United States       Office of Air Quality
Environmental Protection   Rannfng and Standards
Agency          Research Triangle Park, NC 27711
Air
EMB Report 93-UTL-3
May 1003
 Electric Utility
 Gas Fired Boiler
 Emission Test Report
 Houston Lighting and Power Company
 Greens Bayou Unit - 5

 Houston, Texas
         ^5r22^V

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    GAS-FIRED BOILER EMISSION TEST REPORT
     HOUSTON  LIGHTING AND  POWER  COMPANY
             GREENS BAYOU UNIT 5
                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 not been reviewed by
the U. S. Environmental Protection Agency.

     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  FACILITY DESCRIPTION	   4
     2.2  AIR POLLUTION CONTROL DEVICES 	   5
          2.2.1  Nitrogen Oxide (NOJ  Control  	   5
          2.2.2  Sulfur Dioxide (S02)  Control  	   5
          2.2.3  Particulate Control  	   5
     2.3  SAMPLE POINT LOCATION, UNIT 5 EXHAUST STACK 	   7

3.0  SUMMARY AND DISCUSSION OF RESULTS  	   9
     3.1  OBJECTIVES AND TEST MATRIX	   9

3.2  FIELD TEST CHANGES AND PROBLEMS	10
     3.3  SUMMARY OF RESULTS	11
          3.3.1  FTIR Results	11
               3.3.1.1  Gas Phase Results 	  11
               3.3.1.2  Sample Concentration Results  	  12
          3.3.2  Instrumental and Manual Test Results	26
          3.3.3  Process Results	31
               3.3.3.1   Operating Conditions 	  31
               3.3.3.2   Problems and/or Variations During Testing  .  .  31

4.0  SAMPLING AND ANALYTICAL PROCEDURES	39
     4.1  EXTRACTIVE SYSTEM FOR DIRECT GAS PHASE ANALYSIS 	  39
          4.1.1  Sampling System	39
          4.1.2  Analytical System  	  40
          4.1.3  Sample Collection Procedure	  .  40
     4.2  SAMPLE CONCENTRATION  	  43
          4.2.1  Sampling System	43
          4.2.2  Analytical System  	  43
          4.2.3  Sample Collection Procedure  	  45
     4.3  CONTINUOUS EMISSIONS MONITORING 	 	  45
     4.4  FLOW DETERMINATIONS	46
     4.5  PROCESS OBSERVATIONS  	  47
     4.6  ANALYTICAL PROCEDURES 	  47
          4.6.1  Description of K-Matrix Analyses 	  47
          4.6.2  Preparation of Analysis Programs 	  48
          4.6.3  Error Analysis of data	49
          4.6.4  Concentration Correction Factors 	  51
          4.6.5  Analysis of Sample Concentration Spectra 	  51
                                     n

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                                (Continued)
5.0  INTERNAL QUALITY ASSURANCE/QUALITY CONTROL ACTIVITIES  	  53
     5.1  QC PROCEDURES FOR MANUAL FLUE GAS TEST METHODS	53
          5.1.1  Sample Concentration Sampling QC Procedures  	  53
          5.1.2  Manual Sampling Equipment Calibration Procedures ...  54
               5.1.2.1  Temperature Measuring Device Calibration  ...  54
               5.1.2.2  Dry Gas Meter Calibration 	  54
     5.2  QC PROCEDURES FOR INSTRUMENTAL METHODS  	  54
          5.2.1   Daily Calibrations,  Drift  Checks,  and System Bias
               Checks	54
     5.3  QA/QC CHECKS FOR DATA REDUCTION, VALIDATION, AND REPORTING   .  55
          5.3.1  Sample Concentration 	  56
          5.3.2  Gas Phase Analysis	56
          5.3.3  FTIR Spectra	57
     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

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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)  Greens  Bayou  electric
generating station, Unit 5, gas-fired boiler in Houston, Texas.  The test was
conducted on May 20 and 21, 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.    The 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 is 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 EPA1.

     This  report   was  prepared  by  Entropy,  Inc.  under  EPA Contract  No.
68D20163, Work Assignment No.  1-34.  The  field test was performed under Work
Assignment  4 of  the  same  Contract.     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


                                     1

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analysis of the  extracted  gas  stream (hereafter referred to  as  "gas phase
analysis") and (2)  sample concentration followed by thermal desorption.  Gas
phase analysis involves  extracting  gas  from the 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 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,   850 to  1100 dry  liters of flue gas were sampled
during each sample concentration  run.   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
Greens Bayou and parked directly beneath the sample location.   The test was
performed over a two-day period.

     Entropy  tested  the  boiler exhaust  gases  at  the  stack.   The furnace
burned natural gas.  Section 2.0 contains descriptions of  the process and the
sampling point location.

     Gas phase analysis  was used  to measure sulfur dioxide (S02), nitrogen
oxides (NOJ,  carbon  monoxide  (CO),  carbon  dioxide (C02), and  ppm levels of
other  species.    EPA  instrumental  test  methods  were  used  to  provide
concentrations of CO,  C02, 02,  and  hydrocarbons.   Sample concentration was
used to measure  HAPs  at  ppb levels.   Entropy  conducted three  4-hour sample
concentration runs at  the exhaust stack.   Gas  phase  analysis  was performed
concurrently with the sample concentration  runs.   Combustion gas  volumetric
flows were  calculated from fuel  data provided  by  the  facility.    The test
schedule is given in Section 3.1.

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1.3  PROJECT ORGANIZATION

     This testing  program was  funded and  administered by  the Industrial
Studies Branch (ISB)  and the Emissions Measurement Branch (EMB)  of the Office
of Air  Quality Planning  and  Standards  (OAQPS)  of the  U.S.  EPA.    An RTI
representative 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) 945-8063
HLPC Greens Bayou:
Mr. Keith Nemec
(713)  458-3157
EMB Work Assignment
Managers:
Ms. Lori Lay             (919) 541-4825
Mr. Dennis Holzschuh     (919) 541-5239
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
Dr. Ed Potts
RTI Representative:
Mr. Jeffrey Cole
(919)  990-8606

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            2.0  PROCESS DESCRIPTION AND SAMPLE POINT LOCATIONS
2.1  FACILITY DESCRIPTION

     HLPC's Greens Bayou Unit 5 is located in Houston, Texas.  Greens Bayou
Unit  Five  is  a  tangentially  fired,  tilting-burner,  reheat boiler  with
controlled circulation.  It is  capable of supplying 3,054,000  Ib/hr of steam
to a Westinghouse turbo generator that is rated at a design maximum load of
420 MW.  The  unit normally operates as a  load-following unit, meaning that it
is operated  according  to electric demand (the plant  load  is varied during
normal operation from 90-350 MW).   Unit  5 undergoes a  planned  outage every 2
years for a maintenance inspection.

     During the test, the unit  was operated, whenever  possible, at a high MW
load (415 + 5 MW, approximately 90-100 percent capacity).  This was done to
maintain consistency in the  flue  gas  flow rates  during the test  runs.   The
primary fuel source  for  Unit 5 is natural  gas.  Unit 5 is also  capable of
using No.  6, No. 4, and No. 2 fuel oil as alternate fuels.

     Two forced draft  fans with  motors  rated at 3,500  hp  each provide and
control  the amount of preheated combustion air.  The  fans are located below
the stack (Figure 1), however,  there  is  no direct connection to the stack at
this point.  These fans push combustion  air through the  corner windboxes and
keep the unit under positive pressure.  Windboxes are  corner-mounted modular
firing units containing  air nozzles,  gas nozzles, and  igniters.   The  fans
also provide the sealing  air  (through a separate duct)  that  prevents backflow
through the gas recirculation system.

     In the  combustion chamber,  the preheated air and  fuel  are  introduced
through four windboxes  in the  four corners of the furnace.   Both  fuel and
combustion air  are  projected from the corners of the furnace along a  line
tangential to a small  circle moving  in  a  horizontal  plane  at the center of
the furnace.  The fuel  and combustion  air are  ignited  by an electrical spark
from gas igniters.   The flame zone extends from the corners  of the furnace to
the center where the fireball swirls.  This fireball  location  can be moved by
adjusting the tilting burners up or down in unison.   This technique is  used
to control furnace heat absorption in  the superheater  and reheater sections.
This action controls the  furnace exit-gas temperature for variations  in load.
Normal combustion flame temperatures are approximately  2,000  to 3,000 °F.

     Exhaust gases from the combustion chamber pass through the furnace over
the primary superheater,  secondary superheater, and secondary  reheater.  From
the secondary reheater, the gases pass through an  opening in the rear of the
furnace wall  into  the convection pass.   E-xhaust gases then  pass  over the
primary reheater and economizer to the air preheater  and out the stack.   The
gas recirculation system inlet is located  after the economizer.  Flue gas is
taken from  the economizer  outlet and re-introduced  at the  bottom  of the
furnace.  Recirculation of a  portion of the flue gas through the furnace will
increase  the  steam  temperature.    Temperature  control  is obtained  by
positioning dampers  to regulate  the  amount  of recirculated gas.   Also, the
added flue gas  flow  is used  to broaden  the  combustion zone so that it  does
not  concentrate in  the  burner area.   Keeping the  combustion zone spread

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throughout the  furnace  reduces  NOX  formation which would  be  higher if the
combustion zone were smaller and hotter.
2.2  AIR POLLUTION CONTROL DEVICES

2.2.1  Nitrogen Oxide (NOJ  Control

     Tangentially fired units,  because of their design, are low NOX emitters.
These units provide for more complete mixing of fuel and air.  Although the
gas recirculation installed on the unit  tends  to  reduce  NOX emissions, it is
used  only  as  a  means  of reheat  temperature control  for  the  combustion
chamber.

