DAQ-2024-012035

1

DAQC-1234-24
Site ID 4642 (B4)

MEMORANDUM

TO: STACK TEST FILE – UINTA WAX OPERATING, LLC – Kendall Tribal 4-30-31-
3-1E-H3

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

FROM: Paul Bushman, Environmental Scientist

DATE: December 12, 2024

SUBJECT: Source: One (1) Ajax E-565; SN: 86520
Location: Remote location in Uintah County, UT
Contact: Karen Pratt: 720-990-9927
Tester: Alliance Technical Group, LLC
Site ID #: 4642
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol received December 10, 2024

On December 10, 2024, DAQ received a test notification for the testing of one (1) Ajax E-565 engine
located at Kendall Tribal 4-30-31-3-1E-H3 in Uintah County, UT. Testing will be performed the week of
January 13, 2025, to determine compliance with the emission limits found in Utah Administrative Code
R307-510-4 and 40 CFR 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 3A used to determine dry molecular weight of the gas stream: OK
4. RM 320 used to determine NOx, CO, and VOC emissions: OK

DEVIATIONS: No deviations stated in the protocol.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Uinta Wax Operating, LLC’s pretest protocol and test
notification.
Site Specific Test Plan

Uinta Wax Operating, LLC 978 Crescent Road Roosevelt, UT 84066

Kendall Tribal 4-30-31-3-1E-H3
Uintah, Utah
CAERS ID: 4642

Source to be Tested: (1) Ajax E-565
Proposed Test Date: Week of January 13, 2025
Project No. ECG-2025-0104 Prepared By Alliance Technical Group, LLC 701 W Commerce St Clinton, OK 73601
y Regulatory Information Regulatory Citation

Utah Administrative Code Rule R307-510-4 Standards EPA 40 CFR 60, Subpart JJJJ Standards Source Information
Source Name (1) Ajax E-565

Source ID SN 86520

Target Parameters NOx, CO, VOC
Contact Information
Test Location
Kendall Tribal 4-30-31-3-1E-
H3
Uintah, Utah
40.20224, -109.934

Uinta Wax Operating, LLC
978 Crescent Road
Roosevelt, UT 84066

Karen Pratt
[e-mail]
Regulatory Manager
720-990-9927
Test Company
Alliance Technical Group,
LLC
701 W Commerce St
Clinton, OK 73601

Tyler Frey
[e-mail]
[phone]

Aaron Medina
aaron.medina@alliancetg.c
om

Regulatory Agencies
Utah Department of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

USEPA Region 8
1595 Wynkoop Street
Denver, CO 80202
[e-mail]
Office of Enforcement, Compliance &
Environmental Justice
Alexis North
[e-mail]
[phone]

ECG-2025-0104 Uinta Wax Operating, LLC – Uintah, UT Page

Test Protocol
Table of Contents

RICE Compliance Testing General Protocol Page iii
TABLE OF CONTENTS

1.0 Testing Objective.......................................................................................................................................... 1-1
1.1 RICE Operating Condition for Testing .................................................................................................... 1-1
1.2 Safety Requirements ................................................................................................................................ 1-2
2.0 Summary of Test Program ............................................................................................................................ 2-1
2.1 Test Program Description ........................................................................................................................ 2-1
2.2 Process/Control System Parameters to be Monitored and Recorded ....................................................... 2-1
2.3 Sample Location ...................................................................................................................................... 2-2
2.4 Proposed Test Schedule ........................................................................................................................... 2-2
2.5 Test Programs and Procedures ................................................................................................................. 2-2
2.6 Emission Limits ....................................................................................................................................... 2-4
2.7 Test Report ............................................................................................................................................... 2-5
3.0 Testing Methodology .................................................................................................................................... 3-1
3.1 VFR Measurements .................................................................................................................................. 3-3
3.2 O2 Measurements ..................................................................................................................................... 3-3
3.3 BWS Measurements ................................................................................................................................. 3-3
3.4 NOx, CO, CO2, NMEHC, HCOH Measurements .................................................................................... 3-3
3.5 Gas Dilution System Certification ........................................................................................................... 3-4
3.6 Data Acquisition ...................................................................................................................................... 3-4
3.7 Operating Procedures ............................................................................................................................... 3-5
3.8 Example Calculations............................................................................................................................... 3-6
4.0 Quality Assurance Program .......................................................................................................................... 4-1
4.1 Continuous Emission Monitoring Analyzer Data Quality ....................................................................... 4-1
4.1.1 Calibration and Linearity Checks ............................................................................................................. 4-1
4.1.2 Drift Checks ............................................................................................................................................. 4-1
4.1.3 Other QA/QC Checks .............................................................................................................................. 4-1
4.2 Data Reduction, Validation and Reporting .............................................................................................. 4-1
4.2.1 Summary of EPA Method 320 ................................................................................................................. 4-2
4.2.2 Check detector linearity. .......................................................................................................................... 4-2
4.2.3 Collect a background spectrum. ............................................................................................................... 4-3
4.2.4 Collect a background spectrum. ............................................................................................................... 4-3
4.2.5 During testing ........................................................................................................................................... 4-3
4.2.6 Post-test calculations ................................................................................................................................ 4-4

