DAQ-2025-001381

1

DAQC-261-25
Site ID 10005 (B4)

MEMORANDUM

TO: STACK TEST FILE – KINDER MORGAN ALTAMONT, LLC – Main Gas
Processing Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: March 6, 2025

SUBJECT: Location: Main Compressor Station located near Altamont, Duchesne County, UT
Contact: Brittany Brumley: 713-420-6314
Tester: Emissions Testing Group, Wyatt Dickey: 713-420-2471
Sources: Engine Units ICE 1-10 and 12
FRS ID #: UT0000004901300006
Permit# 1300006003 dated September 27, 2022
Subject: Review of Pretest Protocol dated February 24, 2025

On February 28, 2025, the DAQ received a protocol for the emissions testing of Engine Units ICE 1-10
and 12, operating at the Kinder Morgan Altamont Main Gas Processing Plant located near Altamont,
Duchesne County, UT. Testing will be performed March 31, through April 11, 2025, to determine
compliance with NOx, CO, and VOC emission limits found in 40 CFR 60 Subpart JJJJ and Permit
Conditions II.B.2.a and II.B.2.b for engine units ICE 1-9, and Conditions II.B.3.a, II.B.3.b, II.B.4.a, and
II.B.4.b for engine units ICE-10 and ICE-12.

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 for the determination of stack gases moisture content: OK
5. RM 7E used to determine NOx emissions: OK
6. RM 10 used to determine CO emissions: OK
7. RM 19 used to determine emissions exhaust flow: OK
8. Method ASTM D6348-03 used to determine VOC emissions: OK

* - / $ - - $ )
2

DEVIATIONS: None noted.

CONCLUSION: The pretest protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Pretest Protocol received February 28, 2025
ONGAN
ALTATONT LLC
FedEx 2856 9497 8338
February 24,2025
Harold Burge, Manager
Major Source Compliance Section
Utah Department of Environmental Quality
195 North 1950 West
salt Lake city, uT 84716
Re: Kinder Morgan Altamont LLC
Altamont Main Gas Processing PIant, Title V Permit No. 1300006003
DIT'AIITMENT OF
ENVIHONMENIAL QUAUTY
DIVISION OF AIR OUALITY
Emission Test Notification, Engine ICE-I, ICE-2, ICE-3, lCE4, ICE-S, ICE-5, ICE-7, ICE8, ICE-9, ICE-10, and
tcE-12
Dear Mr. Burge,
Kinder Morgan Altamont LLC (Kinder Morgan) plans to conduct periodic emission testing on engine ICE-1
(company lD: K-2A), ICE-2 (K-28), ICE-3 (K-2C), lCE4 (K-1A), ICE-S (K-18), ICE-6 (K-1C), ICE-7 (K-3A), ICE-8 (K-38),
ICE-g (K-3C), ICE-10 (K-3D), and ICE-12 (K-1D) at Altamont Main Gas Processing Plant located in Duchesne
County, Utah. The engines are equipped with Non-Selective Catalytic Reduction (NSCR) technology to control
emissions and air fuel ratio controllers. Operation of these engines is authorized under Title V Permit No.
1300006003 issued by the Utah Division of Air Quality (UDAq on September 27,2022.
The emission testing will be conducted as required in conditions 11.B.2.a.1, 11.B.3.a.1, and 11.B.4.a.1 of the permit
to demonstrate compliance with emission limits:
Engine Engine Modeland Rating Pollutant Limit
(lblhr)
Limit
(e/hp-hrl
rcE-1(K-2A)
rcE-2 (K-28)
rcE-3 (K-2C)
rcE-4 (K-1A)
rcE-s (K-18)
rcE-6 (K-1C)
rcE-7 (K-3A)
rcE-8 (K-38)
rcE-e (K-3c)
Waukesha 7042 GSI 1,030
hp (850 hp at site
conditions)
Nitrogen Oxides (NOx)1_.59 0.7
Carbon Monoxide (CO)7.74 0.5
rcE-10 (K-3D)Waukesha 5794 GSI
1,373 hp at 1,200 rpm
Nitrogen Oxides (NOx)7.52 0.5
Carbon Monoxide (CO)L.52 0.5
tcE-Lz (K-r.D)Waukesha 17044 GSI Nitrogen Oxides (NOx)1.95 o.7
Carbon Monoxide (CO)3.09 1.11
ln addition, engines ICE-10 (K-3D) and ICE-12 (K-1D) are subject to 40 CFR 60 subpart JJJJ, Stondords of
Performonce for Stationary Spork lgnition lnternol Combustion Engines, and must meet the standards below
either in ppmvd at\5% Oz or on a g/hp-hr basis.
lcE-l0
Pollutant
Standard
(ppmvd attS%Ozl (e/hp-hr)
Nitrogen Oxides (NOx)160 2.O
Carbon Monoxide (CO)540 4.O
Volatile Organic Compounds (VOC)*85 1.0
ICE-12
Pollutant
Standard
(ppmvd atti%Ozl (e/hp-hr)
Nitrogen Oxides (NOx)82 1.0
Carbon Monoxide (CO)270 2.O
Volatile Organic Compounds (VOC)*60 o.7
*Per NSPS JJJJ, emissions of formaldehyde should not be included when calculating emissions of volatile organic
compounds
The emission testing is scheduled to be conducted in the weeks of March 31,2025 and April 07,2025 if agreed
upon by the UDAQ. Due to unforeseen circumstances, there could be changes to the above schedule. The
UDAQ will be notified about any changes in writing or by email as soon as possible.
