DAQ-2024-008162

1

DAQC-498-24
Site ID 15938 (B4)

MEMORANDUM

TO: STACK TEST FILE – UINTA WAX OPERATING, LLC – North Randlett
Compressor Station

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: May 22, 2024

SUBJECT: Source: Compressor Engine Units #1 (SN: N6W/4EK00075), #2 (SN:JEF01814),
#3 (SN:N6W/JEF02569:), #4 (SN:JEF01637), and
#5 (SN:N6W/JEF01780)
Location: Randlett, Uintah County, Utah
Contact: Karen Pratt: [phone]
Tester: Oasis Emission Consultants, Inc.
Site ID #: 15938
Permit/AO #: DAQE-AN159380002-23 dated December 11, 2023
Subject: Review of Pretest Protocol dated May 17, 2024

On May 17, 2024, Utah Division of Air Quality (DAQ) received protocols for testing of the compressor
engine units #1, 2, 3, 4, and 5 at North Randlett Compressor Station in Uintah County, Utah. Testing will
be performed June 18-21, 2024, to determine compliance with the emission limits found in condition
II.B.2 of DAQE-AN159380001-19 and 40 CFR Part 60, Subpart JJJJ.

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 3 used to determine dry molecular weight of the gas stream: OK
4. RM 320 used to determine moisture content; NOx, CO, and VOC emissions: OK
DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: The methods proposed in the protocol are capable of determining
compliance with the unit’s emission limits, it is recommended the pretest
protocol be determined as acceptable.

ATTACHMENTS: Uinta Wax’s pretest protocol and notice of testing date.

May 17, 2024

Rik Ombach
Minor Source Compliance Manager
PO Box 144820
Salt Lake City, UT 84114-4820

Re: Periodic Source Emission Testing Notification and Protocol Submission For Uinta
Wax Operating, LLC’s North Randlett Compressor Station, Unit IDs: #1, #2, #3 &
#5, Located in Uintah County, Utah

In order to comply with the requirements of Utah Department of Environmental Quality (UDEQ)
Approval Order # DAQE-AN159380002-23 and EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ), we
have been requested to conduct source emission testing on two (2) Caterpillar G3516B and two
(2) Caterpillar G3516J 4-stroke, lean burn (4SLB) engines located at Uinta Wax Operating,
LLC’s North Randlett Compressor Station (Site ID: 15938) in Uintah County, Utah. A summary
of the units and details of our testing procedures can be found in the attached protocol.

Testing has been scheduled with the client for the Tuesday, June 18th - Friday, June 21st, 2024
test campaign.

If you have any questions or concerns, please contact the undersigned at [phone].

Sincerely,
Oasis Emission Consultants, Inc.
__________________________
Christopher N. Knott, P.Eng
Director, Engineering & Operations

enc.

May 17, 2024

Rik Ombach
Minor Source Compliance Manager
PO Box 144820
Salt Lake City, UT 84114-4820

Re: Source Test Notification and Protocol Submission For Uinta Wax Operating,
LLC’s North Randlett Compressor Station, Unit ID: #4, Located in Uintah County,
Utah

In order to comply with the requirements of Utah Department of Environmental Quality (UDEQ)
Approval Order # DAQE-AN159380002-23 and EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ), we
have been requested to conduct source emission testing on one (1) Caterpillar G3516J 4-stroke,
lean burn (4SLB) engine located at Uinta Wax Operating, LLC’s North Randlett Compressor
Station (Site ID: 15938) in Uintah County, Utah. This engine is new to the North Randlett
Compressor Station. A summary of the unit and details of our testing procedures can be found in
the attached protocol.

Testing has been scheduled with the client for the Tuesday, June 18th - Friday, June 21st, 2024
test campaign.

If you have any questions or concerns, please contact the undersigned at [phone].

Sincerely,
Oasis Emission Consultants, Inc.
__________________________
Christopher N. Knott, P.Eng
Director, Engineering & Operations

enc.

