COMMONWEALTH OF MASSACHUSETTS

EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS

MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION

In the Matter of OADR Docket Nos. 2017-011 and 2017-012

Algonquin Gas Transmission LLC Waterways Application No. W16-4600

PREFILED TESTIMONY OF JOHN HINCKLEY, Q.E.P.

Submitted in Support of the Town of Weymouth
 TABLE OF CONTEXTS

I. Introduction ........................................................................................... 1

II. Testimonial Objectives .............................................................................. 2

III. Summary of Expert Opinions ...................................................................... 3

IV. Startup Emissions .................................................................................... 4

A. Reasons for Including Startup Emissions in Modeling ................................ 4

B. Adaptation of Electronic Modeling to Include Startup Emissions .................. 6

C. Results of Emissions Modeling with Startup Emissions ............................ 10

V. Other MassDEP Plan Approvals Modeling Air Toxics ...................................... 13

VI. Unanticipated Methane Emissions............................................................... 13

VII. Additional Air Plan Approval Requirements .................................................. 14

VIII. Conclusion .......................................................................................... 16

I. Introduction

1. My name is John Hinckley.

2. I submit this prefiled testimony in support of the Town of Weymouth in this
proceeding.
3. My résumé is attached to this testimony as Exhibit A.
4. I am currently employed by GeoInsight, Inc. as an Associate/Air Compliance
Specialist. My business address is 186 Granite Street, Suite 3A, Manchester, New Hampshire
02101.
5. I am an air quality consultant with 20 years of permitting, modeling,
management, and public speaking experience.
6. I earned a B.S. in Natural Resources from the University of Vermont in 1994
and an M.S. in Environmental Science & Engineering from the University of Virginia in 1998.
7. I am certified as a Qualified Environmental Professional (“Q.E.P.”). I also have
specialized training from the U.S. EPA Air Pollution Training Institute, in the U.S. EPA
Method 9 Visual Opacity Assessment, and in AERMOD Modeling. I have these areas of
expertise: Air Quality Modeling; Emission Estimation; Air Permit Application Preparation; and
Pollution Control Technology Evaluations.
8. I am also professionally affiliated with the Air & Waste Management Association
(AWMA) and the Institute for Professional Environmental Practice (IPEP).
9. Throughout my career, I have worked on a variety of often complicated air
permit modeling analyses. A representative sampling of my experience is included in my
résumé, which I do not repeat here.
10. I have prepared air permit applications and performed peer reviews for projects
burning pipeline natural gas, liquefied natural gas (LNG), compressed natural gas (CNG),
landfill gas, liquefied petroleum gas (LPG), and biogas from anaerobic digestion of manure and
organic waste (“gas projects”) over the past 20 years as an air compliance specialist. As part of

1
this work, I have also either personally performed or directed and reviewed the technical work
associated with natural gas projects such as estimating emissions (including air toxics), assessing
pollution control technology requirements, and modeling air dispersion of pollutants in
ambient air. I have evaluated emissions from combusting natural gas in boilers, spark ignition
internal combustion engines, and combustion turbines. I have also evaluated emissions from
natural gas storage facilities, including compressed natural gas (CNG) and liquefied natural gas
(LNG) storage facilities.

II. Testimonial Objectives

11. I have been asked by the Town of Weymouth (“Weymouth”) to review the
Massachusetts Department of Environmental Protection’s (“MassDEP”) Air Quality Plan
Approval for Application No. SE-15-027 (“Plan Approval”). Weymouth asked me to provide
my professional opinions regarding this document and with respect to the potential of the
proposed compressor station (the “Compressor Station”) that Algonquin Gas Transmission,
LLC (the “Applicant”) seeks to construct in North Weymouth, Massachusetts pursuant to that
Air Plan Approval.
12. In preparing my testimony, I specifically reviewed the following documents:

• The October 2015 MassDEP Non-Major Comprehensive Plan Approval

Application (“October 2015 Application”);

• The May 2018 Update to the 2016 Air Dispersion Modeling Report
(“Updated Air Dispersion Modeling Report”);

• The May 2018 Update to the 2016 Non-Major Comprehensive Plan

Approval Application (“Proposed Plan Approval Update”);

• The January 11, 2019 Plan Approval from MassDEP (“Air Plan
Approval”); and

• The January 2019 Mass DEP Response to Public Comments on the

“Proposed Plan Approval”.

