HomeMy WebLinkAboutDAQ-2025-0010841
DAQC-190-25
Site ID 10756 (B4)
MEMORANDUM
TO: STACK TEST FILE – NORTHWEST PIPELINE, LLC – Vernal Compressor
Station
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Paul Bushman, Environmental Scientist
DATE: February 19, 2025
SUBJECT: Sources: One (1) Caterpillar 3412 engine; Unit ID EG-1, and one (1) Solar Taurus
70 Model T-10302S turbine; Unit ID T2
Location: Uintah County, UT
Contact: Derek Forsberg: 801-584-6748
Tester: Emissions Science, Inc.
Site ID #: 10756
Permit/AO #: DAQE-AN107560012-24, dated January 9, 2024
Subject: Review of Pretest Protocol received February 18, 2025
On February 18, 2025, Utah Division of Air Quality (DAQ) received the protocol for the testing of One
(1) Caterpillar 3412 engine; Unit ID EG-1, and one (1) Solar Taurus 70 Model T-10302S turbine; Unit ID
T2 at Northwest Pipeline, LLC Vernal Compressor Station in Uintah County, UT. Testing will be
performed during the week of March 19-20, 2025, to determine compliance with the emission limits
found in 40 CFR Part 60 Subpart JJJJ and 40 CFR Subpart KKKK.
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 emissions: OK
7. RM 25A used to determine VOC emissions: OK
8. ASTM D6348-03 alternative method used to determine H2O content; O2, CO2, NOx,
and CO emissions: OK
2
DEVIATIONS: None.
CONCLUSION: The protocol appears to be acceptable.
RECOMMENDATION: Send protocol review and test date confirmation notice.
ATTACHMENTS: Northwest Pipeline, LLC pretest protocol and test notification.
E.S.I
Grand Junction, CO
Phone 970.628.4849 www.emissions-science.com
Emissions Testing Protocol & Source Test Plan
Northwest Pipeline LLC
Vernal Compressor Station Uintah County, Utah
40 CFR Part, 60 Subpart JJJJ Performance Testing for Emergency Generator
Facility Permit #
DAQE-AN0107560007-10
Source to be tested:
EG-1
Proposed Test Date: March 19, 2025
Protocol Prepared by: James Olinger Emissions Science, Inc.
1
Table of Contents
Introduction: …………………………….….. Page 2
Purpose of Test ……………………………... Page 2
Description of Plant ………………………… Page 2
Description of Sources ……………………... Page 2, 3
Operation of sources during test …….……… Page 3
Test Methods ……………………………….. Page 3 - 5
Detailed Test Procedure ……………………. Page 5, 6
Test Report …………………………………. Page 6, 7
Proposed Test Dates ………………………... Page 7
Contractor Supplied Equipment …….……… Page 7
Contact Personnel …………………………... Page 7
Appendices
Appendix 1 …………..Sample Calculations
Appendix 2 …………..Sample QA / QC Performance Checks
Appendix 3 …………..Sample System Schematics
Appendix 4 …………..Stack Diagram (2022 Data)
2
Source Test Plan
Introduction:
Northwest Pipeline LLC has contracted Emissions Science, Inc. (ESI) to perform EPA
approved reference method compliance emissions testing under Subpart JJJJ for an
emergency generator at the Vernal Natural Gas Compressor Station. The Vernal Facility
Permit # is, DAQE-AN0107560007-10 and the source is identified as, EG-1.
Purpose of Test:
The purpose of the test is to demonstrate compliance of the source under 40 CFR Part 60,
Subpart JJJJ. The testing will quantify pollutant concentrations from the exhaust stack of
one, reciprocating internal combustion engine. The source (EG-1) is an Emergency
Generator for generating electrical power and the testing will sample for concentrations
of; Carbon Monoxide (CO), Nitrogen Oxides (NOx) and VOC’s as Non-Methane Organic
Compounds (NMNEOC) or Non-Methane, Non-Ethane Organic Compounds (NMEOC).