2.2.2  Sulfur Dioxide (SO..)  Control

     Emissions of S02 are considered negligible for natural  gas firing.  When
the alternative fuel  (fuel  oil) is used, S02 emissions are controlled by the
use of low sulfur content oil, or split-firing of fuel oil and natural gas.
Current State  regulations  limit  fuel  oil  sulfur  content  to  0.7  percent by
weight.  Lower sulfur fuel oil  (less than 0.3 percent sulfur)  or split-firing
to achieve 150 ppm S02  is required as of July  31, 1993.

2.2.3  Particulate Control

     Particulate and visible emissions are  limited by the use of natural gas
as the primary fuel and utilization of No.  2 distillate oil  as an alternate
fuel.

     The process information provided in the  section above was supplied by
Greens Bayou plant personnel.

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     Secondary
      Reheater
     Secondary
     Superheater
 Primary
Reheater
      Primary
    Superheater
\
    Combustion
     Chamber
   Comer-mounted
   Windboxes (4)
                        Economizer
                                                                 Stack
                                      Hot, Clean
                                     Combustion
                                         Air
                                         Gas Recirculation,
                                          Sealing Air Duct
                          Cold, Clean
                        Combustion Air
                                          Gas
                                      Recirculation
                                        Damper
                                        Gas
                                    Recirculation
                                        Fan
                            Forced
                             Draft
                             Fans
   Figure 2-1:  Houston Light & Power - Greens Bayou Unit Five
                   Combustion Air & Flue Gas Flow

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2.3  SAMPLE POINT LOCATION, UNIT 5 EXHAUST STACK

     The  sampling  was   conducted   at  the  rectangular   exhaust   stack,
approximately 8  ft.  downstream of  the air preheater  outlet.    Figure  2-2
indicates the position of the test  location in  relation  to the furnace  and
other components of the system.   Figure 2-3  provides greater detail  of  the
test location.   The measurement  point on the stack is approximately 114 feet
above ground level.  The stack dimensions  are  11 ft.  deep by 26.5 ft. wide.
Four 6-inch sampling ports are evenly spaced across the width of the stack.
For gas phase analysis,  the  location  was  reached using  150  feet of heated
Teflon line.  The middle two ports were used for sampling.

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t 1

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3.5'
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.5'

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                                                                                            Gas Phase
                                                                                            Sample Port


                                                                                               Sample
                                                                                            • Concentration
                                                                                             Sample Port
50104 9/93         Figure 2-2.  Houston Lighting and Power, Greens Bayou Unit 5 Exhaust Stack.

                                                    8

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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 boilers.  EPA will also
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, 1  ppm  and above
               using  gas  phase analysis, and  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.

          •    Obtain   process   information  from  Greens  Bayou.     This
               information includes the rate of power production during the
               testing periods.


     Table 3-1 presents the test  schedule that was  followed at Greens Bayou.

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           TABLE 3-1. FTIR TESTING SCHEDULE AT GREENS BAYOU STACK #5
SAMPLING PERIODS
Date
5/19/93
5/20/93

5/21/93
5/21/93
Run#a
Amb
1
2
3
Amb
Gas Phase
Analysis

1130-1416
1550-1936
1109-1316

Sample
Cone.
1740-1840
0930-1330
1530-1930
0945-1345
1415-1515
CEM Analyzers
O2,CO2,CO,HC

1016-1416
1417-1934
1106-1350

Thermal Desorption
Date
5/20
5/21
5/21
5/21
5/21
Time
2340-2354
2358-0021
0024-0046
1452-1508
1608-1624
         Amb denotes an ambient sample.
3.2  FIELD TEST CHANGES AND PROBLEMS

     Initially, the plan called for two 4-hour sample concentration runs on
May 20 and performing gas phase analysis concurrently for the entirety of the
two 4-hour periods.   Instead,  the first sample  concentration  run began as
soon as the sampling system was ready and the process was operating at full
load.   The  gas  phase run  started  soon   after the  beginning  of  sample
concentration Run 1, continued^through the end of Run 1 and into Run 2, but
was stopped before the  end of sample concentration Run 2.  Gas phase analysis
was also performed for less than the 4 hours of sample concentration Run 3.
Orsat  analysis  provided  data  for  the  periods  when  the CEMs  were  not
operating.   This  plan  was the  best  way  to accomplish  the  test objectives
while completing the test runs within the originally planned time.

     On the  evening of May  20  (after  Run 2  and  before  Run 3)  Entropy
performed a  spiking  test  using formaldehyde in  an  experiment  unrelated to
this  project.   During  the course  of the  experiment samples  spiked  with
formaldehyde  were  introduced  to  the sample  conditioning systems.    The
polymeric  form (paraformaldehyde) readily  condenses on  the  walls of the
PermaPure membrane.  Because the membrane has a  large surface area,  extensive
purging is usually required to remove some compounds.  Traces of formaldehyde
remained in the PermaPure system and contaminated three of the FTIR samples
from Run 3.  The formaldehyde concentration in these FTIR samples  was  about
5 ppm.  This contamination did not interfere with the FTIR analysis for any
other species.
                                     10

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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.   Spectra  were  analyzed, using procedures
developed by Entropy,  to determine  concentrations of any species detected.
These  results  are  presented  in  Tables  3-2 and 3-3.   Maximum  possible
concentrations were  calculated  for undetected  HAPs.    These  results  are
presented in Tables 3-4 to 3-6.

3.3.1.1  Gas  Phase  Results  -- Each gas phase FTIR spectrum  was separately
analyzed for the presence of HAPs and other species.  Compounds detected in
the gas phase samples were;

     •    Water vapor.

     •    C02 and CO.

     •    Nitric oxide (NO)  was the largest component of  the  NOX emissions.
          The NO stack concentration, from 51 to 79 ppm,  could  be measured in
          hot/wet, condenser and PermaPure samples.

     •    N02 and N20 were detected, but not quantified because quantitative
          reference spectra are not currently available.

     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 multiplied by an appropriate scaling  factor  and subtracted from each of
the sample spectra.  The remaining  base lines were then analyzed for every
compound  represented  in  the  quantitative  reference  spectra   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 3-4 and 3-5 respectively.
The results are averages of the calculated values for all  of the spectra over
the 3 sample runs.

     The maximum  possible  concentrations  for HAPs given in  Table  3-4  for
hot/wet samples  and  Table 3-5  for  condenser samples represent upper limits
for the in-stack  concentrations.   This means that,  for  a HAP to have been
present  in  the  gas  stream,  its concentration  must have  been below  the
calculated maximum possible concentration.  The results presented in Tables
3-4 and 3-5  indicate how effectively these compounds could  be  measured  by
FTIR analysis with the analytical system used for this test.

     The hot/wet gas  phase spectra are difficult to analyze because of strong
interference from water  vapor.  Even  so,  in results from the  hot/wet  gas
phase data, 96 compounds give maximum possible concentrations below 10 ppm,
of these 70 are below 5 ppm and 29 are 1 ppm or lower.
                                     11

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     Previously, Entropy developed analysis programs to analyze for HAPs in
FTIR  spectra  of  samples  extracted   from   a   coal-fired  boiler  stack.
Statistical analyses snowed 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  boiler  (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.

3.3.1.2   Sample  Concentration Results   -- The sample  concentration spectra
represent  integrated  samples  over each 4-hour  run.    In  addition  to water
vapor, C02, CO, and NO,  the following compounds  were detected;

     •    Ammonia (NH3)  was detected in the stack samples form all three runs
          and  in both of the ambient samples.

     •    Freon(ll) (CC13F) was  detected  in the  stack sample  from Run 1.
          This has been identified in sample concentration spectra taken at
          other emission sources and it is believed to be a contaminant.

     •    HC1 was detected in  trace  amounts in the post-test ambient sample.

     •    Evidence of hexane was observed  in  samples from  all three  runs and
          also the ambient samples.  Absorbencies similar to hexane are often
          observed in  spectra  of desorbed samples.  These features are due to
          a mixture  of alkane  hydrocarbons,  including hexane,  the sum of
          whose spectra gives absorbances which appear similar to hexane.

     Table 3-3 shows calculated  concentrations of HC1 and ammonia from all of
the test  runs.   The concentration of CC13F could not  be determined because
quantitative   reference  spectra  are  not   currently   available.     The
concentration  for HC1  was near its limit of detection.  The calculated value
is  shown  only  for  the  spectrum  where  HC1   was  detected.     In-stack
concentrations were estimated by  dividing  the  in-cell  concentration by the
concentration  factor (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,  NO  and   NH3.
Therefore,  the  values   in   Table   3-3  represent   lower  limits  on  the
concentrations for these species.  Upper limits  for  NH3  and HC1 are provided
by the values  given  in  the gas phase data (Tables 3-4  and 3-5)   Table 3-6
gives maximum  possible concentrations for species not detected using Tenax.

