DAQ-2025-003078

1
DAQC-594-25
Site ID # 10219 (B4)
MEMORANDUM

TO: STACK TEST FILE – KINDER MORGAN ALTAMONT – Bluebell CS

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: June 24, 2025

SUBJECT: Location: 5564 North 5000 West, Cedarview, Duchesne County, Utah
Contact: Fariba Mehdizadeh, 713-420-6182 Garret Taylor 435-454-3927
Tester: Emissions Testing Group, Zachary McCain, 713-420-7434
Source: Engines C-250 and C-251
FRS ID #: UT0000004901300033
Permit# 1300033003 dated June 30, 2022, revised February 28, 2025
Subject: Review of pretest protocol dated June 16, 2025

On June 17, 2025, the DAQ received a protocol for testing engines C-250 and C-251 located at the Kinder
Morgan Altamont Bluebell Gas Processing Plant in Altamont, Duchesne County, Utah. Testing will be
performed July 21-25, 2025, to determine compliance with 40 CFR 60 Subpart JJJJ and Permit Conditions
II.B.5.a, II.B.5.b, II.B.5.c, and 40 CFR 60 Subpart JJJJ for NOx, CO, and VOC emission limits.

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: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Pretest Protocol received June 17, 2025.
* - / $ - - $ )
KINDEn*noRGAN
7 ALrAmoNr LLc
June 16, 2025
Harold Burge, Manager FEDEX
Major Source Compliance Section
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Kinder Morgan Altamont LLC
Bluebell Facility (Gas Plant), Title V Operating Permit # 1300033003
Emission Test Notice: Engines C-250, C-251
Dear Mr. Burge,
Kinder Morgan Ahamont LLC (Kinder Morgan) proposes to conduct compliance emission testing on engines C-250, C-
251at its Bluebell Facility (Bluebell) located in Duchesne County, Utah. Operation of the engines is authorized under
the referenced Title V permit issued bythe Utah Division of Air Quality (UDAQ on February 28, 2025. Testing is planned
to begin the week ol July 2L,2025.
The proposed emission testing will be conducted, in accordance with the attached testing protocol, to confirm
compliance with applicable emission limits. A summary of applicable emission limits is provided below.
DEPATTTMENT OF
ENVIITONMENTAL OUAUTY
JLIN 1 7 2C25
DIVISION OF AIR OUAI.JW
Engine lD
(Site lD)Engine Model/ HP Emission
Controls Pollutant Emission Limit Emission Umit Basis
c-250
c-257
Caterpillar G3516LE
1,340 hp
Oxidation
Catalyst
NOx 4.43\b/hr Title v 1300033003
co 1.68|b/hr Title v 1300033003
Total voc 2.O7lblhr Title V 1300033003
Please contact me at (7L3) 420-6t82 or via email at [e-mail] if you have any
questions.
Sincerely,
Fariba Mehdizadeh
EHS Engineer
.,;rl:/J,;,:1;,;//
KINDE*#uoq,H*l;Emissions Testing Group
1001 Louisiana St., Suite 1000
Houston, TX77002
Emissions Test Protocol
Tvro (2) CaHfilarG3516 tE Natlral Gas Fired Eqines
Units G2fiarnG251
Title V Operating Permit Number: 1300033003
Emissions Testing Group File # 25-158
Scheduled Test Date: Week of July 21,2025
Kinder Morgan Altamont LLC
Bluebell Facility Gas Plant
Dudrene County, tJT
Reviewed
by:
June 11r2025
State of Utah Depattment of Environmenta! Quality
Division of Air Quality (DAA)
Zackary McGain
Emissions Testing Group
(7{3) 420,-7434
Nathan Liebmann
Emisslons Testlng Group
(7{3) 420,-36,6,4
DIVISION OF AIR OUALITY
EuvinoNUElt1AL ouAqY
Date:
Prepared
for:
Prepared
by:
REV 42 01i2t-)25
Table of @ntents
INTRODUCTION
EMISSIONS SAMPLING PROCESS
GENERAL TESTING PROCEDURE ..........................5
EPA REFERENCE AND ASTM METHODS ............5
INSTRUMENT CHECKS AND CALIBRATIONS.... ......................7
EPA PRorocol Gesss (40CFR60, AppENDIx A - M7E.7.l )....... .........................7
INTERFERENCE RESPoNSE (40CFR60, AppENDIx A - M78.8.2.7) ... ...................... 7
ANALYZER CALTBRATToN ERRoR TEST (40CFR60, APpENDtx A - M78.8.2.3).. . . ..........................................7
NOu ToNO CoNVERSIoN EnHctrNcv (40CFR60, AppEttotx A-M78.8.2.4)...................................................7
tlEspoNSE TrME TEsr (40CFR60, AppENDIx A - M7E.8 .2.6)............... ................. 8