2
 13. In the past, I have also previously reviewed and I am therefore generally aware
of the following documents:

• The October 2015 Air Dispersion Modeling Report;

• The February 2016 Non-Major Comprehensive Plan Approval

Application Supplement (“February 2016 Application Supplement”);

• The February 2016 Air Dispersion Modeling Supplement; and

• The March 30, 2017 Air Quality Proposed Plan Approval.

III. Summary of Expert Opinions

14. My professional opinions are briefly summarized as follows.

15. Ambient air toxics concentrations from the proposed Compressor Station will
likely occur at levels higher than those modeled by the Applicant—specifically, at levels that
exceed the MassDEP Threshold Effects Exposure Limit (“TEL”) and Allowable Ambient Limit
(“AAL”) for formaldehyde and benzene (a regulated air toxic pollutant) at certain receptor
locations.
16. The air toxics emissions modeling (“emissions modeling”) performed by the
Applicant did not account for emissions from startup operations (“startup emissions”). I
therefore supplemented the Applicant’s emissions modeling to include startup emissions for
two scenarios: (i) 9-minute startups (the Applicant’s “estimate” of startup time), and (ii) 30-
minute startups (the maximum allowable startup time authorized by the Plan Approval).
17. The results of my modeling of both scenarios demonstrate that project ambient
concentrations of formaldehyde will be at higher levels than those anticipated by the Plan
Approval. When startup emissions for 9-minute startups are included in the Compressor
Station’s modeled emissions, the corresponding concentrations exceed the AAL for
formaldehyde. When 30-minute startups are included in the Compressor Station’s modeled
emissions, the corresponding concentrations exceed both the TEL and AAL for formaldehyde.

3
 18. Additionally, benzene emissions and concentrations are directly proportional to
those of formaldehyde. I thus multiplied the ratio of my modeling results (the formaldehyde
result divided by the TEL or AAL) by the Applicant’s benzene result to estimate benzene
concentrations with the inclusion of startup emissions. That analysis shows that including
startup emissions from 30-minute startups, will result in benzene concentrations exceeding the
AAL.
19. Finally, even if these modeling results did not require denial of the Applicant’s
Plan Approval application, the Plan Approval for the proposed Compressor Station issued by
MassDEP omits important conditions that would ensure that the proposed gas turbine’s
oxidation catalyst will effectively and continuously achieve its purpose for controlling
emissions. In my professional opinion, the Plan Approval should include two or more
additional conditions to ensure compliance.
20. I explain these opinions and the basis for each in the testimony below.

IV. Startup Emissions

21. As part of preparing this testimony, I peer reviewed the Applicant’s Plan
Approval application, the Applicant’s emissions modeling submitted in support of that
application, and the Plan Approval.
22. Part of my peer review focused on “startup conditions” for the Compressor
Station’s combustion turbine (“turbine”).
23. While I note, based on the Application, that shutdown conditions also have
some potential for elevated levels of emissions as compared to emissions during normal
operations, that potential is less than for startup conditions. My modeling is conservative
because it does not take into account an increase in emissions during shutdown periods.

A. Reasons for Including Startup Emissions in Modeling

24. The Applicant projects 416 startups per year.

4
 25. The Applicant estimates that the duration of an individual startup event will be
approximately 9 minutes.
26. While the duration of startups is relatively short compared with the year-round,
continuous operating time modeled by the Applicant, that does not mean that the Compressor
Station’s turbine will emit a proportionally small amount of air toxics during those events. It
also does not mean that startup emissions will have negligible impacts on ambient air quality.
27. To the extent that the Applicant and MassDEP appear to make that assumption
(MassDEP Response to Public Comments on the “Proposed Plan Approval,” Jan. 11, 2019,
comment 19), I disagree with it. In fact, because the turbine’s catalyst will not effectively
reduce emissions during startups, and because emissions during startup tend to be greater than
during normal operation, the emissions that will be produced during startups are significantly
higher than those that would be produced during normal operations.
28. The Applicant proposes to reduce volatile organic compound (VOC)
emissions—including formaldehyde and benzene—by using an oxidation catalyst. The
oxidation catalyst essentially destroys (i.e., oxidizes) those compounds by converting them to
carbon dioxide (CO2) through a process called oxidation, which requires a minimum
temperature of 880 degrees Fahrenheit (°F) (its “effective operating temperature”). According
to the Application, the catalyst will destroy 95% of formaldehyde (the design destruction
efficiency) once the gas turbine has reached its normal operating state and the catalyst bed has
reached its effective operating temperature.
29. Startups, however, are different. The Compressor Station’s proposed turbine
emits a significantly higher quantity of air toxic pollutants (such as formaldehyde and benzene)
during startup events than during normal operations. This is because the proposed catalyst will
not operate at its design destruction efficiency and therefore not fully destroy formaldehyde,
benzene, and other volatile organic compounds (by oxidization) until it has reached its effective
operating temperature, which is reached after the startup period is finished.

