SOURCE TEST REPORT EMISSION COMPLIANCE RETEST SEATTLE STEAM

SOURCE TEST REPORT EMISSION COMPLIANCE RETEST SEATTLE STEAM COMPANY SEATTLE, WASHINGTON

Prepared For:

Seattle Steam Company 1319 Western Avenue Seattle, Washington 98101

For Submittal To:

Puget Sound Clean Air Agency 1904 Third Avenue, Suite 105 Seattle, Washington 98101

Prepared By:

The Avogadro Group, LLC 3003 SW 153rd Drive, Ste. 215 Beaverton, Oregon 97006

December 2, 2011

Seattle Steam Company December 2, 2011 2011 Test Report: Emissions Compliance Retest

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SUMMARY INFORMATION

Source Location: Seattle Steam Company 1319 Western Avenue Seattle, WA 98101

Source Information

Contact: Mr. Mick Reeves Title: Chief Engineer Telephone: (206) 658-2028

Regulatory Agency: Puget Sound Clean Air Agency Contact: Mr. Brian Renninger Telephone: (206) 689-4077

Unit: Wood-fired boiler

Purpose: Determination of compliance with conditions of Order of Approval for NOC 10065

Procedures: EPA 1, 2, 3A, 4, 5, 19, 26 PSCAA 5 BAAQMD ST-1B

Permit: NOC No. 10065, Reg. No. 13786

Test Date (s): November 3, 2011

Testing Firm: The Avogadro Group, LLC

Testing Company Information

3003 SW 153rd Drive, Ste. 215 Beaverton, Oregon 97006

Certification: ARB Independent Tester

Contact: Mr. Kevin Donahoe Mr. Erick M. Mirabella Project Manager Client Account Manager

Telephone: (503) 658-2091 (925) 680-0935 Facsimile: (503) 427-1153 (925) 680-4416


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TABLE OF CONTENTS

SECTION

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

PAGE

2.0 TESTING CONTRACTOR ..................................................................................5

3.0 SOURCE LOCATION INFORMATION ...........................................................6 3.1 FACILITY DESCRIPTION .........................................................................6 3.2 SAMPLING LOCATIONS ..........................................................................6

4.0 TEST DESCRIPTION ..........................................................................................7 4.1 PROGRAM OBJECTIVES .........................................................................7 4.2 TEST CONDITIONS ...................................................................................7 4.3 TEST SCHEDULE ......................................................................................7 4.4 TEST PROCEDURES .................................................................................8 4.4.1 Gaseous Emissions 4.4.2

.........................................................................9 Particulate Matter (as PM10) Emissions

4.4.3 .......................................10

Ammonia Emissions 4.4.4

.....................................................................10 Hydrogen Chloride Emissions

4.4.5 ......................................................11

Volumetric Flow Rate, Moisture Content, and Mass Emission Rate

4.4.6 ...............................................................................11

Process Data

5.0 DISCUSSION OF RESULTS .............................................................................13

.................................................................................11

APPENDICES

A STANDARD MEASUREMENT PROCEDURES ............................................. A

B QUALITY ASSURANCE .................................................................................... B B.1 Quality Assurance Program Summary and ARB Certification B.2 CEMS Performance and Calibration Data B.3 Test Equipment Calibration Data

C DATA SHEETS ..................................................................................................... C C.1 Sample Location C.2 Plant Process and CEMS Data C.3 Avogadro CEMS Data C.4 Particulate Matter Data Sheets C.5 Ammonia Data Sheets C.6 Hydrogen Chloride Data Sheets


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APPENDICES (Continued)

SECTION

D EMISSION CALCULATIONS ........................................................................... D

PAGE

D.1 General Emission Calculations D.2 Particulate Matter Emissions Spreadsheets D.3 Ammonia Emissions Spreadsheets D.4 Hydrogen Chloride Emissions Spreadsheets D.5 Example Calculations

E LABORATORY RESULTS ................................................................................. E E.1 Particulate Matter Laboratory Results E.2 Ammonia Laboratory Results E.3 Hydrogen Chloride Laboratory Results E.4 Fuel Analysis Results

F SUPPORTING DOCUMENTS .......................................................................... F F.1 Copy of Operating Permit F.2 Correspondence


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SECTION 1.0

The Avogadro Group, LLC (Avogadro) was contracted by Seattle Steam Company (SSC) to perform a series of emission tests at their facility in Seattle, Washington. The testing program was conducted to demonstrate compliance with the limits specified in the operating permit (Order of Approval for Notice of Construction No. 10065, Registration No. 13786), as issued by the Puget Sound Clean Air Agency (PSCAA). This test program was a retest for particulate matter (PM10) and ammonia (NH3) of the initial compliance emission tests conducted June 16, 2011 and a permit-required quarterly test for hydrogen chloride (HCl).