SysrEM BIAS CHECK (40CFR60, AppENDIx A - M7E.8.2.5 & M7E.8.5).. ...........8
VOC AND CHzO DptennrnAiloN ............ ................9
DElenurNertoN or STRaTFICAIoN (40CFR60, AppENolx A - M7E.8.1.2). . . .. . .... ............................... I I
CALCULATIONS
CoNCENTRATTON CORRECTION.......... .............. 13
l5% oxYGEN CORRECTION ................... .............. 14
MASS EMISSION CALCULATIONS, METHOD I9........... .........15
MINTMUM DETECTABLE CoNcENrRailoN................. .................... 16
RSTEnENcECELLABSoRTnON PATH LENGTH......... ..................... 17
Sevple CELL ABSoRprroN PATH LENGTH ............. 18
WET-DRyPoLLLrrANTCoNcExrrRenoNCoRRECTloN ............. 19
VOC CALCULATToNS By RESPoNSE FACroRS....... ........................20
iii:v42 (rl./2i.ll5
List of Figures
Ust of TaHes
Table l: Engine Detail
Table 3: Available Instrumentation...........................,............................ 4
Table 4: Unit Conversion Factors........................... l5
Llst of Equations
Equation 2: EPA Fuel Specific Fd factor
Equation 3: Emissions Corrected
Equation 4: Mass Emission Rate
Equation 7: Noise Limited Minimu
Equation 8: Analytical Minimum Detectable Concentration #2.....................
Equation 9: Analytical Minimum
Equation l0: Reference Cell Path Length..........
Equation ll: Sample Cell Path l*ngth..........
Equation 12: Dilution Factor
Equation 13: Expected Spike Concentration
Equation 14: Spike Recovery, Percenl
Equation 15: Moisture Corrected Concentration
Equation 16: VOC as Methane by Response Factors......... ..............20
Equation l8: Total VOC for Approval Order Permit Limits .................20
t4
t4
l5
t6
l6
t7
t7
l8
l8
l9
l9
I
I
I
..19
l,,Ev 4'2 01t2025
lntroduction
The Company's Emissions Testing Group (ETG) will be conducting sour@ emissions
testing at the Kinder Morgan Altamont, LLC Bluebell Facili$ Gas Plant in tulfillment of the
State of Utah Department of Environmential Quality (UDEO) Title V Operating Permit
Number 1300033003. The purpose of this test is to demonstrate compliance with permitted
emission limits 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. Alltesting 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 nonethane
VOC will be reported on a propane basis. Formaldehyde emissions will be excluded for the
purpose of compliance demonstration with 40CFR60 SubpartJJJJ standards (VOC) butwill
be included fcr the purpose of compliance with VOC permit limits (Total VOC).
The testing is tentatively scheduled for the week of July 21, 2025 t 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
Table 2: Emission Units and Requirements
c-250 &
c-251
REV 4201t2025
FACILIry INFORMATION
Facili$: Kinder Morgan Altamont LLC Contact:
Bluebell Facility
Duchesne County, UT
GPS Coordinates:
LAT 40.381450 LONG -110.084043
Fariba Mehdizadeh
Air Compliance
1001 Louisiana St., Suite 1000
Houston, TX77002
[e-mail]
(713) 420$182
EM ISSIONS GROUP I N FORMATION
Facility:Emissions Testing Group Contact:
1001 Louisiana St., Suite 1000
Houston, TX77002
Zackary McCain
Emissions Testing Group
[e-mail]
(713)420-74U
2
REV 4201t2025
Emissions Sampling Process
PROCESS DESCRIPTION
The Caterpillar G3516 LE (1,340 hp @ 1,400 rpm) reciprocating compressor engines
are four stroke, lean burn, natural gas fired internal combustion engine, equipped with
an Oxidation 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 TESTVEHICLE
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 (En4. The EW 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
realtime and outputs the data averages to a video monitor and 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, including 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 stiainless
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 trailer. See Figure 1 for the flow schematic.
RZ\,./ 42 A1i2A2a
g
...*
+wL&*
l-EcElla
Pume E- Lflotrln.',.o A 6'w.v v.rv.
