DAQ-2024-005216

1

DAQC-204-24
Site ID 12901 (B4)
MEMORANDUM

TO: STACK TEST FILE – MID-AMERICA PIPELINE COMPANY – Lisbon Compressor
Station

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: February 29, 2024

SUBJECT: Source: Solar Saturn 20 Turbine Compressor Engine Units #1 – #3
Location: Lisbon CS, 30-miles SE of Moab, San Jaun County, UT
Contact: Patrick Abbot, 970-263-3016
Tester: Oasis Emission Consultants, Inc. Chris Knott, 307-382-3297
FRS Site ID #: UT0000004903700037
Permit #: AO DAQE-AN129010003-13 dated October 7, 2013
Subject: Review of Pretest Protocol dated February 29, 2024
________________________________________________________________________________________

On February 29, 2024, the DAQ received a pretest protocol for the Mid-America Pipeline Lisbon Compressor
Station - Solar Saturn 20 Turbine Compressor Engine Units #1 – #3. Testing will be performed on April 2-4,
2024, to demonstrate compliance with emission limits found in EPA 40 CFR 60, Subpart KKKK and permit
Condition II.B.2.b for VOC, CO, and NOX emissions.

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 concentrations of emissions; OK
6. RM 10 used to determine CO concentrations of emissions; OK
7. RM 25A/18 used to determine VOC concentrations of emissions: OK
DEVIATIONS: None.

CONCLUSION: The pretest protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

HPV: No.

ATTACHMENTS: Pretest protocol dated February 29, 2024

ENTERPRISE PRODUCTS PARTNERS L.P.
ENTERPRISE PRODUCTS HOLDINGS LLC
(General Partner)
ENTERPRISE PRODUCTS OPERATING LLC
P.O. BOX 4324 1100 LOUISIANA STREET
HOUSTON, TEXAS 77210-4324 HOUSTON, TEXAS 77002-5227
713.381.6500 www.enterpriseproducts.com
February 29, 2024
Via Website
Utah Department of Environmental Quality, Division of Air Quality
ATTN: Mr. Rob Leishman, Jr.- Air Quality Specialist
Permitting and Compliance Division
https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh
RE: Notification of Performance Testing
Mid-America Pipeline Company LLC
Lisbon Station Permit DAQE AN129010003-13
Engine: Solar Saturn 20 S/N 0468S71 Unit ID #1
Engine: Solar Saturn 20 S/N OHA13-S8310 Unit ID #2
Engine: Solar Saturn 20 S/N OHE13-S7678 Unit ID #3
Mr. Leishman,
Enterprise Products Operating LLC, operator for Mid-America Pipeline Company, LLC, is
providing notification of scheduled performance testing of three Solar Saturn 20 gas turbines
(Unit #1 S/N 0468S71, Unit #2 S/N OHA13-S8310 and Unit #3 S/N OHE13-S7678) in
accordance with DAQE-AN129010003-13 and 40 CFR 60 Subpart KKKK. Testing is scheduled
to be conducted between April 2nd and 3rd, 2024. A copy of the testing protocols is enclosed with
this notification.
Should you have any questions or require additional information, please contact Patrick Abbott,
Senior Field Environmental Scientist at [phone] or Brian Stone, Field Environmental
Manager at [phone].
Thank you,
Jon E. Fields
Director, Field Environmental
/bjm
Attachment

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

Approval Order # DAQE-AN129010003-13
& Federal Regulation: EPA 40 CFR 60, Subpart KKKK

Turbines: (2) Solar Saturn 20
Unit IDs: T1 & T3

Mid-America Pipeline Company, LLC
Lisbon Pump Station,
San Juan County, Utah

February 14, 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
emission testing for Mid-America Pipeline Company, LLC (MAPL) by Oasis Emission
Consultants, Inc.
1.1 TEST PROGRAM ORGANIZATION

Approval Order No.: DAQE-AN129010003-13

Federal Regulation: EPA 40 CFR 60, Subpart KKKK

Facility / Location: Lisbon Pump Station (Site ID: 12901)
5 miles E of Hwy. 160
30 miles SE of Moab
Moab, UT 84532

Client: Mid-America Pipeline Company, LLC (MAPL)
Address: 744 Horizon Ct., Ste 224
Grand Junction, CO 81506
Contact: Patrick Abbott, Senior Environmental Scientist
Email: [e-mail]
Phone: [phone]

Test Company: Oasis Emission Consultants, Inc.
Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Chris Knott, P.Eng., Director, Engineering & Operations
Phone: [phone] Fax: [phone]

Laboratory: MW Services1
Address: 1210 D Street
Rock Springs, WY 82901
Phone: [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 MW Services will only be utilized if Method 18 is deemed necessary to determine the Ethane concentration for the
measurement of VOC.
1.2 TEST PROJECT OBJECTIVE(S)

The purpose of performing source emission testing is to satisfy the requirements set out
by UDEQ Approval Order # DAQE-AN129010003-13 Conditions II.B.2.b, II.B.2.c and
40 CFR 60, Subpart KKKK (NSPS Subpart KKKK). Relevant information is provided in
the table below.

