baseline was  calculated  through the range
midpoint using the average absorbance values, and the baseline was subtracted
from the data prior to K-matrix analysis.

     Before K-matrix  analysis  was applied to data all  of the  spectra were
inspected to determine what species  had been  detected.   Program files were
constructed that  included reference spectra representing the detected species
and were  then used  to  calculate  concentrations  of the  detected species.
Sample concentration spectra were  also analyzed using program files that were
shown by the validation testing to be suitable for measuring some HAPs.

4.6.3  Error Analysis of data

     The principal constituents of the gas phase samples were water, C02, NO,
and N02.  A program file was prepared  to  quantify  each of these compounds.
Other than these species and N20 no major absorbance features were observed
in  the  spectra.    After  concentrations  of  the  main  constituents  were
determined,  the  appropriate standard  was scaled  and  subtracted from  the
spectrum of the sample mixture.   This  helped  verify the calculated  values.
New  spectra  were  generated  from  the  original   absorbance  spectra  by
successively subtracting scaled standard spectra of water, C02,  NO, and N02.
The resulting "subtracted"  spectra were analyzed for detectible absorbencies
of any HAPs  and,  for undetected species, the maximum possible concentrations
that could have been present in the samples.

     Maximum possible (minimum  detectible)  concentrations  were determined in
several steps.   The noise  level  in the appropriate  analytical  region  was
quantified  by  calculating  the root mean  square  deviation  (RMSD)   of  the
baseline in the subtracted  spectrum.   The  RMSD was multiplied  by the width
(in cm"1) of the analytical region to give an equivalent "noise area" in the
subtracted spectrum.  This value was compared to the integrated area of the
same analytical  region  in  a standard  spectrum of  the  pure compound.   The
noise was calculated from the equation:
                         RMSD =  ' -1- v " "   '  v ° "                     (6>
                                   fl i=i
where:

     RMSD =    Root mean square deviation in the absorbance values within a


                                     48

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               region.

               Number of absorbance values in the region.

               Absorbance  value  of  the  ith  data point  in  the  analytical
               region.

               Mean of all  the absorbance values in the region.
If a species is detected, then the error in the calculated concentration is
given by:
                             RMSD x  (x2  -
                          =            2
                                  Area,
                                               x CON,
(7)
where:

     Eppm  =    Noise related error in the calculated concentration, in ppm.

       x2  =    Upper limit, in cm"1, of the analytical region.

       x,  =    Lower limit, in cm"1, of the analytical region.

    AreaR  =    Total band area (corrected for path length, temperature, and
               pressure)  in  analytical  region  of  reference spectrum  of
               compound of interest.

     CONR  =    Known  concentration  of  compound  in  the  same  reference
               spectrum.

This  ratio  provided  a  concentration  equivalent to  measured area  in the
subtracted spectrum.   For instances when a compound  was  not detected, the
value Eppm was equivalent  to  the minimum detectible  concentration of that
(undetected) species in the sample.

     Some concentrations  given  in  Tables  3-3  to  3-5 are  relatively high
(greater than 10 ppm) and there are several possible reasons for this.

     •    The reference spectrum of the compound may show low absorbance at
          relatively high concentrations so that its  real  limit of detection
          is high.  An example of this may be acetonitrile.

     •    The region of the spectrum used for  the analysis may have residual
          bands or negative features resulting from the spectral subtraction.
          In these cases the absorbance of the reference band may  be large at
          low concentrations,  but  the  RMSD  is also large (see Equation 7).

                                     49

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          An example of  this  is  methyl  chloride.   If  the maximum possible
          concentrations  for  the  hot/wet   samples  (14.42  ppm)  and  the
          condenser samples (6.52 ppm) are compared for methyl chloride, the
          drier spectra give a significant improvement because it is easier
          to perform good  spectral  subtraction  on spectra where absorbance
          from water bands is weaker.

     •    The  chosen  analytical  region may be  too  large,  unnecessarily
          including regions of noise where  there is  no absorbance from the
          compound of  interest.   An example of this may  be  ethyl  benzene
          where the chosen analytical region is more than 250 cm  .