Utah Department of Environmental Quality
Division of Air Quality
Compliance Test Protocol

Approval Order # DAQE-AN159380002-23
and EPA 40 CFR 60, Subpart JJJJ

Engines: (2) Caterpillar G3516B & (2) Caterpillar G3516J
Unit IDs: #1, #2, #3 & #5

Uinta Wax Operating, LLC
North Randlett Compressor Station,
Uintah County, Utah

May 17, 2024

Prepared By:

Oasis Emission Consultants, Inc.
2730 Commercial Way
Rock Springs, WY 82901

1.0 INTRODUCTION

The purpose of this document is to provide relevant information pertaining to proposed periodic source
emission testing for Uinta Wax Operating, LL C by Oasis Emission Consultants, Inc.

Approval Order No.: DAQE-AN159380002-23

Federal Regulation: EPA 40 CFR 60, Subpart JJJJ

Facility/ Location: North Randlett Compressor Station (Site ID: 15938)
The facility is located five (5) miles west of Randlett, in
Uintah County, Utah.
UTM Coordinates: 593,702 m Easting, 4,453,005 m Northing
UTM Zone 12

Emission Sources: Unit IDs: #1 & #2 – (2) Caterpillar G3516B

Unit ID: # 3 & #5 – (2) Caterpillar G3516J
1.1 TEST PROGRAM ORGANIZATION

Client: Uinta Wax Operating, LLC

Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Contact: Josh Morgan, Operations Tech
Email: [e-mail]
Cell.: [phone]

Test Company: Oasis Emission Consultants, Inc.

Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Christopher Knott, P.Eng., Director, Engineering & Operations
Phone: [phone] Fax: [phone]

State Authority: Utah Department Of Environmental Quality

Address: PO Box 144820
Salt Lake City, UT 84114-4820
Contact: Rik Ombach, Minor Source Compliance Manager
Email: [e-mail]
Phone: [phone]

Stack Test Report Submission:
https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh
1.2 TEST PROJECT OBJECTIVE(S)

The purpose of performing source emission testing is to satisfy the requirements set out by NSPS
JJJJ and UDEQ Approval Order # DAQE-AN159380002-23.
2.0 SOURCE TEST PROGRAM DESCRIPTION

2.1 Test Contractor

All source emission tests will be performed by Oasis Emission Consultants, Inc., based out of
Rock Springs and Sheridan, Wyoming. Processed test results and all raw data captured during
the tests are forwarded to Chris Knott, P.Eng., Director of Engineering and Operations and/or
Charles Chapman, Manager of Technical Services, for quality control and data checking. Once
approved, tests are forwarded to the client.

2.2 Test Dates

The units will be tested by Oasis Emission Consultants, Inc. during the June 18th – 21st, 2024
test campaign.
2.3 Report Date

The compliance test reports will be submitted no later than 60 days following the compliance
tests.

2.4 Emission Source Description

A summary of the units to be tested is provided below:

UDEQ APPROVAL
ORDER #
UNIT ID ENGINE HP RICE
CONFIGURATION
ENGINE
MANUFACTURE
DATE
DAQE-AN159380002-23
#1 Caterpillar G3516B 1,380 4SLB 8/31/1993
#2 Caterpillar G3516B 1,380 4SLB 11/14/2012
#3 Caterpillar G3516J 1,380 4SLB 1/22/2014
#5 Caterpillar G3516J 1,379 4SLB 6/4/2012

2.5 Testing Methodology and Procedures

Emission Source Limitations:

The sources will be tested according to methodologies described in this protocol. Any emission
levels which, based on averaged levels, exceed the limitations listed will be flagged in the test
report(s). Relevant information is provided in the tables below.