INTRODUCTION

The testing program was conducted by Kevin Donahoe, Doug Morical, and Daniel Sloat of Avogadro on November 3, 2011. Process operations were coordinated by Tim Sonnichsen of Sonnichsen Engineering and Mick Reeves with SSC. Portions of the tests were observed by Brian Renninger of PSCAA. The tests were conducted according to the initial compliance test plan dated December 16, 2009 that was submitted to and approved (after follow-up correspondence from Avogadro) by the PSCAA. Tests were performed to measure the following emission parameters:

• Ammonia (NH3) Pollutant Species for Compliance

Hydrogen chloride (HCl) Total particulate matter (as PM10)

• Oxygen and carbon dioxide (O2 and CO2) Gaseous Species as Diluent Gases

• Feedwater rate (surrogate for steam production) Facility Data

Urea injection rate Fuel statistics (heat values, moisture content), as applicable Carbon monoxide and nitrogen oxides emissions (CO and NOX)

This report presents the test results, descriptions of the testing procedures, descriptions of the facility including operation of the unit and the sampling locations. The average emission test results are summarized in Tables 1-1 through 1-3. Detailed results for individual test runs can be found in Section 5.0 and in the appendices. All supporting data including Avogadro’s quality assurance procedures and CARB certification for source testing, process data, gaseous data, field data sheets, calculations and spreadsheets, and equipment calibrations are located in the appendices.


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TABLE 1-1 SUMMARY OF AVERAGE AMMONIA RESULTS

SEATTLE STEAM COMPANY: WOOD-FIRED BOILER NOVEMBER 3, 2011

Parameter Result Permit Limit Unit Data:

Feedwater rate, klb/hr 78.8 -- Urea flow rate, gal/hr 8.81 -- NOX, ppmvd (facility CEMS) 64.7 85

Flue Gas: O2, % volume dry 9.917 -- CO2, % volume dry 10.78 -- Stack flow rate, dscfm 32,235 --

NH3 Emissions: ppm volume dry 1.11 -- ppm volume dry @ 7% O2 1.42 25.0 lb/hr 0.10 -- ton/year 0.42 -- lb/MMBtu 0.0009 -- Note: Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of

operation per year.


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TABLE 1-2 SUMMARY OF AVERAGE PARTICULATE MATTER RESULTS



Feedwater rate, klb/hr 76.1 -- Urea flow rate, gal/hr 9.05 --

Flue Gas: O2, % volume dry 11.26 -- CO2, % volume dry 9.460 -- Moisture, % by volume 16.52 -- Flue gas temperature, °F 290.7 -- Stack flow rate, dscfm 32,798 --

F½ Particulate Matter: gr/dscf 0.0067 -- lb/hr 1.889 -- ton/year 8.273 -- lb/MMBtu 0.0206 --

B½ Particulate Matter: gr/dscf 0.0004 -- lb/hr 0.119 -- ton/year 0.520 -- lb/MMBtu 0.0013 --

Total Particulate Matter: gr/dscf 0.0071 0.010 lb/hr 2.008 -- ton/year 8.793 12.8 lb/MMBtu 0.0219 -- Note: Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of

operation per year.


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TABLE 1-3 SUMMARY OF AVERAGE HYDROGEN CHLORIDE RESULTS



Feedwater rate, klb/hr 78.8 -- Urea flow rate, gal/hr 8.81 --

Flue Gas: O2, % volume dry 9.917 -- CO2, % volume dry 10.78 -- Moisture, % by volume 18.42 -- Flue gas temperature, °F 288.7 -- Stack flow rate, dscfm 32,235 --

HCl Emissions: ppm volume dry 0.046 -- ppm volume dry @ 7% O2 0.058 -- lb/hr 0.008 -- ton/year 0.037 -- lb/MMBtu 0.0001 0.004 Note: Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of

operation per year.