( t ) Pr.tturto.ur.8nr, f littns -D<F Htnd v'ki \-/il;;lo'' _5fl-ll;ii.ij: .6|nffir.,.,
Solonokr *f 3-yyryvor. €F Drt.,Fnrr 4-.,- !:;Il *,
Figure 1: Sample System Schematic
Table 3: Available Instrumentation
NOx Thermo Fisher Scientific /
Teledvne 42i I T200H Thermal reduction of NOz to NO.
Chemiluminescent reaction of NO with Os
Variable to
10,000 ppm
CO Thermo Fisher Scientific /
Teledvne 48i / T300M NDIR with Gas Filter Conelation Variable to
10.000 oom
TotalVOC MAX iR Fourier Transform I nfrared Soectroscoov
Oz Servomex 1440 I 4900 Paramaqnetic 0to25%
Barometric
Pressure Rosemount 3051 20 - 31 "Hg
WEUDry
Temperature
Humiditu
Vaisala Model HMP 233 40 "F to 140'F
0o/o -'100o/o
4
REV 42 41t20',25
@neral 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.
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 TotalVOC will be determined using an FTIR following ASTM D6348
as allowed 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 willaffect
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 report.
EPA REFERENCE AND ASTM METHODS
MerHool
"Sample and Velocity lraverses 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 fiow disturbance. 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.
Memoo3A
"Determination of Orygen and Carbon Dioxide Concentntions in Emissions from
Stationary Sources (lnstrumental Analyzer ProcedurQ" The objective of Method 3A is
to determine the Oz 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 measurement of Oz in percent. Method 3A testing will be perbrmed 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.
RFV 42 0'1 /2025
Meruoo4
"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 alternative to determine stack gas moisture.
MEmooTE
"Determination of Nitrogen Oxides Emissions from Stationary Sources (lnstrumental
Analyzer ProcedurQ" The objective of Method 7E testing is to determine the NOx
concentration ftom the source. Method 7E 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 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.
Memoo {O
"Determination of Carbon Monoxide Emissions from Sktionary Sources
(lnstrumental Analyzer ProcedurQ" 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 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 Rates' 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 rate 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. 1
' The same exhaust flow calculation will be used for CO and Total VOC.
6
l).;\j 42 ()ll'Zi).la)
ASTM D6348
"Determination of Gaseous Compounds by Extractive Direct lntertace Fourier
Transform lnfrared (FTIR) Spectroscopy" The objective of ASTM D6348 is to determine
the VOC and CHzO 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 will be performed on each engine for the
determination of VOC and CHzO 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
softryare. Calibrations and test results will be found in the test report APPENDIX.
I NSTRUM 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 Pnorocol CrAsEs (4OCFR6O, AryEtuxA -NflE.7.0
Calibration sheets for EPA Protocol 1 calibration gases will be available at the test site and
will be included in the test report APPENDIX.
I rrrnrrnercE RESFoNSE (4OGFR6O, [ppsrtDD( a - NVeS,iLl)
Vendor instrument data conceming interference response in the NOx, CO and 02 analyzers
will be included in the test report APPENDIX.
Anarv;an GaueRAnolr Ennon Tesr (4OCFR6O, APPE{DDI A - It l7E823)
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 +l- 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.
NO2 ro NO @xvrnsox ErRqexcv (4(rcFR6O, AnRetoot A-M7E,82A}
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.
P,EV 42 Cj1 2i)'25
Serupre Lne LeaxGxecx
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 (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 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 will be
included in the test report APPENDIX.
Respons= TIME TEsr (4OGFR6O, Alrsrrux a - MZE.A2.6)
Before sampling begins, it 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 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 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.
$rsrrm Bns Gxecx (4OCFR6O, AnnetuxA- 1fiE.825 & M7E.8.5)
Before sampling begins, the upscale gas is determined as mentioned in the Response Time
Iesf 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 analyzeis 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 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 acceptable if the
direct gas reading of the analyzer is within +l- 5o/o of the mmplete sample train reading of
the analyzer [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 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.
lla\.t 4? lt 1 l2!) ),)
VOG erO GHzO DSTNMINATPN
VOC and CHzO 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 Obiectives
Accuracy: 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 EQUATIONSsecfion 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 for VOC and CHzO during spike and recoveries.
3 CF1 will be used as a tracer gas for acetaldehyde spiking.I Ethylene will be utilized as a Calibration Transfer Standard (CTS).
9
REV 4201t2025
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 will follow 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 veriftcation
against pretest values:
identified in Annex A-B of Method ASTM D6348
to
t l?v 42 01t 21) 25
EMISSIONS TESTING
Sampre LocATrolr exo Sgr+.lp
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 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.