2.5.1 UDEQ Approval Order # DAQE-AN159380002-23

Unit
ID
Engine Make /
Model
Engine S/N HP Max. Allowable
NOx
Max. Allowable
CO
Max. Allowable
VOC
#1 Caterpillar
G3516B
N6W/4EK00075 1,380 1.52 lbs/hr,
41 ppm @ 15% O2
1.37 lbs/hr,
61 ppm @ 15% O2
2.13 lbs/hr,
60 ppm @ 15% O2
#2 Caterpillar
G3516B
JEF01814 1,380 1.52 lbs/hr,
41 ppm @ 15% O2
1.37 lbs/hr,
61 ppm @ 15% O2
2.13 lbs/hr,
60 ppm @ 15% O2
#3 Caterpillar G3516J N6W/JEF02569 1,380 1.52 lbs/hr,
41 ppm @ 15% O2
1.37 lbs/hr,
61 ppm @ 15% O2
2.13 lbs/hr,
60 ppm @ 15% O2
#5 Caterpillar G3516J N6W/JEF01780 1,379 1.52 lbs/hr,
41 ppm @ 15% O2
1.37 lbs/hr,
61 ppm @ 15% O2
2.13 lbs/hr,
60 ppm @ 15% O2

2.5.2 EPA 40 CFR 60, Subpart JJJJ

Unit
ID
Engine Make /
Model
HP NOx EPA
Standard
CO EPA
Standard
VOC EPA
Standard
#1 Caterpillar
G3516B
1,380 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
#2 Caterpillar
G3516B
1,380 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
#3 Caterpillar
G3516J
1,380 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
#5 Caterpillar
G3516J
1,379 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

The engines will be tested according to EPA 40 CFR 60, Subpart JJJJ §60.4244 for nitrogen
oxides (NOx), carbon monoxide (CO) and Volatile Organic Compounds (VOC). The test reports
will show results in accordance with NSPS JJJJ Table 1 and Table 1 Footnote a. Footnote a
allows owners and operators of stationary engines to choose to comply with the NSPS JJJJ
standards in units of either grams per brake-horsepower hour (g/Bhp-hr) or units of parts per
million volume dry standardized to 15% oxygen (ppmvd @ 15% O2). Uinta Wax Operating,
LLC intends to demonstrate compliance on a g/BHp-hr basis with current EPA standards.

Emission Measurement Methodologies:

Three, one hour tests will be conducted on each engine according to EPA 40 CFR 60 (A),
Methods 1-3 & EPA 40 CFR 63 (A), Method 320 for NOx, CO, VOC (as NMNEHC C3) and
H2O. Each of the test runs will consist of readings taken at one (1) minute intervals. Oxygen
levels will be measured to allow for the correction to 15% O2. O2 & CO2 will be measured using
a Fyrite analyzer.

The MKS 2030 analyzer will be operated using a 0.5 cm-1, Medium Norton Beer Apodization
and 60 second averaging.

Based on the compounds that will be measured, the MKS 2030 analyzer has been configured in
the following manner, which is intended to cover all types of natural gas fired engines.

The MKS 2030 software provides a Natural Gas Method that is designed to minimize all
expected interferences by removing the regions in the quant region where they are most absorbed
(i.e. picket fence approach). So, for example, all the water peaks that are greater than about 0.1
abs are removed from the quant region. Since the spectral noise measured (sample spectrum) is
in the range of 0.001 absorbance, it is desirable to have any error within this range. The MKS
software will match the water calibration spectrum to the sample spectrum at any 1 point in the
spectrum to about 1% precision. So, 1% of 0.1 absorbance is 0.001 abs. This is why any peaks
greater than this for interfering compounds are usually excluded so they do not interfere. To
summarize, the MKS software and the method are designed to minimize any interferences by
removing their largest interfering absorptions.

QA spiking procedures will be followed for pre and/or post testing. Various factors often make
determining the exact concentrations for spiking procedures indiscernible prior to testing, even if
the engine has been previously tested. Furthermore, it is infeasible to obtain and transport a
multitude of gas concentrations for varying analytes. Therefore, a mixed gas bottle with a high
enough concentration for multiple engines may be utilized during the spiking procedures. A
summary of all spiking procedures/results will be provided in the final test report.

The CO2 present in the native sample will be used as the tracer. There are two components that
make up the spike: 90% native and 10% spike. Both the native and spike are being added to the
gas cell and measured simultaneously. Since the CO2 concentration for most engines is very
stable during testing, the reduction in its concentration when a spike is applied can provide very
accurate prediction on the ratio of spike gas to engine emission.