lf you have any questions about this submittal, please contact me at [phone] or by email at
Britta ny_Bru m ley@ ki ndermorga n.com
Sincerely,
Brittany Brumley
EHS Manager
Mechanical Testing File # 25-049
KlilDEEfHoEGAtl
{ ALr IOrfi LLc
Emissions Testing Group
1001 Louisiana St., Suite 1000
Houston, TX77002
Emissions Test Protocol
Nine (9)Waukesha LTC/;2CIS| NatiralGas Fircd Ergires
One (1)Waukesha L7044GSI NatrralC,as Fircd Egine
One (1)Waukeslm L57%GS! NanrralC,ffi Fired Ergine
UnibKlA K-28,K-2C,K€B, K-18, K-ZAK-1C, K€A K.3C, K-1D, K€D
Title V Operating Permit Number: 1300006003
Emissions Testing Group File # 25-049
Scheduled Test Dates: Weeks of March 31 , 2025 and April 07 , 2025
ENVII]ONMENIAL
Kinder Morgan Altamont LLC
Mdn Gas Plant
Dudresne fuunty, UT
Date:
Prepared
for:
Prepared
by:
Reviewed
by:
February 17r2025
State of Utah Depailment of Environmental Quality
Division of Air Quality (DAA)
Wyatt Dickey
Emissions Testing Group
(7rs) 420,-2471
Nathan Liebmann
Emissions Testing Group
(7{3) 420,-36,64
FEB ?8 2C:5
DIVISION OF AIB OUALTTY
OF
OUALITY
[tF-V 42 0 1/20;]o
Table of Gontents
INTRODUCTION ................. I
EMISSIONS SAMPLING PROCESS
GENERAL TESTING PROCEDURE ..........................6
EPA REFERENCE AND ASTM METHODS ............6
INSTRLMENT CHECKS AND CALIBRATIONS.... ......................8
EPA PRorocol GASES (40CFR60, AppENDrx A - M78.7.1)....... ......................... 8
INTERFERENCe neseoNse (40CFR60, AppENDrx A - M78.8.2.7) ... ...................... 8
ANralvznnCALrBRAiloNERRoRTEsr(40CFR60,AppENDrxA-M7E.8.2.3) .. ......................................8
NOzroNO CoweRsroN EnnrcraNcv (40CFR60, AeneNox A-M7E.8.2.4).........,.. ................8
RESeoNSE TIME TESr (40CFR60, AppErlox A- M7E.8.2.6)................ ................9
SysrEM Bns Cnrcr (40CFR60, AppENDrx A-M78.8.2.5 &M7E.8.5)... ..........9
VOC DETERMINATION .................. l0
DETERMTNATToN oF SrRArrFrcArroN (40CFR60, AppENDrx A-M78.8.1.2)............ ...............12
CONCENTRATION CORRECTION....... .................14
15% oxYGEN CORRECTION............... ,................. 15
MASS EMISSION CALCLILATIONS, METHOD I9............ ........ 16
CALCULATION DETERMINATION OF COZ .,..,.,17
CALCULATION DETERMINATION OF H2O......... ..................... 17
MINIMUM DE.rEcre.elg CONCENTRATION. ............. 18
REpEnENca CELL ABSoRpnoN Pe.tu LeNcrH....,.... ..................... 19
SevpIe CEI-I- ABSoRPTIoN PATH LENGTH. ............ 20
WEr-Dny PoLlureNr CoNCENTRATTON CoRREcrroN .............22
VOC CALCULATTONS sv REspoNsE FACT'oRS....... ........................22
li[ \,i,1;) () ] /,)r)-)
Ust of Figures
Figure 1: Sample System Schematic.....
List of Tabls
Table 2: Emission Units and Requirements..................... ....................2
Table 4: Unit Conversion Factors..t6
Ust of Equations
Equation l: Bias Correction Calculation.. ................... I
Equation 2: EPA Fuel Specific Fd factor...... ...............I
Equation 3: Emissions Corrected to l5o/o Oxygen......... ................... I
Equation 4: Mass Emission Rate (lb/hr)..
Equation 5: Mass Emission Rate (g/bhp-hr).........
Equation 6: YoCOz Dry Calculation (Stoichiometric)I
I
I
Equation 7 z ohHzO Calculation (Stoichiometric)
Equation 8: Noise Limited Minimum Detectable Concentration #l
....1
4
5
5
6
6
7
7
8
8
9
9
Equation 9: Analy,tical Minimum Detectable Concentration #2............... ............. I
Equation 10: Analytical Minimum Detectable Concentration #3
Equation 11 : Reference Cell Path Length ......... .......... I
Equation 12: Sample Cell Path Length.......... ..............20
Equation 13: Dilution Factor
Equation 14: Expected Spike Concentration
Equation 15: Spike Recovery, Percent ........-............. 21
Equation 16: Moisture Corrected Concentration.................... .........22
Equation 17: VOC as Methane by Response Factors......... ..............22
20
2t
Rf,v 4;-) 0l/,)02':j
Introduction
The Company's Emissions Testing Group (ETG) will be conducting source emissions
testing atthe Kinder Morgan Altamont LLC Main Gas Plant in fulfillment of the State of Utah
Department of Environmental Quality (UDEO) Title V Operating Permit Number
1300006003. The purpose of this test is to demonstrate compliance with permitted emission
limits and 40CFR60 Subpad JJJJ for the units listed below.
Table 1 and Table 2 present the emission units and species to be measured during the
testing along with applicable permit limits. All testing will be conducted in accordance with
Environmental Protection Agency (EPA) test methods as described in 40CFR60, Appendix
A, and this test protocol.