DErEnilvtlrrAnolr oF S[RATtFtcATpN (4{rcFR6O, AReetox A - M7E.8.{.2)
A stratification check will be performed on units C-250 and C-251 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.
Reciprccating lnternal Gombustion Engines with Circular Stacks
ln order to ascertain the presence or absence of stratification 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 criterion for a three point
stratification test is not met, twelve traverse points will be utilized for the test. The mean
concentrationswillbeusedtodeterminetheamountofstratification. lfeachoftheindividual
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) ftom 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
stratifted, and samples will be taken from three points, spaced a|16.7%,50.0% and 83.3%
of the measurement line. lf the gas stream is found to be stratified because the 0.5%
criterion 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 1 -2 of 40CFR60 Appendix A, Method 1 .
FuelGesAvlr.vsts
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.
RFV 42 01t2025
11
@upuarce Tesr Rurs
The exhaust gas from the engines will be sampled continuously to determine NOx, CO,
VOC, CHzO and Oz concentrations for three (3) individua! sixty (60) minute test runs
@ > 90% of rated (or @ highest achievable) load. lt would be inaccurate to estimate the
anticipated production capacity of the engines priorto 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.
TesrReponr
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.
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 values from before and after the test.
The equation is as follows:
rcsas=G-cr)#Lm-Lo
Equation 1: Bias Gorrection Calculation
Nomenclature:
Csas: Average effluent gas concentration adjusted for bias (ppmvd)
e : Average unadjusted gas concentration indicated by data recorder br 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^ot Acfual concentration of the upscale calibration gas (ppmv)
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.t3
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 Utilig Steam Generators" for naturalgas. Equation 2 will be
used to determine the EPA fuel specific Fd factor.
l(3.64. H*7o6) + (1.53 . C*ton) + (0.14 . N2v/go7o) - (0.46. Oz*tv)f
Fd. =GCV
PFuelGas
Equation 2: EPA Fuel Specific Fd factor
Nomenclature:
Fa: Fuel specific F-factor (dscf/MMBTU)
H*so7o'. Hydrogen weight percent
Cy,soTo'. Carbon weight percent
Nz*tvot Nitrogen weight percent
O2*6o7;. Oxygen weight percent
GCV: Heating value of the tuel (BTU/dscf)
ppuercast Density of the fuel gas (lb/scf)
1 5o/o O)C/GE N CORRECT! ON
The measured concentration of NOx will be corrected to 15% Oz as set forth in 40CFR60,
Appendix A, Method 7E.
us.9 1NOx - NOx oa, " \ng _ rtq)
Equation 3: Emissions Corrected to 15% Orygen
Nomenclature:
NOr: Corrected emission concentration (ppmvd) s
NOy,,y;. Observedemissionconcentration(ppmvd)
o/oor'. ObservedO2concentration(%)
s The same formula is used for CO, VOC, TotalVOC.
llFv 42 01t2n25
14
MASS EMISSION CALCUIANONS, METHOD 19
The F-factor Method and guidance from Part 75 will be used to calculate mass emission
rates (lb/hr) for NOx, CO and TotalVOC. Equation 4 will be used to determine the mass
emission rate.
