HomeMy WebLinkAboutDAQ-2025-0039751
DAQC-796-25
Site ID # 11168 (B4)
MEMORANDUM
TO: STACK TEST FILE – URBAN OIL AND GAS GROUP, LLC – Helper Station
THROUGH: Harold Burge, Major Source Compliance Section Manager
FROM: Robert Sirrine, Environmental Scientist
DATE: August 12, 2025
SUBJECT: Location: Located 3-miles Northeast Helper, Carbon County, Utah
Contact: Kirt Rasmussen, 435-820-9801 or 435-636-2402
Tester: Emissions Science Inc. James Olinger, 970-628-4849
Source: Engines 1801, 1802, 1972, and 1973
FRS ID #: UT0000004900700049
AO# DAQE-AN111680016-25 dated May 21, 2025
Subject: Review of Pretest Protocol dated August 11, 2025
On August 11, 2025, the Utah Division of Air Quality (DAQ) received a protocol for the emissions
testing of Engines 1801, 1802, 1972, and 1973 operating at the Kinder Morgan Altamont East Gas
Processing Plant located near Altamont, Duchesne County, Utah. Testing will be performed September
24-26, 2025, to determine compliance with NOX, CO, and VOC emission limits found in 40 CFR 60
Subpart JJJJ, and AO Condition II.B.9.a.
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. CDPHE used for portable monitor testing of CO and NOX 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 August 10, 2025.
Robert Sirrine
E.S.I
Grand Junction, CO
Phone 970.628.4849 www.emissions-science.com
Emissions Testing Protocol & Source Test Plan
Urban Oil & Gas
Helper State CPF & Helper II Compressor Stations
Carbon County, Utah
Stationary RICE
Compliance Emissions Testing Like-Kind Replacement
Monitoring: Nitrogen Oxides and Carbon Monoxide
&
Periodic Testing Using a Portable Emissions Analyzer
Approval Orders:
Helper CPF: DAQE-ANl11680016-25
Helper II: DAQE-AN2494003-04
Proposed Test Dates:
September 25th – 26th, 2025
Protocol Prepared by:
James Olinger
Emissions Science, Inc.
1
Table of Contents
Introduction: …………………………….….. Page 2
Purpose of Test ……………………………... Page 2
Description of Plant ………………………… Page 2
Description of Sources ……………………... Page 2, 3
Operation of sources during test …….……… Page 3
Test Methods ……………………………….. Page 3 - 5
Detailed Test Procedure ……………………. Page 5, 6
Test Report …………………………………. Page 6, 7
Proposed Test Dates ………………………... Page 7
Contractor Supplied Equipment …….……… Page 7
Contact Personnel …………………………... Page 7, 8
Appendices
Appendix 1 …………..Sample Calculations
Appendix 2 …………..Sample QA / QC Performance Checks
Appendix 3 …………..Sample System Schematics
Appendix 4 …………..Stack Diagram (Assumed)
2
Source Test Plan
Introduction:
Urban Oil & Gas has contracted Emissions Science, Inc. (ESI) to perform EPA approved
reference method compliance emissions tests under the requirements set forth in the
Approval Orders for: Helper State CPF: DAQE-ANl11680016-25 and Helper II, DAQE-
AN2494003-04. These tests are intended to demonstrate compliance with the conditions set
forth in the approval orders.
Purpose of Test:
The purpose of the test is to demonstrate compliance for one, like-kind replacement source at
the Helper State CPF Compressor Station by quantifying the concentrations and mass
emission rates from the exhaust stacks of one, reciprocating internal combustion engine that
drives a compressor package and the testing will sample for Carbon Monoxide (CO) and
Nitrogen Oxides (NOx).
Three additional sources at the Helper State CPF Compressor Station will be sampled using a
portable emissions analyzer under the rules and regulations from the Colorado CDPHE
portable analyzer test protocol. One source at the Helper II site will be measured also using a
portable analyzer.
Description of Facility:
The Helper Compressor Stations are located NE of Price, Utah in Carbon County. The
compressor stations are used to gather and treat natural gas for delivery into a gas pipeline.
Description of Sources to be tested:
The sources that will be tested under this source test plan are natural gas-fired, reciprocating,
internal-combustion, lean-burn engines. The sources to be tested are detailed below.
Detailed Source Information:
Helper II: Source # 1803. Caterpillar 3516 TALE. Site Rated at 1206 BHP.
