DAQ-2025-002887

DAQC- 548-25
Site ID # 10005 (B4)
MEMORANDUM

TO: STACK TEST FILE – KINDER MORGAN ALTAMONT LLC – Main Compressor
Station

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: June 9, 2025

SUBJECT: Location: Main CS located near Altamont, Duchesne County, Utah
Contact: Erin Dunman, 303-914-7605
Tester: Emissions Testing Group, Alex Bradley 713-420-5434
Source: Engine Units ICE 2 and ICE 5 replacement
FRS ID #: UT0000004901300006
Permit# 1300006003 dated September 27, 2022
Subject: Review of Pretest Protocol dated June 2, 2025

On June 6, 2025, the DAQ received a protocol for the emissions testing of Engine Units ICE 2 and ICE 5,
operating at the Kinder Morgan Altamont Main Gas Processing Plant located near Altamont, Duchesne
County, Utah. Testing will be performed the week of July 14, 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.

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
DEVIATIONS: None noted.

CONCLUSION: The pretest protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Pretest Protocol received June 6, 2025.
* - / $ - - $ )
EI{UNON"EilrT,- diAIJlY
JUN - 6 2025
onfisollt c An qxrltY
FedEx 2893 1805 9441
June2,2025
Harold Burge, Manager
Major Source Compliance Section
Utah Department of Environmental Quality
195 North 1950 West
salt Lake city, uT 84115
Re: Kinder Morgan Altamont LLC
Altamont Main Gas Processing Plant, Title V Permit No. 13ffifi)5003
Emission Test Notification, Engines ICE-2 & ICE-S
Dear Mr. Burge,
Kinder Morgan Altamont LLC (Kinder Morgan) plans to conduct initial emission testing on engines ICE-2 (K-28)
and ICE-S (K-1B) 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 an air fuel ratio
controller. Operation of these engines is authorized under Title V Permit No. 1300006003 issued by the Utah
Division of Air Quality (UDAa) on September 27 ,2022.
The engines were swapped out for newer ones with the same make, model, and horsepower. UDAQ was
notified of the "re-up" on April 30,2025. At the time of this notice, unit ICE-5 began operation on 05/11./2025
and unit ICE-2 has not started up yet but will be by the time of the test. Kinder Morgan will provide a startup
notification upon such time.
ln addition, the new engine is subject to 40 CFR 60 subpart JJJJ, Stondards of Performance for Stotionory Spark
lgnition lnternol Combustion Engines, and must meet the standards listed in the table below.
The emission testing will be conducted as required in condition 11.8.2.a.1 of the permit to demonstrate
compliance with emission limits:
Engine Engine Model
and Rating
Emission
Control Pollutant Limit Basis
rcE-2 (K-28)
&
rcE-s (K-18)
Waukesha
7042 GSI 1,030
hp (850 hp at
site conditions)
NSCR NOx
1.59 lblhr
0.7 g/bhp-hr
Title V Permit
s1300005003
1.0 s,/bhp-hr
or
82 ppmvd @ L5%Oz
40 CFR 50 Subpart
]JJJ
CO
1..74lb/hr Title V Permit
#1300005003
2.0 g,/bhp-hr
or
270 ppmvd @ 75%Oz
40 CFR 60 Subpart
JJJJ
Total
VOC
0.16|b/hr Proposed Permit
Limit
VOC*
0.7 g,/bhp-hr
or
60 ppmvd @ 15% Oz
40 CFR 50 Subpart
JJJJ
rPer NSPS JJJJ, emissions of formaldehyde should not be included when calculating emissions of volatile organic
compounds
The emission testing is scheduled to be conducted the week of July 14,2025 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.