The schematic for our sampling system, which is the same as the system provided in Method
320, is shown below.

The sampling system is used to draw the sample from the stack at an elevated temperature,
remove particulates and push the gas through a secondary heated line into the MKS 2030
analyzer to maintain correct pressure and temperature. There is no reduction in water
concentration or any other component.

Figure 1: Schematic of FTIR Sampling System.

The MKS Multigas 2030 FTIR system inherently converts the wet levels of NOx, CO & VOC to
dry levels and displays the dry levels to the Compliance Specialist(s) via a computer display. The
system is able to perform this conversion due to the FTIR also measuring the moisture content of
the effluent stream. Therefore, it is the dry levels that are typically logged.

Measurement of VOC (NMNEHC C3):

The algorithm currently used for NMNEHC C3 and developed for natural gas fired applications
by Dr. Spartz and MKS instruments in accordance with EPA standards, is the following:

(2.4*c8/(1+exp((2-c8)/0.2))+1.9*c11/(1+exp((2-c11)/0.2))+6*c12/(1+exp((0.5-c12)
/0.2))+2.85*c13/(1+exp((2-c13)/0.2))+3*c14/(1+exp((1-c14)/0.2)))/3

c8= acetylene
c11= ethylene
c12= hexane
c13= propylene
c14= propane

Note: The constants in front of each of the compounds listed represents the FID response factor
when calibrated with Propane.

As with any CEMS analyzer, the FTIR may demonstrate a negative zero bias. The “exp”
functions listed in the algorithm above are intended to mathematically filter out any negative
biases and set them to approach zero.

Engine/Compressor Operating Parameters:

Engine operating parameters, where applicable, will be recorded for each test which may include
engine rpm, air/fuel ratio setting(s), suction/discharge pressures, etc.

Engine Load Approximation:

Oasis Emission Consultants Inc. will approximate the engine load using the measured process
parameters, such as gas throughput, suction/discharge pressure/temperature; by correlating the
intake manifold conditions with the engine manufacture heat balance data; the engine load; or,
the engine load obtained from the engine control panel.

Test Methods:

Oasis Emission Consultants, Inc. will employ EPA Method 320 for NOx, CO, VOC & H2O.
Oxygen and CO2 levels in the exhaust stream will be monitored through the use of a Fyrite
analyzer, concurrently with each FTIR test. All test methods that we intend to utilize are listed
below.

 EPA 40 CFR 60 Appendix A, Method 1: Method 1 requires measurement of the various
physical attributes of a stack to establish appropriate sampling locations. An O2 stratification
check will be performed according to 8.1.2 of Method 7E prior to testing to determine
sampling location for engines with stack diameters greater than 6 inches, but less than 12
inches. For stacks equal to or greater than 12 inches in diameter, if the sampling port
locations meet the minimum Method 1 criterion for distance from disturbances, sampling
may be conducted at three points. If sampling ports do not meet Method 1 criterion for
distance from disturbances, stacks equal to or greater than 12 inches in diameter will have an
O2 stratification check performed to determine sampling locations. An O2 stratification is not
required for engines with a stack diameter less than 4 inches.
 EPA 40 CFR 60 Appendix A, Method 2: Method 2 provides the means to calculate the
average wet velocity for the exhaust effluent gas. This method employs the use of a standard
or S-type pitot tube, a thermometer and an inclined manometer. The temperature, static &
differential pressures are all used to calculate the average wet velocity. This value may be
used in conjunction with the known stack diameter, and measured moisture content, to
approximate the average dry volumetric flow rate.
 EPA 40 CFR 60 Appendix A, Method 3: Method 3 provides the means to calculate the dry
molecular weight of the effluent gas. After passing through a gas condenser, O2 & CO2 gas
concentrations from the effluent stream are measured by a Fyrite analyzer. Measurements
will be taken in conjunction with those from Method 2. The dry molecular weight will be
calculated for each of the test runs. The O2 levels will also be used to allow for the correction
to ppm @ 15% O2.
 EPA 40 CFR 63 Appendix A, Method 320: NOx, CO, VOC & H2O concentrations are
obtained by running the engine exhaust through a heated sample line (191 deg C) to an MKS
2030 FTIR analyzer. When a gas sample is introduced in the gas cell, the infrared beam is
partially absorbed by the gas species present. The spectral frequencies absorbed and their
intensity are due to the atoms associated with the chemical bond and the strength of that
bond. The absorption spectrum is unique for each infrared-active gas. The MKS FTIR
analyzer measures the absorption spectrum, and its analysis algorithm measures the
concentration of each gas using pre-loaded calibrations. The MG2000 software allows for the
continuous measurement, display and recording of the sample stream.