Test Protocol
Table of Contents

RICE Compliance Testing General Protocol Page iv
LIST OF TABLES AND FITURES

Figure 1-1: Basic RICE Block Flow Diagram ........................................................................................................... 1-2
Figure 2-1: General Diagram – RICE Sample Port Location ................................................................................... 2-2
Table 2-1: Test Methodology ................................................................................................................................... 2-3
Table 2-2: Federal Emission Limits.......................................................................................................................... 2-4
Table 3-1: Source Testing Methodology .................................................................................................................. 3-1
Table 3-2: Instrument Summary ............................................................................................................................... 3-1
Figure 3-1: Sampling System Flow Diagram ........................................................................................................... 3-2

Test Protocol
Introduction

RICE Compliance Testing General Protocol Page 1-1
1.0 Testing Objective
Reciprocating internal combustion engines (RICE) are subject to EPA 40 CFR 60, Subpart JJJJ as well as facility
operating permits. This protocol covers testing to demonstrate compliance with these regulatory requirements.
Testing will include determining the concentrations and emission rates of nitrogen oxides (NOx), carbon monoxide
(CO), and non-methane-ethane hydrocarbons (NMEHC) from RICE. The emissions data will be evaluated against the
limits found in the most current version of the facility operating permit and the applicable federal standard.

1.1 RICE Operating Condition for Testing
Normal Operating Capacity (HP): > 90% of Maximum (+/- 10% of 100% load)
Testing Operational Rate (HP): > 90% of Maximum (+/- 10% of 100% load) at current site conditions.

If testing cannot be conducted at >90% of maximum load, the test will be completed at the maximum achievable load
at the site conditions on the day of testing.

According to the US EPA’s April 2, 2013, Implementation Question and Answer Document for National Emission
Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines and New Source
Performance Standards for Stationary Compression Ignition and Spark Ignition Internal Combustion Engines: “The
test should be conducted within 10% of the highest achievable load for the engine at the engine’s site conditions. If
operating conditions change such that the highest achievable load for the engine at the engine’s site conditions changes
and the original test load is not within 10% of the new highest achievable load, then the engine must be retested.”

Test Protocol
Introduction

RICE Compliance Testing General Protocol Page 1-2
Figure 1-1: Basic RICE Block Flow Diagram

1.2 Safety Requirements
Testing personnel will undergo site-specific safety training for all applicable areas upon arrival at the site. Alliance
personnel will have current OSHA or MSHA safety training and be equipped with hard hats, safety glasses with side
shields, steel-toed safety shoes, hearing protection, fire resistant clothing, and fall protection (including shock
corded lanyards and full-body harnesses). Alliance personnel will conduct themselves in a manner consistent with
Client and Alliance’s safety policies.

A Job Safety Analysis (JSA) will be completed daily by the Alliance Field Team Leader.

Test Protocol
Summary of Test Programs

RICE Compliance Testing General Protocol Page 2-1
2.0 Summary of Test Program
To satisfy the requirements of the EPA 40 CFR 60, Subpart JJJJ, the facility will conduct a performance test program
to determine the compliance status of each applicable RICE.
2.1 Test Program Description
Three (3) 60‐minute sampling runs will be conducted. Ambient temperature, relative humidity and barometric pressure
will be recorded at the beginning of each sampling run, the sample line temperature will be recorded on 15-minute
intervals.