Description of Plant:
The Vernal Compression Facility is located at 1025 E 7550 N near Vernal Utah. UTM
coordinates 641.300 m Easting & 4,492.000 m Northing UTM Zone 12 The site has an
approximate elevation of 6,100’ ASL. The facility is used to compress natural gas for
delivery into a natural-gas pipeline.
Description of Sources to be tested:
The source that will be tested under this source test plan is a natural gas-fired,
reciprocating, internal combustion engine (RICE). The compressor engine is a Caterpillar
3412 lean-burn source. The source is not equipped with an SCO catalyst system. This
source is equipped with Air / Fuel Ratio Controller and low-NOx combustor for
emissions controls.
Detailed Source Information:
One source at the Vernal Compressor Station will be tested using approved EPA test
methods.
3
Detailed Source Information (continued):
Caterpillar 3412 TA, Four-cycle, lean-burn (RICE). Plate Rated at 637 HP.
EG-1 and Serial # CTP02968. The source is equipped with an A/F Ratio controller
and a low-NOx combustor.
Operation of Sources during Testing Process:
This source will be tested for three, sixty-minute test runs at an operational engine load
that will equal or exceed 90% of site rated horsepower (or maximum achievable load on
the test date). The horsepower will be provided by Northwest Pipeline personnel and
operational parameters such as RPM’s, inlet manifold temperature and pressure and
electrical output in kW, Etc. are expected to be a part of the HP calculations. Other
parameters such as, site elevation, ambient temperature and pressure Etc. will also be
recorded during the testing program. As an alternative, E.S.I. technicians have the
capability to calculate HP’s with the Caterpillar Gas Engine Rating Pro (GERP) software
and this program may be used to calculate HP values.
It is the responsibility of NW Pipeline personnel to provide safe access to “hand-tight”
EPA compliant sample ports.
Test Methods:
ESI proposes the following EPA reference methods for this source test plan.
Note* The instrumental methods were updated by the EPA in the final rule which was
published on August 14th, 2006.
EPA Reference Method 1
Purpose: Establishing stack diameter and velocity traverse points.
Equipment: Measurement device and calculator.
Calculations: (See Appendix 1)
EPA Reference Method 3A
Purpose: Determination of Carbon Dioxide (CO2) & Oxygen (O2)
concentrations in exhaust gas.
Equipment: Instrumental Method using non-dispersive infra red (NDIR) for
continuous sampling of CO2 and a paramagnetic sensor for O2.
Calculations: (See Appendix 1)
4
Test Methods (continued):
EPA Reference Method 4
Purpose: Determination of Moisture Content in Stack Gases (Gravimetric).
Equipment: Sample probe, barometer, scale, moisture train in an ice-bath
(consisting of three glass impingers to capture moisture and a fourth impinger
containing a known quantity of silica gel used as a drying agent.) and a Method
5 sampling system containing the following components: system pump, flow
meter, thermocouple, vacuum gauge, dry gas meter.
Calculations: (See Appendix 1)
EPA Reference Method 7E
Purpose: Determination of Nitrogen Oxides (NOx) Emissions from Stationary
Sources.
Equipment: Instrumental Method using Chemiluminescence based technology
for continuous sampling of Nitrogen Oxides (NOx), Heated Sample Line
capable of keeping gas sample above the point of condensation (approximately
245 ° 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 NO2 convertor efficiency checks will be performed on the
analyzers.
Calculations: (See Appendix 1)
EPA Reference Method 10
Purpose: Determination of Carbon Monoxide (CO) Emissions from Stationary
Sources.
Equipment: Instrumental Method using NDIR for continuous sampling of
Carbon Monoxide, Gas Conditioning System, Sample Probe, System Pump,
Etc.
Calculations: (See Appendix 1)
EPA Reference Method 25A
Purpose: Determination of total Gaseous Organic Concentration using a Flame
ionization Analyzer equipped with a non-methane cutter (results expressed as
Propane.)
