DAQ-2024-005028

DAQC-083-24
Site ID #10627 (B4)
MEMORANDUM

TO: STACK TEST FILE – NORTHWEST PIPELINE – Moab Compressor Station

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: January 30, 2024

SUBJECT: Source: Unit P005 Solar Centaur T-4700, 4680 hp, Compressor Turbine
Location: 23 miles South of Moab, Utah on Highway 191
Contact: Derek Forsberg, 801-584-6748
Tester: Emissions Science, Inc. James Olinger 970-749-5474
FRS ID#: UT0000004903700029
Permit #: 3700029005 dated September 25, 2020
Subject: Review of Pretest Protocol Dated January 26, 2024

On January 29, 2024, the DAQ received a stack test protocol for emissions testing of the Northwest
Pipeline – Moab Compressor Station, Solar Centaur T-4700, 4680 hp, Compressor Turbine P005. Testing
will be performed on March 14, 2024, to demonstrate compliance with the NOx and CO emission limits
found in Permit Conditions II.B.2.a, and II.B.2.b.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses; OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate; OK
3. RM 3A used to determine dry molecular weight of the gas stream; OK
4. RM 4 used to determine moisture content; OK
5. RM 7E used to determine NOx emissions; OK
6. RM 10 used to determine CO concentrations of emissions; OK
7. RM 19 used to determine NOX and CO emission exhaust flowrates with fuel meter: OK
DEVIATIONS: None noted.

CONCLUSION: The Northwest Pipeline stack testing protocol for testing the Moab CS Turbine
P0005 stack emissions has been evaluated appears to be acceptable.

RECOMMENDATION: Send protocol review & test date confirmation notice.

ATTACHMENT: Northwest Pipeline stack test protocol dated January 26, 2024.