• Emissions testing will be conducted on the exhaust of the RICE control device.
• Performance testing will be conducted at the maximum normal operation load for each RICE at current site
conditions.
• All efforts will be made to conduct and complete the scheduled emission testing from 7:00 a.m. to 7:00 p.m.
• The emissions test report will be submitted within 60 days of completion of the testing, or according to
conditions in the air permit.
2.2 Process/Control System Parameters to be Monitored and Recorded
Alliance and/or facility personnel will collect operational and parametric data at least once every 15 minutes during
the testing. The following list identifies the measurements, observations and records that will be collected during the
testing program:

• Engine Speed (RPM)
• Engine Load (%)
• Suction Pressure (PSI)
• Discharge Pressure (PSI)
• Engine Brake Work (HP-hr)
• Fuel Heating Value (Btu)
• Fuel Consumption Rate (scfh)
• Catalyst inlet temperature (°F)
• Catalyst outlet temperature (°F)
• ΔT across the catalyst (°F)
• ΔP across the catalyst (inches water)

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Summary of Test Programs

RICE Compliance Testing General Protocol Page 2-2
2.3 Sample Location
Sampling will be conducted at the control device exhaust for each RICE. Conformance with U.S. EPA Reference
Test Method 1 will be evaluated prior to initiating testing. The diagram below provides a general layout of the test
port location for a typical RICE.

Figure 2-1: General Diagram – RICE Sample Port Location

2.4 Proposed Test Schedule
All efforts will be made to conduct and complete the scheduled emission testing from 7:00 a.m. to 7:00 p.m. based on
the schedule identified in the test date notification.
2.5 Test Programs and Procedures
The following outlines the test procedures that will be used for the test program.
• Conduct stack measurements according to EPA Method 1.
• Ducts with diameters equal to or less than six inches will be sampled at the centroid of the duct.
Documentation of Method 1 measurements will be included in the test report for reference.
1. For ducts with diameters greater than six inches in diameter, AST plans to sample from a threaded port
or flanged fitting in accordance with Method 1 guidance. An EPA certified rake probe will be utilized
to negate the need for a manual stratification test.

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Summary of Test Programs

RICE Compliance Testing General Protocol Page 2-3
Table 2-1: Test Methodology
Test Location Parameter EPA Test Method Reported Value Number Duration of Test Run(s)
Outlet
Volumetric Flow Rate (VFR) 1 1-2 or 19 dscfh
3 / 1 hr
Oxygen (O2) 3A %
Carbon Dioxide (CO2) 320 %
Moisture (BWS) 320 %
NOx 320 ppmvd @ 15% O2
g/hp-hr
lb/hr
ton/yr 2
CO 320
NMEHC 320
HCHO 320
Ambient
Conditions
Temperature Vaisala oF
3 measurements Barometric Pressure Pressure Transducer in Hg
Relative Humidity Vaisala %

1. Alliance may elect to utilize the calculations in Method 19 to determine volumetric flow rate in lieu of Methods 1
and 2. If brake specific fuel consumption (BSFC) is available or the engine type, it will be used in the Method 19
calculations. If a current fuel analysis and fuel rate is available, it may be used in the Method 19 calculations. Example
calculations for each option are provided in Section 3.8.
2. Ton per year emissions data will be based on the lb/hr value at 8760 hours/year or other operating schedule as
specified in the permit.

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Summary of Test Programs

RICE Compliance Testing General Protocol Page 2-4
2.6 Emission Limits
The emission limits for each pollutant are listed below.

Table 2-2: EPA 40 CFR 60, Subpart JJJJ Standards According to the requirements of EPA 40, CFR 60 Subpart JJJJ § 60.4233(d), non-emergency stationary SI ICE
manufactured after July 1st, 2008, and rated between 25 hp and 100 hp must comply with the requirements of the
standards for field testing listed in 40 CFR § 1048.101(c). Under 40 CFR § 1048.101(c)(2) the HC + NOx standard
is 3.8 g/KW-hr (2.8 g/BHp-hr) and the CO standard is 6.5 g/kW-hr (4.8 g/BHp-hr). For natural gas-fueled engines,
owners and operators are not required to measure non-methane hydrocarbon emissions or total hydrocarbon
emissions to show that the engines meet the emission standards; that is, HC is assumed to equal zero.

Utah Administrative Code Rule R307-510-4 Standards

In accordance with the Utah Administrative Code Rule R307-510-4 from the Oil and Gas Industry: Natural Gas
Engine Requirements (510), testing will be conducted to show levels in units of HC+NOx and CO (as g/BHp-hr).