Concentrations of Volatile Organic Compounds (VOC) will be determined using an FTIR
following ASTM D6348 as allowed by 40CFR60 Subpart JJJJ. Non-methane non-ethane
VOC will be reported on a propane basis.
The testing is tentatively scheduled for the weeks of March 31, 2025 and April 07, 2025 if
agreed upon by the State of Utah Division of Air Quality (DAO). The ETG will provide as
much notice as possible to any changes in this schedule.
Table 1: Engine Detail
K-1A (rCE4)221564 Waukesha L7042GSt NSCR 45RB 850 1t2811972
K-28 (tCE-2)365276 Waukesha L7042GSl NSCR 4SRB 850 8t26t1981
K-2C (rCE-3)279787 Waukesha L7042GSl NSCR 4SRB 850 7t21t1976
K-38 (rCE-8)298597 Waukesha L7042GSl NSCR 4SRB 1030 7t21t1976
K-18 (rCE-s)349845 Waukesha L7042GSt NSCR 4SRB 850 3t2gt1g74
K-2A (rCE-1)241514 Waukesha L7042GSt NSCR 4SRB 850 3t31t1975
K-1C (rCE-6)265181 Waukesha L7042GSt NSCR 4SRB 850 3t28t1974
K-3A (rCE-7)252851 Waukesha L7042GSt NSCR 4SRB Bs0 9t24t1973
K-3C (rCE-e)wAU-1713816 Waukesha L7042GSt NSCR 4SRB 1030 24-Ju12024
K-3D (rCE-10)c-1731011 Waukesha L5794GSl NSCR 4SRB 1373 11t14t2007
K-1D (rCE-12)5283701 040 Waukesha L7044GSl NSCR 4SRB 1260 1t22t2011
Ilt,v.1i)01,,,{i1i
Table 2: Emission Units and Requirements
K-1A (rCE-4)
K-28 (tCE-2)
K-2C (rCE-3)
K-38 (ICE-B)
K-18 (rCE-s)
K-2A (rCE-1)
K-1C (rCE-6)
K-3A (rCE-7)
K-3C flCE-g)
NOx EPA Method 7E 1.59 lb/hr
0.7 o/bho-hr
Approval Order DAQE-AN1 0005001 6-20
CO EPA Method 10 1.14lblhr
0.5 g/bhp-hr
K-3D (rCE-10)
NOx EPA Method 7E
1.52lblhr
0.5 o/bho-hr Approval Order DAQE-AN 1 0005001 6-20
2.0 g/bhp-hr
9,7
160 ppmvd @ 15% Oz
40CFR60 Subpart JJJJ
CO EPA Method 10
1.52lblhr
0.5 o/bhp-hr Approval Order DAQE-AN1 0005001 6-20
4.0 g/bhp-hr
or
540 ppmvd @ 15% Oz
40CFR60 Subpart JJJJ
VOC ASTM D6348
1.0 g/bhp-hr
oL
86 opmvd @.15% Oz
40CFR60 Subpart JJJJ
K-1D (rCE-12)
NOx EPA Method 7E
1.95 lb/hr
0.7 q/bhp-hr Approval Order DAQE-AN 1 000500 1 6-20
1.0 g/bhp-hr
o!.
82 oomvd @.15% Oz
40CFR60 Subpart JJJJ
CO EPA Method 10
3.09 lb/hr
1.11 o/bho-hr Approval Order DAQE-ANl 0005001 6-20
2.0 g/bhp-hr
9I
270 ppmvd @ 15% Oz
40CFR60 Subpart JJJJ
VOC ASTM D6348
0.7 g/bhp-hr
or
60 ppmvd @ 15o/o Oz
40CFR60 Subpart JJJJ
2
Rt v 4:? 01/1025
FACILITY INFORMATION
Facility: Kinder Morgan Altamont LLC Contact:
Main Gas Plant
P.O. Box 587
Altamont, UT 84001
GPS Coordinates:
LAT 40.355881 LONG -110.327233
Erin Dunman
AirCompliance
1667 Cole Blvd
Lakewood, CO 80401
Erin_D [e-mail]
(303) e14-7605
EMISSIONS GROUP INFORMATION
Facility:Emissions Testing Group Contact:
1001 Louisiana St., Suite 1000
Houston, TX77002
Wyatt Dickey
Emissions Testing Group
Wyatt_Dickey@ki ndermorga n.com
(713\420-2471
3
REV4201/2025
Emissions Sampling Process
PROCESS DESCRIPTION
The Waukesha L7042GS| (850 hp), Waukesha L7042GS| (1,030 hp), Waukesha
L7044GS| (1,260 hp) and Waukesha L5794GS| (1,373 hp) reciprocating compressor
engines are four stroke, rich burn, natural gas fired internal combustion engines,
equipped with NSCR catalysts, driving gas compressors. The energy released during
the combustion process drives gas compressors, raising the pressure of the incoming
gas from an initial "suction" state to a more compressed "discharge" state.
EMISSIONS TEST VEHICLE
The ETG has conducted emission tests on reciprocating engines and turbines for many
years. This testing experience has enabled the ETG to design and assemble an accurate
and versatile emissions test vehicle (Erv). The ETV is one of three environmentally
controlled box trailers housing all analyzers, computers and auxiliary equipment.
A Data Acquisition Control System (DACS) scans instrument outputs and the data is
transfened to a computer for analysis and storage. The computer monitors the readings in
real-time and outputs the data averages to a video monitorand the hard drive. The readings
are recorded and represented in Central Standard Time (CST) due to our headquarters
located in Houston, Texas.