Utah Department of Environmental Quality
Division of Air Quality
Compliance Test Protocol

Approval Order # DAQE-AN159380002-23
and EPA 40 CFR 60, Subpart JJJJ

Engine: (1) Caterpillar G3516J
Unit ID: #4

Uinta Wax Operating, LLC
North Randlett Compressor Station,
Uintah County, Utah

May 17, 2024

Prepared By:

Oasis Emission Consultants, Inc.
2730 Commercial Way
Rock Springs, WY 82901

1.0 INTRODUCTION

The purpose of this document is to provide relevant information pertaining to proposed source
emission testing for Uinta Wax Operating, LLC by Oasis Emission Consultants, Inc.

Approval Order No.: DAQE-AN159380002-23

Federal Regulation: EPA 40 CFR 60, Subpart JJJJ

Facility/ Location: North Randlett Compressor Station (Site ID: 15938)
The facility is located five (5) miles west of Randlett, in
Uintah County, Utah.
UTM Coordinates: 593,702 m Easting, 4,453,005 m Northing
UTM Zone 12

Emission Source: Unit ID: #4 – (1) Caterpillar G3516J
The natural gas fired Caterpillar G3516J 4SLB compressor
engine is rated at 1,380 hp and is subject to the requirements
listed in NSPS JJJJ.
1.1 TEST PROGRAM ORGANIZATION

Client: Uinta Wax Operating, LLC

Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Contact: Josh Morgan, Operations Tech
Email: [e-mail]
Cell.: [phone]

Test Company: Oasis Emission Consultants, Inc.

Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Christopher Knott, P.Eng., Director, Engineering & Operations
Phone: [phone] Fax: [phone]

State Authority: Utah Department Of Environmental Quality

Address: PO Box 144820
Salt Lake City, UT 84114-4820
Contact: Rik Ombach, Minor Source Compliance Manager
Email: [e-mail]
Phone: [phone]

Stack Test Report Submission:
https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh
1.2 TEST PROJECT OBJECTIVE(S)

The purpose of performing source emission testing is to satisfy the requirements set out by NSPS
JJJJ and UDEQ Approval Order # DAQE-AN159380002-23.
2.0 SOURCE TEST PROGRAM DESCRIPTION

2.1 Test Contractor

All source emission tests will be performed by Oasis Emission Consultants, Inc., based out of
Rock Springs and Sheridan, Wyoming. Processed test results and all raw data captured during
the tests are forwarded to Chris Knott, P.Eng., Director of Engineering and Operations and/or
Charles Chapman, Manager of Technical Services, for quality control and data checking. Once
approved, tests are forwarded to the client.

2.2 Test Date

The unit will be tested by Oasis Emission Consultants, Inc. during the June 18th – 21st, 2024 test
campaign.
2.3 Report Date

The compliance test report will be submitted no later than 60 days following the compliance test.

2.4 Emission Source Description

A summary of the unit to be tested is provided below:

UDEQ APPROVAL
ORDER #
UNIT ID ENGINE HP RICE
CONFIGURATION
ENGINE
MANUFACTURE
DATE
DAQE-AN159380002-23 #4 Caterpillar
G3516J
1,380 4SLB 3/30/2012

2.5 Testing Methodology and Procedures

Emission Source Limitations:

The source will be tested according to methodologies described in this protocol. Any emission
levels which, based on averaged levels, exceed the limitations listed will be flagged in the test
report(s). Relevant information is provided in the tables below.