     Other absorbance bands, which remain  unidentified,  were  observed in the
sample from Run  2.   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.  contamination).  The
first  ambient sample  and spectra  of   samples  from Runs  1  and  2  contain
negative  absorbance features  due  to  methane  meaning that  traces of methane
were  in  the cell when  the  single beam background  spectrum was collected.
This minor contamination caused no difficulty with the analysis.
                                     12

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     Spectral  analysis  programs  were also  previously  developed for  the
validation of the sample concentration technique.  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.
                                     13

-------
TABLE 3-2. FTIR RESULTS FROM ANALYSIS OF GAS PHASE SAMPLES
Date
5/20/93
Run
#
1.0
2.0
Sample
Time
1124-1127
1135-1138
1145-1147
1152-1155
1210-1212
1225-1227
1326-1328
1338-1342
1345-1348
1400-1404
1412-1415
1546-1549
1554-1555
1600-1602
1713-1715
1720-1724
1730-1740
1745-1800
1820-1831
1901-1903
1912-1914
1924-1926
1930-1932
Sampling System
to FTIR (a)
Hot/Wet
Condenser
Condenser
Perma-Pure
Hot/Wet
Condenser
H2O
(%)
17.0

17.0
-


Flow Rate
(DSCFM)
646,974
646,974
622,720
622,720
622,720
622,720
NO
ppm Ib/hr
77.8 235.1
73.4 221.8
78.1 236.1
75.7 228.8
68.9 208.2
74.6 225.5
71.7 216.7
72.0 217.6
70.4 212.8
78.9 238.5
78.1 236.1
75.5 219.6
74.2 215.9
73.9 215.0
74.9 217.9
75.7 220.2
73.5 213.8
74.2 215.9
74.2 215.9
60.1 174.8
58.1 169.0
59.6 173.4
64.1 186.5

-------
TABLE 3-2. (Continued)
Date
5/21/93
Run
#
3.0
Sample
Time
1108-1109
1113-1114
1120-1121
1131-1133
1143-1145
1150-1152
1158-1200
1205-1208
1220-1233
1236-1246
1250-1259
1302-1315
Sampling System
to FTIR
Hot/Wet
Condenser
Perma-Pure
H2O
(%)
17.0


Flow Rate
(DSCFM)
568,071
568,071
568,071
NO
ppm Ibs/hr
54.9 145.7
53.6 142.2
52.2 138.5
55.9 148.4
58.4 155.0
56.8 150.7
56.2 149.1
60.0 159.2
56.2 149.1
55.3 146.8
50.9 135.1
57.5 152.6

-------
TABLE 3-3.  CONCENTRATIONS CALCULATED FOR SOME MAP'S THAT WERE
               DETECTED IN SPECTRA OF CONCENTRATED SAMPLES EXTRACTED
               FROM THE UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOLER.

Run*

1
2
3
Ambient 1
Ambient 2
Nitric Oxide (a)
In-Cell Flue Gas
(ppm) (c) (ppm) (d)
21.44
21.27
10.65


0.2079
0.1768
0.0595
0.0000
0.0000
Ammonia
In-Cell Flue Gas
(ppm) (ppm)
5.12
1.00
0.49
12.27
0.95
0.0496
0.0083
0.0027
0.0913
0.0071
Hydrogen Chloride
In-Cell Flue Gas
(ppm) (ppm)




1.78
0.0000
0.0000
0.0000
0.0000
0.0133
Hexane (b)
In-Cell Flue Gas
(ppm) (ppm)
2.03
1.82
1.95
1.14
1.30
0.0197
0.0151
0.0109
0.0085
0.0097
       (a) Compounds detected on Tenax for which Entropy has obtained quantitative reference spectra.
         Blank spaces indicate a non-detect.
       (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 3-4. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF HOT/WET SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Acetonttnle
Acrolein
Acrylonitnle
Mlyl Chloride
Benzene
Bromoform
1,3-Butadiene
Carbonyl Sulfide
Chlorobenzene
Ethyl Benzene
Ethyl Chloride
Ethylene Oibromide
i-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
Vinyl Chloride
i/inylidene Chloride
O-xylene
P-xylene
Carbon Oisulfide
Carbon Tetrachloride
Chloroform
Analytical Region (wni(b)
1041.40 - 1042.88
2636.11 - 2875.59
922.19 - 997.82
893.51 - 1002.22
3036.88 - 3063.07
1135.90 - 1154.20
870.00 - 1052.64
2029.21 - 2075.69
1012.42 - 1036.64
2866.13 - 2921.27
943.43 - 1000.16
1167.96 - 1208.92
2835.27 - 3005.43
2948.11 - 2972.53
1017.96 - 1020.72
1140.70 - 1222.63
2872.05 - 2994.95
1137.50 - 1232.04
1249.95 - 1285.66
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
832.23 - 906.69
899.81 - 904.54
852.81 - 1056.06
1059.44 - 1113.01
2859.84 - 3095.04
2854.43 - 3083.14
2171.29 - 2184.68
793.89 - 800.58
758.21 - 781.25
STACK
RMSD(c)
1.29E-03
1.58E-03
5.58E-03
5.26E-03
1.37E-02
5.33E-03
6.05E-03
4.49E-02
7.30E-03
2.00E-03
5.57E-03
7.12E-03
5.80E-03
5.70E-03
2.31 E-03
7.29E-03
6.05E-03
1.08E-02
1.48E-01
5.15E-03
6.08E-03
4.09E-03
3.99E-03
1.97E-03
4.70E-03
4.72E-03
6.24E-03
4.49E-03
1.47E-03
6.12E-03
9.87E-03
1.07E-02
1.08E-02
2.56E-02
1.95E-02
3.51 E-02
Max. Con.
(ppmMd)
6.89
2.06
4.59
4.29
6.41
1.00
6.33
2.56
6.72
4.08
7.76
5.07
0.84
6.53
7.55
5.37
2.55
1.21
60.60
5.68
7.16
3.10
0.36
3.11
4.90
0.91
0.75
2.77
0.62
6.25
2.63
6.78
5.88
24.30
0.38
1.77
                                 17

-------
TABLE 3-4. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF HOT/WET SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Cutnene
1,2-Epoxy Butane
Ethylene Oxide
Methanol
Methyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
'ropylene Oxide
^-xylene
Acetone
Acetaldehyde
Acetophenone
Acrylic Acid
Aniline
Uenzotnchloride
Benzyl Chloride
3is(chloromethyl)ether
Chloroacelic acid
2-Chloroacteophenone
Chloromethyl methyl ether
Chloroprene
o-Cresol
m-Cresol
p-Cresol
1,2-Dibromo-3-chloropropane
1 ,4-Dichlorobenzene
Dichloroethyl ether
1 ,3-Oichloropropene
Dichlorvos
N.N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1 -Dimethyl hydrazine
Dimethyl phthalate
1,4-Dioxane
Epichlorohydrin
Analytical Region (wn)(b)
1015.82 - 1063.57
902.37 - 919.70
866.90 - 875.00
2807.91 - 3029.40
1057.95 - 1105.30
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2910.25 - 2952.78
1182.00 - 1255.03
2685.41 - 2744.40
874.88 - 1126.36
1104.89 - 1164.68
1102.90 - 1123.63
866.50 - 877.90
1262.87 - 1279.12
1068.78 - 1154.25
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 - 1146.08
875.90 - 878.80
1092.80 - 1114.07
1139.68 - 1172.77
1159.10 - 1185.50
855.88 - 904.72
995.96 - 1031.06
1109.35 - 1155.04
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
2861.10 - 2864.80
943.52 - 981.73
STACK
RMSD(C)
7.18E-03
3.95E-03
1.69E-03
7.07E-03
9.44E-03
1.92E-03
4.76E-03
1.14E-02
4.04E-03
1.23E-02
1.54E-03
8.59E-03
6.32E-03
8.37E-03
1.56E-03
2.13E-01
8.09E-03
7.52E-03
9.48E-03
6.74E-03
1.59E-03
6.05E-03
3.52E-03
6.11E-03
3.15E-03
4.20E-03
6.58E-03
2.09E-02
4.98E-03
1.11E-02
3.35E-03
1.54E-03
5.03E-03
1.12E-02
1.17E-03
6.35E-03
Max. Con.
(ppm)(d)
17.71
2.87
0.41
5.68
1.66
1.74
0.75
7.20
2.46
5.35
2.53
7.14
0.79
2.66
0.29
96.56
0.86
1.60
1.74
0.97
0.28
2.51
0.63
0.66
5.36
1.80
0.73
4.17
0.57
6.34
0.82
0.95
4.06
5.83
0.18
5.08
                                 18

-------
 TABLE 3-4. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
           HAPs NOT DETECTED IN SPECTRA OF HOT/WET SAMPLES EXTRACTED FROM
           UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Ethyl Acrylate
Ethylene Bichloride
Ethylidene bichloride
Formaldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
Hexachloroethane
Hexamethylphosphoramide
Hydrochloric Acid
Isophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
N-Nitrosodimethylene
\l-Nitrosomorpholine
Phenol
aeta-Propiolactone
Propionaldehyde
1,2-Propylenimine
Quioline
Styrene Oxide
1 , 1 ,2,2-Tetrachloroethane
2.4-Toluene diisocyanate
a Toluidine
1 ,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tnethylamine
Ammonia
Analytical Region (wni (b)
1181.93 - 1210.00
1227.88 - 1241.50
930.35 - 1126.16
2788.33 - 2842.20
976.90 - 997.70
1227.02 - 1240.42
995.46 - 1042.73
949.42 - 1019.53
2817.35 - 2823.26
2681.20 - 3130.60
885.27 - 905.56
2683.00 - 3061.78
779.31 - 783.55
841.70 - 861.39
928.00 - 1085.28
892.23 - 1024.64
879.40 - 882.40
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
2858.50 - 2951.85
1009.00 - 1198.39
1178.04 - 1204.16
856.27 - 863.36
2756.62 - 2839.34
893.10 - 926.00
STACK
RMSD(c)
6.55E-03
5.49E-03
9.45E-03
1.24E-03
2.78E-03
6.07E-03
6.73E-03
5.51 E-03
1.04E-03
1.12E-02
2. 14 E-03
7. 62 E-03
1.26E-02
5.84E-03
7.33E-03
5.18E-03
4.08E-04
4.35E-03
8.12E-03
2.20E-03
7.16E-03
3.09E-03
8.86E-03
2. 11 E-03
3.07E-03
1.09E-02
6.62E-03
2.23E-03
1.26E-03
3.83E-03
Max. Con.
(ppm)(d)
0.33
3.01
12.98
1.23
0.38
0.45
23.35
0.74
1.00
6.94
0.21
8.17
1.21
2.26
2.22
2.03
0.79
0.89
8.53
0.93
1.05
2.12
1.98
1.50
2.49
7.26
1.98
0.52
0.52
2.28
(a) HAP's for which Entropy has obtained quantitative reference spectra.
(b) Frequency 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 (in ppm) of undetected compound, that could have been present in FTIR samples,
    calculated according to procedures discussed in Sections 4.6.3 and 3.3.1.
                                      19