Please contact me at [phone] or via email at [e-mail] if you have any
questions regarding this letter.
cc: Mechanical Testing File # 74-747
Sincerely,
A+>t
Erin Dunman
Environmental Engineer
KINDEd,lnoRGAN
7 ALTAMoHTLLc
Emissions Testing Group
1001 Louisiana Sl., Suite 1000
Houston, fX77OO2
Emissions Test Protocol
Tvuc (2)\Ahukesha L7042GS! Natunalcm Fired Ergines
Units K-1B ard K-28
Title V Operating Permit Number: 1300006003
Emissions Testing Group File # 14-147
Scheduled Test Date: Week of July 14,2025
Kinder Morgan Altamont LLC
Main Gm Plant Compressor Station
Ductrcsne County, UT
Date:
Prepared
for:
Prepared
by:
Reviewed
by:
UTAH DF.PARTMENT OF
ENVIRONMENTAL QUALITY
JUN - 6 2025
.'."rr.l OF AIR
May 21,2025
State of Utah Department of
Environmental Quality (UDEa)
Division of Air Quality (DAA)
Alexa Badley
Emissions Testing Group
(713) 42O-s434
Johndunn Johnston
Emissions Testing Group
(713) 42O-33s0
Table of Gontenb
...........I
INTRODUCTION ...........-.---.-...--. 1
EMISSIONS GROUP IMORMATION..................... .....................2
EMISSIONS SAMPLING PROCESS ......................3
GENERAL TESTING PROCEDURE ......................5
EPA REFERENCE AND ASTM METHODS............... .................5
INSTRLMENT CHECKS AND CALtsRATIONS........... ............7
EPA PRorocol GASES (40CFR60, AppENDx A - M7E.7.1)........ ......................7
I}.rERFERENCE RESPoNSE (40CFR60, APPENDD( A - M78.8.2.7) .............-..... ............................7
ANALYZER CeLBRATToT{ ERROR TESr (40CFR60, AppENDx A - M7E.8.2.3) .........................7
NO2 ro NO CowERsroN EFFTCTENCY (40CFR60, AppENDrx A - M78.8.2.4)..... ........-.............7
RESPONSE TIMG TESr (40CFR60, AppENDx A - M7E.8.2.6).. ............................ 8
SysrEM BLAS CmcK (40CFR60, AppENDrx A-M7E.8.2.5 & 1v17E.8.5)........................... 8
SA-N,IPLE LocATIoN AND Sm-up .......................... I
DETERMNATToN oF SrRArtrrcArroN (40CFR60, AppENDx A - M78.8. I .2) . ... . . .. .. ............................ I
CALCUT-ATIONS .............-.--..-..... 13
Llst of Figures
Figure 1: Sample System Schematic ..-.4
List of Tables
Table l: Engine Detail ..... I
Table 2: Emission Units and Requirements ...................... 2
Llst of Equations
Equation 1: Bias Correstion Calculation....
Equation 2: EPA Fuel Specific Fd factor
Equation 3: Emissions Corrected to 75oh Orygen
Equation 4: Mass Emission Rate Qb/hr)...
Equation 5: Mass Emission Rate (g/bhphr)....................
Equation 6: Noise Limited Minimum Detectable Concentration #1 .........................
Equation 7: Ana\rtical Minimum Detectable Concentration #2
Equation 8: Analytical Minimum Detectable Concentration #3...................
Equation 9: Reference Cell Path Length
Equation l0: Sample Cell Path Length....l8
Equation ll: Dilution Factor ...18
Equation 12: Expected Spike Concentration l8
Equation 13: Spike Recovery, Percent...................
Equation I 4: Moisture Corrected Concentration
Equation 15: VOC as Methane by Response Factors............................-. 20
Equation 16: YOC as Propane....
Equation 17: Total VOC for Approval Order Permit Limits............ ..................20
l3
t4
t4
l5
l5
l6
l6
l6
t7
19
l9
20
20
lntroduction
The Company's Emissions Testing Group (ETG) will be conducting source emissions
testing at the Kinder Morgan Altamont LLC Main Gas Plant Compressor Station in fulfillment
of the State of Utah Department of Environmentai Quaiity (UDEO)Title V Operating Permit
Number 1300006003. The purpose of this test is to demonstrate compliance with Approval
Order DAQE-AN100050016-20 permitted emission limits and 40CFR60 Subpart JJJJ for
the units listed beiow.