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Summary of Test Programs

RICE Compliance Testing General Protocol Page 2-5
Test Report
The final test report must be submitted within 60 days of the completion of the performance test and will include the
following information.
• Test Results Summary (TRS) Table – Summary table with results in comparison to applicable limit will be
noted. The first page of the test report shall be a Test Results Summary (TRS).
• Introduction – Brief discussion of project scope of work and activities.
• Certification Statement – Signed document stating that to the best of our knowledge, the source test report
has been checked for completeness, and the results presented herein are accurate, error-free, legible, and
representative of the actual emissions measured during testing.
• Results and Discussion – A summary of emission and process operational data with comparison to
regulatory requirements along with a description of process conditions and/or testing deviations that may
have affected the testing results.
• Methodology – A description of the sampling and analytical methodologies. All applicable reference
method sampling procedures and process operations will be cited without any changes to the way they were
proposed in the protocol.
• Method Deviations – All deviations from the approved reference method sampling and process operations
will be clearly summarized. A brief, but thorough, justification for each deviation must be provided.
• Field Data – Copies of actual handwritten/electronic field data sheets and/or analyzer data.
• Quality Control Data – Copies of all instrument calibration data and/or calibration gas certificates.
• Process Operating/Control Data – Process descriptions, operating parameters, control system data. Other
pertinent process/control device data will be summarized on a run-to-run basis for each pollutant tested and
process condition.
• Illustrations – Drawing and/or diagrams of the emission point and sampling system(s) will be included.

Test Protocol
Testing Methodology

RICE Compliance Testing General Protocol Page 3-1
3.0 Testing Methodology
This section provides a description of the sampling and analytical procedures for each test method that will be
employed during the test program. All equipment, procedures and quality assurance measures necessary for the
completion of the test program meet or exceed the specifications of each relevant test method. The emission testing
program will be conducted in accordance with the test methods listed in Table 3-1.

Table 3-1: Source Testing Methodology
Parameter U.S. EPA Reference Test Methods Notes/Remarks
VFR 1-2 or 19 Full Velocity Traverses or F-Factor
Calculations
O2 3A Instrumental Analysis
CO2 320 FTIR Analysis
BWS 320 FTIR Analysis
NOx 320 FTIR Analysis
CO 320 FTIR Analysis
NNEHC 320 FTIR Analysis
HCHO 320 FTIR Analysis
Gas Dilution System Certification 205 --
Table 3-2: Instrument Summary
Analyte Instrument Range Target Calibration Gas Span
NOx /CO/CO2 Train 1 MKS 2030 FTIR 0‐10 ppm to 0‐100,000 ppm 100 ppm / 20%
O2 M & C PMA30 0‐1% / 0‐3% / 0‐10% / 0‐30% / 0‐100% 20%
NOx MKS 2030 0‐10 ppm to 0‐5,000 ppm 100 ppm
CO MKS 2030 0‐50 ppm to 0‐1,000 ppm 100 ppm
CH4 /NMNEHC MKS 2030 0‐10 ppm to 0‐100,000 ppm 1.5-2.5x the measured concentration

Test Protocol
Testing Methodology

RICE Compliance Testing General Protocol Page 3-2
Figure 3-2: Sampling System Flow Diagram

Test Protocol
Quality Assurance Program

RICE Compliance Testing General Protocol Page 3-3
3.1 VFR Measurements
Stack gas volumetric flow rate was determined using EPA Method 2. EPA Method 2 establishes volumetric flow rate
by measuring the average temperature and velocity of stack gas using a s type pitot.
3.2 O2 Measurements
Concentrations of O2 in the exhaust stack will be analyzed using an M&C oxygen analyzer. It will measure the
paramagnetic susceptibility of the sample gas by means of a magneto‐dynamic type measuring cell. The measuring
cell of the analyzers consists of a dumbbell of diamagnetic material, which is temperature controlled electronically at
50˚C. The higher the oxygen concentration, the greater the dumbbell is deflected from its rest position. This deflection
is detected by an optical system connected to an amplifier. Surrounding the dumbbell is a coil of wire. A current is
passed through this coil to return the dumbbell to its original position. The current applied is linearly proportional to
the percent oxygen concentration in the sample gas. This concentration is displayed on a digital panel meter.
3.3 BWS Measurements
Moisture (BWS) content will be measured using EPA Method 320. See Section 3.5.

Stack gas moisture content will be calculated based on the estimated formation of water as determined by the fuel
analysis and ambient humidity. These calculations are based on the measured fuel consumption rate, the specific
ambient humidity and the combustion products (based on EPA Method 19 calculations) plus the amount of oxygen
removed from the exhaust gas by the combustion reaction with hydrocarbons to form water (CH4+2 O2→CO2+2
H2O), as shown below:

%m = 100*[(VWF+VWA) / (VD+VWF+VWA)]

Where:
%m = stack gas moisture content, percent volume basis
VD = volume of dry combustion products
VWA = volume of water in combusted air (ambient humidity)
VWF = volume of water from combusted fuel
3.4 NOx, CO, CO2, BWS, NMEHC, HCOH Measurements
NOx, HCHO, CO, CO2 emissions and BWS content will be measured using an MKS 2030 FTIR multi‐gas analyzer
following EPA Method 320. The FTIR uses an infrared spectral‐reference library that has been validated against the
on‐line EPA library or against NIST traceable gas mixtures. A slipstream sample of exhaust gas will be analyzed
hot/wet during the entire duration of each run. An averaging time of 60 seconds will be observed.