-------
TABLE 3-5. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF CONDENSED SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Acetonrtrile
Acrolein
Acrylonitrile
Ally) Chloride
lenzene
Bromoform
,3-Butadiene
Carbonyl Sullide
Chlorobenzene
Ethyl Benzene
Ethyl Chloride
Ethylene Dibromide
n-Hexane
Methyl Bromide
Methyl Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methyl Methacrylate
vlethylene Chloride
2-Nitropropane
'ropylene Dichloride
Styrene
fetrachloroethylene
Toluene
1 ,1 ,2-Trichloroethane
rrichloroetfiylene
2,2,4-Trimethylpentane
Wnyl Acetate
Vinyl Bromide
Vinyl Chloride
i/inylidene Chloride
O-xylene
P-xylene
Caiton Oisulfide
Carbon Tetrachloride
Chloroform
Analytical Region (wn)(b)
1041.40 - 1042.88
913.70 - 1000.35
92Z19 - 997.82
893.51 - 1002.22
3036.88 - 3063.07
1135.90 - 1154.20
870.00 - 1052.64
2029.21 - 2075.69
1012.42 - 1036.64
2866.13 - 2921.27
2916.56 - 3041.03
1167.96 - 1208.92
2835.27 - 3005.43
2948.11 - 2972.53
1017.96 - 1020.72
1140.70 - 1222.63
2872.05 - 2994.95
1137.50 - 1232.04
1249.95 - 1285.66
831.47 - 868.50
996.86 - 1038.00
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
899.81 - 904.54
852.81 - 1056.06
834.13 - 898.73
2859.84 - 3095.04
2854.43 - 3083.14
2171.29 - 2184.68
793.89 - 800.58
758.21 - 781.25
STACK
RMSD(c)
1.40E-03
3.15E-03
3.24E-03
3.18E-03
2.31 E-03
1.81E-03
3.23E-03
1.56E-02
2.44E-03
1.96E-03
3.08E-03
2.05E-03
3.21 E-03
1.87E-03
1.46E-03
2.28E-03
3.38E-03
3.06E-03
8.45E-03
1.86E-03
2.18E-03
2.46E-03
2.16E-03
2.77E-03
3.41 E-03
2.65E-03
3.28E-03
1.78E-03
1.05E-03
3.19E-03
1.73E-03
3.45E-03
3.46E-03
1.48E-02
5.11E-03
1.92E-02
Max. Con.
(ppm)(d)
7.47
2.00
2.67
2.59
1.08
0.34
3.38
0.89
2.24
4.01
2.29
1.46
0.47
2.14
4.78
1.68
1.42
0.34
3.45
2.05
2.57
1.86
0.20
1.31
3.55
0.41
0.39
1.10
0.44
3.26
1.10
2.19
1.89
14.12
0.10
0.97
                               20

-------
TABLE 3-5. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF CONDENSED SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Cumene
,2-Epoxy Butane
Ethylene Oxide
Methanol
ilethyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
'ropylene Oxide
ri-xylene
Acetone
Acetaldehyde
Acetophenone
Acrylic Acid
Aniline
Jenzotrichloride
Benzyl Chloride
)n(chloromethyl)ether
Chloroacetic acid
2-Chloroacteophenone
Chloromethyl methyl ether
Chloroprene
o-Cresol
m-Cresol
p-Cresol
1 ,2-Dibromo-3-chloropropane
1 ,4-Dichlorobenzene
Dlchloroethyl ether
1 ,3-Dichloropropene
Dichlorvos
N.N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1-Dimethyl hydrazine
Dimethyl phthalate
1,4-Dioxane
Epichlorohydrin
Analytical Region (wn)(b)
1015.82 - 1063.57
2859.05 - 3076.29
866.90 - 875.00
2807.91 - 3029.40
1057.95 - 1105.30
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2910.25 - 2952.78
1182.00 - 1255.03
3006.20 - 3009.20
1140.40 - 1286.06
1104.89 - 1164.68
1102.90 - 1123.63
866.50 - 877.90
1262.87 - 1279.12
1068.78 - 1154.25
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 - 1146.08
875.90 - 878.80
1092.80 - 1114.07
1139.68 - 1172.77
1159.10 - 1185.50
855.88 - 904.72
995.96 - 1031.06
1109.35 - 1155.04
768.00 - 791.00
835.77 - 876.95
2655.32 - 3156.07
889.55 - 917.52
1057.80 - 1103.90
856.12 - 974.09
1157.86 - 1254.16
2861.10 - 2864.80
943.52 - 981.73
STACK
RMSD(C)
3.32E-03
3.48E-03
9.48E-04
3.29E-03
429E-O3
9.98E-04
1.79E-03
3.54E-03
2.09E-03
3.41 E-03
6.41 E-04
5.02E-03
1.94E-03
1.90E-03
8.79E-04
9.31 E-03
3.63E-O3
2.19E-03
4.12E-03
1.75E-03
8.72E-04
2.19E-03
1.80E-03
1.95E-03
1.54E-03
2.00E-03
1.91 E-03
1.08E-02
1.85E-03
3.38E-03
1.76E-03
4.24E-03
2.94E-03
3.15E-03
8.33E-04
3.18E-03
Max Con.
(ppm)(d)
8.18
1.48
0.23
2.65
0.75
0.90
0.28
2.24
1.27
1.48
1.53
0.65
0.24
0.60
0.16
4.22
0.39
0.46
0.76
0.25
0.16
0.91
0.32
0.21
2.63
0.86
0.21
2.15
0.21
1.92
0.43
0.97
2.37
1.63
0.13
2.54
                                 21

-------
 TABLE 3-5. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
           HAPs NOT DETECTED IN SPECTRA OF CONDENSED SAMPLES EXTRACTED FROM
           UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Ethyl Acrylate
•thylene Bichloride
Ethylidene bichloride
Formaldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
texachloroe thane
•lexamethylphosphoramide
Hydrochloric Acid
Isophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
N-Nitrosodimethylene
vl-Nitrosomorpholine
Phenol
jeta-Propiolactone
Propionaldehyde
1 ,2-Propy lenimine
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
rriethylamine
Ammonia
Analytical Region (wn)(b)
1181.93 - 1210.00
1227.88 - 1241.50
930.35 - 1126.16
2788.33 - 2842.20
847.50 - 864.50
1227.02 - 1240.42
995.46 - 1042.73
949.42 - 1019.53
2817.35 - 2823.26
2681.20 - 3130.60
885.27 - 905.56
2683.00 - 3061.78
779.31 • 783.55
841.70 - 861.39
928.00 - 1085.28
892.23 - 1024.64
1162.67 - 1195.76
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
2858.50 • 2951.85
1009.00 - 1198.39
1178.04 - 1204.16
856.27 - 863.36
2756.62 - 2839.34
893.10 - 926.00
STACK
RMSD(c)
1.70E-03
1.67E-03
4.45E-03
1.25E-03
2.09E-03
1.77E-03
2.47E-03
2.63E-03
8.43E-04
3.37E-03
1.19E-03
3.08E-03
3.74E-03
1.85E-03
3.76E-03
3.13E-03
1.92E-03
2.79E-03
2.96E-03
1.41E-03
3.05E-03
1.57E-03
3.17E-03
1.19E-03
2.45E-03
4.62E-03
1.66E-O3
1.25E-03
1.22E-03
2.15E-03
Max. Con.
(ppm)(d)
0.08
0.92
6.12
1.23
0.19
0.13
8.56
0.35
0.81
2.09
0.12
3.31
0.36
0.71
1.14
1.23
0.29
0.57
3.11
0.60
0.45
1.08
0.71
0.85
1.99
3.08
0.50
0.29
0.51
1.28
(a) HAP's for which Entropy has obtained quantitative reference spectra.
(b) Frequency 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 (in ppm) of undetected compound, that could have been present in FTIR samples,
    calculated according to procedures discussed in Sections 4.6.3 and 3.3.1.
                                    22

-------
TABLE 3-6. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF CONCENTRATED SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Acetonitrile
Acrolein
Acrylonitrile
Ally! Chloride
tanzene
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
Vlethylene Chloride
2-Nitropropane
Propylene Oichloride
Styrene
Tetrachloroethylene
Toluene
1 . 1 ,2-Trichloroethane
Frichloroethylene
2.2,4-Trimethylpentane
Vinyl Acetate
Vinyl Bromide
Vinyl Chloride
Vinylidene Chloride
O-xylene
P-xylene
Carbon Oisulfide
Carbon Tetrachloride
Chloroform
Analytical R
1041.40 - 1042.88
2636.11 - 2875.59
922.19 - 997.82
893.51 - 1002.22
3036.88 - 3063.07
1135.90 - 1154.20
870.00 - 1052.64
2029.21 • 2075.69
1012.42 - 1036.64
2866.13 - 2921.27
2916.56 - 3041.03
1167.96 • 1208.92
2835.27 - 3005.43
2948.11 - 2972.53
1017.96 • 1020.72
1140.70 - 1222.63
2872.05 - 2994.95
1137.50 - 1232.04
1249.95 - 1285.66
2875.79 - 3039.65
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
899.81 - 904.54
852.81 • 1056.06
1059.44 - 1113.01
2859.84 - 3095.04
770.61 - 819.06
2171.29 - 2184.68
793.89 - 800.58
758.21 - 781.25
STACK
RMSO(C)
4.55E-04
8.59E-04
-7.26E-03
6.81 E-03
6.33E-03
2.42E-03
6.08E-03
1.59E-02
3.03E-03
1.63 E-03
6.94E-03
3. 71 E-03
3.07E-03
2.52E-03
3.29E-04
5.18E-03
3.23E-03
5.61 E-03
1.55E-02
6.27E-03
2. 73 E-03
5.01 E-03
2.56E-03
1.67E-03
6.23E-03
6.00E-03
3.28E-03
6.61 E-03
2.35E-04
6.99E-03
7.66E-03
6.60E-03
3.75E-03
1.11E-02
5.68E-03
1.74 E-03
Max. Con.
(ppm)(d)
2.42
1.12
5.98
5.56
2.96
0.45
6.36
0.90
2.79
3.33
5.15
2.64
0.45
2.89
1.08
3.82
1.36
0.63
6.33
5.31
3.21
3.80
0.23
2.63
6.49
1.15
0.39
3.31
0.10
7.14
2.04
4.18
2.14
10.53
0.11
0.09
                                 23