Unit ID Turbine Turbine S/N HP Max.
Allowable
NOx
Max.
Allowable
CO
Max.
Allowable
VOC
T1 Solar Saturn 20 0468S71 1,342 5.75 lbs/hr,
100 ppmdv @
15% O2
4.21 lbs/hr,
120 ppmdv @
15% O2
0.50 lbs/hr,
25 ppmdv @
15% O2
T3 Solar Saturn 20 OHE13-S7678 1,342 5.75 lbs/hr,
100 ppmdv @
15% O2
4.21 lbs/hr,
120 ppmdv @
15% O2
0.50 lbs/hr,
25 ppmdv @
15% O2
*The serial numbers will be included in the final reports, if currently unavailable.

The units will be tested according to EPA 40 CFR 60 (A), Methods 1-4, 7E, 10 & 25A, in
addition to the applicable procedures found in NSPS Subpart KKKK. Method 25A will
be conducted utilizing a THC Flame Ionization Analyzer equipped with a Hydrocarbon
Cutter per 40 CFR 1065.265. Method 18 may also be employed to account for Ethane
levels. Three, one hour tests will be conducted on each turbine for Oxides of Nitrogen
(NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC). Testing will be
conducted at the maximum achievable load per the requirements of Subpart KKKK.
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 turbines will be tested by Oasis Emission Consultants, Inc. during the April 2nd –
4th, 2024 test campaign.

2.3 Report Date

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

2.4 Testing Methodology and Procedures

Oasis Emission Consultants Inc. will approximate the turbine load using process
parameters measured, such as gas throughput, suction/discharge pressure/temperature,
manufacturer’s BSFC, panel reading or fuel measurement (if available).

Oasis Emission Consultants, Inc. will employ EPA 40 CFR 60 (A) methods as required
by UDEQ Approval Order # DAQE-AN129010003-13 Condition II.B.2.d and EPA 40
CFR 60, Subpart KKKK. These methods are described on the following page.

 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.
 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 (Method 4), to
approximate the average dry volumetric flow rate.
 EPA 40 CFR 60 Appendix A, Method 3A: Method 3A 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 an instrumental 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 15% O2.
 EPA 40 CFR 60 Appendix A, Method 4: Method 4 allows for the evaluation of
the moisture content within the effluent stream. A sample of the effluent stream is
extracted at a constant rate. The water is condensed from the stream through a
series of impingers surrounded by an ice bath. The total mass of the water
condensed and the total volume of gas measured are used to calculate the
moisture content within the exhaust effluent stream. Moisture content will be
calculated for each of the test runs.
 EPA 40 CFR 60 Appendix A, Method 7E: Method 7E is the instrumental
method for measuring the NOx concentration in the effluent stream. After passing
through a sample conditioning system, NOx concentration is measured by a
chemiluminescent gas analyzer. The analyzer is calibrated using EPA Protocol
G1 gas before and after each one hour test run.
 EPA 40 CFR 60 Appendix A, Method 10: Method 10 is the instrumental
method for measuring the CO concentration in the effluent stream. After passing
through a sample conditioning system, CO concentration is measured by a NDIR
gas analyzer. The analyzer is calibrated using EPA Protocol G1 gas before and
after each one hour test run.
 EPA 40 CFR 60 Appendix A, Method 25A: Non – Methane Hydrocarbons will
be measured on a hot-wet basis by using a Flame Ionization Analyzer equipped
with a Hydrocarbon Cutter. The FID analyzer will measure levels of both THC
and Methane. The NMHC levels are automatically measured and output by the
analyzer by subtracting the measured Methane levels from the Total Hydrocarbon
levels. This analyzer will be calibrated using EPA Protocol G1 Propane (C3) gas
before and after each one hour test.
 EPA 40 CFR 60 Subpart KKKK § 60.4400: Subpart KKKK regulates the
Nitrogen Oxide (NOx) and Sulfur Dioxide (SO2) pollutants. NOx will be
measured using Method 7E. A stratification check will be performed prior to
testing to determine sampling location according to EPA 40 CFR 60 Subpart
KKKK § 60.4400(a)(3)(ii)(B).