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 descnbed in 40CFR60, Appendix
A, and this test protocol.
Concentrations of Volatile Organic Compounds (VOC) and Formaldehyde (CHzO) will be
determined using an FTIR following ASTM D6348 as ailowed by a0CFR60 Subpart JJJJ.
Non-methane non-ethane VOC will be reported on a propane basis. Formaldehyde
emissions will be excluded for the purpose of compliance demonstration with 40CFR60
Subpart JJJJ standards (VOC) but will be included for the purpose of compliance with VOC
permit limits (Total VOC).
The testing is tentatively scheduled for the week of July 14, 2025 tf agreed upon by the
State of Utah Division of Air Quality (DAO). The ETG wiil provide as much notice as possible
to any changes in this schedule. TBD - Will be provided on the final test report
Table 1: Engine Detail
Unit Name
{PermitlD}
Serial
Number ilanufacturer tiodel Catalyst
Type Type Horsepower MFG
Date
K-18 (rCE-s)WAU-
1737335 Waukesha L7O42GSI 54 NSCR 4SRB 1,030 4t2025
K-28 (rCE-2)TBD Waukesha TBD TBD TBD TBD TBD
Table 2: Emission Units and Requirements
Unit Name
(Permit lD)
Emission
Species
Applicable
Test Method Applicable Limits Permit Basb
K-18
K.2B
NOx EPA Method 7E
1.59 lbihr
0.7 gibhp-hr
ApprovalOrder DAQE-
AN100050016-20
1.0 g/bhp-hr
or
82 ppmvd @ 15% Oz
40CFR60 Subpart JJJJ
CO EPA Method 10
1.14lblhr
0.5 grbhp-hr
ApprovalOrder DAQE-
AN,100050016-20
2.0 g/bhp-hr
9!,
270 ppmvd @ 15% Oz
40CFR60 Subpart JJJJ
voc ASTM D6348
0.7 g/bhp-hr
9!,
60 oomvd @ 15o/o Oz
40CFR60 Subpari JJJJ
Total
VOC ASTM D6348 0.16 lb/hr ApprovalOrder DAQE-
AN100050016-20
FACILITY INFORMATION
Facility: Kinder Morgan Altamont LLC Contact:
Main Gas Plant
17790 West 3750 North
Altamont, UT 84001
GPS Coordinates:
LAT 40.3s5881 LONG -110.328233
EMISSIONS GROUP INFORMATION
Facility: Emissions Testing Group Contact:
1001 Louisiana St., Suite 1000
Houston, fX77OO2
Erin Dunman
Air Compliance
'1667 Cole Blvd, Suite 3000
Lakewood, CO 80401
Erin_Dunman@kindermorgan. com
(30s) e14-7605
Alexa Badley
Emissions Testing Group
Alexa_Badley@kindermorgan. com
(713) 42CUU
Emissions SamplilU Process
PROCESS DESCRIPTION
The Waukesha LTM2GS| 54 (1,030 hp) reciprocating compressor engines are four
stroke, rich burn, natural gas fired internal combustion engines, equipped with an
NSCR catalyst, 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 (ET\i). 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
transferred to a computer for analysis and storage. The computer monitors the readings in
real-time and outputs the data averages to a video monitor and the hard drive. The readings
are recorded and represented in Centrai 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 orygen (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
assembiy. 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 reguiator. Stainiess steel needle valves
control the sample flow to each analyzer. See Figure 1 forthe 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. Afterthe sample has passed through the analyzer, it is purged
outside of the traiier. See Figure 1 for the flow schematic.
samolB Finer
5ampl0 Lrns
B iaJ
Chrllor
P ! gr
E!:F
Figure 1: Sample System Schematic
Table 3: Available lnstrumentation
g
-re
s-$<-
-<@-
LIS.END.