Equipment: Heated Flame Ionization Analyzer or FID equipped with GC
column for analysis and subtraction of methane and ethane, Heated Sample
Line, Particulate Filter. Calculations: (See Appendix 1)
5
Test Methods (continued):
ASTM D 6348-03 (Alternate Method for 3A, 4, 7E, & 10).
As an alternative, ESI may elect to use FTIR technology to determine
concentrations from for the analytes normally measured under EPA Methods
3A, 4, 7E & 10. The FTIR will not be used to measure VOC’s.
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. The site-specific safety plan for this facility will be reviewed and implemented.
All equipment will be assembled, allowed to reach operational temperature and inspected
for damage and correct assembly. The exhaust stack will be measured for proper sample
port locations 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. The analyzers will then be
challenged with EPA Protocol or NIST Gasses and calibrated to minimize potential drift
during the sampling process.
For methods 7E, 10 & 25A, the calibration error test, system bias check, system response
time check, interference check and NO2 => NO conversion efficiency test will be
completed prior to performing any stack sampling. Operational engine load will be
determined and if found acceptable, the sampling program will be initiated. Three, 60-
minute sample runs will be performed on the source detailed in this test protocol and will
be measured for NOx, CO and VOC concentrations.
If Method 4 is selected, a gas sample from the exhaust stack will be concurrently run
through a moisture train in an ice bath to gravimetrically remove the moisture and the dry
sample gas will be transported to a calibrated, dry gas meter to measure sampled flow in
cubic feet.
The moisture train will consist of four, glass impingers fitted with stainless-steel tubing
inserts. The first two impingers will be seeded with a small quantity of de-ionized water
and will be weighed and recorded. The third impinger will be dry and empty, weighed
and recorded. The fourth impinger will be seeded with a known quantity of silica gel as a
drying agent and will also be weighed and recorded.
6
Detailed Test Procedures (continued).
At the end of the sample period, all four impingers will be weighed and recorded to
determine the moisture gain from a known sample volume of stack gas to calculate the
stack moisture content as is required in EPA method 4.
Alternatively, the Gasmet DX-4000 FTIR may be used to measure stack moisture as
allowed under ASTM D-6348-03. ESI will adhere to all requirements listed under the
ASTM method if this analyzer is selected for the compliance testing. The QA/QC
requirements under Annexes 1-8 from ASTM D-6348-03 will be adhered to.
EPA methods 3A, 7E, and 10 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.
For the determination of VOC’s, a heated Flame Ionization Detector (FID) with a non-
methane cutter will be used to determine Total Hydrocarbons (THC) and methane to
measure VOC’s as NMNEOC under EPA Method 25A. Alternately, a FID with a GC
column will be used to quantify and subtract ethane & methane to determine NMNEOC
under ALT-106.
If the GC method is chosen, a gas sample from the exhaust stack will be injected into the
FID/GC with a positive displacement pump. After the separation of the C1 & C2
compounds, a back-flush technique will be used to measure any organic compounds C3 or
greater (as propane).
Test Report:
The test report will contain all relevant data necessary to demonstrate a complete and
accurate accounting of the testing program. The reported data will include a summary of
the test methods and results, diagrams and schematics of the sampling system and
exhaust stack, recorded field data, sample calculations used to obtain emission rates,
calibration gas certificates, analyzer calibration results and other QA/QC measurements
(such as; system bias and interference checks).
The collected data for NOx, CO and VOC data will be displayed in the report as a
concentration of parts per million (ppmvd) corrected to 15% O2 as indicated for
compliance under Subpart JJJJ with the pollutants corrected to 15% O2.
7
Test Report (continued):
The draft copy of the complete test report will be available three weeks after the
completion of the testing program and the final copy will be delivered within one
additional week upon final acceptance by the client.
Proposed Test Dates:
ESI proposes the following test date for this project.
March, 18, 2025 - Mobilization and equipment set-up at the Vernal Facility.
March 19, 2025 - Testing Source EG-1 starting at approximately 10:30 AM
Contractor Supplied Equipment:
Emissions Science, Inc. will supply all analysis equipment, tools and personnel necessary
for the scope of this project as is required under the test methods section found in this
document. ESI will further guarantee that all equipment and methods used in the testing
program will meet or exceed minimum requirements under all applicable test methods.
