EMISSIONS TEST PROTOCOL

Anadarko Petroleum Corporation

Stack Testing of the Main Engines on the 

Diamond Offshore BlackHawk

Drillship in the Gulf of Mexico 

Prepared for:

Anadarko Petroleum Corporation

1201 Lake Robbins Road

The Woodlands, TX 77380

Prepared by:

5540 Centerview Drive

Raleigh, NC 27606

(919) 256-6231

TRC Project No. 215228-0020

April 4, 2014
Anadarko

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Table of Contents

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TABLE OF CONTENTS

1.0 INTRODUCTION & OVERVIEW..................................................................................... 1

1.1 Purpose of Test Program ................................................................................................................ 1

1.2 Source Description.......................................................................................................................... 1

Table 1.2.1 – Source Identifications ............................................................................................... 1

1.3 Scope of Test Program.................................................................................................................... 1

Table 1.3.1 – Scope of Work............................................................................................................2

1.4 Proposed Test Schedule..................................................................................................................2

1.5 Discussion of Test Method Deviations and/or Exceptions..........................................................2

1.5.1 Substitution of EPA Method 5 for EPA Method 201A ...................................................2

1.5.2 Sampling Location in Stacks at Unusual Angles or with Sample Train Obstructions ...............2

1.5.3 Sampling for Gaseous Pollutants in Engine Exhaust Stacks .........................................3

1.6 List of Project Participants .............................................................................................................3

2.0 DESCRIPTION OF SOURCES & COLLECTION OF PROCESS DATA...............................4

2.1 List of Emission Units/Sources .....................................................................................................4

2.2 Process Data Collection ..................................................................................................................4

2.3 Emission Unit Load Levels.............................................................................................................4

2.4 Emission Unit Loading Methods ...................................................................................................4

2.5 Fuel Certifications or Analysis .......................................................................................................4

3.0 DISCUSSION OF SAMPLING LOCATIONS.....................................................................5

3.1 Engine Stacks...................................................................................................................................5

4.0 SAMPLING AND ANALYSIS PROCEDURES ..................................................................6

4.1 Traverse Point Location (EPA Method 1)......................................................................................6

4.2 Stack Gas Velocity & Volumetric Flow Rate (EPA Method 2).....................................................6

4.3 O2 & CO2 Concentrations (EPA Method 3A).................................................................................6

4.4 Moisture Content (EPA Method 4)................................................................................................7

4.5 Filterable and Condensable Particulate Matter Emissions (EPA Method 5/202).....................7

4.5.1 Sample Collection .............................................................................................................7

4.5.2 Sample Recovery...............................................................................................................8

4.5.3 Sample Analysis ................................................................................................................8

4.6 TRC CEMS.......................................................................................................................................8

4.6.1 Instrument Checks and System Integrity; Setup Day....................................................9

4.6.2 CEMS Calibrations – Methods 3A, 7E, 10 & 25A...........................................................9

4.6.3 Bias Checks – Methods 3A, 7E, 10 & 25A .......................................................................9

4.6.4 CEMS Data Acquisition System.....................................................................................10

4.6.5 CEMS Components.........................................................................................................10

4.6.5.1 O2 and CO2 Measurements (EPA Method 3A)..................................................11

Table 4.6.5.1 – TRC O2/CO2 CEMS Zero and Span Gas Ranges .................................12

4.6.5.2 NOx Measurements (EPA Method 7E)............................................................12

Table 4.6.5.2 – TRC NOx CEMS Zero and Span Gas Ranges......................................12

4.6.5.3 CO Measurements (EPA Method 10)...............................................................12

Table 4.6.5.3 – TRC CO CEMS Zero and Span Gas Ranges ........................................ 13

4.6.5.4 – VOC Measurements (EPA Method 25A)....................................................... 13

Table 4.6.5.4 TRC VOC CEMS Zero and Span Ranges ................................................14

4.6.6 Gaseous Pollutant Sampling with 3 Point Traverse .....................................................14
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TABLE OF CONTENTS (continued)

5.0 QUALITY ASSURANCE PLAN ...................................................................................... 15

5.1 QA/QC Procedures, Organization & Flow Chart ........................................................................ 15

5.2 Calibration Procedures and Frequency ....................................................................................... 15

5.2.1 Calibration Gases ............................................................................................................ 15

5.2.2 Reagent Certifications .................................................................................................... 15

5.2.3 Instrument Calibrations ................................................................................................. 15

5.3 Sample Recovery and Chain of Custody Procedures..................................................................16

5.3.1 Shipping and Packing of Samples..................................................................................16

5.3.2 Sample Traceability ........................................................................................................16

5.3.3 Chain-of-Custody Documentation.................................................................................16

5.3.3.1 Labeling...............................................................................................................16

5.3.3.2 Integrity Seals ....................................................................................................16