Pump t- l,lot"ln"',"0 A 5-waY v'toe
snap Frnrns --DIq- ,"no u"n. q-) Pr!$urs O iugo
lli,lio'' {fl- 3:inil: @ F,ow!.,er
gol6nord tr- 3.way vauo -C- orrsrIFiner 4--- 3:il;,0.,-,""
Parameters Manufacturer Model Deteciion Principle Range
NOx Thermo Fisher Scientific 42i Thermal reduction of NOz to NO.
Chemiluminescent reaction of NO with Og
Variable to
10,000 ppm
CO Teledyne T3OOM NDIR with Gas Filter Conelation Vanable to
'10,000 ppm
voc MAX iR Founer Transform lnfrared Soectroscoov
Oz Servomex 4900 ParamaoneJic 0lo 25oh
Barometric
Pressure Rosemount 3051 20 - 31 "Hg
WEVDry
Temperature
Humiditv
Vaisala Model HMP 233 -40'F to'140'F
0o/o - lOOo/o
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 post-catalyst.
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 wiil be
determined by the procedure in 40CFR60, Appendix A, Method 19.
Concentrations of VOC will be determined using an FTIR following ASTM D6348 as
ailowed by 40CFR60 Subpart JJJJ.
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 (DAQ) prior to completion of
any affected test and shall be documented in the ensuing report.
EPA REFERENCE AND ASTM METHODS
MErxoo 1
"Sample and Velocity }ayerses for Stationary Sources" The objective of Method 1 is
to determine the selection of sampling ports 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 from any flow disturlcance. 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. A diagram will
be found in the test repolt APPENDIX.
METHoD3A
"Determination of Orygen and Carbon Dioxide Concentrations in Emissions from
Stationary Sources (lnstumental Analyzer Procedure)" The objective of Method 34 is
to determine the 02 concentrations from the source. Method 3A entails extraction of a gas
sample from a stationary source and routing the sample through a conditioning system to
an analyzer for the measuremeni of Oz in percent. Method 34 testing wiil be performed on
each engine for the determination of Oz. 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. Calibrations and test results will be found in the
test report APPENDIX.
Mrnroo4
"Determination ol Moisture Content in Stack Gases" The oflective 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 aiternative to determine stack gas moisture.
METHoDTE
"Determination of Nitrogen Oxides Emissions 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 wiil be found in the test
report APPENDIX along with NOx converter check results and calibration gas certificates.
MErr{oo {O
"Determination of Carbon Monoxide Emissions 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 performed on each engine for
the determination of CO. 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. Calibrations and test results will be found in the test report
APPENDIX.
MEIHoD 19
"Determination of Sulfur Dioxide Removal Efficiency and Particulate Malter, Sulfur
Dioxide, and Nitrogen Oxide Emission Rates" The objective of Method 19 testing is to
determine the emissions exhaust flow. Method 19 entaiis 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. Meihod '19 testing will be performed
on each engine for the determination of NOx emission rates if a calibrated fuel meter is
used. The NOx poilutant concentration, dry F-Factor and percent of dry Orygen
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
I The same exhaust flow calculation wil be used for CO. VOC, and Totai VOC
ASTM D6344
"Determination of Gasaus Compounds by Extractive Dircct lnbrtace Fouier
Transform lnfrared (FTIR) Specfroscopy"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 D6348 testing wiil be performed on each engine for the determination
of VOC in ppmurv. The acetaldehyde/tracer spike, recovery analysis and minimum
detectible concentration for VOC will be wrthin 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 report APPENDIX.
I NSTRU M ENT CH ECKS AN D CALI BRATIONS
The following instrument checks and calibrations guarantee the integrity of our sampling
system and the accuracy of our data.
EPA Pnorocor- GAsEs (4OGFR6O, Appenox A - MZE.7.1|
Calibration sheets for EPA Protocol 1 calibration gases will be available at the test site and
will be included in the test report APPENDIX.