NMNEHC (VOC) emissions may also be measured using an MKS FTIR multi‐gas analyzer following EPA Method
320. The FTIR uses an infrared spectral‐reference library that has been validated against the on‐line EPA library or
against NIST traceable gas mixtures. A slipstream sample of exhaust gas will be analyzed hot/wet during the entire
duration of each run. An averaging time of 60 seconds will be observed. The recipe being used can detect as followed

Test Protocol
Quality Assurance Program

RICE Compliance Testing General Protocol Page 3-4
acetaldehyde, acetylene, acrolein, benzene, butane, ethylene, formic acid, methanol, oil as octane, propylene, propane,
and isobutane for total VOC (as C3H8) value.

Formaldehyde (HCHO), Acetaldehyde, and Propane will be used as the spike recovery gases for the formaldehyde
and VOC determinations, to meet the requirements of EPA Method 320. These gases have been selected to ensure
that absorbance is measured for the spike gases in the same wavenumber regions as the target analytes. Testing will
be performed only when the spike recoveries meet the requirements specified in Method 320/ASTM D6348.

Formaldehyde (HCHO) will be used as the spike recovery gas for the formaldehyde determination, to meet the
requirements of EPA Method 320, assuming certified standards are available at appropriate concentrations to meet
the requirements specified in Method 320/ASTM D6348. A surrogate for the dynamic spike, required by Section
8.6.2, will not be accepted.

When utilizing Method 320 or ASTM Method D6348, all QA/QC data results, obtained while conducting the required
procedures, specified in Sections 8.6.2, 9.0 and 13.0, must be included in the test report. Additionally, provide a
separate FTIR Quality Assurance Validation Summary Table for each source tested. An example table is provided at
the end of this correspondence indicating the required fields/information and denoting a preferred format.

Sample lines will be selected to minimize transport distance. Each line will be suspended to ensure that there are no
upward or horizontal sections where condensation can accumulate. This includes ensuring the sample line does not
dip to the ground before reaching the analyzer.
3.5 Gas Dilution System Certification
A calibration gas dilution system field check will be conducted in accordance with U.S. EPA Reference Method 205.
Multiple dilution rates and total gas flow rates will be utilized to force the dilution system to perform two dilutions on
each mass flow controller. The diluted calibration gases will be sent directly to the analyzer, and the analyzer response
recorded in an electronic field data sheet. The analyzer response must agree within 2% of the actual diluted gas
concentration. A second Protocol 1 calibration gas, with a cylinder concentration within 10% of one of the gas divider
settings described above, will be introduced directly to the analyzer, and the analyzer response recorded in an
electronic field data sheet. The cylinder concentration and the analyzer response must agree within 2%. These steps
will be repeated three (3) times.
3.6 Data Acquisition
The data acquisition system will consist of a Perma Pure 4300 FCD data collector and a desktop computer. The 4300
FDC scans the instrument output and logs digitized voltages. It translates the digitized voltages into relevant
concentrations in engineering units (ppm, %, etc.). The computer program has several modes of operation: calibration,
data acquisition and data view. A printout of the 60 second averages will be generated on‐line. Calibration data will
also be printed and stored on a third-party data server. The calculated concentration data will be stored on a third-party
data server as a back‐up. At the end of the test run, the test run averages will be generated for each pollutant and
printed by the system. The 3 run total average will be determined from the 3 test runs results