Contact Personnel:
Northwest Pipeline, LLC State of Utah,
295 Chipeta Way Department of Environmental Quality
Salt Lake City, UT 84108 1950 West North Temple
Mr. Derek Forsberg Salt Lake City, UT 84114
Environmental Specialist DAQ Compliance Division
(801) 584.6748 801.536.4129
Emissions Science, Inc.
635 19 ½ Road
Grand Junction, CO 81507
Mr. James Olinger
970.628.4849
Appendix 1
Test Method Calculation Examples
2
Sample Calculations for EPA Reference Method Tests
Note: As the calculations, formulae and unit conversions used for these test procedures are too
numerous to list, the following is a selection of the primary calculations used in the various methods.
EPA Reference Method 1
•Stack Diameter * Distance Percentage from Stack Wall
(Based on # of Traverse Points from Table F1-2)
EPA Reference Method 2
•Section 12.5: Molecular Weight of Stack Gas
Ms = Md (1 – Bws) + 18.0*Bws …Eq. 2-6
Where: Ms = Molecular weight of stack gas, wet basis… (lb/lb-mole) Md = Molecular weight of stack gas, dry basis
Bws = Water vapor in the gas stream proportion by volume
Section 12.6: Average Stack Gas Velocity
o KPCP√∙Pavg√(Ts(abs) / PsMs) …Eq. 2-7
•85.49 m/sec [(1b/1b-mole) (in. Hg) / (oR) (in. H20)]1/2
Where: Kp = Velocity equation constant.
Cp = Pitot tube coefficient, dimensionless
·Pavg = Average velocity head of stack gas… (in. H2O) Ts(abs) = Absolute stack temperature… (oR) Ps = Absolute stack pressure (Pbar + Pg)… (in. Hg) Ms = Molecular weight of stack gas, wet basis… (lb/lb-mole
•Section 12.7: Average Stack Gas Dry Volumetric Flow Rate
o Q = 3600 (1-Bws) Vs A[ Tstd Ps / Ts(abs) Pstd] …Eq. 2-8
Where: 3600 = Conversion Factor… (Sec/hr)
Bws = Water vapor in the gas stream proportion by volume
Vs = Average stack gas velocity… (ft/sec) A = Cross-sectional area of stack… (ft2) Tstd = Standard absolute temperature… (528 oR) Ts(abs) = Absolute stack temperature… (oR)
Pstd = Standard absolute pressure… (29.92 in. Hg)
3
Sample Calculations for EPA Reference Method Tests
EPA Reference Method 4
Dry Gas Volume:
Vm Y Pm Tstd Vm Pm Vm(std) = __________ = K4 Y ______ Eq 4-3 Pstd Tm Tm
Where: Vm(std) = Dry gas volume measured by the dry gas meter, corrected to standard conditions, dscm (dscf). Vm = Dry gas volume measured by dry gas meter, (dcf)
Y = Dry gas meter calibration factor.
Pm = Absolute pressure (for this method, same as barometric pressure) at the dry gas meter, (in. Hg). Tstd = Standard absolute temperature, 528 degrees R Pstd = Standard absolute pressure, 760 mm Hg Tm = Absolute temperature at meter, (R)
Moisture Content:
Vwstd
Bwo = ______ Vmstd + Vwstd
Where:
Bwo = Proportion by volume of water in the gas stream (dimensionless)
Vwstd =Volume of water in the gas sample (standard conditions) cu. Ft. Vmstd = Volume of gas sample through the dry gas meter (standard conditions)
4
Sample Calculations for EPA Reference Method Tests
EPA Method 7E
ER = Cd * 1.912 * 10-3 * Q * T __________________
Hp-hr Where: ER =Emission Rate of NOx in g/hp-hr Cd = Measured NOx concentration in parts per million by volume (ppmv).