5
 30. Formaldehyde is a byproduct of incomplete combustion, as are other air toxics.
Those emissions are therefore higher during startup because the turbine is not combusting
natural gas as efficiently as it will once it has reached normal operating conditions. This means
that, without catalytic control of formaldehyde during startup, there are uncontrolled emissions
of formaldehyde, benzene, and other VOC emissions that are higher than what those
uncontrolled emissions would be once the turbine had completed startup and stabilized.
31. As William Powers explains in his testimony, formaldehyde emissions during
startup will be more than an order of magnitude greater than those produced during normal
operations. In addition, the dispersion conditions for emissions are poorer during startup than
normal operation, which leads to higher ambient pollutant concentrations during startup.
Dispersion of emissions is caused by the buoyancy and momentum of the plume of exhaust in
which they are contained. Buoyancy is less during startup because the plume is cooler than
during normal operation. Momentum is less because the exhaust is moving more slowly during
startup than normal operation.

B. Adaptation of Electronic Modeling to Include Startup

Emissions

32. The Applicant estimated emissions of criteria pollutants and air toxic pollutants
occurring during startup conditions and provided stack parameters for those conditions.
33. The information needed to model startup emissions was developed by the
Applicant and is included in Table B-1Ad, B-1Ae, B-1Af in the Plan Approval Application. This
information includes the exhaust flow rate, exhaust temperature, and emission rate for Step 2:
Ignition-Idle (Step 2) and Step 3: Loading/Thermal Stabilization (Step 3).
34. In light of the facts noted above regarding startup emissions, I expanded the
emissions model as part of my peer review to include startup emissions, using information
included in the Plan Approval Application.
35. I did this in the following steps:

6
 a. First, I1 imported the Applicant’s electronic modeling files into the
emissions modeling interface I use.2
b. Second, I3 performed model runs with the imported model files. I
compared the model results to those in the Applicant’s modeling report
to confirm that the electronic modeling files had been imported
correctly. The modeling files for the six scenarios the Applicant
modeled were completed for the 1-hour nitrogen dioxide model runs
(1-hour NO2 runs) and the 24-hour and annual formaldehyde runs. The
imported model results were the same as the Applicant’s. I therefore
concluded that the Applicant’s files had been imported correctly.
c. Third, once I confirmed a successful import, I reconfigured the
emissions model to include startup conditions for the Applicant’s
Scenario #1. Under that scenario, the turbine would operate at its
maximum capacity (100% load) at normal ambient air temperature
(46.65°F). The application provided the exhaust flow rate and exhaust
flow temperature for the two stages of a startup (See Table B-1Ad,
Table B-1Ae, and Table B-1Af of the plan approval application).
36. The Applicant performed modeling runs each year in a 5-year period (2012 –
2016). For our review, we ran only modeled year 2013 to evaluate startups, because that year
resulted in the highest concentrations when initially modeled. That approach is customary to
assess compliance with air toxics ambient air quality standards using the worst-case year (the
year in which the highest concentrations occurred).

1
At times, GeoInsight support staff assisted me in this analysis.
2
Version 11.13 of the “Beest” software program was used to import the modeling files.
3
At times, GeoInsight support staff assisted me in this analysis.