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SECTION 2.0

Avogadro is a recognized independent contractor that has been approved to conduct emission source testing on behalf of the California Air Resources Board (CARB), pursuant to Section 91200-21220, Title 17, of the California Code of Regulations. Avogadro is a full service source testing and combustion engineering consulting firm with extensive experience in air quality management and pollution control.

TESTING CONTRACTOR

Avogadro provided a professional source test team to conduct the testing as described in this report. Mr. Kevin Donahoe was project manager for the test program at the SSC facility. As project manager, Mr. Donahoe’s responsibilities included overseeing the planning and execution of all air sampling efforts including project coordination and reporting. Mr. Donahoe’s primary objective was to ensure that the results generated by this test program meet the expectations and requirements of both SSC and the PSCAA.


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SECTION 3.0

3.1 FACILITY DESCRIPTION

SOURCE LOCATION INFORMATION

The Seattle Steam facility is located at 1319 Western Avenue in Seattle, Washington. The facility includes a new wood waste-fired boiler (also capable of burning natural gas and oil) used to produce steam for heating various buildings in the central business district and First Hill neighborhood. The exhaust from this boiler is directed into a baghouse for abatement of particulate matter emissions. The boiler also uses urea injection for control of NOX, sodium hydroxide injection for control of acid gases, and limestone injection for control of SO2 emissions.

The boiler/baghouse exhaust stack is equipped with a continuous emission monitoring system (CEMS) and a continuous opacity monitoring system (COMS) designed to provide data for reporting of emissions pursuant to 40CFR60. The CEMS includes an extractive sample conditioning system that delivers sample to the emission monitors. The monitors measure opacity and the dry concentrations of NOX, CO, and O2.

3.2 SAMPLING LOCATIONS

The boiler exhaust is vented to atmosphere via a vertical cylindrical duct; however that duct is located within a larger duct that exhausts emissions from two separate boilers. As a result, an intermediate sampling location was necessary. Sampling was performed on a horizontal duct located inside the building housing the boiler. The duct is equipped with sample ports that are accessible from a combination of a permanent platform and temporary scaffolding. Avogadro personnel conducted measurements of the duct dimensions and sample port locations prior the test. The horizontal duct has an inside diameter of 52 inches with sampling ports that meet EPA Method 1 criteria. Twenty-four traverse points (12 per port) were located according to EPA Method 1 for the isokinetic tests. A diagram of the stack location and the traverse points used is provided in Appendix C.1.

For measurement of O2 and CO2, EPA Method 3A references EPA Method 7E and requires that a preliminary multi-point traverse be conducted to determine whether stratification exists. This preliminary traverse was performed before the tests began per Method 7E specifications. In this case, diluent gas levels at each of three sampling points differed by no more than 5% of the average of the three points, so all compliance test runs were sampled from a single point. The ammonia measurements were conducted from the same sampling point.


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SECTION 4.0

4.1 PROGRAM OBJECTIVES

TEST DESCRIPTION

The objective of the testing program was to demonstrate compliance with emission limits detailed in the PSCAA operating permit. This test program was a retest for particulate matter (PM10) and ammonia (NH3) of the initial compliance emission tests conducted June 16, 2011 and a permit-required quarterly test for hydrogen chloride (HCl).

4.2 TEST CONDITIONS

For the purposes of this emission test program, the boiler was maintained at normal, high load conditions. Process conditions were established and unit operating data were collected by SSC personnel. Other operating parameters were monitored by SSC personnel or its subcontractors and the data provided to Avogadro. Concentrations of NOX and CO were recorded by the facility’s CEMS. All CEMS and process data are included in Appendix C.2

4.3 TEST SCHEDULE

The test program was performed over the course of two days. Table 4-1 on the following page presents the testing schedule.


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TABLE 4-1 TEST SCHEDULE

SEATTLE STEAM COMPANY: WOOD-FIRED BOILER

Day Activity Sample Runs

Run Duration

December 17, 2009 Test plan submittal -- -- November 2, 2011 Travel to site, equipment set-up -- --

November 3, 2011 Compliance tests:

O2, CO2 PM, HCl, NH3

-- 1, 2, 3

as needed

-- 60 min. each 60 min. each

4.4 TEST PROCEDURES

Brief descriptions of the procedures applied to this test program, including any site-specific applications or modifications, are included in the following subsections. Where any conflicts exist in the descriptions, the site-specific description here in Section 4.4 will take precedence. A list of sampling procedures is outlined in Table 4-2 on the following page.