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Quality Assurance Program

RICE Compliance Testing General Protocol Page 3-5
3.7 Operating Procedures
Special calibration and quality control procedures will be followed at the beginning of testing. These are detailed in
Section 4 of this test protocol. The following detailed procedure will be used daily for calibrating and operating the
CEMS system.
1. Turn on data acquisition system (DAS) computer and printer and load data acquisition program. Turn on
the gas conditioner and drain the refrigerated traps. 2. Open all calibration gas cylinders so that the gases can be introduced to the instruments via control panel
valves. 3. Verify that the entire sampling train is up to temperature (191C). 4. Introduce nitrogen to the system to zero all instruments. Adjust the zero potentiometers as required to zero
the instruments. Be sure to check and maintain all flows throughout calibration and testing 5. Record the zero values in the computer calibration routine. 6. Introduce the O2, CO2 or NOx high‐level gas. 7. Make adjustments to the instrument as required and enter the value into the computer calibration routine. 8. Check the calibration table on the computer and make a hard copy. Put the computer on the standby mode. 9. Perform NOx converter check, by introducing NO2. 10. Perform a three-point calibration error check in the direct mode on the analyzer (passing at < ±2% of span)
and a low, mid and high gas calibration error for NMNEHC analyzer(s) (passing at < ±5% of span) at
beginning of the first run only (unless a bias or drift check fails). 11. Begin sampling stack gas, with the computer on standby. Confirm that F0 values are within the expected
range (1.600 – 1.836) and recheck calibration of O2 and CO2 analyzers if not. 12. Perform initial leak check of system. 13. Perform a two point (zero and mid or high calibration gas) initial system calibration bias check (during the
initial bias the response time should be done) in the system calibration mode (passing at < ±5%). 14. After pre‐conditioning for at least two times the system response time, the spike recovery process is
performed with NOx, CO, Propane, SF6, and HCHO. 15. Data collection is started for the appropriate sampling run length, carefully check all flows and pressures
during the operation of the instruments and watch for apparent problems in any of the instruments, such as
unusual readings or unreasonable fluctuations. Check the gas conditioning system periodically. 16. Stop the data acquisition system at the completion of the sampling run and data collection. 17. Perform the final leak check of system. 18. Post‐run two-point final system calibration bias check and run drift calculated from pre and post‐ system
bias (passing at < ±3%). The post‐run bias can be used as the pre‐run bias of the next run

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Quality Assurance Program

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3.8 Example Calculations
Stack Volumetric Flow Rate (Qs), dscfh
060.1 +



−×××
=E
O20.9
20.9FFF
Qs 2FactorHVR

where,
FR = fuel rate, scfh FHV = fuel heating value, Btu/scf
FFactor = fuel factor for natural gas, 8,710 dscf/MMBtu (default) O2 = oxygen concentration, %
Stack Gas Volumetric Flow Rate (Qs), dscfm

where,
HP = engine brake work, horse-power-hour
BSFC = brake specific fuel consumption, Btu/hp-hr
Fd = fuel factor for natural gas, 8,710 dscf/MMBtu (default)
CO2 = oxygen concentration, %
Qs = dscfm

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Quality Assurance Program

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Nitrogen Oxides Concentration @ 15% Oxygen (CNOxc15), ppmvd @ 15% O2

where,
CNOx = NOx concentration, ppmvd
CO2 = O2 concentration, %
CNOxc15 = ppmvd @ 15% O2

Nitrogen Oxides Emission Rate (ERNOx), lb/hr

where,
CNOx = NOx concentration, ppmvd
MW = NOx (as NO2) molecular weight, g/g-mole
Qs = stack gas volumetric flow rate at standard conditions, dscfm
ERNOx = lb/hr

Nitrogen Oxides Emission Rate (ERNOxTPY), ton/yr

where,
ERNOx = NOx emission rate, lb/hr
ERNOxTPY = ton/yr

Nitrogen Oxides Emission Factor (EFNOx), g/hp-hr

where,
ERNOX = NOx emission rate, lb/hr
EBW = engine brake work, HP
EFNOX = g/HP-hr

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Quality Assurance Program

RICE Compliance Testing General Protocol Page 3-8

Carbon Monoxide Concentration @ 15% Oxygen (CCOc15), ppmvd @ 15% O2

where,
CCO = CO concentration, ppmvd
CO2 = O2 concentration, %
CCOc15 = ppmvd @ 15% O2

Carbon Monoxide Emission Rate (ERCO), lb/hr

where,
CCO = CO concentration, ppmvd
MW = CO molecular weight, g/g-mole
Qs = stack gas volumetric flow rate at standard conditions, dscfm
ERCO = lb/hr

Carbon Monoxide Emission Rate (ERCOTPY), ton/yr

where,
ERCO = CO emission rate, lb/hr
ERCOTPY = ton/yr

Carbon Monoxide Emission Factor (EFCO), g/hp-hr

where,
ERCO = CO emission rate, lb/hr
EBW = engine brake work, HP
EFCO = g/HP-hr

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Quality Assurance Program

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NMEHC Concentration @ 15% Oxygen (CNMEHCc15) (as C3H8), ppmvd @ 15% O2

where,
CNMEHC = NMHC concentration (as C3H8), ppmvd
CO2 = O2 concentration, %
CNMEHCc15 = ppmvd @ 15% O2