1.912 x 10-3 = Conversion constant for ppm NOx to grams per standard cubic meter at 20 degrees
Celsius. Q = Stack gas volumetric flow 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 7E (Section 12.9) NO2 convertor oven efficiency
(NOx final – NOfinal)
EFFNO2 = ________________ X 100
(NOx peak – NOx final) EPA Method 10
ER = Cd * 1.164 * 10-3 * Q * T
__________________ Hp-hr Where: ER =Emission Rate of CO in g/hp-hr
Cd = Measured CO concentration in parts per million by volume (ppmv).
1.164 x 10-3 = Conversion constant for ppm CO to grams per standard cubic meter at 20 degrees Celsius. Q = Stack gas volumetric flow 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).
5
Sample Calculations for EPA Reference Method Tests
EPA Method 25A
ER = Cd * 1.833 * 10-3 * Q * T __________________
Hp-hr
Where:
ER =Emission Rate of VOC in g/hp-hr Cd = Measured VOC concentration measured as propane (ppmv). 1.833 x 10-3 = Conversion constant for ppm VOC measured as propane to grams per standard cubic meter at 20 degrees Celsius.
Q = Stack gas volumetric flow 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).
Note: E.S.I. may choose to substitute VOC’s with Non-Methane Hydrocarbon measurements (NMOC’s)
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.
Appendix 2
Sample QA/QC Performance Checks for Emissions Testing
Emissions Science, Inc
Quality Assurance / Quality Control Plan
(As noted and under the allowable tolerances in EPA method 7E)
¾ Verification of correct Calibration Gas Selection and check on expiration dates.
¾ Verification of heated sample line (above dew point of H2O) and thermocouple integrity.
¾ Use of non-reactive sample transport and probe material (stainless-steel, glass, PTFE).
¾ Complete system leak check.
¾ Analyzer Calibration Error Check (3-point linearity check).
¾ Sample system bias check.
¾ System Response Time.
¾ Analyzer Drift Assessment.
¾ NO2 => NO conversion test.
¾ System Purge Time.
¾ Stack stratification test or minimum sample time at each point.
¾ One-minute intervals for data recorder on sample run data (averaged at end of run).
¾ Post-test bias check.
¾ Calibration and run ‘raw’ data preserved as indelible record.
Appendix 3
Sample System Schematics
Emissions Science, Inc.
EPA Methods 2 & 4
Exhaust Stack with
sample ports
Leak-Free
Sample Pump
Moisture Train with ice bath and
"knock-out" impinger train
Sample Probe Pitot Lines
M-5 Meter Box with
vacumn gauge, dual-
inclined manometer,
bypass valves, Etc.
Vacumn
Line
Emissions Science, Inc
Emissions Science, Inc
Emissions Science, Inc.
4J Sample System Schematic
Exhaust Stack with sample ports
Calibration Gas Line
3/8" Heated
System manifold with pump, flow control
valves, overflow valve, Etc.
SRI 8610C
GC 3' Haysep Column (Off-site)
System Moisture Removal Manifold
& Particulate Filter
CAI 650 Chemi- Analyzer
C.A.I. ZRE NDIR
Analyzer System Data Recorder
Data Collection and calculation system
Certified
Calibration gas
Probe with particulate filter
Emissions Science, Inc.
FTIR Sample System Schematic
ASTM 6348-12
Exhaust Stack with sample ports
Calibration Gas Line
System manifold with
pump, flow control valves, overflow
valve, Etc.
FTIR Sample Conditioning &
Particulate Filter
Gasmet DX4000
FTIR
System Data Recorder & Software Certified
Calibration gas
Probe with
particulate filter
3/8" Heated
sample lineto 180 degrees
C
Emissions Science, Inc
EPA Reference Method 1
Velocity and Traverse Points
Client:Northwest Pipeline, LLC Stack DiagramSite:Vernal C.S.