SAMPLING SYSTEM
Continuous analyzers will be used to determine the oxides of nitrogen (NOx), carbon
monoxide (CO), non-methane, non-ethane, excluding formaldehyde volatile organic
compounds (VOC) and oxygen (Oz) emission concentrations. Available instrumentation
and analyzers are listed in Table 3. Brand names and specific models are for reference
only and instruments of equal nominal performance may be substituted from time to time.
Exhaust gas enters the system through a stainless steel probe and a 3-way sample valve
assembly. The sample is transported via a heat-traced Teflon sample line through a
stainless steel sample pump and into a minimum contact condenser specially designed to
dry the sample. The sample is then passed through 3/8" Teflon tubing to a Balston
Microfiber coalescing filter and then to the sample manifold. The sample manifold is
maintained at a constant pressure by means of a pressure bypass regulator. Stainless steel
needle valves control the sample flow to each analyzer. See Figure 1 for the flow
schematic.
For the FTIR analyzer, the exhaust gas is brought into the trailer through the same stainless
steel probe and 3-way sample valve, however, it is next directed through a heated sample
line to the FTIR hotbox where the temperature, pressure and flow rate are kept constant by
way of a pressure regulator, temperature controller and needle-valve flow meter until the
sample enters the analyzer. After the sample has passed through the analyzer, it is purged
outside of the trailer. See Figure 1 for the flow schematic.
4
g
-++.
--{wL
-&--#-
LEGEND
Pump
-l,iirln.lr"
A 5't{rvv.rv.
( P I Ptc8sureOauq!
8n.D tnrnc -+<F H.nd v.h. \-/ll;;lo'' -6fl. ll;ii.lJ: @l- Fbwrsirr
Sol.nold -qf 3-tryryv.tva ....g- Drt.rrnrr 4-"- E:;l;l t"
Figure 1: Sample System Schematic
Table 3: Available Instrumentation
5
NOx Thermo Fisher Scientific /
Teledvne 42i tT200H Thermal reduction of NOz to NO.
Chemiluminescent reaction of NO with Os
Variable to
10.000 oom
CO Thermo Fisher Scientific /
Teledvne 4Bi / T300M NDIR with Gas Filter Conelation Variable to
10.000 opm
voc MAX iR Fourier Transform lnfrared Soectroscoov
Oz Servomex 4900 Paramaonetic 0to25%
Barometric
Pressure Rosemount 3051 20 - 31 "Hs
WeUDry
Temperature
Humiditv
Vaisala Model HMP 233 40 "F to 140"F
}Yo - 100Yo
Rtv420t/;11:?5
General Testing Procedure
EPA Reference methods as described in 40CFR60, Appendix A, and ASTM D6348
designations will be followed in the conduct of this testing. Calibration and test
procedures are detailed under their respective sections of this protocol. All emission
species will be measured poslcatalyst.
Concentrations of NOx will be determined by the procedure described in 40CFR60,
Appendix A, Method 7E. Concentrations of CO will be determined by the procedure
described in 40CFR60, Appendix A, Method 10. Dilution concentration of exhaust
oxygen will be determined by the procedure described in 40CFR60, Appendix A,
Method 3A. Determination of exhaust effluent flow and mass emission rates will be
determined by the procedure in 40CFR60, Appendix A, Method 19.
Concentrations of VOC will be determined using an FTIR following ASTM D6348 as
allowed by 40CFR60 Subpart JJJJ for Units K-3D (lCE-10)and K-1D (lCE-12).
As with any field-based laboratory procedures, circumstances or complications may
from time to time require unforeseen adjustments or accommodations which will affect
the data collection process, but not materially affect the quantified data - any changes
so required shall employ best possible engineering judgment to conform as closely to
the letter of the Reference Methods as possible. Additionally, any substantial deviation
from the protocol which might materially affect the quantified outcome of the test shall
be discussed with the State of Utah Division of Air Quality (DAO) prior to completion of
any affected test and shall be documented in the ensuing repofi.
EPA REFERENCE AND ASTM METHODS
Memoo {
"Sample and Velocity lraverses for Stationary Sources" The objective of Method 1 is
to determine the selection of sampling pods and traverse points for a representative velocity
measurement. Method 1 entails selecting sampling ports at least two stack diameters
downstream and a half diameter upstream ftom any flow disturbancc. Based on the
upstream and downstream measurements of a flow disturbance, a selection of minimum
traverse points will be selected. Method '1 will be performed on each engine. Diagrams will
be found in the test report APPENDIX.
Men'rco 3A
"Determination of Orygen and Carbon Dioxide Concentrations in EmLssions from
Sfafionary Sources (lnstrumental Analyzer Procedur$" The objective of Method 3A is
to determine the Oz concentrations from the source. Method 34 entails extraction of a gas
sample ftom a stationary source and routing the sample through a conditioning system to
an analyzer for the measurement of Oz in percent. Method 3A testing will be performed on
each engine for the determination of Oz. The calibration eror, system bias and system drift
data will be within the tolerances of the method. The previously mentioned data and the
testing data will be recorded on a DACS. Calibrations and test results will be found in the
test report APPENDIX.
6
lll-v 4ir 0 r/;?0;15
Merxoo4
"Determination of Moisture Content in Stack Gases" The objective of Method 4 is to
determine the moisture content of stack gas. Section 16.3 of this method allows the use of
an FTIR as an acceptable altemative to determine stack gas moisture. Section 16.4 of this
method allows the use of calculations using the fuel analysis and ambient conditions as an
acceptable altemative to determine stack gas moisture.