7
 37. From there, we developed different models for four different times within a 24-
hour period during which I assumed a startup would occur. The models represent a startup at
12:00AM, 6:00AM, 12:00PM, and 6:00PM. In other words, the “12:00AM model” represents
a startup occurring at 12:00AM every day in 2013. I chose this approach to provide an
understanding of how startups affect air quality at different times throughout the day.
38. The air emissions model performs calculations on an hourly basis and startups
last less than an hour. Therefore, the emissions model was parameterized to reflect the average
operating conditions occurring over the course of an entire hour in which startup occurs (the
startup hour). To this end, the startup hour was parameterized to reflect a nine-minute startup
by modeling a nine-minute startup followed by 51 minutes of normal operation and a 30-
minute startup by modeling a 30-minute startup followed by 30 minutes of normal operation.
Therefore, I calculated a weighted hourly average of the parameter values needed to model a
startup hour such as the emission rate, exhaust flow rate, and exhaust temperature from both
startup conditions and normal operation conditions. These calculations are included as Exhibit
B.
39. I incorporated startups into Scenario #1 in the following steps:
a. Step 1: I calculated the weighted average emission rate, exhaust flow
rate, and exhaust temperature for the hour when the startup would
occur.
b. Step 2: I added a new emission source called “SU9” to reflect nine-
minute startups and another called “SU30” to reflect 30-minute startups
in the emissions model. These sources reflect the weighted averages of a
startup followed by normal operating conditions during a startup hour.
c. Nine-minute startups were modeled because the Application states
startups will last that long. 30-minute startups were modeled because
the Plan Approval allows that length of time for startups.

8
 d. Step 2: The “hour of day” function of AERMOD4 was used to determine
the single hour in a day when startup emissions would occur. During
this step, I entered a value of zero for every hour the startup would not
occur, and a value of 1 to represent the hour the startup would occur.
This configuration was applied to the SU9 and SU30 sources in the
emissions model. Conversely, the hour-of-day function was configured
for the emission source in the model corresponding to the gas turbine
operating at normal conditions (WTBCO1N) with a value of zero to
represent the hour when startup was modeled and a value of 1 to
represent the hours startup is not occurring. This was done to prevent
the emissions model from double counting the normal condition
emissions as they are reflected in the weighted average values coded into
the SU9 and SU30 emission sources. Although the Application states
that the Compressor Station will experience an average of 416 startups
per year (1.14 per day), this approach conservatively assumed only one
startup per day.
e. Step 4: At separate times, a “source group” named “1NSU9” was added
to the emissions model to represent emissions from the combination of
an hour with a nine-minute startup and all other emission sources
operating during the hour the startup occurs. A “source group” named
“1NSU30” was also added to represent emissions from the combination
of a 30-minute startup and normal operations of all other emission
sources in the hour the startup occurs.

4
AERMOD is an EPA-approved modeling system used for emissions modeling.

9
 f. Step 5: I compared the emission model’s prediction of formaldehyde
from 1NSU9, 1NSU30, SU9, and SU30 to the formaldehyde TEL and
AAL.

C. Results of Emissions Modeling with Startup Emissions

40. I concluded the revised air emissions modeling by comparing the 24-hour and
annual formaldehyde model results with their respective TELs and AALs.
41. Table 1 shows the nine-minute model results compared with TEL and AALs.
As shown below, the AAL is exceeded when the startup occurs when the other emission
sources at the Compressor Station are operating (see column entitled “Startup + All Other
Sources (1NSU9)”.

Table 1: Emission Model Results from Nine-Minute Startup

Parameters Nine Minute Startup
Startup + All
Startup Only Other
Time of Averaging Standard
(SU9) Compliance? Sources Compliance?
Startup Period (µg/m3)
(µg/m3) (1NSU9)
(µg/m3)
6:00 AM 24-HR 2.00 0.61 Yes 0.67 Yes
6:00 AM Annual 0.08 0.06 Yes 0.09 No
12:00 PM 24-HR 2.00 0.62 Yes 0.67 Yes
12:00 PM Annual 0.08 0.06 Yes 0.09 No
6:00 PM 24-HR 2.00 0.61 Yes 0.63 Yes
6:00 PM Annual 0.08 0.05 Yes 0.08 No
12:00 AM 24-HR 2.00 0.66 Yes 0.75 Yes
12:00 AM Annual 0.08 0.05 Yes 0.08 No

42. Table 2 shows the 30-minute model results compared with TEL and AALs. As
shown below, the TEL and AAL are exceeded when the startup occurs in isolation (when no
other emission sources at the facility are operating – see column entitled “Startup Only

10
(SU30)”) and when the other emission sources at the Compressor Station are operating (see
column entitled “Startup + All Other Sources (1NSU30).