5.3.3.3 Chain-of-Custody Procedures...........................................................................16

5.3.3.4 Sampling Trains and Spare Equipment...........................................................16

5.4 Data Handling & Reduction Procedures .....................................................................................16

5.5 Report Content and Timing.......................................................................................................... 17

TABLES & FIGURES

Number Description

1.2.1 Source Identifications for Main Propulsion Engines ................................................................... 1

1.3.1 Scope of Work..................................................................................................................................2

4.6.5.1 TRC O2/CO2 CEMS Zero and Span Gas Ranges .........................................................................12

4.6.5.2 TRC NOx CEMS Zero and Span Gas Ranges ..............................................................................12

4.6.5.3 TRC CO CEMS Zero and Span Gas Ranges................................................................................. 13

4.6.5.4 TRC VOC CEMS Zero and Span Gas Ranges..............................................................................14
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ABBREVIATIONS

< Less than

> Greater than

% Percent

AC Alternating current

acfm Actual cubic feet per minute

ACS American Chemical Society

ASTM American Society for Testing and Materials

Btu British thermal units

° C Degrees Celsius

CEMS Continuous Emission Monitoring System 

cfm Cubic feet per minute

CFR Code of Federal Regulations

CH4 Methane

CAA Clean Air Act

CO Carbon monoxide

CO2 Carbon dioxide

CPM Condensable particulate matter

DAS Data acquisition system

DC Direct current

DI H2O Deionized water

dscfm Dry standard cubic feet per minute

EPA Environmental Protection Agency

° F Degrees Fahrenheit

FIA Flame ionization analyzer

GFC Gas filter correlation

gr/dscf Grains per dry standard cubic meter

g/kW-hr Grams per kilowatt-hour

H2O Water

hp Horsepower

hr Hour

kW Kilowatt

lb/hr Pounds per hour

lb/kW-hr Pounds per kilowatt-hour

IR Infrared

kW Kilowatt

MMBtu Million British thermal units of heat input

MSDS Material Safety Data Sheet

MW Megawatt

NDIR Non-dispersive infrared

N2 Nitrogen

NO Nitric oxide

NO2 Nitrogen dioxide

NOx Nitrogen oxides

O2 Oxygen

O3 Ozone

OCS Outer continental shelf

PC Personal computer

PM Particulate Matter as measured by EPA Method 5
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ABBREVIATIONS (continued)

PM10 Particulate matter less than 10 microns

PM2.5 Particulate matter less than 2.5 microns

PMT Photomultiplier tube

ppm Parts per million

ppmv Parts per million by volume

ppmvd Parts per million by volume, dry

ppmvw Parts per million by volume, wet

PSD Prevention of Significant Deterioration

QA Quality Assurance

QC Quality Control

RM Reference Method

SCR Selective catalytic reduction

SO2 Sulfur dioxide

SOP Standard Operating Procedure

SRM Standard Reference Material

USEPA United States Environmental Protection Agency

VAC Volts alternating current

VDC Volts direct current

VE Visible Emissions

VOC Volatile Organic Compounds
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1.0 - INTRODUCTION & OVERVIEW

1.1 Purpose of Test Program

Anadarko Petroleum Corporation (Anadarko) submitted a PSD Pre-Construction and Title V 

Operating Permit Application to conduct exploratory, completion, and associated maintenance 

activities using the Diamond Offshore Ocean BlackHawk drillship to EPA Region IV in August 

2013. Anadarko has retained TRC Environmental Corporation to conduct source testing of 

certain emission units on the BlackHawk drillship. 

This test protocol describes the emissions testing to be performed on two of the eight drillship 

main engines. Six of the main engines are identical Hyundai HiMSEN 9H32/40 4,500 kW

diesel-fired engines. Two of the main engines are identical Hyundai HiMSEN 18H32/40V 

9,000 kW diesel-fired engines. One of each type (size) of engine will be tested.

Anadarko and TRC propose to measure NOx, CO2, CO, PM, and VOC emissions that may be 

required by the current PSD and Title V Major Source Permit Application that Anadarko 

submitted to EPA Region IV in September 2013.

1.2 Source Description

Included in Table 1.2.1 is a description of the sources to be tested:

Table 1.2.1 – Source Identifications for Main Engines

ID DESCRIPTION MAKE AND MODEL RATING

DR-ME-01 Drillship Main Engine Hyundai HiMSEN 9H32/40 4,500 kW

DR-ME-07 Drillship Main Engine Hyundai HiMSEN 18H32/40V 9,000 kW

1.3 Scope of Test Program

Included in this section are tables with detailed descriptions of the scope of work at each 

emissions source. As referenced below in the last column of each table, the total number of test 

runs are calculated for each emission source. For example, an engine that will be tested at 4 

different load conditions, 3 test runs will be conducted at each load. Hence, there will be 12 

“tests” conducted at that specific emission source. Note that each test run will include 

simultaneous sampling for all of the pollutants for which that emission source must be tested. 