-------
TABLE 3-6. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
         HAPs NOT DETECTED IN SPECTRA OF CONCENTRATED SAMPLES EXTRACTED FROM
         UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Cumene
1,2-Epoxy Butane
Ethylene Oxide
riethanol
Methyl Chloroform
Methyl Iodide
Methyl t-Butyl Ether
'ropylene Oxide
vl-xylene
Acetone
Acetaldehyde
Acetophenone
Acrylic Acid
Aniline
3enzotrichloride
Benzyl Chloride
3is(chloromethyl)ether
Chloroacetic acid
2-Chloroacteophenone
Chloromethyl methyl ether
Chloroprene
o-Cresol
m-Cresol
p-Cresol
1 ,2-Dibromo-3-chloropropane
1 ,4-Dichlorobenzene
Oichloroethyl ether
1 ,3-Dichloropropene
Dichlorvos
N.N-Diethyl aniline
Dimethyl carbamoyl chloride
Dimethyl formamide
1,1 -Dimethyl hydrazine
Dimethyl phthalate
1,4-Dioxane
Epichlorohydrin
Analytical R
1015.82 - 1063.57
902.37 - 919.70
866.90 - 875.00
2807.91 • 3029.40
1057.95 - 1105.30
1250.18 - 1253.53
1195.00 - 1210.00
2875.59 - 3097.75
2910.25 - 2952.78
1182.00 - 1255.03
2685.41 - 2744.40
1140.40 - 1286.06
1104.89 - 1164.68
1102.90 - 1123.63
805.30 - 823.50
1262.87 - 1279.12
1068.78 - 1154.25
1094.97 - 1124.12
1274.39 - 1285.42
1111.02 - 1146.08
875.90 - 878.80
1092.80 - 1114.07
1139.68 • 1172.77
1159.10 - 1185.50
855.88 - 904.72
995.96 - 1031.06
1109.35 - 1155.04
768.00 - 791.00
967.79 - 1000.25
2655.32 - 3156.07
889.55 - 917.52
2824.80 - 2873.60
856.12 - 974.09
1157.86 - 1254.16
2861.10 - 2864.80
943.52 - 981.73
STACK
RMSD(C)
3.50E-03
2.61 E-03
2.82E-03
4.09E-03
7.72E-03
8.29E-04
1.72E-03
6.86E-03
2.16E-03
5.72E-03
6.80E-04
9.49E-03
3.55E-03
4.05E-03
2.04E-03
1.59E-02
5.44E-03
3.78E-03
8.12E-03
3.36E-03
4.83E-04
3. 21 E-03
2.42E-03
3.27E-03
3.34E-03
2.27E-03
3.18E-03
2.80E-03
3.48E-03
5.76E-03
2.49E-03
7.00E-04
6.68E-03
5.51 E-03
3.59E-04
7. 80 E-03
Max Con.
(ppm)(d)
8.64
1.90
0.68
3.29
1.35
0.75
0.27
4.34
1.31
2.48
1.12
1.22
0.45
1.29
0.23
7.19
0.58
0.80
1.49
0.49
0.09
1.33
0.43
0.35
5.69
0.97
0.36
0.56
0.48
3.28
0.61
0.43
5.39
2.86
0.05
6.24
                                   24

-------
 TABLE 3-6. CALCULATED MAXIMUM POSSIBLE (MINIMUM DETECTIBLE) CONCENTRATIONS:
           HAPs NOT DETECTED IN SPECTRA OF CONCENTRATED SAMPLES EXTRACTED FROM
           UNIT 5 STACK AT GREENS BAYOU GAS-FIRED BOILER.
LOCATION
Compound(a)
Ethyl Acrylate
Ethylene Oichloride
Ethylidene dichloride
:ormaldehyde
Hexachlorobutadiene
Hexachlorocylcopentadiene
Hexachloroethane
Hexamettiylphosphoramide
Hydrochloric Acid
sophorone
Maleic Anhydride
Methyl hydrazine
Naphthalene
Nitrobenzene
•J-Nitrosodimethylene
N-Nitrosomorpholine
•"henol
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
rriethylamine
Ammonia
Analytical R
1181.93 - 1210.00
1227.88 - 1241.50
696.22 - 750.59
2788.33 - 2842.20
976.90 - 997.70
1227.02 - 1240.42
995.46 - 1042.73
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
892.23 - 1024.64
1162.67 - 1195.76
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
2858.50 - 2951.85
1009.00 - 1198.39
1178.04 - 1204.16
856.27 - 863.36
2756.62 • 2839.34
893.10 - 926.00
STACK
RMSD(c)
3.13E-03
2.00E-03
2.97E-02
6.98E-04
2.47E-03
1.95E-03
2.71E-03
6.15E-03
3.71 E-04
5.BOE-03
1.14E-03
4.70E-03
1.19E-03
6.93E-03
9.74E-03
6.33E-03
3.84E-03
5.40E-03
4.82E-03
4.42E-04
1.77E-03
2.80E-03
3.87E-03
1.82E-03
2.17E-03
9.32E-03
3.32E-03
1.54E-03
7.78E-04
2.52E-03
Max. Con.
(ppm)(d)
0.16
1.10
8.40
0.69
0.34
0.14
9.40
0.82
0.36
3.60
0.11
5.04
0.11
2.67
2.95
2.49
0.58
1.11
5.07
0.19
0.26
1.93
0.86
1.29
1.76
6.21
1.00
0.36
0.32
1.50
(a) HAP's for which Entropy has obtained quantitative reference spectra.
(b) Frequency 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 (in ppm) of undetected compound, that could have been present in FTIR samples,
    calculated according to procedures discussed in Sections 4.6.3 and 3.3.1.
                                        25

-------
3.3.2  Instrumental and Manual Test Results

     Table 3-7 presents the  results  of the EPA Methods 3A  and  10 tests as
described in Section 4-3.   No HC data were available during the test because
the  analyzer malfunctioned.   But,  judging  from the  FTIR  data,  the  HC
concentration was below the detection limit of the HC  analyzer.  A summary of
the CEM results  is  presented in  Table 3-8.  All  CEM  results  in  the tables
were determined from the average gas  concentration measured during  the run
and adjusted for drift  based  on 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 ensure the  data quality.   All
measurement  system  calibration bias  and  calibration  drift  checks  for each
test run met the applicable specifications of the test methods.
                                     26

-------
TABLE 3-7. RESULTS FROM GREENS BAYOU UNIT 5

Date
5/20/93






















Run
#
1










2











Sample
Time
1124-1127
1135-1138
1145-1147
1152-1155
1210-1212
1225-1227
1326-1328
1338-1342
1345-1348
1400-1404
1412-1415
1546-1549
1554-1555
1600-1602
1713-1715
1720-1724
1730-1740
1745-1800
1820-1831
1901-1903
1912-1914
1924-1926
1930-1932
Sampling System
to FTIR (a)
Hot/Wet








Condenser

Condenser


Perma-Pure




Hot/Wet

Condenser

O2
(%d)
2.1
2.3
2.2
2.3
2.1
1.8
2.1
2.1
2.1
2.1
1.8
1.6
1.8
1.9
1.8
1.7
1.6
1.7
1.7
1.5
1.6
1.7
1.8
CO2
(%d)
10.7
10.6
10.6
10.6
10.7
10.8
10.7
10.7
10.7
10.7
11.0
11.1
10.8
10.8
11.0
11.0
11.1
11.0
11.1
11.1
11.1
11.1
11.0
CO
ppmd
0.0
0.0
0.0
0.0
0.0
1.6
0.0
0.0
0.0
0.0
14.0
4.7
1.1
0.0
0.2
3.4
6.3
4.9
5.9
13.0
10.3
4.7
4.1
Ib/hr
0.0
0.0
0.0
0.0
0.0
4.5
0.0
0.0
0.0
0.0
39.5
12.8
3.0
0.0
0.5
9.2
17.1
13.3
16.0
35.3
28.0
12.8
11.1
Flow Rate
(WSCFM)
779,487








779,487

750,265


750,265




750,265

750,265

Flow Rate
(DSCFM)
646,974








646,974

622,720


622,720




622,720

622,720


-------
                      TABLE 3-7. RESULTS FROM GREENS BAYOU UNIT 5 (Cont.)

Date
5/21/93











Run
#
3











Sample
Time
1108-1109
1113-1114
1120-1121
1131-1133
1143-1145
1150-1152
1158-1200
1205-1208
1220-1233
1236-1246
1250-1259
1302-1315
Sampling System
to FTIR
Hot/Wet



Condenser



Perma-Pure



O2
(%d)
1.9
1.9
1.8
2.0
1.9
1.9
1.9
2.0
1.9
1.9
2.0
2.1
CO2
(%d)
10.9
10.8
10.9
10.8
10.9
10.9
10.9
10.8
10.9
10.9
10.8
10.8
CO
ppmd
0.5
1.1
3.9
0.8
0.9
1.8
0.8
0.7
2.5
2.0
0.0
0.0
Ib/hr
1.2
2.7
9.7
2.0
2.2
4.5
2.0
1.7
6.2
5.0
0.0
0.0
Flow Rate
(WSCFM)
684,423



684,423



684,423



Flow Rate
(DSCFM)
568,071



568,071



568,071



IX)
00
        (a)  Sampling system descriptions are contained in Section 4.1. CEM procedures are
            described in Section 4.3. Description of flow rate calculations is contained in Section 4.4.