NMEHC Compounds Rate (ERNMEHC) (as C3H8), lb/hr

where,
CNMEHC = NMEHC concentration (C3H8), ppmvd
MW = molecular weight, g/g-mole
Qs = stack gas volumetric flow rate at standard conditions, dscfm
ERNMEHC = lb/hr

NMEHC Emission Rate (ERNMEHCTPY) (as C3H8), ton/yr

where,
ERNMEHC = NMEHC emission rate (C3H8), lb/hr
ERNMEHCTPY = ton/yr

NMEHC Emission Factor (EFNMEHC) (as C3H8), g/HP-Hr

where,
ERNMEHC = NMEHC emission rate (as C3H8), lb/hr
EBW = engine brake work, HP
EFNMEHC = g/HP-hr
While utilizing Method 320 for VOC determination, a list of VOCs used in reporting the VOC results will be
included, along with a screenshot of the actual algebraic formula used to calculate the VOCs.

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Quality Assurance Program

RICE Compliance Testing General Protocol Page 4-1

4.0 Quality Assurance Program
Alliance follows the procedures outlined in the Quality Assurance/Quality Control Management Plan to ensure the
continuous production of useful and valid data throughout the course of this test program. The QC checks and
procedures described in this section represent an integral part of the overall sampling and analytical scheme.
Adherence to prescribed procedures is quite often the most applicable QC check.
4.1 Continuous Emission Monitoring Analyzer Data Quality
Continuous monitoring for NOx, CO, NMNEHC, HCHO, O2 and CO2 will be performed using the instruments
discussed in Section 3.0, above. QA/QC procedures for all instrumental analyzers are identical. The primary control
check for the analyzers is an analysis of accuracy following calibration standards as described in the applicable EPA
methodology, on a per‐test basis. The calibration gases will be introduced upstream of the sample conditioning system
for the first calibration per unit and directly to the sampling manifold for the remaining checks. EPA Protocol 1 quality
gases will be used for all calibrating procedures.
4.1.1 Calibration and Linearity Checks
Analyzer calibration will be performed at least once each test day. Analyzer response for NO, O2, CO2 and CO will
be set using the zero and high‐level span gases. Subsequent response to the mid‐level calibration gases must be within
2.0% of the span value.
4.1.2 Drift Checks
At the beginning and end of each test run, zero and mid‐level span gases will be introduced into the instruments. Drift
for each test will be determined using the results of the pre‐test and post‐test calibration checks. Drift must be within
3.0% (5.0% of certified concentration for NMNEHC) of the span value for each test run.
4.1.3 Other QA/QC Checks
A sampling system leak check will be conducted at the beginning of the day, and immediately following each sampling
run, the sampling system must hold a vacuum greater than the highest vacuum induced on the system during the test
run with less than 1 “H2O loss over 60 seconds. A sampling system bias check will be conducted once per day. The
response must be within 5.0% of the span value. Once per unit, a sample system response time will be established.
The test run will not begin until more than two (2) times the system response time has elapsed after the start of
sampling.

4.2 Data Reduction, Validation and Reporting
All data and/or calculations for flow rates and moisture concentrations will be made using a computer spreadsheet.
Calculated data will be validated by independent checks. The independent checks will consist of a pre‐determined
data set being input into the spreadsheet variables. The output values will have been pre‐calculated following EPA
equations and accepted calculations, with the results of the pre‐ determined data set being known, this will confirm
proper function of the spreadsheets. All calculations performed by hand will receive independent spot‐check reviews
for accuracy and completeness on‐site and again with the drafting of the report. All measurement data will be validated

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based on adherence to appropriate sample collection procedures, adherence to appropriate QA/QC procedures, and
stable and representative process operating conditions during sampling and testing.

4.2.1 Summary of EPA Method 320
Establish the test requirements.

Verification of proper validation of measurement system and quantification algorithm for all detected VOC for this
source category will be included in the test report. Rich-burn verses lean-burn and 4-stroke verses 2-stroke will be
considered different source categories.

Determine the detection limit (DL) required for the test and the errors or analytical uncertainties (AU) acceptable at
or near this detection limit.