As an example, simultaneously testing for NOx, CO, CO2, VOC, and PM is considered one test 

run. 

Table 1.3.1 – Scope of Work for BlackHawk

ID DESCRIPTION PARAMETER

TOTAL # OF LOAD 

CONDITIONS

TOTAL # OF 

TESTS

DR-ME-01 Drillship Main Engine 9H32/40 NOx, CO, CO2, VOC, PM 20%, 40%, 60%*, 90%* 12

DR-ME-07 Drillship Main Engine 18H32/40V NOx, CO, CO2, VOC, PM 20%, 40%, 60%*, 90%* 12

TOTAL # of RUNS 24

*These loads may be decreased or not performed depending on current operations when stack testing is 

being performed.
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1.4 Proposed Test Schedule

Anadarko and TRC plan to conduct the emission tests starting in early June following the 

completion of the Noble Bob Douglas stack testing. One engine will be tested at a time. Each 

test run will be 60-minutes in duration. Three test runs will be conducted at each of four (4) 

engine loads. Hence 12 test runs will be conducted on each engine. Emission tests will be 

conducted 24-hours per day using two test crews each working 12-hour shifts. It is anticipated 

that one engine will be completed per test day. 

Anadarko will notify EPA of the test date when the test schedule is determined.

1.5 Discussion of Test Method Deviations and/or Exceptions

1.5.1 Substitution of EPA Method 5 for Method 201A

Based on TRC’s past experiences, EPA Method 201A to determine the filterable portions of PM10 

and PM2.5 cannot be effectively used on the MODU engines due to severe source test conditions 

as well as limitations of this test method. The high stack temperature and the low sampling rate 

required by Method 201A cyclones make it impractical to use Method 201A. Hence, Anadarko 

proposes to use EPA Method 5 to determine total filterable particulate emissions and EPA 

Method 202 to determine condensable particulate emissions. 

Diesel engine particle matter is typically all less than 2.5 microns in size. Typically, for diesel 

engines the Method 5 filterable PM catch is all considered to be less than 2.5 microns. 

1.5.2 Sampling Locations in Stacks at Unusual Angles or with Sample Train

Obstructions

At stacks where there are obstructions that limit access of the sample train or at stacks that are 

at unusual angles, a “split sample train” will be used. A split sample train consists of a heated 

sample probe connected to a heated “mini hot box” or heated filter housing, which in turn will 

be connected by a flexible Teflon® sample line to the back-half impinger train. The Teflon®

sample line connecting the heated filter to the Method 202 condenser and impingers will be 

unheated. This Teflon® “jumper” will be rinsed and recovered with the rinse solvents as 

specified in Method 202. 

1.5.3 Sampling for Gaseous Pollutants in Engine Exhaust Stacks

The “Revisions to Test Methods and Testing Regulations” published in the Federal Register on 

January 9, 2012, specified that engine exhausts could be sampled at the centroid of the exhaust. 

More recently, (March 10, 2014) EPA withdrew the waiver of stratification tests on engine stacks

except for stacks less than 6 inches in diameter. For engine stacks equal to or greater than 12 

inches in diameter that meet the EPA Method 1 criterion for minimum distance of 2 duct 

diameters downstream of a flow disturbance, a 3-point traverse for gaseous pollutants will be 

performed.
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1.6 List of Project Participants

The following individuals should be contacted if there are questions about the test program:

Anadarko Petroleum Corporation:

Sara Carlson

Sara.Carlson@anadarko.com

Sr HSE Representative, Gulf of Mexico

(832) 636-1273 (office)

(832) 506-0888 (cell)

Katie Maness

HSE Manager, Gulf of Mexico

Kathyrn.Maness@anadarko.com

(832) 636-2582 (office)

(281) 639-1660 (cell)

TRC Environmental Corporation

Jim Serne, PE, QSTI

JSerne@TRCSolutions.com

(919) 256-6231 (office)

(919) 302-2529 (cell)

Diamond Offshore BlackHawk

Chad Williams

Operations Manager

cwilliams@dodi.com
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2.0– DESCRIPTION OF SOURCES & 

COLLECTION OF PROCESS DATA

2.1 List of Emission Units/Sources

Only two of the 8 drillship main engines will be tested on the BlackHawk. DR-ME-01 through 

DR-ME-06 are the six (6) drillship main engines each rated at 4,500 hp and DR-ME-07 and DRME-08 are the two (2) drillship main engines each rated at 9,000 hp. These diesel-fired engines

are all Hyundai HiMSEN V – type diesel engines driving AC generators.