IrrenrenerrrcE REripoNsE (4{!CFR6O, ArysNrrx
^
- M7E8,z.n
Vendor instrument data concerning interference response in the NOx, CO and 02 analyzers
will be included in the test report APPENDIX.
ANALvIZER GarBRArroN Ennon Tesr (4OCFR6O, ArpENDx A - M7E823)
The measurement system will be first prepared for use. Each anaiyzer 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 analyze/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 +A 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 iest will be performed on each day of testing following
the procedure described in 40CFR60, Appendix A, Method 7E Section 8.2.4.1. The resufts
of the conversion efficiency test will be included in the test report APPENDIX.
tri: ,' . -_
SAlvtPl.E Lrrue l-lr< Cxrcx
The sample line is leak checked before the test by closing the calibration valve assembly
while the sample pump is operating. Once the maximum vacuum is reached (approximateiy
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 test 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 result of the sample line leak check wiil be
included in the test report APPENDIX.
Respouse TIME TEsr (4OCFR6O' ArpE{Dx A - M7E8,2"6)
Before sampling begins, ii will be determined if the high-level 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 will then
be switched to sample the upscale gas at the outlet of the probe until a stable reading is
obtained, within 95% of the certffied value of the upscale gas. The upscale response time
will be recorded. Next, the lowJevel gas will be introduced in the same manner as the
upscale gas. Once a stable reading is noted, within 5% of the certified 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.
SysrEM BrAs GHEcK (4OGFR6O, A,eE{DD(A -ii7E,825 & M7E.85)
Before sampling begins, the upscale gas is determined as mentioned in the Response Time
Iest section. The system bias check is conducted once prior to and once following the test
runs of the series and consists of first introducing the NOx analyze/s upscale gas directly
at the analyzer. The anal,tlzer is allowed to stabilize and the reading noted. The same gas
is introduced at the probe, passing through the entire sampie train to the analyzer and the
reading noted. The resulting readings indicate any bias attributed to the sample train. This
process is repeated with the NOx analyze/s low gas. The bias check is acceptabie if the
direct gas reading of the analyzer is within +l- 5o/o of the complete sample train reading of
the anaiyzer [per 7E.13.2].
This same procedure is repeated for CO and Oz analyzers. Sample system bias check
forms will be included in the test report APPENDIX.
Bias checks before and after each test run of the senes 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 +A 3 percent of the span value for each of the analyzers [per 7E.13.3j.
The system bias (drift) checks sheet for each test will be included in the test report
APPENDIX.
VOC lrETffifuru{ATrorrt
VOC concentrations will be determined using ASTM D6348. The insirumentation for this
test program is an IMAX-|R 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 dunng the run.
Target Analytes include but are not limited to:
Data Quality Objectives
Accuracv: The accurary of the measurements will be ensured by performing analyte
spiking, prior to the test series, in which spike recoveries will meet +l- 30o/o of predicted
value (see ASTM D6348 EQUAIIONS secflon 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 willbe collected
The QF/QC checks outlined below wiil be performed on the analyzer.
2 Acetaldehyde will be used as a sunogate for VOC during spike and recoveries.
3 SF6, CFr or C2H6 will be used as a tracer gas for acetaldeMe spikjng.
I Etllylene will be utilized as a Calibration Trarsbr Standard (CTS).
RE'/ 42 rll i2C25
Pre-test Analysis:
Minimum Detectable Concentration (MDC) will be determined by
calculating the parameters outlined in Annex A-2 of Method ASTM 06348.
lnstrument noise-limited (MDC#1 )
Analytical algorithm error (MDC#2)
Analytical algorithm error (MDC#3)
Response time will be determined as required in Section 11 of Method
ASTM D6348.
The time required for the residual gases to fall to 5% of their original value
will be determined.
Analyte spiking will be employed for determining the effectiveness of the
sampling and analytical system for transporting and quantifying the target
analytes. This technique will follow procedures outlined in Annex A-5 of
Method ASTM D6348.