     In the second and  third cases the stated maximum possible concentration
may be lowered by choosing a different analytical region, generating better
subtracted  spectra, or by narrowing the  limits of  the  analytical  region.
Entropy has already taken  these  steps with  a number  of compounds.  If more
improvements can be made, they will  be included  in the final report.

4.6.4  Concentration Correction Factors

     Calculated  concentrations   in  sample  spectra  were  corrected  for
differences in absorption pathlength between the reference and sample spectra
according to the following relation:


                        p    - fLr^  v ( TS^  v tc   \                    (ai
                        '-corr ~  T~     "r"    (	'"'
                               \^B)   \Lz
where:

     CCOrr    =   The pathlength corrected concentration.

     C0aio    =   The initial calculated concentration (output of  the Multicomp
               program designed for the compound)

        Lr  =   The pathlength associated with the reference spectra.

        L8     =    The pathlength (22m) associated with the sample spectra.

        T9     =    The absolute temperature of the sample gas  (388 K).

        Tr  =   The absolute gas temperature at which reference  spectra were
               recorded (300 to 373 K).

     Corrections for variation in sample pressure were  considered, and found
to  affect the  indicated  HAP  concentrations  by  no more  that one  to two
percent.   Since  this is  a  small  effect in comparison  to  other sources of
analytical error, no sample pressure corrections were made.
                                     50

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4.6.5  Analysis of Sample Concentration Spectra

     Sample concentration spectra were analyzed in the same manner as  spectra
of the gas phase  samples.  To derive flue gas concentrations it was necessary
to divide the calculated concentrations  by the concentration factor (CF).  As
an illustration, suppose that 10  ft3 (about 283 liters) of gas were  sampled
and then desorbed  into  the  FTIR cell  volume of approximately 8.5 liters to
give concentration factor of  about  33.   If some compound was detected at  a
concentration  of  50  ppm  in  the cell,  then  its  corresponding  flue gas
concentration was about 1.5 ppm.  When determining the concentration factor
it was also important  to consider that the dry gas meter was cool  relative to
the FTIR cell. Also,  the total  sampled volume was measured after most of the
water was removed.  The total  volume of gas sampled was determined from the
following relation:
     where:

     Vfiue  =    Total volume of flue gas sampled.
     Vco,  =    Volume of gas sampled as measured at the dry gas meter  after
               it passed through the collection tube.
     Tf(ue  =    Absolute temperature of the  flue gas at the sampling location.
     T00|  =    Absolute temperature of the sample gas at  the dry  gas meter.
        W =    Fraction (by volume) of flue gas stream that was water vapor.


     The concentration  factor,  CF, was  then determined  using V{,ua and  the
volume of the FTIR cell (Vcell) which was measured at an absolute temperature
(Toell) of about 300 K:
                               CF =     ^                            (10)
                                     \ V cell I
     Finally, the  in-stack concentration  was  determined using  CF and the
calculated concentration of the sample contained  in the  FTIR cell, Coell.
                                r
                                '-flue
                                     51

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             5.0  QUALITY ASSURANCE/QUALITY CONTROL ACTIVITIES

     Quality  assurance   (QA)  is defined  as  a  system  of  activities  that
provides a mechanism of  assessing  the  effectiveness  of the quality control
procedures.  It is a total integrated program for assuring  the reliability of
monitoring and  measurement  data.   Quality  control  (QC)  is defined  as the
overall system of activities designed to ensure a quality product or service.
This  includes  routine  procedures for obtaining  prescribed   standards  of
performance in the monitoring and measurement process.

     The specific internal QA/QC procedures that were used during this test
program to facilitate the production of useful and valid data are described
in this section.   Each  procedure  was an integral part  of the test program
activities.  Section 5.1  covers  method-specific  QC procedures for the manual
flue  gas  sampling.   Section 5.2  covers  the QC procedures  used for the
instrumental methods.  QC checks of data reduction, validation and reporting
procedures are covered in Section 5.3, and corrective actions are discussed
in Section 5.4.
5.1  QC PROCEDURES FOR MANUAL FLUE GAS TEST METHODS

     This section  details  the QC procedures that  were  followed during the
manual testing activities.