Serial # WPW00319.
This source is equipped with a Caterpillar Air/Fuel Ratio Controller (AFR).
3
Detailed Source Information (Continued):
Helper State CPF: Source # 1801. Caterpillar 3516 TALE. Site Rated at 1206 BHP.
Serial # 4EK01658. (Like-kind replacement).
This source is equipped with a Caterpillar Air/Fuel Ratio Controller (AFR).
Helper State CPF: Source # 1802. Caterpillar 3516 TALE. Site Rated at 1206 BHP.
Serial # WPW02047.
This source is equipped with a Caterpillar Air/Fuel Ratio Controller (AFR).
Helper State CPF: Source # 1972. Caterpillar 3516 TALE. Site Rated at 1206 BHP.
Serial # 4EK02610.
This source is equipped with a Caterpillar Air/Fuel Ratio Controller (AFR).
Helper State CPF: Source # 1973. Caterpillar 3516 TALE. Site Rated at 1206 BHP.
Serial # 4EK05034.
This source is equipped with a Caterpillar Air/Fuel Ratio Controller (AFR).
Operation of Sources During Testing Process:
The source identified as 1801 will be tested for three, sixty-minute test runs at an operational
engine load that will equal or exceed 90% of site rated horsepower or maximum achievable
load on the test date. The horsepower will be provided by Urban Oil & Gas personnel and
operational parameters such as suction pressure, discharge pressure, unit volume, RPM’s,
Etc. are expected to be a part of the HP calculations. Caterpillar’s GERP software program
may also be used the generate a HP value. Other parameters such as RPMs,
suction/discharge pressures, site elevation, ambient temperature Etc. will also be recorded
during the testing program. It is the responsibility of Urban Oil & Gas to provide safe access
to “hand-tight” EPA compliant sample ports and the catalyst temperature & differential
pressures.
Test Methods:
ESI proposes the following EPA reference methods for this source test plan.
Note* The instrumental methods were updated by the EPA in the final rule which was
published on August 14th, 2006.
EPA Reference Method 1
Purpose: Establishing stack diameter and velocity traverse points.
Equipment: Measurement device and calculator.
Calculations: (See Appendix 1)
4
Test Methods (continued):
EPA Reference Method 2
Purpose: Determination of Stack Gas Velocity and Volumetric Flow Rate.
Equipment: Pitot Tube, Manometer / Draft Gauge, Thermocouple, Barometer.
Calculations: (See Appendix 1)
EPA Reference Method 3A
Purpose: Determination of Carbon Dioxide (CO2) & Oxygen (O2) concentrations
in exhaust gas.
Equipment: Instrumental Method using non-dispersive infra-red (NDIR) for
continuous sampling of CO2 and a paramagnetic sensor for O2.
Calculations: (See Appendix 1)
EPA Reference Method 4
Purpose: Determination of Moisture Content in Stack Gases (Gravimetric).
Equipment: Sample probe, barometer, scale, moisture train in an ice-bath
(consisting of three glass impingers to capture moisture and a fourth impinger
containing a known quantity of silica gel used as a drying agent.) and a Method 5
sampling system containing the following components: system pump, flow meter,
thermocouple, vacuum gauge, dry gas meter.
Calculations: (See Appendix 1)
EPA Reference Method 7E
Purpose: Determination of Nitrogen Oxides (NOx) Emissions from Stationary
Sources.
Equipment: Instrumental Method using Chemiluminescence based technology for
continuous sampling of Nitrogen Oxides (NOx), Heated Sample Line capable of
keeping gas sample above the point of condensation (approximately 225 degrees
F), Gas Conditioning System (to remove moisture prior to gas sample entering the
analyzers). All applicable QA/QC assurances required under EPA Method 7E such
as; calibration error checks, system bias checks, interference checks and NO2
convertor efficiency checks will be performed on the analyzer.
Calculations: (See Appendix 1)
5
Test Methods (continued):
EPA Reference Method 10
Purpose: Determination of Carbon Monoxide (CO) Emissions from Stationary
Sources.
Equipment: Instrumental Method using NDIR for continuous sampling of Carbon
Monoxide, Gas Conditioning System, Sample Probe, System Pump, Etc.
Calculations: (See Appendix 1)
Portable Analyzer Testing under the CDPHE Portable Analyzer Protocol.