System performance parameters will be determined following procedures
outlined in Annex A€ of Method ASTM D6348.
Noise Equivalent Analysis (NEA)
Line Position
Resolution
Linearity
A commercially prepared spectral library will be utilized for quantification
of collected sample spectra. As such, the resolution, line position and
apodization function used for the reference spectra will be the same for
field spectral data.
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
EMISSIONS TESTING
SArvrPr-E Locarrox ano Ser+rp
A single point probe consisting of 3/8 inch stainless tubing open at one end will be used
to collect the sample. The sampling point in the exhaust stack wiil 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, AppendixA. 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.
DErERrurNAnoN oF $rnmncanox (4OGFR6O, Arys{pD( a- M7EA12)
A stratification check will be performed on units K-1B and K-28 using the sample probe.
Three points on a line passing through the centroidal area will be used, spaced at
16.7o/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 tntemal Gombustion Engines with Gircular Stacks
For exhaust stacks larger than four inches in diameter, a stratification check will be
performed before the first run of each test.
ln order to ascertain the presence or absence of stratif cation on engines with circular stacks,
exhaust concentrations of Oz or other analytes will be measured at three points on a line
passing through the centroidal area of the exhaust duct. lf the cntenon for a three point
stratification test is not met, twelve traverse points will be utilized for the test. The mean
concentrations will be used to determine the amount of stratification. lf each of the individual
traverse point NOx concentrations is within t5 percent of the mean concentration for all
traverse points, or the individual traverse point diluent concentrations differs by no more
than t3ppm or t0.3 percent COz (or Oz) from the mean for all traverse points, the gas stream
will be considered unstratified and samples will be collected from a single point that most
closely matches the mean. lf the 0.3% criterion is not met, but the concentration at each
traverse point differs from the mean concentration for all traverse points by no more than: t
0.5% difference of mean concentration, the gas stream will be considered minimally
stratified, and samples will be taken from three points, spaced at 16.70/o,50.0% and 83.3%
of the measurement line. lf the gas stream is found to be stratified because the 0.5%
cnterion for a 3-point test is not met, twelve traverse points will be utilized for the test, in
accordance with Table 1-'1 or Table 'l-2 of 40CFR60 Appendix A, Method 1.
Fuel Gas Anar-vsts
A fuel gas sample will be taken during the testing. The sample will be analyzed by a
pipeline gas chromatograph. This analysrs wiil give the actual specific gravity and BTU
so that fuel flow and mass emissions can be accurately caiculated. The analysis will
be included in the test repoit APPENDIX.
1'l
Golplnrce TEsil RuNs
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 @ 2
90% of rated (or @ highest achievable) load. lt would be inaccurate to estimate the
anticipated production capacity of the engines pnorto the day of testing due to the variabiiity
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. Catalyst
measurements such as inlet catalyst temperature and the pressure drop across the
catalyst will be obtained 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.
Tesr REPoRT
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 will follow 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.
P.EV 47C1fr425
12
Galculations
CONCENTRATION CORRECTION
Emission concentration conections required in 40CFR60, Appendix A, Method 7E will be
calculated by using the bias check low and upscale vaiues ftom before and after the tbst.
The equation is as follours:
csas=G-c")Hum vo
Equation 1: Bias Correction Calculation
Nom'errclature:
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^; Actual concentration of the upscale calibration gas (ppmv)
REV 42 Ci,.?C25
{3
EPA F.FACTOR
A fuel specific Fd factor will be calculated as descnbed in EPA Method 19, "Determination
of Sutfur Dioxide Removal Efftcienry and Particulate, Sulfur Dioxide and Nitrogen Oxides
Emission Rates from Eiectric Utility Steam Generators'for natural gas. Equation 2 will be
used to determine the EPA fuel specific Fd factor.