5.1.1  Pi tot Tube QC Procedures

     The QC procedures for  pitot  tube AP measurements during the test runs
followed guidelines set forth by EPA Method 2.

     The following QC steps were followed during these tests:

     •  The S-type pitot tube was visually inspected before sampling.

     •  Both  legs  of the  pitot  tube  were leak  checked before  and after
        sampling.

     •  Proper orientation  of the S-type pitot tube  were maintained while
        making measurements.   The roll  and pitch  axis  of the S-type pitot
        tube was maintained at 90° to the flow.

     •  The magnehelic set was leveled and zeroed before each run.

     •  The pitot  tube/manometer  umbilical  lines  were inspected before and
        after sampling for leaks and  moisture condensate  (lines were cleared
        if found).

     •  Reported duct dimensions and  cross-sectional duct area were verified
        by on-site measurements.

     •  The stack gas temperature measuring system was checked by observing
        ambient temperatures prior to placement in the stack.
                                     52

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     The QC procedures that were followed in regards to accurate sample gas
volume determination are:

     •  The dry gas meter  is  fully  calibrated  immediately before the field
        test using an EPA approved intermediate standard.

     •  Pre-test and post-test leak  checks were completed  and were less than
        0.02 cfm or 4 percent of the average sample rate.

     •  The gas  meter was  read  to  a  thousandth  of  a  cubic foot  for the
        initial and final readings.

     •  Readings of the dry gas meter and meter  temperatures were taken every
        10 minutes during sample collection.

     •  Accurate barometric pressures were recorded at least once per day.

     •  Post-test dry gas meter checks  were  completed  to verify the accuracy
        of the meter full calibration constant (Y).

5.1.2  Sample Concentration Sampling QC Procedures

     QC procedures that  allowed representative  collection  of organics by the
sample concentration sampling system were:

     •  Only properly cleaned  glassware and prepared adsorbent tubes that had
        been kept closed  with  stainless steel caps were used for any sampling
        train.

     •  The filter, Teflon® transfer line, and adsorbent tube were maintained
        at ±10eF of the specified temperatures.

     •  An ambient sample was analyzed for background contamination.

5.1.3  Manual Sampling Equipment Calibration Procedures

5.1.3.1   Type-S  Pi tot  Tube  Calibration --  EPA  has  specified  guidelines
concerning the construction and geometry of  an  acceptable  Type-S pitot tube.
If the  specified  design  and construction guidelines  are  met,  a pitot tube
coefficient  of 0.84  is  used.   Information pertaining  to  the  design and
construction of the Type-S pitot tube is presented in detail in Section 3.1.1
of EPA document 600/4-77-027b.  Only Type-S  pitot  tubes meeting the required
EPA specifications were  used.   The pitot  tubes'were  inspected and documented
as meeting EPA specifications prior to field sampling.

5.1.3.2   Temperature Measuring Device Calibration  -- Accurate temperature
measurements  are  required  during  source  sampling.   The bimetallic  stem
thermometers  and  thermocouple  temperature  sensors  used during the  test
program were calibrated  using  the procedure described in Section 3.4.2 of EPA
document 600/4-77-027b.   Each temperature sensor  is calibrated at a minimum
of three points  over the anticipated  range  of use against a NIST-traceable
mercury-in-glass  thermometer.   All  sensors were  calibrated  prior to field
sampling.
                                     53

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5.1.3.3  Dry Gas Meter Calibration  -- Dry gas meters (DGMs) were used in the
sample trains to monitor the  sampling rate and to measure the sample volume.
All DGMs  were  fully calibrated  to determine the volume  correction factor
prior to their  use in the field.  Post-test calibration checks were performed
as soon as  possible  after  the equipment was returned as  a  QA  check on the
calibration  coefficients.    Pre-  and  post-test  calibrations  should  agree
within 5 percent.  The calibration procedure is documented in Section 3.3.2
of EPA document 600/4-77-237b.