Table 2: Emission Model Results from 30-Minute Startup

Parameters 30 Minute Startup
Startup +
Startup Only All Other
Time of Averaging Standard
(SU30) Compliance? Sources Compliance?
Startup Period (µg/m3)
(µg/m3) (1NSU30)
(µg/m3)
6:00 AM 24-HR 2.00 2.30 No 2.35 No
6:00 AM Annual 0.08 0.25 No 0.28 No
12:00 PM 24-HR 2.00 2.29 No 2.35 No
12:00 PM Annual 0.08 0.25 No 0.28 No
6:00 PM 24-HR 2.00 2.19 No 2.26 No
6:00 PM Annual 0.08 0.22 No 0.25 No
12:00 AM 24-HR 2.00 2.39 No 2.48 No
12:00 AM Annual 0.08 0.22 No 0.25 No

43. There is a possible second approach to modeling formaldehyde emissions. In

this, the hourly emission rate for formaldehyde during startup (2.01 lb/hour for the nine-
minute startup and 6.7 for the 30-minute startup) would be multiplied by the ratio of the
number of estimated startup hours (62.4 hours/year for the nine-minute startup and 208
hours/year for the 30-minute startup) divided by the number of hours in a year. The hour of
day feature of AERMOD would not be necessary because it would be assumed the ratioed
emissions occurred every hour of every day. The results of using such a model would result in
annualized emissions exceeding the AAL for 30-minute startups but not for nine-minute
startups. These results are summarized in Table 3 below.

11
Table 3: Emission Model Results from 30-Minute Startup Using Annualized Emissions
Parameters 30 Minute Startup
Startup +
Startup Only All Other
Averaging Standard
(SU30) Compliance? Sources Compliance?
Period (µg/m3)
(µg/m3) (1NSU30)
(µg/m3)
24-HR 2.00 1.20 Yes 1.26 Yes
Annual 0.08 0.19 No 0.22 No

44. In my opinion, the available information does not support solely using the ratio-
based model. While this approach is used for modeling intermittent operations such as
startups, it may underestimate air toxics concentrations given that the total quantity of
emissions produced is not modeled within a single hour and given that the quantity of startup
emission is significantly higher than normal operations emissions. Therefore, it is appropriate
to use my model that assumes startups at fixed points in time and which help to identify an
approximate worst-case hour (the hour producing the highest air toxics concentrations from
startups) and results in a more conservative result.
45. The formaldehyde emissions modeling can also be used to project benzene
emissions. Table 4-18 through Table 4-23 of the applicant’s modeling report show annual
benzene concentrations at approximately 42.6% of the benzene AAL. This corresponds to a
concentration of 0.0426 micrograms per cubic meter (µg/m3). The annual formaldehyde
results for the column entitled Startup Only (SU30) shown in Table 2 of this document are
approximately 2.7 to 3.1 times the AAL. Formaldehyde emissions are directly proportional to
benzene emissions. Therefore, multiplying the benzene result by one of the formaldehyde
multipliers (2.7or 3.1) from the four different hours modeled can be used to estimate an annual
benzene concentration. Multiplying the benzene concentration of 0.0426 µg/m3 by the lower

12
multiplier of 2.7 yields of 0.1159 µg/m3, which is approximately 16% higher than the benzene
AAL of 0.10 µg/m3. Table 4 shows how the benzene concentrations were estimated.

Table 4: Estimate of Benzene Emissions Using Formaldehyde Results

Adjusted
Benzene
Result
(Multiplier
÷
Startup Applicant's Applicant's
Formaldehyde Only Multiplier Benzene Benzene Benzene
Time of Averaging Standard (SU30) (SU30 ÷ Result Result) Standard % of
Startup Period (µg/m3) (µg/m3) Standard) (µg/m3) (µg/m3) (µg/m3) Standard
6:00 AM 24-HR 2.00 2.30 1.1 0.2170 0.2494 0.6 42%
6:00 AM Annual 0.08 0.25 3.1 0.0426 0.1338 0.1 134%
12:00 PM 24-HR 2.00 2.29 1.1 0.2170 0.2481 0.6 41%
12:00 PM Annual 0.08 0.25 3.1 0.0426 0.1323 0.1 132%
6:00 PM 24-HR 2.00 2.19 1.1 0.2170 0.2372 0.6 40%
6:00 PM Annual 0.08 0.22 2.7 0.0426 0.1159 0.1 116%
12:00 AM 24-HR 2.00 2.39 1.2 0.2170 0.2598 0.6 43%
12:00 AM Annual 0.08 0.22 2.7 0.0426 0.1167 0.1 117%

V. Other MassDEP Plan Approvals Modeling Air Toxics

46. As part of my testimony, Weymouth provided to me copies of several plan

approvals for other projects. Those plan approvals are included as Exhibits C-E.
47. In each of those plan approvals, MassDEP notes that emissions modeling for air
toxics did not include background levels of those toxics when the emissions modeling was
compared to the applicable AALs and TELs. Each of those plan approvals stated that
background data were “not available.”
48. It is my understanding that background data for air toxics such as formaldehyde
and benzene are available for this proposed Compressor Station site.