TABLE 4-2 TEST PROCEDURES

SEATTLE STEAM COMPANY: WOOD-FIRED BOILER

Parameter Reference Method Measurement Principle Detection Limits

O2 EPA 3A Paramagnetism < 2% of full scale CO2 EPA 3A Non-dispersive infrared < 2% of full scale NH3 BAAQMD ST-1B Ion-selective electrode < 0.5 ppmvd

PM10 EPA 5

PSCAA 5 Isokinetic sampling and

gravimetric analysis < 0.0005 gr/dscf

HCl EPA 26A Ion chromatography < 0.5 ppm Moisture EPA 4 Gravimetry N/A

Volumetric flow rate EPA 2 Pitot and temperature

traverse N/A


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4.4.1

Concentrations of the gaseous constituents of the stack gas (O2, and CO2) were measured using Avogadro’s dry extractive continuous emissions monitoring system (CEMS) described in Appendix A. This system meets the requirements of EPA and CARB methods for gaseous species. Concentrations of NOX and CO were recorded by the facility’s CEMS.

Gaseous Emissions

The CEMS includes components to extract a representative sample from the source, remove the moisture and particulate matter from the sample stream, and transport the sample to the analyzers. The primary components of this subsystem are:

1) A quartz, titanium, stainless steel or glass probe - heated or insulated as necessary to avoid condensation,

2) Sample filtration – filters located on the probe, pump, and prior to all of the analyzers for removal of particulate matter,

3) Teflon® tubing - connecting the probe to the sample conditioner and the sample conditioner to the analyzer manifold - heated or insulated as necessary to avoid condensation,

4) Sample conditioner - glass or stainless steel flasks immersed in an ice bath to remove the moisture from the sample gas stream,

5) Vacuum pump - a leak-free pump with Teflon diaphragm to transport the sample gas through the system,

6) Sample manifold - a distribution system, constructed of stainless steel and Teflon tubing, to direct sample gas to the analyzers, and

7) Sample flow rate control - a series of rotameters, vacuum gauges and pressure gauges connected to the manifold used to maintain the appropriate sample flow rates.

The calibration gas system utilizes only EPA Protocol gases to verify the operation, linearity, and range settings of the electronic analyzers. The sample gas system allows for the introduction of the protocol gases to the analyzers either directly through the manifold (calibration error check - performed once daily) or through the sampling system (system bias check - performed with each run).

The electronic analyzers are rack-mounted and are maintained in the mobile lab. The data acquisition and recording system is based on a digital system known as MoleDAQ. It includes software for controlling the collection of calibration and emission monitoring data, and hardware for connection of the analyzer outputs to the recording system. Test results can be provided in three forms: on-site printouts of the digitized data, diskette recordings of the digitized data, and strip charts of the monitoring data. For this test program, on-site printouts of the one-minute averages are provided.


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4.4.2

Triplicate 60 minute runs were performed for the determination of total particulate matter (PM). The total PM emissions have been reported as PM10 (particulate matter with an aerodynamic diameter less than ten microns) in accordance with the permit-specified test method. Total PM was measured using EPA Method 5 as approved by PSCAA Board Resolution 540. The apparatus included a borosilicate glass sampling probe attached to an oven containing a heated glass filter holder and filter. The filter holder was connected by a length of Teflon tubing to the impinger train. The impinger train was connected to the control box, containing the sampling pump and dry gas meter. The sampling rate and nozzle size were chosen to allow isokinetic sampling at the proper rate.

Particulate Matter (as PM10) Emissions

The filterable “front-half” PM was recovered from the sampling apparatus as described in EPA Method 5. The filterable portion of the sample consists of two fractions: (1) the filter, and (2) the acetone rinses of the probe, nozzle, and front-half of the filter holder. The sample was analyzed gravimetrically to determine the concentration of filterable PM.

The “back-half” contents were recovered and analyzed as described in PSCAA Board Resolution 540, or PSCAA Method 5. As soon as possible following the conclusion of the tests, the impingers were purged with nitrogen at a rate of 20 liters per minute. The condensable portion of the sample consists of two fractions (continued from the filterable portion): (3) impinger contents and water rinses of the impingers, back-half of the filter holder, and Teflon sample line, and (4) acetone rinses of the impingers, back-half of the filter holder, and Teflon sample line. For each test run, Fraction (3) was extracted with dichloromethane in a separatory funnel once the samples were shipped to Avogadro’s laboratory. The analysis included gravimetric measurement of the residue from the aqueous and organic fractions. PSCAA Method 5 does not specify whether the acetone rinse fraction is to be considered inorganic or organic, so has simply been noted in the appendices as “Impinger rinse.” The blank-corrected results were used to determine the concentration of condensable particulate matter.