5.2  QC PROCEDURES FOR INSTRUMENTAL METHODS

     The flue gas was  analyzed for CO, 02,  C02,  and HC.   Prior to sampling
each day, a pre-test leak check of  the  sampling system from the probe tip to
the heated manifold  was performed and was less than 4 percent of the average
sample  rate.    Internal  QA/QC  checks for  the  instrumental  test 'method
measurement systems are presented below.

     Method 3A  requires  that  the tester :  (1)  select  appropriate apparatus
meeting the applicable equipment specifications of the method, (2) conduct an
interference response  test prior  to the  testing program,  and (3)  conduct
calibration error (linearity),  calibration  drift,  and  sampling system bias
determinations during the testing program to demonstrate conformance with the
measurement   system   performance   specifications.       The   performance
specifications are identified  in the following table.
            TABLE 5-1.   INSTRUMENTAL TEST METHOD  SPECIFICATIONS.
PERFORMANCE TEST
Analyzer Calibration Error
Sampling System Bias
Zero Drift
Upscale Calibration Drift
Interference Check
SPECIFICATION
± 2% of span for zero, mid-, and
high-range calibration gases
± 5% of span for zero and upscale
calibration gases
± 3% of span over test run period
± 3% of span over test run period
± 7% of the modified Method 6 result
for each run
     A three-point  (i.e.,  zero,  mid-,  and high-range) analyzer calibration
error  check  is conducted  before initiating  the  testing by  injecting the
calibration  gases  directly  into  the  gas   analyzers   and  recording  the
responses.  Zero and upscale calibration checks are conducted both before and
after each test run  in order to quantify measurement system calibration drift
and  sampling  system bias.   Upscale  is either the  mid-  or  high-range gas,
whichever most closely approximates the flue gas level. During these checks,
the  calibration gases are  introduced  into the sampling  system at the probe
outlet so that the calibration gases are  analyzed  in the  same manner as the
                                     54

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flue gas samples.  Drift is the difference between the pre- and post-test run
calibration check responses.   Sampling system bias is the difference between
the test run calibration check responses  (system calibration) and the initial
calibration error responses  (direct  analyzer calibration) to the  zero and
upscale calibration gases.  If an acceptable post-test bias check result is
obtained but the zero or  upscale drift  result  exceeds  the drift limit, the
test run result is valid; however, the  analyzer calibration  error  and bias
check procedures must be repeated before conducting the next test run.  A run
is considered invalid and must be repeated if the post-test zero or upscale
calibration check result  exceeds  the bias specification.  The  calibration
error and bias checks must be repeated and acceptable results obtained before
testing can resume.

     Although not required by Methods 10  and 25A,  the  same calibration and
data reduction procedures required by Method 3A were used for the CO and HC
determinations to improve the quality of the reference data.


5.3  QA/QC CHECKS FOR DATA REDUCTION, VALIDATION, AND REPORTING

     Data quality audits were conducted  using data quality indicators which
require the detailed review of: (1) the  recording and transfer of raw data;
(2)  data  calculations;  (3)  the  documentation   of  procedures;  and  (4)  the
selection of appropriate data quality indicators.

     All  data  and/or calculations  for  flow rates,  moisture content,  and
sampling rates were spot checked for accuracy and completeness.

     In  general,  all  measurement  data   have  been  validated  based  on  the
following criteria:

     •  Acceptable sample collection procedures.

     •  Adherence to prescribed QC procedures.

Upon  completion of  testing,  the  field  coordinator  was responsible  for
preparation of  a data summary  including  calculation results and  raw data
sheets.

5.3.1  Sample Concentration

     The sample concentration custody procedures for  this test  program are
based on EPA recommended procedures.  Because collected  samples were analyzed
on-site, the custody  procedures emphasize careful  documentation of sample
collection and field analytical  data.  Use of chain-of-custody documentation
was  not  necessary,  instead  careful  attention  was  paid  to  the  sample
identification coding.   These procedures are discussed  in more detail below.