VI. Unanticipated Methane Emissions

13
 49. In a prior proceeding involving an application for a Chapter 91 permit for the
Compressor Station, I testified that the Compressor Station presents a risk to public safety at

the surrounding properties if an unanticipated release of methane were to occur. A copy of

my testimony in that proceeding is attached hereto as Exhibit F.
50. While I presented that testimony in terms of the safety risk that would be
presented by the Compressor Station, I note that a release of methane would potentially be
“injurious” to human health.
51. In my prior testimony, I concluded that the weather data I evaluated indicates
that a methane plume could travel in any direction from the Compressor Station but would
most likely be carried in an easterly direction by a prevailing westerly wind.
52. The results of my modeling indicate that a plume of methane at a flammable
concentration could extend from approximately 1,000 feet to 4,600 feet downwind of the
origin of the leak.
53. Thus, as my analysis demonstrated, combustion of an unanticipated methane
release could result in fatalities or injuries to persons in the vicinity of the release, and thus
would be injurious to public health.

VII. Additional Air Plan Approval Requirements

54. Even if these modeling results did not require denial of the Applicant’s Plan
Approval application, the Plan Approval for the proposed Compressor Station issued by
MassDEP lacks important conditions that would ensure that the proposed gas turbine’s
oxidation catalyst will effectively and continuously achieve its purpose for controlling
emissions.
55. The oxidation catalyst is a critical component of the Project because it is the
Project’s sole control technology for reducing the emissions of air toxics such as formaldehyde
and benzene. Therefore, it is essential that the Plan Approval include conditions for reporting
and emission testing at a frequency that ensures that the catalyst is operating properly. Failure

14
of the catalyst would result in emissions of all VOC air toxic pollutants at levels far greater than
those estimated by the emissions modeling or authorized by the Plan Approval.
56. As written, the Plan Approval requires emission testing every two years. In my
opinion, that is not enough testing without other interim conditions being required. These
conditions would verify that the catalyst is operating in conformance with its design. Further,
absent a requirement to submit a report that summarizes these data, there is no way for the
MassDEP to be informed about the catalyst’s performance apart from the required biennial
stack testing.
57. The Plan Approval requires continuous monitoring of the pressure drop across
the catalyst and the inlet temperature to the catalyst. Specifically, the Plan Approval requires a
minimum temperature at the catalyst inlet of 880°F and a minimum pressure drop across the
catalyst bed of 2.83 inches of water column (in. of W.C.). However, the Plan Approval does
not require the facility to evaluate the data monitored and data logged periodically (for
example, every six months); compare the data against numeric standards (such as 2.83 in. of
W.C. and 880°F); and evaluate the number of instances the pressure drop and temperature
deviated from the numeric standards.
58. By way of analogy, this type of requirement is mandated by Title 40, chapter
63, subpart ZZZZ of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)
for certain diesel engines that require a catalyst to comply with carbon monoxide (CO)
emission limits. Facilities operating these engines must continuously monitor the catalyst inlet
temperature and the pressure drop across the catalyst. These facilities are also required to
submit a semiannual report to the state regulatory agency (such as the MassDEP) and the
United States Environmental Protection Agency (USEPA). The semiannual report provides a
summary of the evaluation of all temperature and pressure drop data collected and the number
of deviations from the temperature and pressure drop required for the facility. A semiannual

15
report would inform the Applicant and the Facility as to how the proposed catalyst is
performing between the biennial stack tests.
59. In addition to a semiannual report, the facility operator should be required to
measure CO emissions periodically to evaluate catalyst performance. CO is a surrogate for
gaseous air toxics, so in this case it would also serve as a surrogate for formaldehyde. For this
purpose, a handheld portable analyzer can be used to measure CO emissions upstream and
downstream of the catalyst to estimate the catalyst destruction efficiency. The handheld
portable analyzer results should be submitted in conjunction with the semiannual report.

VIII. Conclusion

60. This concludes my direct prefiled testimony. To the best of my knowledge,

belief, and based upon the materials I listed earlier that I have reviewed in connection with this
testimony, this testimony is accurate as of the date set forth below.

16