willffis.
January 26,2024
295 Chipeta Way
P.O. Box 58900
Salt Lake City, Utah
84't 58-0900
I'TAH DEPARTMENT OF
ENVIRONMENTAL OUATITY
UtahDivisionofAirQuality JAN 29 l|,24
Attn: Harold Burge
P. O. Box 144820
Salt Lake City, UT 84114-4820 DIVISION OF AIR QUALITY
RE: Northwest Pipeline LLC - Moab Compressor Station
Turbine Emissions testing
Dear Mr. Burge:
Northwest Pipeline LLC (Northwest) respectfully submits the enclosed emissions testing protocolto
demonstrate compliance with emission limits in Title V permit # 3700029005, Conditions ll,B.2.a and
ll.B.2.b. Northwest plans to test Unit P005, a Solar Centaur T-4700S at the Moab Compressor Station on
March 14,2024, according to the enclosed protocol.
lf you have any questions regarding this notification or attached emissions testing protocol, please feel
free to contact me at [phone].
Sincerely,
v*.ila
Derek Forsberg
Environmental Manager
Enclosure: Moab C/S Emissions testing protocol
cc: Salt Lake File
Ernissions
.r flscienceffi hrc.
Bo&y llomia Bq3iG
Proposed Test Date:
March 14,2024
Protocol Prepared by:
James Olinger
Emissions Science, Inc.
-T.ITAH
DEPARTMENT OF
E}URONMENTAL OUAI.JTY
JAN 2 9 2024
DIVISION OF AIR QUALITY
Emissions Testing Protocol & Source Test Plan
Northwest Pipeline, LLC
Moab Compressor Station
San Juan County, Utah
Utah Department of Environmental Quality Permit
# 370002900s
Source II):
P005
Solar Centaur T-4700s
E.S.I
Grand Junction, CO
Phone [phone]+9 urq
^/.emissions-science.com
Introduction:
Purpose of Test
Source to be Tested
Test Methods & Proced
Contact Personnel ....
Proposed Test Dates
Detailed Source Test
Delivered Data Package ...
Contractor Supplied Equi
Appendix 1 .... ....Sample C
Appendix 2 .... ....QAiQC
Appendix3.... ....EPA
Appendix 4 .... . ...Sample S Schematics (Methods 1-4, 7E,
Table f Contents
Page 1
Page I
Page I
PageI-5
Page 5
Page5-6
Page 6
Page 6
Page 6
dices
ions Used for Source Testing
for Source Testing
1 Expected Stack Configuration
10)
Source Test Plan
Introduction:
Northwest Pipeline,LLC has contracted Emissions Science, Inc. to perform an initial
performance emissions test under the requirements set forth in the State of Utah
Department of Environmental Quality Permit # 3700029005. The source willbe tested
in accordance with 40 CFR Part 60 (Methods 1, 3,{, 7F,,10 & 19) on one, mechanical
drive gas turbine (RICE) located at the Moab Compressor Station in San Juan County,
Utah. The Moab Facility is used to compress natural gas into a pipeline for delivery.
Purpose of Test:
The purpose of the test is to demonstrate compliance with the concentrations and mass
emission rates of Carbon Monoxide and Nitrogen Oxides as required under the permit
# 3700029005.
Source to be Tested:
One source at the Moab Facility will be tested.
The source is as follows;
P005. Solar Centaur T-4700. Stationary Combustion Turbine
Site Rated HP 4680. Serial Number: OHA14-C3845
Source Retrofitted with SoLoNOx Technology.
Test Methods:
ESI proposes the following EPA reference methods for this source test plan.
Note* The instrumental methods were updated by the EPA in thefinal rule which was published on
August l4th, 2006.
EPA Reference Method I
o Purpose: Establishing stack diameter and velocity traverse points.
. Equipment: Measurement device and calculator.
o Calculations: (See Appendix 1)
Test Methods: (continued)
EPA Reference Method 3,A'
. Purpose: Determination of Carbon Dioxide (COz) & Oxygen (Oz)
concentrations in exhaust gas.
o Equipment: Instrumental Method using non-dispersive infra-red (NDIR) for
continuous sampling of COzand a Paramagnetic sensor for Oz.
. Calculations: n/a
EPA Reference Method 7E. Purpose: Determination of Nitrogen Oxides (NO, Emissions from Stationary
Sources.
Equipment: Instrumental Method using Chemiluminescence based technology for
continuous sampling of Nitrogen Oxides (NO*), Heated Sample Line capable of
keeping gas sample above the point of condensation (approximately 250 degrees
F), Gas Conditioning System (to remove moisture prior to gas sample entering the
analyzers). All applicable QA/QC assurances required under EPA Method 7E such