Date:03/23/22 Stack Diameter (ID):8.25
Unit ID:EG-1 Downstream Disturbance:16
Stack ID:N/A Upstream Disturbance: 26
Stack Dia.8.25 Inches
Point #% of Stack Depth Measure (in.)Measure (cm)
1 0.032 0.50 1.27
2 0.105 0.87 2.20
3 0.194 1.60 4.07
4 0.323 2.66 6.77
5 0.677 5.59 14.19
6 0.806 6.65 16.89
7 0.895 7.38 18.75
8 0.968 7.75 19.69
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23 Point #NOx ppm Deviation Validity
24 16.7%283.88 0.1 YES
50.0%290.99 2.4 YESItalics indicate alternate point 83.0%277.75 2.3 YES
Avg.284.21 1.6 ☼
Stack Cross Section
Stratification Test
Muffler
SCO Catalyst
Gas Flow
Phone: 970.628.4849
Emissions Science, Inc.
4.Grand Junction, CO
E.S.I
Grand Junction, CO
Phone 970.628.4849 www.emissions-science.com
Emissions Testing Protocol & Source Test Plan
Northwest Pipeline LLC Vernal Compressor Station Uintah County, Utah 40 CFR Part, 60 Subpart KKKK &
Performance Testing for Stationary Combustion Turbines
Facility Permit # DAQE-AN0107560007-10 Source to be tested: T2
Proposed Test Dates: March 20th, 2025
Protocol Prepared by: James Olinger Emissions Science, Inc.
Table of Contents
Introduction: …………………………….….. Page 2
Purpose of Test ……………………………... Page 2
Description of Plant ………………………… Page 2
Description of source ……………………... Page 2, 3
Operation of source during test .…….……… Page 3
Test Methods ……………………………….. Page 3-5
Detailed Test Procedure ……………………. Page 6
Test Report …………………………………. Page 6, 7
Proposed Test Dates ………………………... Page 7
Contractor Supplied Equipment …….……… Page 7
Contact Personnel …………………………... Page 7, 8
Appendices
Appendix 1 …………..Sample Calculations
Appendix 2 …………..Sample QA / QC Performance Checks
Appendix 3 ………….. Sample Train Schematic
2
Source Test Plan
Introduction:
Northwest Pipeline LLC has contracted Emissions Science, Inc. (ESI) to perform a series of emissions tests under the requirements set forth under NSPS 40 CFR Part 60, Subpart KKKK for stationary combustion turbines. The source is described in the DAQE Title V Permit, DAQE-AN0107560007-10 and is identified as T2. The test will seek to determine continuous compliance with NOx emission limits under the
rules set by the USEPA. The performance testing will be performed on one, stationary
combustion turbine used for gas compression located at the Vernal Compressor
Station in Uintah County, Utah.
Purpose of Test:
The purpose of the test is to demonstrate annual (or biennial) compliance monitoring of Nitrogen Oxides (NOx) for the source identified in this protocol. The test program will quantify NOx concentrations from the exhaust stack of one, stationary combustion turbine. Description of Plant:
The Vernal Compression Facility is located at 1025 E 7550 N near Vernal Utah. UTM
coordinates 641.300 m Easting & 4,492.000 m Northing UTM Zone 12 The site has
an approximate elevation of 6,100’ ASL. The facility is used to compress natural gas
for delivery into a natural-gas pipeline.
Description of Source to be Tested: The turbine that will be tested under this source test plan is a natural gas-fired, stationary combustion turbine identified as T2 and is used for gas compression. Detailed Source Information:
The source is described as follows;
T2: Solar Taurus 70 Model T-10302S (SoLoNOx). Serial # TC10455. This source is rated at 662.2 MMBtu/Hr and 9755 HP
(@ 6100’ ASL and 0 degrees F).
3
Operation of Source During Testing Process:
To meet the requirements under, 40 CFR, Part 60, Subpart, KKKK, the turbine will be
tested for at least three, 20-minute test runs at the maximum achievable operational load based on site and facility conditions for the test date. (75% - 125% of peak load as is required under subpart KKKK). No testing will be allowed if the ambient temperature is < 0 ° F as is mandated under the KKKK test protocol.