2.5.1 UDEQ Approval Order # DAQE-AN159380002-23

Unit
ID
Engine Make /
Model
Engine S/N HP Max. Allowable
NOx
Max. Allowable
CO
Max. Allowable
VOC
#4 Caterpillar
G3516J
JEF01637 1,380 1.52 lbs/hr,
41 ppm @ 15% O2
1.37 lbs/hr,
61 ppm @ 15% O2
2.13 lbs/hr,
60 ppm @ 15% O2

2.5.2 EPA 40 CFR 60, Subpart JJJJ

Unit
ID
Engine Make /
Model
HP NOx EPA
Standard
CO EPA
Standard
VOC EPA
Standard
#4 Caterpillar
G3516J
1,380 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

The engine will be tested according to EPA 40 CFR 60, Subpart JJJJ §60.4244 for nitrogen
oxides (NOx), carbon monoxide (CO) and Volatile Organic Compounds (VOC). The test report
will show results in accordance with NSPS JJJJ Table 1 and Table 1 Footnote a. Footnote a
allows owners and operators of stationary engines to choose to comply with the NSPS JJJJ
standards in units of either grams per brake-horsepower hour (g/Bhp-hr) or units of parts per
million volume dry standardized to 15% oxygen (ppmvd @ 15% O2). Uinta Wax Operating,
LLC intends to demonstrate compliance on a g/BHp-hr basis with current EPA standards.

Emission Measurement Methodologies:

Three, one hour tests will be conducted on the Caterpillar G3516J engine according to EPA 40
CFR 60 (A), Methods 1-3 & EPA 40 CFR 63 (A), Method 320 for NOx, CO, VOC (as
NMNEHC C3) and H2O. Each of the test runs will consist of readings taken at one (1) minute
intervals. Oxygen & CO2 will be measured using a Fyrite analyzer.

The MKS 2030 analyzer will be operated using a 0.5 cm-1, Medium Norton Beer Apodization
and 60 second averaging.

Based on the compounds that will be measured, the MKS 2030 analyzer has been configured in
the following manner, which is intended to cover all types of natural gas fired engines.

The MKS 2030 software provides a Natural Gas Method that is designed to minimize all
expected interferences by removing the regions in the quant region where they are most absorbed
(i.e. picket fence approach). So, for example, all the water peaks that are greater than about 0.1
abs are removed from the quant region. Since the spectral noise measured (sample spectrum) is
in the range of 0.001 absorbance, it is desirable to have any error within this range. The MKS
software will match the water calibration spectrum to the sample spectrum at any 1 point in the
spectrum to about 1% precision. So, 1% of 0.1 absorbance is 0.001 abs. This is why any peaks
greater than this for interfering compounds are usually excluded so they do not interfere. To
summarize, the MKS software and the method are designed to minimize any interferences by
removing their largest interfering absorptions.

QA spiking procedures will be followed for pre and/or post testing. Various factors often make
determining the exact concentrations for spiking procedures indiscernible prior to testing, even if
the engine has been previously tested. Furthermore, it is infeasible to obtain and transport a
multitude of gas concentrations for varying analytes. Therefore, a mixed gas bottle with a high
enough concentration for multiple engines may be utilized during the spiking procedures. A
summary of all spiking procedures/results will be provided in the final test report.

The CO2 present in the native sample will be used as the tracer. There are two components that
make up the spike: 90% native and 10% spike. Both the native and spike are being added to the
gas cell and measured simultaneously. Since the CO2 concentration for most engines is very
stable during testing, the reduction in its concentration when a spike is applied can provide very
accurate prediction on the ratio of spike gas to engine emission.

The schematic for our sampling system, which is the same as the system provided in Method
320, is shown below.

The sampling system is used to draw the sample from the stack at an elevated temperature,
remove particulates and push the gas through a secondary heated line into the MKS 2030
analyzer to maintain correct pressure and temperature. There is no reduction in water
concentration or any other component.

Figure 1: Schematic of FTIR Sampling System.