4.4.3

Triplicate 60-minute BAAQMD ST-1B runs were performed for the determination of ammonia emissions. Modifications to the method included a stainless steel (as opposed to glass) probe, the addition of a sample line rinse to the sample line purge at the conclusion of the run, and an increased sampling rate. As the results are well above the sensitivity, we do not expect that these modifications had a significant impact on the results. A measured sample volume was extracted from the stack through a series of impingers. The impingers contained 200 ml of 0.1 N HCl. Upon completion of the test run, the samples were recovered with de-ionized water into polyethylene sample bottles. The samples were analyzed at the Avogadro laboratory by ion-selective electrode for ammonia concentrations.

Ammonia Emissions


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4.4.4

Triplicate 60-minute test runs for HCl were conducted according to EPA Method 26A. The sampling apparatus included a heated glass probe attached to an oven containing heated filter holder, Teflon frit, and ultrapure Teflon glass mat filter. Both the probe liner and filter holder temperature were maintained above 248°F during sampling. The filter holder was connected by a length of Teflon tubing to the impinger train containing four chilled impingers in series. The traverse points and sample nozzle were chosen to maintain isokinetic sampling conditions during the tests.

Hydrogen Chloride Emissions

The first and second impingers each contained 100 ml of 0.1N sulfuric acid (H2SO4), the third was empty, and the fourth contained silica gel. A second pair of impingers containing dilute sodium hydroxide solutions is usually included in the impinger train for collection of halogens; however, the method was modified to exclude these since only hydrogen chloride is of interest. The back half of the filter holder, impinger line and acid impingers were recovered for analysis. The impinger contents were transferred into pre-cleaned polyethylene containers followed by rinses with DI water. Since only gaseous HCl was required to be quantified and PM was determined separately, the filter and front half rinses were discarded.

4.4.5

Stack gas flow rate and moisture content were determined by EPA Methods 2 and 4 in conjunction with every PM and HCl test. These tests provided data for calculating a sampling rate and proper nozzle size. The absence of cyclonic flow was verified prior to the tests.

Volumetric Flow Rate, Moisture Content, and Mass Emission Rate

Mass emission rates in units of lb/hr were calculated using the measured flow rate and pollutant concentration. This figure was then extrapolated to provide results in units of ton/yr, although these figures are likely inflated due to the use of 8,760 annual operating hours (constant operation) in all calculations. Emission rates in units of lb/MMBtu were calculated using the pollutant concentrations and the procedures included in EPA Method 19 using the EPA “Fd” factor provided by a fuel sample collected by SSC. See the calculations in Appendix D.6 for more detail on the calculations and Appendix E.4 for the fuel analysis data.

4.4.6

The plant’s unit operating data was used to document process conditions during the test runs. Unit operating data was collected by SSC personnel or its subcontractors and

Process Data


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provided to Avogadro. The operational data presented in this report includes the following:

• Feedwater flow rate (surrogate for steam production), klb/hr • Urea flow rate, gal/hr • CEMS outputs for O2, CO, and NOX

The operational data is included in this report to document unit load conditions during the test. Some of that data has been summarized in Tables 1-1 and 5-1 through 5-3, and the remainder can be found in Appendix C.3. Avogadro provided barometric pressure and ambient temperature data throughout the day.


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SECTION 5.0

The average results for the boiler are compared to the applicable emission limits in Section 1.0. Individual run data is presented in Tables 5-1 through 5-3. The test results show that the facility is in compliance with their respective permit compliance limits. Emissions have been reported in units consistent with those in the permits.

DISCUSSION OF RESULTS

Additional information is included in the appendices. Appendix A contains generic descriptions of standard measurement procedures. Appendix B presents the quality assurance information, including instrument calibration data. Raw field data sheets are included in Appendix C. Appendix D presents the general and specific equations used for the emissions calculations and computer spreadsheets. Laboratory results can be found in Appendix E. Supporting information including a copy of the permit and project-related correspondence are located in Appendix F.