-------
 TABLE 3-8.   SUMMARY OF CEM AND MANUAL TEST RESULTS AT GREENS BAYOU UNIT 5


DATE
5/20/93





5/21/93



RUN
#
1

2



3



SAMPLE
TIME
1124-1347
1400-1415
1546-1602
1713-1831
1901-1914
1925-1932
1108-1132
1143-1208
1220-1315
SAMPLING
SYSTEM
TO FTIR
Hot/Wet
Condenser
Condenser
PermaPure
Hot/Wet
Condenser
Hot/Wet
Condenser
PermaPure

02
(%d)
2.2
2.0
1.8
1.7
1.5
1.7
1.9
1.9
2.0

C02
(%*}
10.7
10.8
11.0
11.0
11.1
11.1
10.8
10.9
10.8
CO


Ppmd
0.0
3.0
6.8
4.3
11.8
4.0
1.2
2.4
0.9

Ib/hr
0.0
8.5
18.5
11.7
32.0
10.9
3.0
5.9
2.2
FLOW
RATE
(WSCFM)
779,487

750,265



684,423


FLOW
RATE
(DSCFM)
646,974

622,720



568,071


     Each test run emission rate (expressed in units of Ib/hr) was computed
using the averaged concentration measurement  for  the test period, the flue
gas volumetric flow rate, and the appropriate conversion factors.   The boiler
exhaust gas flow rates were determined using EPA Method 19  procedures and the
measured flue gas 02 and are presented  in Table 3-9.  The natural gas analysis
data were  supplied by HLPC and  are included  in  Appendix A.  The  sets of
analysis data were averaged and used with the fuel feed rates to  the boiler
during the test periods to  compute  the heat  consumption and  Fd-factor needed
to determine  the  dry  exhaust  gas  volumetric flow  rate  (in units  of dry
standard cubic  feet  per  minute,  dscfm) for each  test  run.   Wet  basis flow
rates (wscfm) were computed based on 17% H20 in the flue gas.
     TABLE  3-9.   BOILER EXHAUST  GAS  VOLUMETRIC  FLOW  RATE DETERMINATIONS


RUN
NO.
1
2
3


GCV
(Btu/ft3)
1034
1034
1034

AVG. FUEL
FLOW
(mmft3/day)
93.8
92.3
83.3

HEAT
CONSUMPTION
(mmBtu/hr)
4044.7
3975.9
3589.2


Fd
(dscf/mmBtu)
8633
8633
8633


02
(%d)
2.1
1.7
1.9
FLUE
GAS
FLOW
(dscfm)
646,974
622,720
568,071
     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
3-10 are within the range of acceptable values.
                                     29

-------
TABLE 3-10.  VALIDATION OF 0,  AND  CO, MEASUREMENT DATA
RUN NO.
1
2
3
02
(%d)
2.2
2.0
1.8
1.7
1.5
1.7
1.9
1.9
2.0
C02
(%d)
10.7
10.8
11.0
11.0
11.1
11.1
10.8
10.9
10.8
CALCULATED
F0
1.75
1.75
1.74
1.75
1.75
1.73
1.76
1.74
1.75
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 Results

3.3.3.1      Operating  Conditions   --   The   preheater  outlet  and  inlet
temperatures, natural gas flow (mmBtu/hr), generator output (in megaWatts),
stack gas 02  concentration  (in percent) are presented Table 3-11 and Figures
3-1 to 3-3.

3.3.3.2    Process Variations During  Testing  --  Variations and changes that
occurred with the process are listed below.

     1)   During Run 1 (9:30 a.m. to 1:30 p.m., 5/20/93),  a cooling tower fan
           (1 of 10)  was turned off from 10:40 a.m.-11:07 a.m. and from 1:25
          p.m. to the end of Run 1.

     2)   During Run  2  (3:30  p.m.  to 7:30 p.m.,  5/20/93),  a "frozen shut"
          high-pressure steam governor valve  (1  of  8)  was cycled twice and
          freed.  This  action  resulted in increases in  all  monitored data
          except the oxygen  reading.   Subsequent decreases  resulted when
          plant personnel  cycled the valve again and it remained closed.

     3)   During Run 3 (9:45  a.m.  to  1:45   p.m.,  5/21/93),  the  unit  was
          operated between 360  and  370 MW.  This range was used to reduce the
          possibility  of  damage  from  the   "frozen"  high-pressure  steam
          governor valve.
                                     31

-------
TABLE 3-11 Process Data Sheet: Houston Lighting and Power Co., Greens Bayou, Unit Five

Date
Testl
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93


Test 2
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93

Time

9:30 AM
9:38 AM
9:46 AM
9:54 AM
10:02 AM
10:10 AM
10:18 AM
10:26 AM
10:34 AM
10:42 AM
10:50 AM
10:38 AM
11:06 AM
11:14 AM
11:22 AM
11:30 AM
11:38 AM
11:46 AM
11:54 AM
12:02 PM
12: 10PM
12: 18PM
12:26 PM
12:34 PM
12:42 PM
12:50 PM
12:58 PM
1:06 PM
1:14 PM
1:22 PM
1:30 PM



3: 30PM
3:38PM
3-.46PM
3:54PM
4:02 PM
4: 10PM
4: 18PM
4:26 PM
4:34 PM
4:42 PM
4:50 PM
4:58 PM
MW
Operating capacity

414.01
414.01
413.80
417.17
413.80
413.80
414.01
413.80
413.80
414.01
412.71
411.56
411.77
413.23
414.01
414.01
414.38
414.38
414.17
414.38
413.64
413.80
414.38
413.80
413.64
414.01
413.07
413.07
413.23
413.44
412.29



413.80
427.14
432.76
408.96
411.77
411.36
410.83
411.20
410.99
411.20
410.83
410.83
DegF
Preheater inlet temp.

657.80
657.43
657.80
658.02
658.10
657.88
657.80
658.02
657.88
657.88
657.58
657.80
658.02
657.88
657.80
658.02
658.70
659.00
658.93
658.63
658.18
658.10
657.80
656.68
656.60
657.13
656.83
656.83
656.98
657.43
657.88



654.20
656.98
661.70
659.68
656.98
655.77
654.80
654.80
655.02
655.02
654.73
654.27
DegF
Preheater outlet temp.

264.88
265.48
265.48
265.70
266.08
266.30
266.60
267.20
267.73
267.88
268.33
268.63
268.93
268.78
268.93
269.75
270.20
270.73
270.43
270.28
269.83
270.43
269.98
269.60
269.90
269.98
269.98
270.20
270.28
270.28
271.03



269.30
271.03
274.10
273.58
270.88
270.43
269.98
269.83
269.90
270.20
270.28
270.28
Percent
Oxygen

1.6287
1.7556
1.8305
1.7480
1.8457
1.7112
1.7274
1.7263
1.7871
1.6786
1.6916
1.7090
1.7068
1.7632
1.7600
2.0887
1.9726
2.0041
1.9325
2.0313
1.7730
1.8457
1.6211
1.5430
1.5972
1.5820
1.5592
1.5549
1.7665
1.8522
1.8609



1.4724
1.5451
1.4106
1.6504
1.7437
1.6015
1.6330
1.6265
1.6970
1.6265
1.4670
1.6211
Million Btu/hr
Natural Gas Flow

4052.2
4064.9
4060.3
4060.3
4057.1
4049.1
4051.2
4041.3
4037.5
4036.8
4039.7
4035.8
4040.5
4042.9
4045.5
4054.3
4048.3
4048.3
4048.5
4045.7
4041.6
4043.3
4037.8
4040.4
4043.9
4035.9
4024.8
4037.4
4037.1
4043.6
4039.9



4014.2
4139.6
4184.1
3876.3
3958.8
3963.4
3964.4
3965.1
3973.8
3958.5
3960.0
3963.2
                                       32

-------
TABLE 3-11 Process Data Sheet: Houston Lighting and Power Co., Greens Bayou, Unit Five (Cont.)

Date
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93




Time
5:06PM
5: 14PM
5:22 PM
5:30 PM
5:38 PM
5:46 PM
5:54 PM
6:02 PM
6: 10PM
6:18 PM
6:26 PM
6:34 PM
6:42 PM
6:50 PM
6:58 PM
7:06 PM
7: 14PM
|_ 7:22 PM
7:30 PM



MW
Operating capacity
410.99
410.99
410.63
411.36
410.99
410.99
410.99
411.56
410.99
411.56
411.93
411.20
411.20
411.93
411.36
411.56
411.20
411.36
411.77



•ta for 3D flow traverse (after Test 2)

5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93

7:38 PM
7:46 PM
7:54 PM
8:02 PM
8:10 PM
8:18 PM
8:26 PM
8:34 PM
8:42 PM
8:50 PM
8:58 PM
9:06 PM
9: 14PM
9:22 PM
9:30 PM
9:38 PM
9:46 PM
9:54 PM
10:02 PM
10: 10PM
10: 18PM
10:26 PM
10:34 PM
























DegF
Preheater inlet temp.
654.73
655.33
655.18 ,
654.65
654.20
653.60
654.13
654.50
654.27
654.58
654.73
654.43
654.13
654.73
653.98
653.90
653.68
653.98
654.13




























DegF
Preheater outlet temp.
270.88
270.50
270.13
269.98
269.68
269.68
269.38
269.83
269.60
269.98
269.90
269.60
269.83
269.68
269.08
268.70
268.93
268.70
268.93




























Percent
Oxygen
1.5864
1.7545
1.7133
1.4279
1.4279
1.5028
1.4355
1.6601
1.5820
.6081
.5375
.5994
.6406
.5961
.3596
.3520
.3715
1.4160
1.5820




























Million Btu/hr
Natural Gas Flow
3966.6
3969.3
3967.9
3959.8
3960.3
3974.3
3971.2
3965.4
3963.7
3977.3
3959.6
3952.6
3966.2
3972.7
3955.3
3954.6
3970.2
3963.6
3960.8





3959.2
3972.9
3844.2
3845.2
3862.1
3631.7
3722.7
3340.8
3069.2
2703.6
2701.6
2607.2
2707.2
2566.2
2544.3
2410.2
2469.7
2507.8
2494.2
2535.0
2599.0
2463.0
2300.0
                                        33

-------
TABLE 3-11 Process Data Sheet: Houston Lighting and Power Co., Greens Bayou, Unit Five (Cont.)