MenlooTE
"Determination of Nitrogen Oxides Emlssions from Stationary Sources (lnstrumental
Analyzer Procedure)" The objective of Method 7E testing is to determine the NOx
concentration from the source. Method 7E entails extraction of a gas sample from a
stationary source and routing the sample through a conditioning system to an analyzer for
the measurement of NOx (NO and NOz) in ppmvd. Method 7E testing will be performed on
each engine for the determination of NOx. The calibration error, system bias and system
drift data will be within the tolerances of the method. The previously mentioned data and
the testing data will be recorded on a DACS. This data and test results will be found in the
test report APPENDIX along with NOx converter check results and calibration gas
certificates.
Meffioo {O
"Determination of Carbon Monoxide Emrbsions from Stationary Sources
(lnstrumental Analyzer Procedure)" The objective of Method 10 is to determine the CO
concentrations from the source. Method 10 entails extraction of a gas sample from a
stationary source and routing the sample through a conditioning system to an analyzer for
the measurement of CO in ppmvd. Method 10 testing will be pefformed on each engine for
the determination of CO. The calibration enor, system bias and system drift data will be
within the tolerances of the method. The previously mentioned data and the testing data
will be recorded on a DACS. Calibrations and test results will be found in the test report
APPENDIX.
MEmoo {9
"Determination of Sulfur Dioxide Removal Efficiency and Pafticulate Matter, Sulfur
Dioxide, and Nitrogen Oxide Emission Rafes" The objective of Method 19 testing is to
determine the emissions exhaust flow. Method 19 entails a NOx emission rate determined
by an Oxygen-Based F-Factor on a dry basis. An F-Factor is the ratio of gas volume of the
products of combustion to the heat content of the fuel. Method 19 testing will be performed
on each engine for the determination of NOx emission rates if a calibrated fuel meter is
used. The NOx pollutant concentration, dry F-Factor and percent of dry Oxygen
concentration will be collected and calculated for the method. Test results will be found in
the test report APPENDIX along with the emission rate formulas found in Equation 4 and
Equation 5.1
1 The same exhaust flow calculation will be used for CO and VOC
Rl v 42 ()11,)ll )rl
ASTM 116348
"Determination of Gaseous Compounds by Extractive Direct lntertace Fourier
Transform lnfrared (FTIR) Spectroscopy" The objective of ASTM D6348 is to determine
the VOC concentrations from the source. ASTM D6348 entails extraction of a gas sample
from a stationary source and routing the sample through a heated system to an FTIR for
measurement. ASTM D634B testing will be performed on Units K-3D (lCE-10) and K-1D
(lCE-12) for the determination of VOC in ppmvw. The acetaldehyde/tracer spike, recovery
analysis and minimum detectible concentration for VOC will be within the tolerances of the
method. The previously mentioned data and the testing data will be recorded on FTIR
software. Calibrations and test results will be found in the test repod APPENDIX.
I NSTRU M ENT CH ECKS AN D CALIBRATIONS
The following instrument checks and calibrations guarantee the integrity of our sampling
system and the accuracy of our data.
EPA PnoroooL GAsEs (4OCFR6O, ARearoxA- M7E.7.t)
Calibration sheets for EPA Protocol 1 calibration gases will be available at the test site and
will be included in the test report APPENDIX.
lrrrnr=nexcE REspoNsE (4OGFR6O, AppEr{Dx A - MTE,,&2.7
Vendor instrument data conceming interference response in the NOx, CO and 02 analyzers
will be included in the test report APPENDIX.
Analvzn GaueRATroN ERRoR TEsr (4OCFR6O, Arp61e,, 4 - M7E.823)
The measurement system will be first prepared for use. Each analyzer will be set to
the correct response and that response will be recorded by the data acquisition system.
A calibration curve will then be established to convert each analyzer's response to
equivalent gas concentrations as introduced to each analyzer. Then zero, mid and
high calibration gases will be introduced without adjustment to the analyzers and their
responses will be recorded. These linearity checks will be performed daily, and these
responses will be considered acceptable if they are within +/- 2 percent of the span.
This curve will remain unchanged throughout the test. The analyzer calibration checks
(linearity) sheets will be included in the test report APPENDIX.
An NOz to NO conversion efficiency test will be performed on each day of testing following
the procedure described in 40CFR60, Appendix A, Method 7E Section 8.2.4.1. The results
of the conversion efficiency test will be included in the test report APPENDIX.
tif: v 4:l t)1/,rir..)5
Sampt-e Lrre l-axGHEGt(
The sample line is leak checked before and after the test by closing the calibration valve
assembly while the sample pump is operating. Once the maximum vacuum is reached
(approximately 12 - 15 inches of mercury) the valve on the pressure side of the pump is
closed (See Figure 1) thus sealing off the vacuum section of the sampling system. The
leak tests for each unit will be considered acceptable if the vacuum gauge reading drops by
an amount less than '1 inch of mercury over a period of 1 minute. The results of the sample
line leak checks will be included in the test report APPENDIX.
REspoNsE TrME TEsr (4OGFR6O, Appsirpt, 4 - M7E.&2.G)
Before sampling begins, it will be determined if the highJevel or mid-level calibration gas
best approximates the emissions and the more appropriate gas will be used as the upscale
gas. A response time test will be performed by first introducing the zero gas into the sample
system at the outlet of the probe until all readings are stable. The calibration valve willthen
be switched to sample the upscale gas at the outlet of the probe until a stable reading is
obtained, within 95% of the certified value of the upscale gas. The upscale response time
will be recorded. Next, the low-level gas will be introduced in the same manner as the
upscale gas. Once a stable reading is noted, within 5% of the cedified value of the upscale
gas, the downscale response time will be recorded.
This process will be completed once per analyzer to determine upscale and downscale
responses. The greater of the upscale or downscale response will be classified as the
response time and all test points will be monitored for a period of time at least twice the
response time. The results of the response time tests will be included in the test report
APPENDIX.