All constituents in the VOC recipe will, at a minimum, be reported as the MAU/MDC as stated in Sections 1.3-1.4 of
Method 320.

a) Measure system noise and MAU/MDL
System noise is determined by measuring two successive single beam spectra at minimal integration time (15 seconds)
while the cell is purged with pure N2. The short integration time is to assure that there is no change in the sample or
system purge during measurements. The absorbance spectrum, resulting from using one of the single beams as
background to the other, will then contain predominantly system noise since the spectral features will mostly cancel.
Noise is then determined by measuring the Peak‐to‐peak and RMS absorbance noise at approximately 2450 to 2550
cm‐1and 900 to 1000 cm‐1. These regions should be free of dominant H2O or CO2 lines and should be reasonable
estimates of noise in the two dominant analysis regions. The 900 to 1000 cm‐1 region will have slightly larger noise
because of incomplete cancellation of H2O present in this region.
.Perform leak checks
Leak check both the sample system and the FTIR cell prior to any testing. For the sample system valve at the probe
and monitor total flow through the system. Method 320 calls for a flow of less than 200 ml/min with the probe closed
in order to pass. Testing the FTIR cell is important only for cells running at negative absolute pressure. In this case
pump the cell to as low a pressure as possible and measure the pressure rise over 2 minutes. For 301, the leak must be
less than 4% of the cell volume at the sampling pressure in order to pass. An alternative approach is to compute
percent‐dilution by:

% Dilution = Leak Rate (Torr/min)*Cell Volume(Liters)
Flow Rate(Liters/min)*Pressure(Torr)

Where the flow rate and the pressure in the denominator are the values to be used during routine testing.
4.2.2 Check detector linearity.
This is important only for quantum detectors (MCT, InSb etc.) and not for thermal detectors like the DTGS.
Linearization is done by verifying that there is no signal in the single beam beyond detector cutoff (say at 100 cm‐1
to 300 cm‐1) and that the zero line in the single beam at opaque regions (e.g. water and CO2 band centers) line up

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with the zero after detector cut‐off. The CAI 700 hardware has a linearization circuit built into the detector
preamplifier. This can be adjusted to provide linear response for the conditions of the test by following the CAI 700
linearization procedures.
4.2.3 Collect a background spectrum.
Prior to collecting the background, pump the cell to less than 5 mm of Hg and back fill with N2 or flush it with 10
volumes of pure N2. With pure N2 flowing at a moderate rate (1‐2 l/m), collect a background single‐ beam spectrum
with 1 minute (or longer) averaging time to get a high signal to noise spectrum.

Save this spectrum in the “Backgrounds” folder on the C‐drive. If necessary, generate a “synthetic Io” and save this
in the backgrounds folder as well. The background file in the CAI automatic collection software should then be set to
this file.
4.2.4 Collect a background spectrum.
Before any data is collected, collect a spectrum of the CTS gas. This is done by again pumping the system and
backfilling it or by flowing 10 volumes of the gas through the cell prior to collecting the final spectrum. In automated
systems, it is recommended that this be done by starting the flow of the CTS gas while acquiring data at a relatively
short acquisition time (~1 minute). This will assist in determining system response time below. If the reported
concentration for the CTS gas is then viewed in real time, when the concentration is clearly stable (not rising or falling)
the cell has reached equilibrium. A CTS spectrum should then be acquired at the averaging time to be used during
routine data collection. Formaldehyde will be used as the CTS gas. Perform Spiking. Formaldehyde at 50.0 ppm and
sulfur hexafluoride at 10.0 ppm with a balance of nitrogen should be spiked into the sample stream as close as possible
to the probe. This process is repeated for NOx/CO, and Propane at the bottle concentrations (3000ppm). The spikes
should be injected at no more than 20% of total flow and should produce an observable change in the ambient
concentrations. Independent spike samples (as determined from the system response time above) should be done with
independent periods of no spiking between each. If the source is varying slowly this is corrected for using the zero‐
spike levels before and after each analyte spike and fitting a regression line to the means of these periods. Method 320
requires that:

avg. spike value accepted spike value
4.2.5 During testing
During data collection, the baseline of the single beam spectra should be tracked to determine if there is any change
in the background or Io spectrum. If the baseline in non‐absorbing regions shifts by more than 5% a new background
or Io should be collected and the data for that period reanalyzed using MKS reprocessing software.

0.70

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4.2.6 Post-test calculations
The gas matrix (composition) should be checked by reviewing the spectra to make sure it is what was expected when
the analysis routine was developed. If compounds are present in analysis regions that can cause interference, these
must be added to the analysis routine before performing final data analysis. Perform a post‐test CTS spectrum. This
spectrum should be compared to that taken at the beginning of the test period. The concentrations reported for the
CTS gas should agree to within 5% to pass Method 320