(Similar to ASTM D6522-00)
Detailed Test Procedure:
For the one source requiring EPA test methods, prior to the test procedure the test site will be
inspected for potential safety hazards and a Job Site Analysis (JSA) will be held with all
persons who may be affected by the testing program. The site-specific safety plan for this
facility will be reviewed and implemented.
All equipment will be assembled, allowed to reach operational temperature and inspected for
damage and correct assembly. The exhaust stack will be measured for inside diameter and
proper sample port locations and the traverse points will be calculated and marked on the
Pitot tube according to the criteria found in EPA Method 1. The entire sampling system
(including analyzers, sample lines, moisture trains, gas meter and gas conditioning manifold)
will be tested for potential leaks. The analyzers will then be challenged with EPA Protocol
Gasses and calibrated to minimize potential drift during the sampling process.
The calibration error test, system bias check, system response time check, interference check
and NO2 => NO conversion efficiency test will be completed prior to performing any stack
sampling. Operational engine load will be determined and if found acceptable, the sampling
program will be initiated. Concurrent with the gas sample being delivered to the analyzers
(for EPA methods 3A, 7E, and 10) the pitot traverse procedure will be performed with a
dual-inclined manometer to collect the data used to calculate stack velocity and volumetric
flow from EPA method 2. Three, 60-minute sample runs will be performed on this source
measuring for NOx & CO concentrations.
A gas sample from the exhaust stack of this source will be concurrently run through a
moisture train in an ice bath to gravimetrically remove the moisture and then the dry
6
Detailed Test Procedure (continued):
sample gas will be transported to a calibrated, dry gas meter to measure sampled flow in
cubic feet. The moisture train will consist of four, glass impingers fitted with stainless-steel
tubing inserts. The first two impingers will be seeded with a small quantity of de-ionized
water and will be weighed and recorded. The third impinger will be dry and empty, weighed
and recorded. The fourth impinger will be seeded with a known quantity of silica gel as a
drying agent and will also be weighed and recorded. At the end of the sample period, all four
impingers will be weighed and recorded to determine the moisture gain from a known
sample volume of stack gas to calculate the stack moisture content as is required in EPA
method 4.
EPA methods 3A, 7E, and 10 are instrumental methods and will be completed in accordance
with instrument manufacturer specifications and under the individual method requirements
established by the EPA. A data recorder will be used to log measured data in one-minute
increments for each measured gas species.
Three additional sources (1802, 1972 & 1973) at Helper State CPF and one source at the
Helper II Compressor Station will be tested under the CDPHE Portable Analyzer Protocol
document and will also be measured for NOx & CO concentrations. A fuel consumption and
the most recent extended fuel gas analysis showing the BTU content of the fuel gas for these
sources will be provided by Urban Oil & Gas personnel. EPA Method 19 conversion factors
will be used to determine mass emission rates from these sources. The tests using the
portable emissions analyzer will be one sample of a 21-minute duration on each source.
If an accurate fuel consumption is not available, the default BSFC value detailed in the
CDPHE portable analyzer protocol will be used.
All five sources will be tested to mass emission rate limitations or concentration limitations
as are applicable in the respective approval orders for each source.
Test Report:
The test report for the EPA Compliance Testing will contain all relevant data necessary to
demonstrate a complete and accurate accounting of the testing program. The reported data
will include a summary of the test methods and results, diagrams and schematics of the
sampling system and exhaust stack, recorded field data, sample calculations used to obtain
emission rates, calibration gas certificates, analyzer calibration results and other QA/QC
measurements (such as; system bias and interference checks).
7
Test Report (continued):
The collected data for NOx and CO will be displayed in the report as a concentration of parts
per million (ppmv). The mass emission rates for NOx and CO will also be calculated in lb/hr
and to assure compliance with the permit limitations.
The draft copy of the complete test report will be available three weeks after the completion
of the testing program and the final copy will be delivered within one additional week upon
final acceptance by the client.
The portable analyzer test report will be in a basic format showing all analyzer calibration
procedures (pre/post-test, sensor stability and linearity tests) and will also illustrate measured
concentrations as well as engine operations and site conditions.
Proposed Test Dates:
ESI proposes the following test date for this project.
September 24th, 2025 – Mobilization and equipment set-up at the Helper State Facility.
September 25th, 2025 for the one source (like-kind replacement) requiring EPA Compliance
Methods.