SysilEu Bns Gxecx (4(rcFR6O, AnRexox A - M7E.&iL5 & MTEAJS)
Before sampling begins, the upscale gas is determined as mentioned in the Response Time
Iesf section. The system bias check is conducted once priorto and once following the test
runs of the series and consists of first introducing the NOx analyzer's upscale gas directly
at the analyzer. The analyzer is allowed to stabilize and the reading noted. The same gas
is introduced at the probe, passing through the entire sample train to the anallzer and the
reading noted. The resulting readings indicate any bias attributed to the sample train. This
process is repeated with the NOx analyzer's low gas. The bias check is acceptable if the
direct gas reading of the analyzer is within +l- 5% of the complete sample train reading of
the analyzer [per 7E.13.2].
This same procedure is repeated for CO and the 02 analfzers. Sample system bias check
forms will be included in the test report APPENDIX.
Bias checks before and after each test run of the series will be used to determine a low and
upscale drift for the NOx, CO and 02 analyzers. The zero and upscale drift for the test run
period is less than +/- 3 percent of the span value for each of the analyzers [per 7E.13.3].
The system bias (drift) checks sheet for each test will be included in the test report
APPENDIX.
I
VOG D TTRMNATK,N
VOC concentrations will be determined using ASTM D6348. The instrumentation for this
test program is an MAX-iR FTIR analyzer. To determine compliance with the emission
standard, the FTIR will be used to measure the pollutant concentration on a wet basis then
convert the concentration and exhaust flow to a dry basis using the FTIR moisture
determined during the run.
Target Analytes include but are not limited to:
Data Quality Objectives
Accuracv: The accuracy of the measurements will be ensured by performing analyte
spiking, prior to the test series, in which spike recoveries will meet +/- 30% of predicted
value (see ASTM D6348 EQUAIIONS section below).
Precision: The precision of the measurements will be ensured by consecutive
Calibration Transfer Standard (CTS) analysis, performed prior to and following the test
series, in which measured values will meet +l- 5% of certified value.
Test Runs: Three test runs, each 60 minutes in duration will be collected
The QA/QC checks outlined below will be performed on the analyzer.
2 Acetaldehyde will be used as a sunogate forVOC during spike and recoveries.
3 SFo, CFr or QH6 will be used as a tracer gas for acetaldehyde spiking.
4 Ethylene Wll be utilized as a Calibration Transfer Standard (CTS).
RFV 42 01/ia),)i
10
Pre-test Analysis:
calculating the parameters outlined in Annex A-2 of Method ASTM D6348.
ASTM D6348.
will be determined.
sampling and analytical system for transporting and quantifying the target
analytes. This technique willfollow procedures outlined in Annex A-5 of
Method ASTM D6348.
outlined in Annex 4-6 of Method ASTM D6348.
of collected sample spectra. As such, the resolution, line position and
apodization function used for the reference spectra will be the same for
field spectraldata.
Field Sampling & Analysis
Post-test Analysis
Following data collection, the following checks will be performed again for verification
against pre-test values:
identified in Annex A-8 of Method ASTM D6348
tiF:v :1;., f) I 1.)tl2i)
11
EMISSIONS TESTING
Sarun-e Locamor aro Sgr+rp
A single point probe consisting of 3/B inch stainless tubing open at one end will be used
to collect the sample. The sampling point in the exhaust stack will be at least eight
stack diameters downstream from any disturbance and at least two stack diameters
upstream from any disturbances as specified in Method 1, 40CFR60, Appendix A. lf
these criteria cannot be met, the sample probe will be placed at least two stack
diameters downstream and a half diameter upstream from any flow disturbance
(40CFR60, Appendix A, Mtd 1, 11.1.1) or as needed to ensure a high integrity sample
from each engine's exhaust.
DerERurNATroN oF STRATTFTGATrcN (4{!GFR6O, Appenox A- M7E.8.{.2)
A stratification check will be performed on each unit using the sample probe. Three
points on a line passing through the centroidal area will be used, spaced at 16.70/o,
50.0% and 83.3% of the measurement line or a matrix system will be set up. The
sampling time will be at least twice the system response time at each traverse point.
Reciprocating lntema! Gombustion En gines with Gircu lar Stacks
For exhaust stacks larger than four inches in diameter, a stratiflcation check will be
performed before the first run of each test.
FuelGasAxalYss
A fuel gas sample will be taken during the testing. The sample will be analyzed by a
pipeline gas chromatograph. This analysis will give the actual specific gravity and BTU
so that fuel flow and mass emissions can be accurately calculated. The analysis will
be included in the test report APPENDIX.
12
fll \"/ L1:) 0 1 r,)ll;)i
@upuanceTEsr Rurs
The exhaust gas from the engines will be sampled continuously to determine NOx, CO,
VOC and Oz concentrations for three (3) individual sixty (60) minute test runs @ >
90% of rated (or @ >-90o/o highest achievable) load. lt would be inaccurate to estimate
the anticipated production capacity of the engines prior to the day of testing due to the
variability in daily pipeline conditions.
Other important parameters such as compressor suction and discharge pressures,
engine speed and ambient conditions will be monitored during the test.
The data acquisition system will scan the analyzers every second during the test run.
The computer will average the outputs every ten seconds and the raw data will be
included in the report. A summary of the data, with each test run averaged will be
given in the test report APPENDIX.
Any emissions limit exceedance will be reported in accordance with permit and
applicable regulatory requirements. lf there is an emission limit exceedance, a twenty
(20) minute run will be recorded in as found state. After the twenty minute run,
corrective actions will take place to resolve the issue. lf the issue can't be resolved, the
unit will be shut down and the test will be re-scheduled.