Date
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93
5/20/93

Test3
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93

Tune
10:42 PM
10:50 PM
10:58 PM
11:06PM
11: 14PM
11:22PM
11:30PM
11:38 PM
11:46PM
11:54PM
12:02 AM
12:10 AM
12:18 AM
12:26 AM
12:34 AM
12:42 AM


9:44 AM
9:52 AM
10:00 AM
10:08 AM
10:16 AM
10:24 AM
10:32 AM
10:40 AM
10:48 AM
10:56 AM
11:04 AM
11:12 AM
11:20 AM
11:28 AM
11:36 AM
11:44 AM
11:52 AM
12:00 PM
12:08 PM
12:16 PM
12:24 PM
12:32 PM
12:40. PM
12:48 PM
12:56 PM
1:04 PM
1:12 PM
1:20 PM
1:28 PM
MW
Operating capacity


















365.26
366.20
364.69
366.20
364.32
365.83
366.20
364.11
365.05
364.32
363.75
363.02
363.54
363.54
366.20
364.11
364.89
362.24
366.56
364.69
364.69
366.20
363.02
363.39
363.39
363.18
363.54
365.83
363.02
DegF
Preheater inlet temp.


















642.20
642.73
642.80
642.58
641.38
642.13
642.27
642.50
642.43
642.20
642.43
641.90
642.50
643.02
642.88
642.13
642.20
642.43
643.02
642.88
642.43
643.02
642.20
642.20
642.73
643.10
642.43
642.80
643.33
DegF
Preheater outlet temp.


















257.08
257.53
257.83
258.13
257.83
258.73
258.58
258.88
259.33
259.18
259.48
259.48
259.40
260.23
260.60
260.38
260.08
260.08
260.23
260.30
260.60
260.60
260.38
260.38
260.68
260.68
260.60
260.83
260.68
Percent
Oxygen


















1.8316
2.0215
1.9585
1.7990
1.8110
1.8088
1.9184
1.9184
1.9336
1.7969
1.6471
1.7773
1.7969
1.8945
1.9227
1.7969
1.7914
1.7285
2.0551
1.6743
1.6547
1.9282
1.7990
1.8945
2.0085
1.9455
2.162S
1.8869
1.9282
Million Btu/hr
Natural Gas Flow
1894.8
1529.3
1535.0
1526.5
1521.0
1S38.1
1570.3
1594.5
1596.4
1525.9
1538.0
1480.5
1463.4
1518.5
1545.8
1555.1


3557.6
3598.6
3656.6
3588.9
3593.8
3628.6
3573.9
3573.9
3652.5
3568.3
3560.4
3562.9
3585.4
3572.4
3608.9
3586.8
3559.6
3539.2
3695.6
3561.9
3608.3
3648.3
3618.6
3556.0
3615.8
3574.5
3592.7
3574.5
3543.1
                                       34

-------
TABLE 3-11 Process Data Sheet: Houston Lighting and Power Co., Greens Bayou, Unit Five (Cont.)

Date
5/21/93
5/21/93


Time
1:36 PM
1:44 PM

MW
Operating capacity
363.%
365.26

Data for 3D flow traverse (after Test 3)

5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93
5/21/93

1:52 PM
2:00 PM
2:08 PM
2:16 PM
2:24 PM
2:32 PM
2:40 PM
2:48 PM
2:56 PM
3.04PM
3:12 PM
3:20 PM
3:28PM














DegF
Preheater inlet temp.
643.70
642.80
















DegF
Preheater outlet temp.
260.53
261.13
















Percent
Oxygen
1.8989
1.7871
















Million Btu/hr
Natural Gas Flow
3559.5
3548.2



3543.2
3570.3
3617.3
3508.7
3583.8
3543.2
3602.2
3606.5
3462.2
3505.7
3571.8
3523.8
3547.3
                                         35

-------
GO
CD
         418

         417

         416

         415

         414

         413

         412
         411
            630im   1002am.   1034 «m   ll:06am.   11:38 im   12:10pm   1242pm.   1:14 pm.
                g46am.   10:1ta.m.   lOSOam   11:22
-------
CO
         435

         430


         425

         420


         415


         410


         405
             3:30pm.    402p.m.   4:34p.m.   S:06p.m.   S:36p.m.   6:10pm.   6:42p.m.    7:14p.m.
                 3:46 pm   4:IBp.m.   450pm.   5:22 p m.   554pm.    626pm.    658pm.    7:30 pn
                     Generator Output, Megawatts
         Outlet Temp. (F)
         276
274

272

270

268

266

264
                                                                  664
            330pm   4
-------
CO
00
       367


       366


       365


       364


       363


       362
844«m    1016am    1048am   1120a.m.   1152am.   1224pm.   1256pm   126pm.
    1000am.   1032am.   1104am   11:36 am.   12.08pm.   1240pm   112pm.    t:44pm.
                                                                      2.2

                                                                      2.1

                                                                       2

                                                                      1.9

                                                                      1.8

                                                                      1.7

                                                                      1.6
                                                                                   644am.    10:18 am.  1048am   11:20 am.   11:52 am.   1224pm.   1258pm.   128pm
                                                                                       10:00im.   10:32am.   11:04 am   11:36i m.   1208pm.   12:40pm.   1:12pm    1:44 pin
                            Generator Output, Megawatts
                                                                                          Stack Gas Oxygen (percent)

       Outlet Temp. (F)
       262
       261

       260

       259

       258

       257

       256
                                                     Inlet Temp. (F)    3.750
                                                              646
                                                                     3,700
                                                              645

                                                              644    3>65°

                                                              643    3,600

                                                              642
                                                                    3,550
                                                              641
           B:44«m   10:18 am   10:48 am    1120am   1152am   1224pm   1256pm    121pm.
              lOOOam.   1032am   11.
-------
                  4.0  SAMPLING AND ANALYTICAL PROCEDURES
     The FTIR analysis uses two different techniques.  The first, referred to
as direct gas phase  analysis,  involves transporting the gas  stream to the
sample manifold and 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 within the cell.   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.  This, in turn,
provides a corresponding increase in  sensitivity for  the  detection  of any
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  EPA  instrumental test
methods.  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 was used to transport the  gas  stream from the stack
directly  to  the  infrared  absorbance cell.   Figure  4-1   illustrates  the
sampling system used for both  FTIR gas  phase analysis  and  EPA instrumental
test methods.

4.1.1  Sampling System

     Flue gas  was  extracted through  a  stainless steel probe.   A Balston®
particulate filter rated  at 1  micron was  installed  at the outlet  of the
sample probe.  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.  A 150-ft length of Teflon® sample line
was  sufficient  to  reach the FTIR  truck.   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  within  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.


                                    39

-------
     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.
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"1).  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.
Figure 4-2 shows the arrangement of the FTIR instrumentation.

4.1.3  Sample Collection Procedure

     During all three  runs, gas phase and sample concentration testing were
performed  concurrently at the  stack.   During  a  test  run,  flue  gas was
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 next sample required  less than 10 minutes.  During each run,
about 12 gas phase samples were analyzed.
                                     40

-------
                                                     Vent
           In-Slack
          Particulate
            Filter
                         Extractive
                           Probe
                                                  Heated
                                                  Pump
                                               Heated
                                              Transport
                                                Lines
                                                                                             Hot/Wet
                                                 Perma-Pure
                                                    Dryer
                                                                                            Condenser
                                                                    Heated
                                                                   Manifold




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

-------
ro
                                                                                   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,  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  U-shaped
collection tube filled with 10 g  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 conducted for 4 hours  at  approximately 0.12 to
0.17 dcfm for  a total  sampled volume between 30 and  40 dcf.   The sampling
rate was close to the maximum that can be achieved with the sampling system
and collection times provided a volumetric concentration that  is proportional
to the amount of gas sampled. The  resulting increase  in sensitivity allowed
detection to sub-ppm concentrations  for  some compounds.

4.2.2  Analytical  System

     Sample tubes were  analyzed  using thermal desorption-FTIR.   The sample
tubes were wrapped  with  heat tape  and placed  in an insulated chamber.  One
end  of  the sample  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  to  carry  desorbed
compounds into the FTIR absorption  cell.  About 7 liters  of nitrogen at 240°F
was  required  to carry the  desorbed  gases  to  the cell and  bring 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.
                                     43

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

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4.2.3  Sample Collection Procedure

     The sample concentration  test apparatus was set up at the location after
the  test  team  performed leak  checks  of  the  system.    The  sample  flow,
temperature of the heated box, and the tube  outlet temperature were monitored
continuously and recorded at 10-minute intervals during each run.  At the end
of each run  flow was interrupted and the  charged 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.


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  sampling system and a set of  gas  analyzers were used to
analyze flue gas samples  extracted  at the exhaust stack.  The CO,  C02, and 02
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.,   water vapor and  particulate matter)  before being  transported  and
analyzed.   The HC analyzer received  hot/wet sample.    All  components  that
contact the gas sample were either Type  316 stainless steel or 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.