As time allows, the additional portable analyzer tests may be accomplished after the EPA
compliance testing is completed. Alternately, if time is not available on the 25th, ESI may
perform the portable analyzer testing on 09/26/2025.
Contractor Supplied Equipment:
Emissions Science, Inc. will supply all analysis equipment, tools and personnel necessary for
the scope of this project as is required under the test methods section found in this document.
ESI will further guarantee that all equipment and methods used in the testing program will
meet or exceed minimum requirements under all applicable test methods.
Contact Personnel:
Urban Oil & Gas
Helper State CPF & Helper II Compressor Stations
Mr. Kurt Rasmussen
6825 South 5300 West
Price, UT 84501
(435) 636-2402
8
Contact Personnel (continued):
Emissions Science, Inc.
635 19 ½ Road
Grand Junction, CO 81507
Mr. James Olinger
970.628.4849
State of Utah,
Department of Environmental Quality -DAQ
1950 West North Temple
Salt Lake City, UT 84114
Mr. Harold Burge
801.536.4129
Appendix 1
Sample Emissions Calculations
2
Sample Calculations for EPA Reference Method Tests
Note: As the calculations, formulae and unit conversions used for these test procedures are too
numerous to list, the following is a selection of the primary calculations used in the various methods.
EPA Reference Method 1
Stack Diameter * Distance Percentage from Stack Wall
(Based on # of Traverse Points from Table F1-2)
EPA Reference Method 2
Section 12.5: Molecular Weight of Stack Gas
Ms = Md (1 – Bws) + 18.0*Bws …Eq. 2-6
Where:
Ms = Molecular weight of stack gas, wet basis… (lb/lbmole)
Md = Molecular weight of stack gas, dry basis
Bws = Water vapor in the gas stream proportion by volume
Section 12.6: Average Stack Gas Velocity
o KPCP√∙Pavg√(Ts(abs) / PsMs) …Eq. 2-7
85.49 m/sec [(1b/1b-mole) (in. Hg) / (oR) (in. H20)]1/2
Where:
Kp = Velocity equation constant.
Cp = Pitot tube coefficient, dimensionless
ꞏPavg = Average velocity head of stack gas… (in. H2O)
Ts(abs) = Absolute stack temperature… (oR)
Ps = Absolute stack pressure (Pbar + Pg)… (in. Hg)
Ms = Molecular weight of stack gas, wet basis… (lb/lbmole
Section 12.7: Average Stack Gas Dry Volumetric Flow Rate
o Q = 3600 (1-Bws) Vs A[ Tstd Ps / Ts(abs) Pstd] …Eq. 2-8
Where:
3600 = Conversion Factor… (Sec/hr)
Bws = Water vapor in the gas stream proportion by volume
Vs = Average stack gas velocity… (ft/sec)
A = Cross-sectional area of stack… (ft2)
Tstd = Standard absolute temperature… (528 oR)
Ts(abs) = Absolute stack temperature… (oR)
Pstd = Standard absolute pressure… (29.92 in. Hg)
Sample Calculations for EPA Reference Method Tests
3
EPA Reference Method 4
Dry Gas Volume:
Vm Y Pm Tstd Vm Pm
Vm(std) = __________ = K4 Y ______ Eq 4-3
Pstd Tm Tm
Where:
Vm(std) = Dry gas volume measured by the dry gas meter, corrected to standard conditions, dscm
(dscf).
Vm = Dry gas volume measured by dry gas meter, (dcf)
Y = Dry gas meter calibration factor.
Pm = Absolute pressure (for this method, same as barometric pressure) at the dry gas meter, (in. Hg).
Tstd = Standard absolute temperature, 528 degrees R
Pstd = Standard absolute pressure, 760 mm Hg
Tm = Absolute temperature at meter, (R)
Moisture Content:
Vwstd
Bwo = ______
Vmstd + Vwstd
Where:
Bwo = Proportion by volume of water in the gas stream (dimensionless)
Vwstd =Volume of water in the gas sample (standard conditions) cu. Ft.
Vmstd = Volume of gas sample through the dry gas meter (standard conditions)
Sample Calculations for EPA Reference Method Tests
4
EPA Method 7E
ER = Cd * 1.912 * 10-3 * Q * T
__________________
Hp-hr
Where:
ER =Emission Rate of NOx in g/hp-hr
Cd = Measured NOx concentration in parts per million by volume (ppmv).