The source horsepower and fuel usage for the turbine will be provided to ESI
technicians by Northwest Pipeline LLC and based on best available data from the
process monitors in the control room. Other parameters such as NPT %, NPG %, T5
turbine temperatures Suction, Discharge and other available data will also be recorded
during the testing program.
It is the responsibility of Northwest Pipeline LLC to provide safe access to hand-tight,
EPA compliant, sample ports. Test Methods: ESI proposes the following EPA reference methods for this source test plan.
Note* The instrumental methods were updated by the EPA in the final rule which was published on
August 14th, 2006. EPA Reference Method 1
• Purpose: Establishing stack diameter and velocity traverse or sample measurement points.
• Equipment: Measurement device and calculator.
• Calculations: (See Appendix 1)
EPA Reference Method 3A
• Purpose: Determination of Carbon Dioxide (CO2) & Oxygen (O2) concentrations in exhaust gas.
• Equipment: Instrumental Method using non-dispersive infrared (NDIR) for continuous sampling of CO2 and paramagnetic sensor for O2. (The paramagnetic sensor is part of the Chemiluminescence Analyzer.)
• Calculations: (See Appendix 1)
4
Test Methods (continued):
EPA Reference Method 7E
• Purpose: Determination of Nitrogen Oxides (NOx) Emissions from
Stationary Sources. Equipment: Instrumental Method using a Chemiluminescence based NOx analyzer equipped with an internal NO2 convertor oven for continuous sampling of Nitrogen Oxides (NO), Heated Sample Line and a Gas Conditioning System. EPA Reference Method 7E (Section 16.2.2) NO2 => NO converter efficiency test.
• Purpose: Determination of NO2 => NO converter oven efficiency.
• Equipment: Use of converter oven and the Tedlar® bag method as is
specified in the ‘Update of Continuous Instrumental Test Methods Final
Rule”.
• Calculations: (See Appendix 1)
All applicable QA/QC assurances required under EPA Method 7E such as; linearity checks, bias and calibration error checks, interference checks, Etc. Northwest Pipeline LLC will provide a current, valid purchase contract, tariff sheet, or transportation contract for the fuel specifying the maximum total sulfur content of all fuels combusted in the affected facility. (Reference 40 CFR 60.4360) No monitoring
of SO2 will be performed by ESI under this test protocol.
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 to determine inside diameter and proper sample port locations will be determined and marked on the sample probe 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. The
analyzers will then be challenged with EPA Protocol Gasses and calibrated to
minimize potential drift during the sampling process.
5
Test Procedures (continued):
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 and ambient conditions will be determined and if found acceptable, the sampling program will be initiated.
EPA methods 3A and 7E 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.
Test Report: The test report will contain all relevant data necessary to demonstrate a complete an accurate accounting of the testing program. The reported data will include a summary of the test methods and results, diagrams and schematics of the sampling system and exhaust stack, recorded field data, sample calculations, calibration gas certificates,
analyzer calibration results and other QA/QC measurements (such as; system bias and
interference checks).
For the purposes of the performance testing under the KKKK test procedure the
following limits and emission units will be used.
Source T2: NOx – 25 ppmvd @ 15% O2 (Heat Rating of > 50 MMBtu - < 850 MMBtu) The draft copy of the complete test report will be available three weeks after the completion of the testing program and the final copy will be delivered within one additional week upon final acceptance by the client.
Proposed Test Dates:
ESI proposes the following test dates for this project.
March 20, 2025
ESI anticipates the source testing will begin at approximately 10:30 AM and ending approximately 2:30 PM on March 20, 2025.
6
Contractor Supplied Equipment:
Emissions Science, Inc. will supply all analysis equipment, tools and personnel
necessary for the scope of this project as is required under the test methods section
found in this document. ESI will further guarantee that all equipment and methods used in the testing program will meet or exceed minimum requirements under all applicable test methods. Contact Personnel:
Northwest Pipeline, LLC 295 Chipeta Way
Salt Lake City, UT 84108 Mr. Derek Forsberg
Environmental Specialist (801) 584.6748
Emissions Science, Inc.