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

Approval Order # DAQE-AN129010003-13
& Federal Regulation: EPA 40 CFR 60, Subpart KKKK

Turbine: (1) Solar Saturn 20
Unit ID: T2

Mid-America Pipeline Company, LLC
Lisbon Pump Station,
San Juan County, Utah

February 14, 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
emission testing for Mid-America Pipeline Company, LLC (MAPL) by Oasis Emission
Consultants, Inc.
1.1 TEST PROGRAM ORGANIZATION

Approval Order No.: DAQE-AN129010003-13

Federal Regulation: EPA 40 CFR 60, Subpart KKKK

Facility / Location: Lisbon Pump Station (Site ID: 12901)
5 miles E of Hwy. 160
30 miles SE of Moab
Moab, UT 84532

Client: Mid-America Pipeline Company, LLC (MAPL)
Address: 744 Horizon Ct., Ste 224
Grand Junction, CO 81506
Contact: Patrick Abbott, Senior Environmental Scientist
Email: [e-mail]
Phone: [phone]

Test Company: Oasis Emission Consultants, Inc.
Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Chris 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 UDEQ Approval Order # DAQE-AN129010003-13 Conditions II.B.2.b, II.B.2.c and
40 CFR 60, Subpart KKKK. Relevant information is provided in the table below.

Unit ID Turbine Turbine S/N* HP Max.
Allowable
NOx
Max.
Allowable
CO
T2 Solar Saturn 20 OHA13-S8310 1,342 6.00 lb/hr,
100.0 ppmdv
@ 15% O2
4.38 lb/hr,
120.0 ppmdv
@ 15% O2
*The serial number will be included in the final report, if currently unavailable.

The unit will be tested according to EPA 40 CFR 60 (A), Methods 1-4, 7E & 10, in
addition to the applicable procedures found in Subpart KKKK. Three, one hour tests will
be conducted on this turbine for Oxides of Nitrogen (NOx) and Carbon Monoxide (CO).
Testing will be conducted at the maximum achievable load per the requirements of
Subpart KKKK.
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 turbine will be tested by Oasis Emission Consultants, Inc. during the April 2nd – 4th,
2024 test campaign.

2.3 Report Date

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

2.4 Testing Methodology and Procedures

Oasis Emission Consultants Inc. will approximate the turbine load using process
parameters measured, such as gas throughput, suction/discharge pressure/temperature,
manufacturer’s BSFC, panel reading or fuel measurement (if available).

Oasis Emission Consultants, Inc. will employ EPA 40 CFR 60 (A) methods as required
by UDEQ Approval Order # DAQE-AN129010003-13 Condition II.B.2.d and EPA 40
CFR 60, Subpart KKKK. These methods are described on the following page.

 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.
 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 (Method 4), to
approximate the average dry volumetric flow rate.
 EPA 40 CFR 60 Appendix A, Method 3A: Method 3A 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 an instrumental 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 15% O2.
 EPA 40 CFR 60 Appendix A, Method 4: Method 4 allows for the evaluation of
the moisture content within the effluent stream. A sample of the effluent stream is
extracted at a constant rate. The water is condensed from the stream through a
series of impingers surrounded by an ice bath. The total mass of the water
condensed and the total volume of gas measured are used to calculate the
moisture content within the exhaust effluent stream. Moisture content will be
calculated for each of the test runs.
 EPA 40 CFR 60 Appendix A, Method 7E: Method 7E is the instrumental
method for measuring the NOx concentration in the effluent stream. After passing
through a sample conditioning system, NOx concentration is measured by a
chemiluminescent gas analyzer. The analyzer is calibrated using EPA Protocol
G1 gas before and after each one hour test run.
 EPA 40 CFR 60 Appendix A, Method 10: Method 10 is the instrumental
method for measuring the CO concentration in the effluent stream. After passing
through a sample conditioning system, CO concentration is measured by a NDIR
gas analyzer. The analyzer is calibrated using EPA Protocol G1 gas before and
after each one hour test run.
 EPA 40 CFR 60 Subpart KKKK § 60.4400: Subpart KKKK regulates the
Nitrogen Oxide (NOx) and Sulfur Dioxide (SO2) pollutants. NOx will be
measured using Method 7E. A stratification check will be performed prior to
testing to determine sampling location according to EPA 40 CFR 60 Subpart
KKKK § 60.4400(a)(3)(ii)(B).