     Each  spectrum  of a  sample  concentration   sample  has been  assigned  a
unique alphanumeric identification  code.  For example, Tinll25A designates a
Tenax spectrum  of a  sample  taken at the  turbine outlet  (HRSG  inlet),  from
sample  tube  number 25.   The  A  means  this  is  the  spectrum of the first
desorption from this tube.   Every  adsorbent  tube has  been inscribed with a
tube identification number.

                                     55

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     The project manager was responsible for ensuring that proper custody and
documentation  procedures  were  followed  for  the  field  sampling,  sample
recovery, and  for  reviewing  the sample inventory after each  run  to ensure
complete  and  up-to-date  entries.   A  sample  inventory  was  maintained  to
provide an overview of all sample collection activities.

     Two  ambient samples  were  prepared at  the turbine  outlet.    One  was
obtained before  the  test  began  and a second after  the test was completed.
One ambient sample was  collected  at the HRSG  outlet.  The  ambient samples
were run  through the identical  trains  used  in the runs.   This  provided a
check for contamination of the sampling  train.   The  charged  ambient tube was
stored  and  analyzed  in the  same  manner as those obtained  during testing.
Ambient  runs  were 1-hour.    The  volume of  air drawn for  the  blanks  was
sufficient  to  verify  that  the sampling  train was  clean  and  performing
properly.   Because relatively minor contamination  was identified from the
ambient  samples,  it  was  accounted  for in  the subsequent  analyses  of the
sample  spectra by using spectral  subtraction.   Major contamination was not
observed in the  samples.

      Sample flow at the dry gas meter was recorded at 10 minute intervals.
Results from the analyzers and the spectra  of the gas phase  samples provided
a check  on  the  consistency of the effluent composition  during the sampling
period.

5.3.2  Gas  Phase Analysis

     During each test run  a total  of 12  gas phase samples were collected and
analyzed.   Each spectrum  was  assigned a unique file  name and a separate data
sheet identifying sample location and sampling conditions.  A comparison of
all spectra in  this  data set  provided  information on the consistency  of
effluent composition  and a real-time check on the performance of the sampling
system.   Effluent  was directed through  all  sampling lines for  at  least 5
minutes and the CEMs  provided  consistent readings over the  same period before
sampling was attempted. This requirement was  satisfied any  time there was a
switch  to  a  different  conditioning  system.    When  the  cell  was  being
evacuated,  the FTIR was continuously scanning to provide a  spectral profile
of  the  empty cell.   A new  sample  was not  introduced  until  there  was  no
residual  absorbance  remaining  from the previous one.   The  FTIR  was  also
continuously scanning during  sample collection to provide a real-time check
on possible contamination in the system.

5.3.3   FTIR Spectra

     For  a  detailed  description  of  QA/QC  procedures   relating to  data
collection  and  analysis,   refer   to   the  "Protocol   For  Applying  FTIR
Spectrometry in  Emission  Testing."  A  spectrum of the calibration transfer
standard (CTS)  was collected  at  the beginning and end of each data collection
session.  The CTS gas  was  100 ppm  ethylene in nitrogen.   The CTS spectrum
provided  a  check on  the operating conditions  of  the FTIR  instrumentation,
e.g. spectral  resolution and  cell path length.  Ambient pressure was recorded
whenever a  CTS spectrum was collected.

     Two copies  of all interferograms and processed spectra of backgrounds,
samples,  and the CTS were stored  on  separate  computer disks.   Additional

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copies of sample and CIS absorbance spectra were also stored for use in the
data  analysis.     Sample  spectra   can   be  regenerated   from   the   raw
interferograms, if necessary.   FTIR spectra are available for inspection or
re-analysis at any future date.

     Pure, dry ("zero")  air was periodically  introduced through the sampling
system in order to check for contamination.   Contamination was not observed,
but on one occasion water condensed in the cell  manifold.  The lines and cell
were purged with dry N2, until  the contamination was eliminated.

     As  successive spectra were  collected  the  position  and slope  of the
spectral base line were  monitored.  If the base line within a data set for a
particular  sample  run  began  to  deviate by  more than  5 percent  from 100
percent transmittance, a new background was collected.