TesrRrponr
The compliance test report will be submitted to the UDEQ within 60 days of test completion.
The ETG will express test results with the same level of precision (values past the decimal
place) as the permit limits are expressed. The test report willfollow the general outline of
this test protocol. Data summaries, raw data, calibration sheets, gas analysis, operating
parameters and other relevant information will be contained in the test report APPENDIX.
{3
Galculations
CONCENTRATION CORRECTION
Emission concentration conections required in 40CFR60, Appendix A, Method 7E will be
calculated by using the bias check low and upscale values from before and after the test.
The equation is as follows:
csas:G-c")HLtn - Lo
Equation 1: Bias Correction Calculation
Nomenclature:
Csas: Average effluent gas concentration adjusted for bias (ppmvd)
e : Average unadjusted gas concentration indicated by data recorder for the test
run (ppmvd)
Cot Average of initial & final system calibration bias check responses for the low
calibration gas (ppmv)
C^t Average of initial & final system calibration bias check responses for the
upscale calibration gas (ppmv)
C^oi Actual concentration of the upscale calibration gas (ppmv)
RFV 42 01/;r()2ai
,t4
EPA F.FACTOR
A fuel specific Fd factor will be calculated as described in EPA Method 19, "Determination
of Sulfur Dioxide Removal Efficiency and Particulate, Sulfur Dioxide and Nitrogen Oxides
Emission Rates from Electric Utility Steam Generators" for naturalgas. Equation 2 will be
used to determine the EPA fuel specific Fd factor.
Fd:[(3.64 .Hwt"t) + (1.53 .C*tot) + (0.14.Nzwton) - (0.46.O2*tv)f
GCV
PFuelGas
Equation 2: EPA Fuel Specific Fd factor
Nomenclature:
Fa:
Hylpyol
Csgolol
N2*soyol
O2s,golo'.
GCV:
Nomenclature:
Nor:.
N oy66rl
o/oO2:
Fuel specifi c F-factor (dscf/MM BTU )
Hydrogen weight percent
Carbon weight percent
Nitrogen weight percent
Orygen weight percent
Heating value of the tuel (BTU/dscf)
pruetcast Density of the fuel gas (b/scfl
15% OXYGEN CORRECTION
The measured concentration of NOx will be conected to 15% Oz as set forth in 40CFR60,
Appendix A, Method 7E.
Nox-Noxoo,"(ffi1
Equation 3: Emissions Corrected lo15'/o Orygen
Conected emission concentration (ppmvd)
Observed emission concentration (ppmvd)
Observed 02 concentration (%)
PF\/ 42 0lI,,r-125
5 The same formula is used for CO and VOC
{5
MASS EMISSION CALCULAIIONS, METHOD 19
The F-factor Method and guidance from Part 75 will be used to calculate mass emission
rates (lb/hr) and (g/bhp-hr)for NOx, CO and VOC. Equation 4 and Equation 5 will be
used to determine the mass emission rates.
E^: coxF6"ffixQnx#
Equation 4: Mass Emission Rate (lb/hr)
E^: c4xFo"ffix 0r, x #"#
Equation 5: Mass Emission Rate (g/bhp-hr)
Nomenclature:
Eum.
Ca,
Fa,
o/oo2:
Qn:
GCV:
BHP:
Pollutant emission rates (lb/hr and g/bhp-hr)
Pollutant concentration (lb/scf)
Fuel specific F-factor for dry Co measurement (dscf/MMBTU)
Orygen concentration in percent, measured on a dry basis
Fuel rate from calibrated AGA compliant meter (scftr)
Heating value of the tuel (BTU/scf)
Brake horsepower
The conversion factors in Table 4 will be used to conect the pollutant concentration in ppm
to lb/scf:
Table 4: Unit Conversion Factors
1.194 x 10-7
7.268x 1Oa
1.1444 x1O-7
RFV4201/?025
,t6
CALCULATION DETERMINATION OF COz
The exhaust COz will be determined using stoichiometric calculations. Equation 6
determines the percentage.
o/oco -( cozeq ).rro'u2 - \ouro- nrorror)i Lwv
Equation 6: YoCOz Dry Calculation (Stoichiometric)
Nomenclature:
OzGD: Oz total moles exhaust actual conditions fom fuel gas analysis at a carbon
balance
C02.,6.,: COz total moles exhaust actual conditions from fuel gas analysis at a carbon
balance
H20gaf HzO total moles exhaust actualconditions from fuelgas analysis at a carlcon
balance
o/oCO2: Calculated Stoichiometric COz Dry (%)
CALCULAIION DETERMINATION OF HzO
The exhaust HzO will be determined using stoichiometric calculations. Equation 7
determines the percentage.