as; calibration error checks, system bias checks, interference checks and NOz
convertor efficiency checks will be performed on the analyzer.o Calculations: (See Appendix 1)
EPA Reference Method 10
o Purpose: Determination of Carbon Monoxide (CO) Emissions from
Stationary Sources.
o Equipment: Instrumental Method using NDIR for continuous sampling of
Carbon Monoxide, Gas Conditioning System, Sample Probe, System Pump,
Etc.
o Calculations: (See Appendix l)
EPA Reference Method 19o Purpose: Determination of Nitrogen Oxide and Carbon Monoxide Emission rates.
. Using industry standard of 8710 SCFA4MBTU and Turbine Fuel Meter / Fuel gas-
BTU value for mass emission rate calculations.
Detailed Test Procedure:
Prior to the test procedure the test site will be inspected for potential safety hazards
and a Job Site Analysis (JSA) will be held with all persons who may be affected by
the testing program. All equipment will be assembled, allowed to reach operational
temperature and inspected for damage and correct assembly. The exhaust stack will be
measured for inside diameter and proper sample port locations. The pitot tube will be
marked at 3 points (76.7,50 & 83.3% of inside stack diameter) and the 3-point
traverse points will be calculated and marked on the pitot tube according to the criteria
found in EPA Method 1. The entire sampling system (including analyzers, sample
lines, moisture trains, gas meter and gas conditioning manifold) will be tested for
potential leaks prior to sampling.
The analyzers will then be challenged with EPA Protocol Gasses and calibrated to
minimize potential drift during the sampling process.
The calibration error test, system bias check, system response time check, NO2 :> NO
conversion efficiency test and stack stratification test will be completed prior to
performing any stack sampling.
Operational turbine load will be determined and if found acceptable, the sampling
program will be initiated. Concurrent with the gas sample being delivered to the
analyzers (for EPA methods 3A,78 and 10). Stack gas will be diverted into a
moisture removal system before introduction to the emissions analyzers. All measured
gas species will be analyzed as parts per million volume dry (ppmvd).
EPA methods 3,{, 78, l0 and 19 are instrumental methods and will be completed in
accordance with instrument manufacturer specifications and under the individual
method requirements established by the EPA. A data recorder will be used to log
measured data in one-minute increments for each measured gas species to these
analyzers.
A stack stratification test will be performed on the turbine prior to the commencement
of sampling. If the source is < 5Yo stratified as allowed under Method 7F, the
sampling will occur from a point in the center area of the duct while the source
maintains the desired load conditions. If the stack is found to be stratified, multiple
point sampling will be used as directed by the test method.
Detailed Test Procedure (continued):
Testing will be performed over 4 load ranges selected by Williams NW Pipeline to
best represent normal operating scenarios from the combustion turbine.
Each of the four load ranges will be sampled for 1, 60-minute sample period and will
measure concentrations of CO & NO, (ppmvd) and the diluent of OzYo from the
source at each load range.
The test program will correct NO* & CO concentration to ppmvd @ 15% Oz for
comparison against any NO* permit limits normalized to the diluent concentration at
l5Yo Oz. Oxides of Nitrogen will also be corrected to ISO ambient standard
conditions.
Turbine fuel meter values from each sample run and the BTU value of the fuel gas
will be used with EPA Method 19 to determine mass emission rates of NO, & CO.
The accepted industry standard of 8710 SCF/MMBTU for the F-factor will be used in
the calculation for mass rates. The testing at various load conditions should ensure the
turbine is meeting the permitted limits across a wide range of operating conditions. At
least one load condition will be at 90-110% of turbine maximum capacity.