     Table 4-1 presents a list of  the  analyzers that Entropy used during the
test program to quantify the  gas concentration levels  at  the  sample point
locations.   Figure 4-1  is  a simplified  schematic of  Entropy's  reference
measurement  system.
                                     45

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           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
     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.

     The  test run  values  are  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.


4.4  FLOW DETERMINATIONS

     Because  the measurement location on the  stack does not satisfy EPA
Method 1 criteria,  flue gas  volumetric  flow was determined using mass balance
calculations based on the natural  gas fuel  usage rate,  fuel composition, and
exhaust gas diluent concentrations (see below).  The flow rate calculations
are based on the use  of F-factors as outlined in EPA Method  19 (40 CFR 60).

     The natural gas feed rate to the boiler 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.   Greens
Bayou  personnel  supplied EPA with  fuel  analysis data  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/mmBtu) could  be determined for the computation of the flue gas
volumetric flow  rates.

     During the  sampling runs, an S-type 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  run.

     Heat  consumption  of  the boiler was  one  of  the  process   parameters
recorded by the RTI  representative  at 8-minute intervals during the test periods.
                                     46

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The dry  exhaust gas flow  rate  was calculated  according to  EPA  Method 19
procedures:



                     DSCFH  = F         °9
                                    20.9-%02d
where:

     Fd   =    Dry basis F-factor (dscf/mmBtu) determined from fuel analysis
     %02d  =    Dry basis concentration measurement from EPA Method 3A
     HC   =    Heat consumption (mmBtu/hr)


4.5  PROCESS OBSERVATIONS

     During the test,  a representative from Research Triangle Institute (RTI)
monitored  the  process  operations  so  that  emissions test  data  could  be
correlated with process data.


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 path length
b, Beer's law can be written in matrix form as


                                  A = KC+E                             (2)
where:

     A =  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;

     K =  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   !(„„  =  banq, where  anq  is the  absorptivity  of the  qth
          compound at the nth wavenumber position;

     C =  The q x m matrix containing the  concentrations of the q  compounds
          in the m reference spectra;
                                     47

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     E =  The n x m matrix representing the random "errors"  in Beer's law for
          the analysis; these  errors  are  not actually due to  a  failure of
          Beer's   law,   but   actually   arise   from  factors   such   as
          misrepresentation  (instrumental  distortion)  of  the  absorbance
          values of the reference spectra, or inaccuracies in the reference
          spectrum concentrations.

     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
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


                            5=[KtK]'1KtA* .                        (3)
Here the superscript t represents  the  transpose of the indicated matrix, and
the superscript -1 represents the matrix inverse.
                              K=ACt[CCt]
                                            "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-apodizing  the
interferograms  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,  K-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 Multicomp analysis  files included spectra representing
interferant species and criteria pollutants  present in the flue gas.

     A number of factors affect the detection and analysis of an analyte in
the stack gas matrix.  One  factor is the composition of the stack gas.  The
major spectral interferants in  the  gas-fired boiler effluent  are water and
C02.  At C02  concentrations  of about 10 percent and higher, weak absorption
bands that are  not visible   at lower concentrations  can interfere with the


                                     48

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spectral analysis if not accounted for.  Some portions of the FTIR spectrum
were not available for analysis because of extreme absorbance  levels of water
and C02, but  most  compounds exhibit at  least  one absorbance  band  that is
suitable for analysis.   Measurable amounts of  NO and N02 were also present
in the samples and these species needed to be accounted for in any analysis
program.  A second factor affecting analyses is the number of analytes that
are to be detected.

     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 for 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.    Analysis  program
files were  constructed that  included reference spectra  representing  the
detected  species.    The   program files   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 their corresponding compounds.

4.6.3  Error Analysis of data

     The principal  constituents of the  gas phase samples were water, C02, NO,
and N02.  A separate multicomp program 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 four main constituents
were determined,  the appropriate standard was scaled  and subtracted from the
spectrum of  the  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
be present in the samples.

     Maximum possible 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 RMS noise 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   «
-i)  S (ArAM)
                                   n
                                                                       (5)
                                     49

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where:

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

   n = Number of absorbance values in the region.

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

 AM  = Mean of all the absorbance values in the region.


If a species is detected, then the error in the calculated concentration is
given by:

                          _  SMSD X  (*,  - *.)                          (6)
                       ppm         AreaR             R



where:

 Ennm =  Noise related error in the  calculated  concentration, in ppm.
  ppin

   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 3-4  to 3-6  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 RMS deviation  is also large (see Equation
         7).  Drier spectra give significant improvement because it  is  easier
         to perform good spectral subtraction on  spectra where absorbance from

                                     50

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         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.

     In the second  and third  cases the stated maximum possible concentration
can be lowered by choosing a different analytical region, generating better
subtracted spectra  or 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  path length  between  the  reference  and sample
spectra according to the following relation:
                        Ccorr -|^|x[^lxfCMlei                   (7)
where:

C00rr   =  the path length corrected concentration.

cc«ic   =  tne initial calculated concentration (output of the Multicomp program
         designed for the compound)

  Lr   =  the path length associated with the reference spectra.

   L8 =  the path length (22m) associated with the sample spectra.

   T8 =  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,  no  sample pressure corrections were made.

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

                                     51

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concentration  of 50  ppm  in the  cell,  then  its  corresponding  flue  gar,
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 tc
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.

     Tfiua  =  Absolute temperature  of the  flue gas  at  the sampling location.

     Ted  =  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 Vf,ue  and  the
volume of the FTIR  cell  (Vce)|) which was measured at an absolute temperature
(TC8|I) of about 300 K:
                           CF '
cell
                                            flue
     Finally,  the  in-stack concentration  was determined  using CF and  the
calculated concentration of the sample contained  in  the  FTIR cell,  Cce)l.
                                         CF
                                     52

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         5.0   INTERNAL  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  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.

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

     •   The dry gas meter is  fully  calibrated every  6  months 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.

                                     53

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     •  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  Manual Sampling Equipment Calibration  Procedures

5.1.2.1  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.

5.1.2.2  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.

5.2.1  Daily Calibrations, Drift Checks, and  System Bias Checks

     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.
                                     54

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           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
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.
                                     55

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

     •  Acceptable sample  collection  procedures.

     •  Adherence  to prescribed  QC  procedures.

Any suspect  data  have been  identified with respect  to  the nature of  the
problem and  potential effect  on  the data  quality.    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, TgrelSOA designates a
Tenax® spectrum of a  sample  collected  during Run  1 at the stack using tube
number 30.   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.

     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.  One was obtained before test began
and a second after  the test was completed.  Ambient samples were run through
the  identical  trains used  in  the  test  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 collected  in  the  test  runs.  The volume
of air drawn for the blanks was sufficient to verify that the sampling train
was clean  and performing  properly.    If relatively minor  contamination  was
identified from the  ambient  sample, it was  accounted  for  in the subsequent
analysis of the sample spectrum using spectral subtraction. Major sources of
contamination were not identified in any instance.

      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

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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 CEM's  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.  At times when the cell was
evacuating, the FTIR signal  was continuously monitored 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  signal was also
monitored  at  times when the cell was being filled to  provide  a real-time
check for significant 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 performed at the beginning and end  of  each  data collection
session.  The  CTS  gas was 100  ppm  ethylene in nitrogen.   The CTS spectrum
provide 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
copies of sample and CTS absorbance spectra were also stored for use in the
data  analysis.   Sample spectra  can be regenerated  from   the  raw inter-
ferograms, 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 to check for contamination.  On two occasions water was condensed in
the  FTIR manifold.  The lines  and cell were purged  with  zero  air,  or dry  N2.
On one occasion, after the condensed water was removed,  absorbance bands were
observed near 2900 cm"1  in the  subsequent  FTIR sample.   It was  determined that
these  absorbances  were not caused  by anything  in the flue gas,  but were
attributed to  contamination that had  been carried  into the cell during the
purging  process  and remained   after the  sample was pumped away.   This was
corrected by taking a new background  spectrum.

     The  position  and   slope  of  the  spectral  base line were  monitored as
successive spectra were collected.   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

     It was the responsibility of the  project manager and the  team members to
see  that data  collection  procedures were  followed  as specified  and that
measurement data met the prescribed acceptance criteria. No major corrective
actions were necessary


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                              6.0 CONCLUSIONS
     Entropy performed an  emission  test using FTIR spectrometry  at Greens
Bayou Unit  5  gas-fired boiler in Houston,  Texas.   Gas phase  analysis  and
sample  concentration   measurements  were  performed  over   two  days.    Gas
analyzers were used to measure CO, 02,  C02,  and hydrocarbons.   Three 4-hour
sample concentrations run were performed at the  stack.  Gas phase analysis
and CEM measurements were performed during the sample concentration runs.

     No significant levels of HAPs were measured using  FTIR to analyze  gas
phase samples, but  NO was detected.   NH3  and HC1  were detected  in sample
concentration spectra. Other unidentified bands were observed in the sample
from sample concentration Run 2  and CFC13, which may  be a contaminant,  was
detected in the sample from Run 1.

     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 Greens Bayou facility.  Utilities present a 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.

     •   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 29 .HAPs  and less than 5 ppm for 70
        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  3-4  to 3-6.    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).


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      •  Temperature of sampling components.

      •  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 maximum possible concentrations
are all  higher than the true detection limits that can  be calculated from the
1  cm'1  data collected  at  Greens Bayou.   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  6.41 ppm.   This  was
determined  in  the  analytical  region  between 3036  and 3063 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.  The moisture
content of the flue gas was estimated  to  be about 17 percent.  This should
have caused no  problem with condensation in the  sampling  line.   But water
soluble species are more difficult to measure at higher moisture levels and
a  moisture  content  of   17   percent   can  present  significant  spectral
interferances for some compounds.  FTIR techniques still 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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