Em- C4xFo"ffixQnx#
Equation 4: Mass Emission Rate (lb/hr)
Nomenclature:
Em: Pollutant emission rate (lb/hQ
Ca, Pollutant concentration (lb/scf)
Fa, Fuel specific F-factor for dry Co m€?sur€ment (dscf/MMBTU)
0/oO2: Orygen concentration in percent, measured on a dry basis
Qn: Fuel rate from calibrated AGA compliant meter (sctt)
GCV: Heating value of the fuel (BTU/scf)
The conversion hctors in Table 4 will be used to conect the pollutant concentration in ppm
to lb/scf
Table 4: Unit Convercion Factors
1.194x1o.7
7.268 x 10€
1.1444 x 1(r.7
7.7895 x 10€
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l5
ASTM D6348 EQUATIONS
Mrrruuur ITETEGTABI-E @rcenrRmor
MDC#1,
NEA:
REF:
Crrfl
Lrefl
Lcettl
NEAl,ts *Cref * Lref
MDC#1' :
-REFk,
Lceu
Equation 5: Noise Limited Minimum Detectable Concentration #1
Nomenclature:
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 *_ Ctr),
Equation 6: Analytical Minimum Detectable Goncentration #2
Nomenclature:
MDC#z: 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 algorithm for the analyte m
on spectra P of the set (ppm)
p
iZa*"
P=7
P:
Cou"
cp:
l?.Ev 4201i2025
16
MDC#3 =\w* *c'"f * Lref
REF#rs Lcel
Equation 7: Analytical Minimum Detectable Concentration #3
Nomenclature:
MDC#3: Analytical algorithm error 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
C,rft Concentration used in generating the reference spectra for analyte m (ppm)
Lref'. Path length used in generating the reference spectra for analyte m (ppm)
Lceut Path length of the cell used to perform the measurements (m)
REFERE{GE CEr ABSORPTK,T{ PENr I.grENr
Equation 8: Reference Gell Path Length
Nomenclature:
Lr: Reference cell absorption path length (m)
Lf , Fundamental CTS absorption path length (m)
Tr: Absolute temperature of reference CTS gas (R)
Tf, Absolute temperature of fundamentalCTS gas (R)
P,: Absolute pressure of reference CTS gas (torr)
Pf , Absolute pressure of fundamentalCTS gas (torr)
C,, Concentration of reference CTS gas (torr)
Cf, Concentration of fundamentalCTS gas (ton)
/g)' Ratio of reference CTS absorlcance to the fundamental CTS absorbance,\er/
determined by classical least squares
L.= Lf (+)(+)e)ai)
17
REV 420112025
Sampue Geu AesoRPTon Penr Lsrcnr
L,=I.(+)(f)exf)
Equation 9: Sample Gell Path Length
Nomenclature:
Ls: Sample cell absorption path length (m)
L,: Reference CTS absorption path length (m)
?s: Absolute temperature of sample CTS gas (R)
Tr, Absolute temperature of reference CTS gas (R)
Ps: Absolute pressure of sample CTS gas (ton)
Pr, Absolute pressure of reference CTS gas (ton)
Cs: Concentration of sample CTS gas (ton)
Cr, Concentration of reference CTS gas (ton)
//"\
Gl, Ratio of sample CTS absorlcance to the rebrence CTS absorbance,
determined by classical least squares
Anar-vrr Sptrcre
DF=Tracer-gp1y6
Tracer-p1pB67
Equation 10: Dilution Factor
Nomenclatute:
DF: Dilution factor of the spike gas
Troc€r-5p1ys: Diluted tracer concentration measured in a spiked sample (ppm)
Tracer-p1ps67: Tracer concentration measured directly in undiluted spike gas (ppm)
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.t8
Cexp=UdtL+CS
Equation 11: Expected Spike Goncentration
Nomenclature:
Cexp: Expected spike concentration of the analyte (ppm)
Ua, Concentration of the analytes in the unspiked samples (ppm)
Uau, Concentration of analytes in spiked sample effluent accounting for dilution
(ppm); Uol= U" x (1 - DF)
Cs, Certified concentration of the calibration standard for the analyte (ppm)
CS CS = Csx DF
DF: Dilution factor of the spike gas
fR::obsxlooLexp
Equation 12: Spike Recovery, Percent
Nomenclature:
R: Percent spike recovery (%)
Cobs: Observed spike concentration of the analyte (ppm)
Cexp: Expected spike concentration of the analyte (ppm)
UYtsr - Dny Pourrrerw @rc=rrnanor @nnecnor
C^ _ "meas
t - (vTl'=o\\100/
Equation 13: Moisture Corrected Concentration
Nomenclature:
Ca, Conected pollutant concentration on a dry basis (ppmvd)
Cmeas: Measured pollutant concentration on a wet basis (ppmvw)
o/oH2O, Measured effluent moisture concentration (%)
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19
VOG Glrcur.ATxtr{s ev REspoNse Facrcns
VOC:
ethylene (ethene)
acetylene (ethyne)
propane
propylene (propene)
butane
L.9 x cLZ *
2.4 x ct3 *
3xct4*
Equation 14: VOC as Methane by Response Factors8
Nomenclatute:
c12 ethylene (ethene) (ppmvw)
c13 acetylene (ethyne) (ppmvw)
c14 propane (ppmvw)
c15 propylene (propene) (ppmvw)
c16 butane (ppmvw)
VOC as propane = V)C as methane f 3
Equation 15: VOG as Prcpane
TotalV0C = VOC as propane + CH2O
Equation 16: TotalVOC forApproval Oder Permit LimltsT
2.85 x c15 *
4xcL6
ffi
DIVISION OF AIR OUALITY
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7 Used for ppnrvd @ 15o/o Oz,lb/hr or g/hphr.
20