5.4  CORRECTIVE ACTIONS

     During the course of the  test program, it  was the responsibility of the
field coordinator and the sampling team members to see that  all  measurement
data procedures were followed  as  specified and  that measurement data met the
prescribed acceptance criteria.
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                      6.0 CONCLUSIONS AND DISCUSSION
     Entropy conducted an emissions  test at T.H. Wharton Electric Generating
Station  in  Houston,  Texas.    Direct  gas  phase  analysis,  and  sample
concentration testing were both performed over two  days.   At the same time
gas analyzers were used to measure CO, 02, C02,  and hydrocarbons in the gas
streams.  Three 4-hour sample concentrations runs were conducted at the gas
turbine  outlet.    Direct  gas  phase  analyses  and  CEM  measurements  were
performed concurrently with the sample concentration runs.  Additionally, one
4-hour sample concentration  run was conducted at  the stack during Run 2 at
the turbine outlet.

     Gas phase analysis revealed the presence of water vapor, CO, C02,  N02 and
NO.  HC1,  ammonia  and nitrous acid (HN02) were detected  in sample concen-
tration spectra.   Also, some unidentified absorption bands were observed in
the sample concentration spectra.

     A primary goal of this  project  was to use FTIR  instrumention  in a major
test program to measure as many  HAPs as possible or  to place upper limits on
their concentrations.  Four other electric utilities were tested along with
the  T.H.  Wharton  facility.   Utilities  present  a  most  difficult  testing
challenge for two reasons:

     1) They are combustion sources so the flue gas contains high levels of
        moisture and C02 (both are spectral  interferants).

     2) The large volumetric flow rates typical of these facilities can lead
        to mass emissions above  regulated limits  even  for HAPs at very low
        concentrations.  This places great demand on the measurement method
        to achieve low detection  limits.  Furthermore,  with natural  gas as
        the combustion fuel,  concentrations of any HAPs formed in the process
        would be expected to be very low.

     This represents the  first  attempt to use  FTIR spectroscopy in such an
ambitious  test  program.     The  program  accomplished  very  significant
achievements and demonstrated important  and  fundamental  advantages of FTIR
spectroscopy as an emissions test method:

     •  Using a single method quantitative  data  were provided for over 100
        compounds.

     •  Software  was  written  to  analyze  a large  data  set and  provide
        concentration  and detection  limit  results  quickly.   The  same or
        similar software  can  be  used  for  subsequent tests with very little
        investment of time for minor modifications or improvements.

     •  The  original  data  are  permanently  stored   so  the results  can be
        rechecked for verification at any time.
     i

     •  A single method  was  used to obtain  both  time-resolved (direct gas)
        and  integrated  (sample  concentration)  measurements  of gas streams
        from two locations simultaneously.

     •  The two techniques of the FTIR method cover different concentration


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        ranges.
     •  Preliminary data (qualitative and quantitative) are provided on-site
        in real  time.
     •  With little effort at optimization  (see below),  detection limits in
        the ppb  range were calculated for 26 HAPs and between  1 and 5 ppm for
        77 other HAPs using direct gas phase measurements of hot/wet samples,
        which present  the  most difficult  analytical  challenge.    Sample
        concentration  provided even lower detection limits for some HAPs.
     •  A compound detect is unambiguous.

     It is appropriate to include some discussion about the "maximum possible
concentrations"  presented  in   Tables  3-3  to  3-5.    These  numbers  were
specifically not labeled as detection  limits because use of that term could
be misinterpreted, but  they will  be referred to  as "detection limits" in the
discussion below.
     In  FTIR  analysis  detection  limits  are  calculated  directly  from  the
spectra  (see  Section  4.6.3  and the  "FTIR Protocol").   These  calculated
numbers do not represent fundamental measurement limits,  but they depend on
a number of factors.  For example:
     Some instrumental  factors
        •  Spectral resolution.
        •  Source  intensity.
        •  Detector response and sensitivity.
        •  Path  length that the infrared beam travels through the sample.
        •  Scan  time.
        •  Efficiency  of infrared transmission  (through-put).
        •  Signal  gain.