1.912 x 10-3 = Conversion constant for ppm NOx to grams per standard cubic meter at 20 degrees
Celsius.
Q = Stack gas volumetric flow rate, in standard cubic meter per hour, dry basis.
T = Time of test run, in hours.
HP-hr = Brake work of the engine, horsepower-hour (HP-hr).
EPA Method 7E (Section 12.9) NO2 convertor oven efficiency
(NOx final – NOfinal)
EFFNO2 = ________________ X 100
(NOx peak – NOx final)
Where:
EffNO2 = NO2 to NO converter efficiency, percent.
NOX Final = The final NOX concentration observed during the converter efficiency test ppmv.
NO Final = The average NO concentration observed with the analyzer in the NO mode during the
converter efficiency test ppmv.
NOX Peak = The highest NOX concentration observed during the converter efficiency test, ppmv.
Sample Calculations for EPA Reference Method Tests
5
EPA Method 10
ER = Cd * 1.164 * 10-3 * Q * T
__________________
Hp-hr
Where:
ER =Emission Rate of CO in g/hp-hr
Cd = Measured CO concentration in parts per million by volume (ppmv).
1.164 x 10-3 = Conversion constant for ppm CO to grams per standard cubic meter at 20 degrees
Celsius.
Q = Stack gas volumetric flow rate, in standard cubic meter per hour, dry basis.
T = Time of test run, in hours.
HP-hr = Brake work of the engine, horsepower-hour (HP-hr).
Note: The proceeding test calculations are examples of the equations used in the testing procedures.
Additional or alternate EPA approved equations may also be used during the testing program.
Appendix 2
Sample QA/QC Performance Checks for Emissions Testing
Emissions Science, Inc
Quality Assurance / Quality Control Plan
(As noted and under the allowable tolerances in EPA method 7E)
¾Verification of correct Calibration Gas Selection and check on expiration dates.
¾Verification of heated sample line (above dew point of H2O) and thermocouple integrity.
¾Use of non-reactive sample transport and probe material (stainless-steel, glass, PTFE).
¾Complete system leak check.
¾Analyzer Calibration Error Check (2 or 4-point linearity check per method).
¾Sample system bias check.
¾System Response Time.
¾Analyzer Drift Assessment.
¾Annexes 1-8 QA/QC from ASTM D6348-12
¾System Purge Time.
¾Stack stratification test or minimum sample time at each point.
¾One-minute intervals for data recorder on sample run data (averaged at end of run).
¾Post-test bias check.
¾Calibration and run ‘raw’ data preserved as indelible record.
Appendix 3
Sample System Schematics
Emissions Science, Inc.
EPA Methods 2 & 4
Exhaust Stack with
sample ports
Leak-Free
Sample Pump
Moisture Train with ice bath and
"knock-out" impinger train
Sample Probe Pitot Lines
M-5 Meter Box with
vacumn gauge, dual-
inclined manometer,
bypass valves, Etc.
Vacumn
Line
Emissions Science, Inc
Emissions Science, Inc
Emissions Science, Inc.
EPA Method 7E
Exhaust Stack with
Calibration
Gas Line
3/8" Heated
System manifold with
pump, flow control
valves, overflow valve,
Etc.
System Moisture
Removal Manifold
& Particualte Filter
Chemiluminescence
Analyzer with
paramagnetic O2 sensor
System Data
Recorder
Data Collection and
calculation system
Certified
Calibration gas
Probe with
particulate filter
Emissions Science, Inc
Emissions Science, Inc.
Sample System Schematic
Exhaust Stack with
Calibration
Gas Line
Semi-Heated
System manifold with
pump, flow control
valves, overflow valve,
Particulate Filter, Etc.
Moisture Removal
System (Ice-bath &
impinger)
Portable
Emissions
Analyzer
Data Collection and
calculation system
Certified
Calibration gas
Stainless-Steel
Probe
Appendix 4
Expected Stack Configuration
Emissions Science, Inc.
EPA Method 1
Field Data Sheet
Client:Site:Unit ID:
Date:Time:
Stack Diameter (I.D.) =
Port Depth =
Upstream Disturbance =
Downstream Disturbance =
Up Stream Down Stream
Notes:
Exhaust Stack with sample ports @ 90 º angles
Engine Muffler
Emissions Science, Inc