The MKS Multigas 2030 FTIR system inherently converts the wet levels of NOx, CO & VOC to
dry levels and displays the dry levels to the Compliance Specialist(s) via a computer display. The
system is able to perform this conversion due to the FTIR also measuring the moisture content of
the effluent stream. Therefore, it is the dry levels that are typically logged.

Measurement of VOC (NMNEHC C3):

The algorithm currently used for NMNEHC C3 and developed for natural gas fired applications
by Dr. Spartz and MKS instruments in accordance with EPA standards, is the following:

(2.4*c8/(1+exp((2-c8)/0.2))+1.9*c11/(1+exp((2-c11)/0.2))+6*c12/(1+exp((0.5-c12)
/0.2))+2.85*c13/(1+exp((2-c13)/0.2))+3*c14/(1+exp((1-c14)/0.2)))/3

c8= acetylene
c11= ethylene
c12= hexane
c13= propylene
c14= propane

Note: The constants in front of each of the compounds listed represents the FID response factor
when calibrated with Propane.

As with any CEMS analyzer, the FTIR may demonstrate a negative zero bias. The “exp”
functions listed in the algorithm above are intended to mathematically filter out any negative
biases and set them to approach zero.

Engine/Compressor Operating Parameters:

Engine operating parameters, where applicable, will be recorded for each test which may include
engine rpm, air/fuel ratio setting(s), suction/discharge pressures, etc.

Engine Load Approximation:

Oasis Emission Consultants Inc. will approximate the engine load using the measured process
parameters, such as gas throughput, suction/discharge pressure/temperature; by correlating the
intake manifold conditions with the engine manufacture heat balance data; the engine load; or,
the engine load obtained from the engine control panel.

Test Methods:

Oasis Emission Consultants, Inc. will employ EPA Method 320 for NOx, CO, VOC & H2O.
Oxygen and CO2 levels in the exhaust stream will be monitored through the use of a Fyrite
analyzer, concurrently with each FTIR test. All test methods that we intend to utilize are listed
below.

 EPA 40 CFR 60 Appendix A, Method 1: Method 1 requires measurement of the various
physical attributes of a stack to establish appropriate sampling locations. An O2 stratification
check will be performed according to 8.1.2 of Method 7E prior to testing to determine
sampling location for engines with stack diameters greater than 6 inches, but less than 12
inches. For stacks equal to or greater than 12 inches in diameter, if the sampling port
locations meet the minimum Method 1 criterion for distance from disturbances, sampling
may be conducted at three points. If sampling ports do not meet Method 1 criterion for
distance from disturbances, stacks equal to or greater than 12 inches in diameter will have an
O2 stratification check performed to determine sampling locations. An O2 stratification is not
required for engines with a stack diameter less than 4 inches.
 EPA 40 CFR 60 Appendix A, Method 2: Method 2 provides the means to calculate the
average wet velocity for the exhaust effluent gas. This method employs the use of a standard
or S-type pitot tube, a thermometer and an inclined manometer. The temperature, static &
differential pressures are all used to calculate the average wet velocity. This value may be
used in conjunction with the known stack diameter, and measured moisture content, to
approximate the average dry volumetric flow rate.

 EPA 40 CFR 60 Appendix A, Method 3: Method 3 provides the means to calculate the dry
molecular weight of the effluent gas. After passing through a gas condenser, O2 & CO2 gas
concentrations from the effluent stream are measured by a Fyrite analyzer. Measurements
will be taken in conjunction with those from Method 2. The dry molecular weight will be
calculated for each of the test runs.
 EPA 40 CFR 63 Appendix A, Method 320: NOx, CO, VOC & H2O concentrations are
obtained by running the engine exhaust through a heated sample line (191 deg C) to an MKS
2030 FTIR analyzer. When a gas sample is introduced in the gas cell, the infrared beam is
partially absorbed by the gas species present. The spectral frequencies absorbed and their
intensity are due to the atoms associated with the chemical bond and the strength of that
bond. The absorption spectrum is unique for each infrared-active gas. The MKS FTIR
analyzer measures the absorption spectrum, and its analysis algorithm measures the
concentration of each gas using pre-loaded calibrations. The MG2000 software allows for the
continuous measurement, display and recording of the sample stream.