o/oH2o - (HzoQP+ H'oq!,!"('b)) - roo\ orrrat + wv /
Eq u ation 7 : o/oHzO Ca lcu lation (Stoich iometri c)
Nomenclature:
OzGo)t Oz total moles exhaust actual conditions from fuel gas analysis at a carbon
balance
WV: Watervaporfromhumidity
H2Oasm16y1t Moles water vapor in air at a carbon balance
H2Ogol. HzO total moles exhaust actual conditions from fuelgas analysis at a carlcon
balance
o/oH2OG6i Calculated Stoichiometric HzO (%)
17
tlt::V 42 01i2'0;)5
ASTM D6348 EQUATIONS
M !N muu ITETEGTABT-E @xceurnarrox
NEAhs *Cref * LrefMDC#L =
-REF#,
Lceu
Equation 8: Noise Limited Minimum Detectable Concentration #1
Nomenclature:
MDC#1
NEA:
REF:
Cr"fl
Lr"fl
Lcettl
Noise limited minimum detectable concentration for analyte m (ppm)
RMS noise for analyte m
Root mean square absorbance value obtained on the reference spectrum
Concentration used in generating the reference spectra for analyte m (ppm)
Path length used in generating the reference spectra for analyte m (ppm)
Path length of the cell used to perform the measurements (m)
MDC#Z: 3 *
p
lZa*"
P=7
_ Ctr),
Equation 9: Analyticat Minimum Detectable Goncentration #2
Nomenclature:
MDC#z Analytical algorithm enor minimum detectable concentration for analyte
(ppm)
Number of sample spectra used
Average concentration for analyte m representing the analytical bias (ppm)
Concentration results produced by the analytical algorithm for the analyte
on spectra P of the set (ppm)
P:
Cave:
cp:
RFV,1,?0r1;2(i:?5
l8
MDC#3 :\'#' *crer * Lref
REFns Lceu
Equation f 0: Analytical Minimum Detectable Concentration #3
Nomenclature:
MDC#3: Analytical algorithm enor minimum detectable concentration for analyte m
(ppm)
REA, Residual equivalent absorbance for analyte m
REF, Root mean square absorbance value obtained on the reference spectrum
Cr"ft Concentration used in generating the reference spectra for analyte m (ppm)
L,"ft Path length used in generating the reference spectra for analyte m (ppm)
Lceut Path length of the cell used to perform the measurements (m)
Remnence Ge-L AasoRprl<rN Panr l-srcrr
Equation 11: Reference Cell Path Length
Nomenclature:
Lr, Reference cellabsorption path length (m)
Lf ' Fundamental CTS absorption path length (m)
Tr: Absolute temperature of reference CTS gas (R)
Tf , Absolute temperature of fundamental CTS gas (R)
Pr, Absolute pressure of reference CTS gas (ton)
Pf, Absolute pressure of fundamental CTS gas (ton)
Cr: Concentration of reference CTS gas (ton)
Cf, Concentration of fundamentalCTS gas (ton)
(t)' Ratio of reference CTS absorbance to the fundamental CTS absorbance,\er/
determined by classical least squares
L.=Lf(+)(+)@Gi)
l9
Rt:v 42 0 t/10;):;
Salrpr- Geu ABsoRprrox Panr l-enenr
Lr=,.(+)G)e)(f)
Equation 12: Sample Cell Path Length
Anelvr= SpHrNG
Nomenclature:
Nomenclature:
DF:
Tracer-sp1ys:
Tracer-p1ps6y:
trs,
1,,
Is'
Tr,
Ps'
Pr:
cs,
cr:
(f),
Sample cell absorption path length (m)
Reference CTS absorption path length (m)
Absolute temperature of sample CTS gas (R)
Absolute temperature of reference CTS gas (R)
Absolute pressure of sample CTS gas (ton)
Absolute pressure of reference CTS gas (ton)
Concentration of sample CTS gas (ton)
Concentration of reference CTS gas (ton)
Ratio of sample CTS absorbance to the reference
determined by classical least squares
CTS absorbance,
DF=Tracer-sp1ys
Tracer-p1pB6y
Equation 13: Dilution Factor
Dilution factor of the spike gas
Diluted tracer concentration measured in a spiked sample (ppm)
Tracer concentration measured directly in undiluted spike gas (ppm)
I'tF V.12 011.)0;2lr
20
Cexp=Udil+CS
Equation 14: Expected Spike Concentration
crro
Uo,
ua*
Cs,
CS
DF,
Nomenclature:
Nomenclature:
R'
Cobs:
cexp:
Expected spike concentration of the analyte (ppm)
Concentration of the analytes in the unspiked samples (ppm)
Concentration of analytes in spiked sample effluent accounting for dilution
(ppm); Uoir= Ua x (1 - DF)
Certified concentration of the calibration standard forthe analyte (ppm)
CS=C"xDF
Dilution factor of the spike gas
^ CobsR:#xL00Lexp
Equation 15: Spike Recovery, Percent
Percent spike recovery (%)
Observed spike concentration of the analyte (ppm)
Expected spike concentration of the analyte (ppm)
REV 42 01/202ir
UUEr - DRy Pourrrar{r @rcerrnanon @nnecron
cd-
Nomenclature:
ca,
Cmeas'.
o/oH2O,
VOG Gll.cuI,ATxrNs BY RESPoNSE Facrons
VOC :
ethylene (ethene)
acetylene (ethyne)
propane
propylene (propene)
butane
Equation 16: Moisture Corrected Goncentration
C*"o,
. (o/oHz?\'- \-mr-/
Corrected pollutant concentration on a dry basis (ppmvd)
Measured pollutant concentration on a wet basis (ppmvw)
Measured effluent moisture concentration (%)
t.9 x cL2 *
2.4 x cL3 *
DL}'A[ITMfNT OF
ENVIHONMT.NIAL OUALIry
FIB 2 ?,
DIVISION OF AIR OUALITY
3xct4*
2.85 x c15 *
4xc76
Equation 17: VOC as Methane by Response Factors6
Nomenclature:
c12 ethylene (ethene) (ppmvw)
c13 acetylene (ethyne) (ppmvw)
c14 propane (ppmvw)
c15 propylene (propene) (ppmvw)
cL6 butane (ppmvw)
VOC as propane = VOC as methane f 3
Equation 18: VOG as Propane
6 Using FID response factors, with ethylene, acetylene, propylene weighted down when below 0 ppm, and straight
readings for propane and butane.
tiFV 4;) 01/2025
22