635 19 ½ Road
Grand Junction, CO 81507 Mr. James Olinger (970) 628-4849 Office State of Utah,
Department of Environmental Quality -DAQ
1950 West North Temple
Salt Lake City, UT 84114
Mr. Harold Burge
801.536.4129
APPENDIX 1
Test Method Calculation Examples
2
Sample Calculations for EPA Reference Method Tests
Note: As the calculations, formulae and unit conversions used for these test procedures are too
numerous to list, the following is a selection of the primary calculations used in the various methods. Alternate approved calculations may be substituted.
EPA Reference Method 1
• Stack Diameter * Distance Percentage from Stack Wall (Based on # of Traverse Points from Table F1-2) Determination of proper sample port placement (minimum 2*diameter downstream & 0.5*diameter upstream of disturbances)
EPA Method 7E
Corrections to a diluent rate of 15% O2
Bias corrected NOx concentration *(5.9/(20.9-Corrected O2))
EPA Method 7E ER = Cd * 1.912 * 10-3 * Q * T __________________ Hp-hr
Where:
ER =Emission Rate of NOx in g/hp-hr Cd = Measured NOx concentration in parts per million by volume (ppmv). 1.912 x 10-3 = Conversion constant for ppm NOx to grams per standard cubic meter at 20 degrees Celsius.
Q = Stack gas volumetric flow 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 7E
Equation 7E-5
Bias Correction
CGAS = (CAVG - CO) CMA
CM - CO
APPENDIX 2
Sample QA/QC Checks
Emissions Science, Inc
Quality Assurance / Quality Control Plan
(As noted and under the allowable tolerances in EPA method 7E)
¾Verification of correct Calibration Gas Selection and check on expiration dates.
¾Verification of heated sample line (above dew point of H2O) and thermocouple integrity.
¾Use of non-reactive sample transport and probe material (stainless-steel, glass, PTFE).
¾Complete system leak check.
¾Analyzer Calibration Error Check (3-point linearity check).
¾Sample system bias check.
¾System Response Time.
¾Analyzer Drift Assessment.
¾NO2 => NO conversion test.
¾System Purge Time.
¾Stack stratification test or minimum sample time at each point.
¾One-minute intervals for data recorder on sample run data (averaged at end of run).
¾Post-test bias check.
¾Calibration and run ‘raw’ data preserved as indelible record.
APPENDIX 3
Sample Train Schematics
Emissions Science, Inc
Emissions Science, Inc.
EPA Method 7E
Exhaust Stack with sample ports
Calibration
Gas Line
3/8" Heated
System manifold with pump, flow control
valves, overflow
valve, Etc.
System Moisture Removal Manifold
& Particualte Filter
C.A.I.
Chemiluminescence Analyzer
C.A.I. ZRE NDIR
& Paramagetic
O2 Analyzer
System Data Recorder
Data Collection and calculation system
Certified
Calibration gas
Probe with
particulate filter
EPA Reference Method 1
Velocity and Traverse Points
Client:Northwest Pipeline, LLC Stack Diagram OutletSite:Vernal C.F.
Date:06/15/23 Stack Diameter (ID):45 "
Unit ID:T2 Downstream Disturbance:126 "
Stack ID:N/A Upstream Disturbance: 62 "
Stack Dia.45 Inches
Point #% of Stack Depth Measure (in.)Measure (cm)
1 0.032 1.44 3.66
2 0.105 4.73 12.00
3 0.194 8.73 22.17
4 0.323 14.54 36.92
5 0.677 30.47 77.38
6 0.806 36.27 92.13
7 0.895 40.28 102.30
8 0.968 43.56 110.64
9
10
11 Stack Cross Section
12
13
14
15
16
17
18
19
20
21 Point #NOx ppm Deviation Validity
22 16.7%7.0 1.1 YES
23 50.0%7.1 0.9 YES
24 83.0%7.1 0.2 YES
Avg.7.08 0.7 ☼
Italics indicate alternate point
Outlet Stratification Test
Muffler
Gas Flow
Emissions Science, Inc.
3.Grand Junction, COPhone: 970.628.4849