- [(3.64,H*tvo) + (1.53.Cwen) + (0.14.Nzwton) - (0.46.?zwtoro))
k--Id_ GCV
-prr"rr*Equation 2: EPA FuelSpecific Fd factor
Nomenclafure:
Fa'. Fuel spectfic F-factor (dscf/MMBTU)
Hwt%t Hydrogen weight percent
Cwtvot Cadcon weight percent
Nz*rxt Nitrogen weight percent
Ozwsot Oxygen weight percent
GCV'. Heating value of the fuel (BTU/dscf)
pruetcas'. Density of the fuel gas (lb/scf)
15% O)C/GEN CORRECTION
The measured concentration of NOx will be corrected to 15% Oz as set forth in 40CFR60,
Appendix A, Method 7E.
/5.9\N)y = N?x ot, " \ng _,/r0r)
Equation 3: Emissions Conected to 15% Orygen
Nomenclafure:
N0y: Conected emission concentration (ppmvd) s
N0p6,'. Observedemissionconcentration(ppmvd)
o/o02'. ObservedO2concentration(%)
5 The sarne formula is used for CO, VOC, and Total VOC.
PEV 42Aii2C25
14
MASS EMISSION CALCULANONS, METHOD 19
The F{actor Method and guidance from Part 75 will be used to calculate mass emission
rates (lb/hr) and (glbhp-hr)for NOx, CO, and VOC. Equation 4 and Equation 5 will be
used to determine the mass emission rates.
20.9E^=CaxFdx (20.9 - o/o?2)
Equation 4: Mass Emission Rate (lb/hr)
20.9E^=CaXFdx (20.9 - o/oo2)
GCVxQhx 196
GCV 453.5
Qr, x 19? *m
Equation 5: Mass Emission Rate (g/bhp-hr)
Nomenclature:
Em,
Ca,
Fa,
o/oO2:
Qn:
GCV:
BHP:
Pollutant emission rates ( lb/hr and glbhphr)
Pollutant concentration (lb/scfl
Fuel specific F-factorfor dry Co measurement (dscf/MMBTU)
Oxygen concentration in percent, measured on a dry basis
Fuel rate from calibrated AGA compliant meter (scfl'r)
Heating value of the fuel (BTU/scf)
Brake horsepoarer
The conversion factors in Table 4 will be used to conect the pollutant concentration in ppm
to lb/scf:
Table 4: Unit Conversion Factors
To Convertfum:To IUlultiply by:
PPm NOx lb/scf 1.194 x 1t7
oom CO lb/scf 7.268 x 10€
opm CsHa lb/scf 1.1444 x1t7
P,EV 42A1nC25
{5
ASTM D6348 EQUATIONS
Mrunneu tfrecregLE Golcerrrnamon
Nomerrclature:
MDC#7
NEA:
REF
C-- "'.
Lr"fl
Lcettl
Nomendaturc:
MDC#2
P:
Cave,
cp:
NEA\s *Cref * LrefMDC#1' =
-REFgu
Lceu
Noise Limited Minimum Detectable Concentration #1
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)
Iy4DC#Z = 3 *_ Ctr),
Analytical Minimum Detectable Concentration #2
p
iZr,*"P=l
Analytical algorithm error 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 algorrthm for the analyte
on spectra P of the set (ppm)
MDC#3 =\'#' *Crel* Ltef' REF% Lceu
Equation 8: Analytical Minimum Detectable Concentration #3
REl/ 42 01/2025
16
Nomenclafuie:
MDC#3: Analytical algorithm enor minimum detectable concentration for analyte
(ppm)
REA, Residual equivalent absorbance for analyte m
REF, Root mean square absorbance value obtained on the reference spectrum
Cref'. Concentration used in generating the reference spectra for analyte m (ppm)
Lr"f'. Path length used in generating the reference spectra for analyte m (ppm)
Lcent Path length of the cell used to perform the measurements (m)
Rrrmgrrce GBr ABsonprtot{ Pem l-srgrn
Lr=
Equation 9: Reference Cell Path Length