     Some sampling factors
        •  Physical and chemical properties of a compound.
        •  Flue  gas composition.
        •  Flue  gas temperature.
        •  Flue  gas moisture content.
        •  Length  of sample line (distance from location).
        •  Temperature of sampling components.
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        •  Sample flow.

Instrumental factors are adjustable.   For  this  program instrument settings
were chosen to duplicate conditions that were successfully used in previous
screening tests and the validation test.  These conditions provide speed of
analysis,  durability  of  instrumentation,  and  the best  chance  to  obtain
measurements of the maximum number of compounds with acceptable sensitivity.
Sampling factors present the same challenges to any test method.

     An additional  consideration is that the  numbers presented in Tables 3-3
to 3-5 are all higher than the true detection limits that can be calculated
from the 1 cm'1 data collected at T.H. Wharton.  This results from the method
of  analysis:  the  noise calculations  were  made  only  after all  spectral
subtractions were  completed.   Each spectral subtraction  adds noise  to the
resulting subtracted spectrum.   For most compounds it is necessary to perform
only some (or none) of the spectral subtractions before its detection limit
can be calculated.   With more sophisticated software it will be possible to
automate  the  process  of  performing  selective  spectral   subtractions  and
optimize  the  detection  limit  calculation  for  each  compound.    (Such  an
undertaking was beyond the scope of the current project.)  Furthermore, the
detection  limits represent averages compiled from the results of all  the
spectra collected at the sampling location.   A more  realistic detection limit
is provided by the  single spectrum whose analysis gives the  lowest calculated
value.     It  would  be  more   accurate to  think  of  "maximum  possible
concentrations"  as placing  upper  boundaries on  the  HAP  detection  limits
provided by these data.

     Another important sampling consideration is the sample composition.  In
Table  3-3 benzene's  detection  limit  is  quoted  as  4.83 ppm.    This  was
determined  in  the  analytical  region  between 3020  and  3125 cm"1.   Benzene
exhibits a much stronger infrared band  at 673 cm"1 but this  band was not used
in  the analysis because  absorbance from  C02  strongly interfered  in  this
analytical  region.   At  a  lower  C02   emission  source  an  identical  FTIR
measurement system would provide  a  benzene  detection  limit below 1 ppm for
direct  gas analysis  (even  ignoring   the  consideration  discussed  in  the
previous paragraph).

     Any  difficulties  associated with  measuring particular compounds  are
related  to the  sampling  conditions and not the  FTIR  analysis.    It  was
necessary to cool  the flue gas  from about  1000°F down to about 300°F.  This
introduced the possibility of condensing relatively non-volatile species in
the sampling line.   The moisture content of  the flue gas was estimated to be
about 15 percent and this  should have caused  no problem with condensation in
the sampling  line.  However,  water  soluble species are  more  difficult to
measure  at  higher  moisture  levels.   FTIR  techniques  offer a good  way to
measure unstable or reactive  species because FTIR spectrometry can be readily
used to  monitor  the sampling system integrity.   That was  not done in  this
test  because  the  primary  goal was the general  one  of measuring as  many
compounds  as   possible,  not  optimizing  the measurement  system  for  any
particular compound or set of compounds.
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                              7.0  REFERENCES

1)   "FTIR Method  Validation  at a  Coal-Fired Boiler,"  EPA  Contract  No.
     68D20163, Work Assignment 2, July,  1993.

2)   "Computer-Assisted  Quantitative Infrared Spectroscopy,"  Gregory  L.
     McClure (ed.), ASTM Special Publication 934 (ASTM), 1987.

3)   "Multivariate Least-Squares Methods Applied to the Quantitative Spectral
     Analysis of Multicomponent Mixtures," Applied Spectroscopy, 39(10), 73-
     84,   1985.

4)   "Fourier Transform Infrared Spectrometry,"  Peter R. Griffiths and James
     de Haseth, Chemical Analysis,  83,  16-25,(1986),  P. J.  Elving,  J.  D.
     Winefordner and I. M.  Kolthoff (ed.),  John Wiley and Sons,.
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