Turbine operating parameters such as RPM's, Suction Pressure, Discharge Pressure,
Operation Hours, Ambient Temperature and Humidity, Etc. will be collected during
each test-run. The running horsepower or turbine heat output will be provided to ESI
technicians by NW Pipeline personnel.
It is the responsibility of, NW Pipeline, LLC personnel to provide safe access to hand-
tight, EPA compliant sample ports. It is also the responsibility of NW Pipeline, LLC
to select the load ranges for the testing based on allowances under Subpart GG.
The source will be tested to determine compliance with the following mass emission
rate limitations.
Carbon Monoxide (CO) - 4.55lbhr
Nitrogen Oxides (NO.) - 6.25\blhr
Detailed Test Procedure (continued):
Sulfur compounds such as SOzwill not be measured during this testing event as
Northwest Pipeline has determined that the sulfur concentrations in the fuel gas are
below the threshold that would trigger testing for SOz.
Contact Personnel:
Northwest Pipeline, LLC
295 Chipeta Way
Salt Lake ciry, uT 84108
Mr. Derek Forsberg
Environmental Specialist
(801) s84.6748
Emissions Science, Inc.
635 19 %Ftoad
Grand Junction, CO 81507
Mr. James Olinger
970.628.4849 Office or 910.749.5474 CelI
State of Utah,
Department of Environmental Quality -DAQ
1950 West North Temple
Salt Lake City, UT 841l4
Compliance Division
80t.s36.4129
Proposed Test Dates:
Moab Compressor Station. Source ID # P005.
Testing for NO* & CO Concentrations and mass emissions rates.
March 14,2024.
Detailed Source Test Schedule:
The test trailer will be set up on site
be energized overnight to ensure it is
Arrival time at the Moab Facility on
calibration procedure and job
hours. Testing ofthe source is ex
Approximate start time 1 0:00- 10:30
Delivered Data Package:
Emissions Science, Inc. will deliver
source test(s). One additional week
any corrections or revisions are
Cpntractor Supplied Equipment:
Emissions Science, Inc. will supply
necessary for the scope of this project
found in this document. (Pages 2-6).
March 13h,2024 and the NDIR analyzer will
to operating temperature.
arch 14ft is expected to be 7:30 AM. The
tasks are expected to take approximately 2.5
to occur as follows.
draft datapackage within 3 weeks of the
be allowed to deliver the final data package if
analysis equipment, tools and personnel
is required under the test methods section
Appendix I
Sample Calculations used for Source Testing
APPENDIX 1
Sample Calculations for EPA Reference Method Tests
Note: As the calculations, formulae and unit conversions usedfor these test procedures are too
n?.tmerous to list, thefollowing is a selection of the primary calculstions used in the various
methods.
EPA Reference Method 1
o Stack Diameter * Distance Percentage from Stack Wall
(Based on # of Traverse Points from Table Fl-2)
EPA Reference Method 2
o Section 12.5: Molecular Weight of Stack Gas
Ms : Md (1 - B*,) + 18.0*B*, ...8q. 2-6
Vf/here:
M, Molecular weight of stack gas, wet basis... (b/lbmole)
Ma Molecular weight of stack gas, dry basis
B*, Water vapor in the gas stream proportion by volume
Section 12.6: Average Stack Gas Velocity
o KpCp{'Puu*{(T,,uo, / P,M.) ...8q.2-7
. 85.49 m/sec [(1bl1b-mole) (in. Hg) / ('R) (in. Hr}))'''
V[here:
Kp Velocity equation constant.
Cp Pitot tube cofficient, dimensionless'Povs Average velocity head of stack gas... (in. HzO)
Ts@bg Absolute stack temperature... (R)
P, Absolute stack pressure (Pu, + Pc)... (in. Hg)
M, Molecular weight of stack gas, wet basis... Qb/lbmole
o Section 72.7: Average Stack Gas Dry Volumetric Flow Rate
o Q:3600 (1-B*,) V' A[ T.ta P, / Ts(abs) P'ta] ...Eq.2-8
Where:
3600 Conversion Factor... (Sec/hr)
8., V[/ater vapor in the gas stream proportion by volume
V, Average stack gas velocity... (ft/sec)
A Cross-sectional area of stack... (ff)
Tsta Standard absolute temperature... (528'R)
T'@o : Absolute stack temperature... (R)
Pstd : Standard absolute pressure... (29.92 in. Hg)
Sample Calculations for EPA Reference Method Tests
EPA Reference Method 4
Dry Gas Volume:
V. Y P* Tr,o
VmGtd) --Eq4-3
V* P,
:K.4 Y
Psta Tm
Vflhere:
V.6ta): Dry gas volume measured by the dry gas meter, corrected to standard oonditions, dscm
(dscf).
Vm: Dry gas volume measured by dry gas meter, (dcf)
Y : Dry gas meter calibration factor.
P.: Absolute pressure (for this method, same as barometric pressure) at the dry gas meter, (in.
Hg).
Tstd : Standard absolute temperature, 528 degrees R
P.ta: Standard absolute pressure, 760 mm Hg
T. = Absolute temperature at meter, (R)
Moisture Content:
Vwsta
B*o:
Vmstd * Vwstd
Where:
B*o : Proportion by volurne of water in the gas stream (dimensionless)
Vwsta :Volume of water in the gas sample (standard conditions) cu. Ft.
Vmstd : Volume of gas sarnple through the dry gas meter (standard conditions)
T,,,
Sample Calculations
EPA Method 7E
ER:Ca*1.912* l0-3*e*T
Hp-tr
V[here:
ER:Emission Rate of NOx in g/hp-hr
Ca: Measured NOx concentration in parts
1.912 x 1t3 : Conversion constantfor ppm
degrees Celsius.
Q: Stack gas volumetricflow rate, in
T : Time of test run, in hours.
HP-hr : Brake work of the engine,
EPA Method 19
NO* Lbl[Ir:
(ppm 11O.) (1.19 x 10-7) ( F-Factor) (
EPA MethodTE (Section 12.9) NOz
(NO.final - NOn'a)
EFFNoz:
(NO*p."t- NO*r*a)
Where:
EffNoz: NO2 to NO corwerter efficiency,
NOx rioor : The final NOX concentration
NO pi"a: The average NO concentration
converter eficiency test ppmv.
NOxpea*: The highest NOX concentration during the converter efficiency test, ppmv.
EPA Reference Method Tests
million by volume (pp*r).
Ox to grams per standard cubic meter at 20
cubic meter per hour, dry basis.
(HP-hr).
.9 I 20.9 -Ozo/o) Gleat Input
oven efficiency
during the converter fficiency test ppmv.
with the analyzer in the NO mode during the
Sample Calculations for EPA Reference Method Tests
EPA Method 10
ER:Ca*1.164*10-:*e*T
Hp-hr
V[here:
ER:Emission Rate of CO in g/hp-hr
Ca: Measured CO concentration in parts per million by volume (pp*u).
1 . t 64 x I0-3 : Conversion constant for ppm CO to grams per standard cubic meter at 20
degrees Celsius.
Q: Stack gas volumetricflow rate, in standard cubic meter per hour, dry basis.
T : Time of test run, in hours.
HP-hr : Brake work of the engine, horsepower-hour (HP-hr).
EPA Method 19
CO LblFIr:
(ppm NO,,) (7.27 x 10-8) ( F-Factor) (20.9 I 20.9-O2oA) (Heat Input uuaru/rr;
NO* ppm @ 15% Oz : (NO* ppm) (5.9 I 20.9-Oz%)
Note: The proceeding test calculations are examples of the equations used in the testing
procedures. Additional or alternate EPA approved equations may also be used during the testing
program. Some equations may not be usedfor this specific job.
Appendix 2
Sample QA/QC Checks for Source Testing
Quality Assurance / Quality Control PIan
(As noted and under the allowable tolerances in EPA method 7E)
F Verification of correct Calibration Gas Selection and check on expiration dates.
F Verification of heated sample line (above dew point of HzO) and thermocouple integrity.
F Use of non-reactive sample transport and probe material (stainless-stee1, glass, PTFE).
F Complete system leak check.
F Analyzer Calibration Error Check (3-point linearity check).
F Sample system bias check.
F System Response Time.
F Analyzer Drift Assessment.
F NOz => NO conversion test.
F System Purge Time.
F Stack stratification test or minimum sarnple time at each point.
' ) One-minute intervals for data recorder on sample run data (averaged at end of run).
F Post-test bias check.
F Calibration and run 'raw'data preserved as indelible record.
Emissions Science,Inc
Appendix 3
Expected Stack Configuration
Client:
Date:
Emissions Science, Inc.
EPA Method 1
Field Data Sheet
Site:
Time:
Unit lD:
Stack Diameter (I.D.) :
<--.--.--->
Upstream Disturbance =
Downstream Disturbance =
Port Depth:
Exhaust Stack with
sample ports @ 90 o
angles
Stack Diameter (I.D.) =
Downstream
Emissions Science, lnc
Appendix 4
Sample System Schematics
Emissions Science, Inc.
EPA Method 7E
UTAH DEPABTMEI.T OF
ENVIRONMENTAL QUAUry
JAN '') '', r-iit t
DIVISION OF AIR QUALITV:
System manifold with
pump, flow control
valves, overflow
valve, Etc.
=lltrr-l=l!=
C.A.I. ZRE NDIR
& Paramagetic
02 Analyzer
c.A.t.
Chemilu minescence
Analyzer
Emissions Science, lnc