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TABLE 5-1 RESULTS SUMMARY

AMMONIA EMISSIONS SEATTLE STEAM COMPANY: WOOD-FIRED BOILER

Test No.: Run 1 Run 2 Run 3 Averages Date: 11/3/11 11/3/11 11/3/11 -- Time: 0937-1037 1052-1152 1202-1302 -- Unit Data:

Feedwater rate, klb/hr 80.1 77.7 78.7 78.8 Urea flow rate, gal/hr 6.48 10.01 9.93 8.81 NOX, ppmvd (facility CEMS) 65.4 64.3 64.5 64.7

Flue Gas: O2, % volume dry 9.526 9.974 10.25 9.917 CO2, % volume dry 10.92 11.07 10.36 10.78 Stack flow rate, dscfm 32,041 32,244 32,421 32,235

NH3 Emissions: ppm volume dry 0.875 0.895 1.565 1.11 ppm volume dry @ 7% O2 1.069 1.139 2.043 1.42 lb/hr 0.074 0.077 0.135 0.10 ton/year 0.326 0.335 0.589 0.42 lb/MMBtu 0.0007 0.0007 0.0013 0.0009

Note: Results for flow rate provided from the concurrent HCl tests. Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of operation per year.


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PARTICULATE MATTER EMISSIONS SEATTLE STEAM COMPANY: WOOD-FIRED BOILER

Test No.: 1-PM 2-PM 3-PM Averages Date: 11/3/11 11/3/11 11/3/11 -- Time: 1325-1429 1440-1545 1555-1659 -- Unit Data:

Feedwater rate, klb/hr 79.3 76.9 72.1 76.1 Urea flow rate, gal/hr 9.73 9.22 8.20 9.05

Flue Gas: O2, % volume dry 10.890 11.450 11.450 11.26 CO2, % volume dry 9.831 9.274 9.274 9.460 Moisture, % by volume 17.026 16.526 16.015 16.52 Flue gas temperature, °F 290.6 290.4 291.1 290.7 Stack flow rate, dscfm 32,550 32,718 33,124 32,798

F½ Particulate Matter: gr/dscf 0.0057 0.0057 0.0087 0.0067 lb/hr 1.589 1.596 2.482 1.889 ton/year 6.960 6.988 10.872 8.273 lb/MMBtu 0.0168 0.0177 0.0272 0.0206

B½ Particulate Matter: gr/dscf 0.0004 0.0005 0.0004 0.0004 lb/hr 0.103 0.131 0.122 0.119 ton/year 0.452 0.572 0.536 0.520 lb/MMBtu 0.0011 0.0015 0.0013 0.0013

Total Particulate Matter: gr/dscf 0.0061 0.0062 0.0092 0.0071 lb/hr 1.692 1.726 2.605 2.008 ton/year 7.411 7.560 11.41 8.793 lb/MMBtu 0.0178 0.0192 0.0286 0.0219

Note: Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of operation per year.


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HYDROGEN CHLORIDE EMISSIONS SEATTLE STEAM COMPANY: WOOD-FIRED BOILER

Test No.: 1-HCl 2-HCl 3-HCl Averages Date: 11/3/11 11/3/11 11/3/11 -- Time: 0937-1041 1052-1156 1202-1305 -- Unit Data:

Feedwater rate, klb/hr 80.1 77.7 78.7 78.8 Urea flow rate, gal/hr 6.48 10.01 9.93 8.81

Flue Gas: O2, % volume dry 9.526 9.974 10.250 9.917 CO2, % volume dry 10.92 11.07 10.36 10.78 Moisture, % by volume 18.88 18.47 17.88 18.41 Flue gas temperature, °F 288.2 288.6 289.2 288.7 Stack flow rate, dscfm 32,041 32,244 32,421 32,235

HCl Emissions: ppm volume dry 0.069 0.052 < 0.017 0.046 ppm volume dry @ 7% O2 0.084 0.066 < 0.023 0.058 lb/hr 0.013 0.009 < 0.003 0.008 ton/year 0.055 0.041 < 0.014 0.037 lb/MMBtu 0.0001 0.0001 < 0.0001 0.0001

Note: Results provided in units of ton/year have been extrapolated from the lb/hr figures based on 8,760 hours of operation per year.

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SOURCE TEST REPORT EMISSION COMPLIANCE RETEST SEATTLE STEAM