Nomenclature:
Reference cell absorption path length (m)
FundamentalCTS absorption path length (m)
Absolute temperature of reference CTS gas (R)
Absolute temperature of fundamental CTS gas (R)
Absolute pressure of reference CTS gas (ton)
Absolute pressure of fundamental CTS gas (ton)
Concentration of reference CTS gas (ton)
Concentration of fundamentalCTS gas (ton)
Ratio of reference CTS absorbance to the fundamental CTS absorbance,
determined by classical least squares
,,(+)H@W)
Lr,
Lf,
Tr,
Tf,
Pr,
Pf,
Cr,
cf,
(fr)
REV 42 01 /2025
17
SAirprE Gs.L AssoRp'noN Panr l-ereru
Equation 10: Sample GellPath Length
Nomelrclature:
Ls, Sample cellabsorption path length (m)
Lr, Reference CTS absorption path length (m)
75, Absolute temperature of sample CTS gas (R)
T, Absolute temperature of reference CTS gas (R)
Ps, Absolute pressure of sample CTS gas (ton)
P,, Absolute pressure of reference CTS gas (ton)
Cs, Concentration of sample CTS gas (ton)
ANATYTESPlloNG
L,=1.(fi)Be)e)
Cr, Concentration of reference CTS gas (ton)
(+), Ratio of sample CTS absorbance to the reference CTS absorbance,Vr,/
determined by classical least squares
DF=Trocer-sp1ys
Tracer-p1ps6y
Equation 11: Dilution Factor
Nomencilafure:
DF Dilution factor of the spike gas
Tracer-sr,*s, Diluted tracer concentration measured in a spiked sample (ppm)
Tracer-p1psqr, Tracer concentration measured directly in undiluted spike gas (ppm)
C"q=Udil+CS
Equation 12: Expected Spike Concentration
P,gt 42UQA25
{8
Nomenclafuie:
Cexp
Uo,
Uau,
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= U" x (1 - DF)
Certified concentration of the calibration standard for the analyte (ppm)
CS=C"xDF
Dilution factor of the spike gas
Equation 13: Spike Recovery, Percent
Cs,
cs
DF
R:
Coos
Cerp
R = c=oo'x
1oo
LexP
YUET - IIRv Pqrurmrr GOilGENTRATIOT{ GORRECTION
^ C^"*
I
--"o- ., -10/oHzO1^ \100/
Equation 14: Moisture Corrected Concentration
Nomerrclafuie:
Nonrerrclafure:
Ca,
Cm"as:
o/oH20,
Percent spike recovery (%)
Observed spike concentration of the analyte (ppm)
Expected spike concentration of the analyte (ppm)
Conected pollutant concentration on a dry basis (ppmvd)
Measured pollutant concentration on a wet basis (ppmvw)
Measured effluent moisture concentration (%)
RE/ 42Ui2A?5
VOG GercLr-qnois eY REsPottrsE FAcroRs
VOC =
ethylene (ethene)
acetylene (ethyne)
propane
propylene (propene)
butane
Equation 15: VOC as Methane by Response FactorsE
Norrrencilatrre:
c12 ethylene (ethene) (ppmwt)
c13 acetylene (ethyne) (ppmvw)
c14 propane (ppmvw)
c15 propylene (propene) (ppmvw)
c16 butane (ppmvw)
V)C as propane = VOC as methanef3
Equation 16: VOC as Propane
TotalVOC = VOC as propane + CHIO
Equation 17: TotalVOC forApproval Order Permit LimitsT
6 Usirg FID response fuciors, with eth/ene, acetyiene, propyene uebhted do\m ufierl
readirgs for popane ard hrtane.
7 Used fon ppmvd @ 15o/oo.,lMrr orghphr.
L.9 x c1.2 *
2.4 x c73 *
3xc14*
2.85 x c15 *
4xc76
D-IVI.SION OF AIR QUALITY
R t 42018425
2A
belov 0 ppm, and st'aigfrt