2.2 Emission Unit Load Levels

Anadarko intends to test each engine at four operating loads. These engines will typically 

operate at relatively low loads. The four target loads are 20%, 40%, 60% and 90%. Depending 

on the current operations 60% and 90% loads may be decrease or not performed. The measured 

pollutant emission rate data will plotted versus these loads and a graph drawn.. 

2.4 Emission Unit Loading Methods

Management of the load levels and durations will be done under the direction of the BlackHawk

personnel. 

2.5 Fuel Certification & Analysis

Anadarko will provide certification of sulfur content for each shipment of fuel from the fuel 

supplier, or they will obtain a representative fuel sample and determine the sulfur content.
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3.0–DISCUSSION OF SAMPLING LOCATIONS

Emissions testing on sea going vessels presents some very unique access and mobility challenges

as exhaust stacks often run inside of or next to inhabited spaces. Due to the gases that can be 

emitted, vessel operators cannot allow exhaust lines to be opened inside of an inhabited space. 

Further, testing of vessel main engines is typically performed at sea where vessel motions can be 

quite significant. In all situations, the test ports have to be located in an area that best provides 

safe access for all personnel in dynamic situations.

At each source, emissions will be sampled via two or more sample ports located on circular 

stacks. The samples ports will be located 90 degrees apart. If adequate straight sections of stack 

exist, ports will be located such that they are more than eight (8) stack diameters downstream 

from the nearest flow disturbance and more than two (2) stack diameters upstream from the 

nearest flow disturbance (stack exit). If an adequate straight run of pipe or stack is not available 

to meet the “8 and 2 criteria,” the ports will be located such that the sample ports will be located 

a minimum of 2 diameters after a flow disturbance and a minimum of 0.5 diameters before a 

flow disturbance. The stack diameter and distances to flow disturbances will be measured prior 

to commencing the emissions tests. The minimum allowable number of sample points will be 

utilized to conduct the emissions tests. Method 1 data sheets with the actual diameter will be 

prepared in the field and included in the test reports. A diagram of the stack and sample port 

location will also be included on the field data sheet for inclusion in the test report. If the sample 

ports are not labeled, TRC will designate left and right ports as looking from the sample probe, 

for testing purposes. To illustrate the typical size, orientation, and location of sample ports, 

photographs of the actual stacks will be provided in the Test Report. Note that many marine 

engine stacks are oriented at an angle rather than vertically. In some cases access to one of the 

ports may be blocked or limited such that only a single sample port can be accessed with a 

Method 5 sample train.

3.1 Engine Stacks

For gaseous pollutants, per the March 10, 2014 guidance issued by EPA’s Emissions 

Measurement Center, the engine stacks will be sampled using a 3-point traverse of the exhaust

stack. 

For particulate sampling, the engine stacks equal to or larger than 12-inches in diameter will be 

traversed.

The 4,500 hp engines have stacks that are 750 mm (approx. 29.5-inches) in diameter. The 

9,000 hp engines have stacks that are 1,100 mm (approx. 43.3-inches) in diameter. 
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4.0 – SAMPLING AND ANALYSIS PROCEDURES

All sampling and analytical procedures used in this test program will be based on procedures 

published by the EPA in accordance with the guidelines published in Title 40, Code of Federal 

Regulations, Part 60 (40 CFR 60), Appendix A; and in Subpart M of 40 CFR 51. Copies of these 

methods are available from the EPA EMTIC electronic bulletin board or the Code of Federal 

Regulations which can be obtained online.

 Method 1 Sample and Velocity Traverses for Stationary Sources

 Method 2 Determination of Stack Gas Velocity and Volumetric Flow Rate (Type S Pitot Tube)

 Method 3A Determination of Oxygen and Carbon Dioxide Concentrations in Emissions from 

Stationary Sources (Instrumental Analyzer Procedure) 

 Method 4 Determination of Moisture Content in Stack Gases

 Method 5 Determination of Particulate Matter Emissions from Stationary Sources

 Method 7E Determination of Nitrogen Oxides Emissions from Stationary Sources (Instrumental 

Analyzer Procedure)

 Method 10 Determination of Carbon Monoxide Emission from Stationary Sources (Instrumental 

Analyzer Procedure)

 Method 25A Determination of Total Hydrocarbons by Flame Ionization Analyzer

 Method 202 Dry Impinger Method for Determining Condensable Particulate Matter Emissions 

From Stationary Sources

4.1 Traverse Point Location (EPA Method 1)

As described in Section 3, the engine stacks will be sampled for the gaseous pollutants using a 3-

point traverse. For determining the PM emissions the engine stacks will be traversed to 

determine the gas velocity and volumetric flow rate. The procedures specified by EPA Method 1, 

“Sample and Velocity Traverses for Stationary Sources will be used to select representative flow 

and pollutant measurement locations. A measurement site where the exhaust stream is flowing 

in a known direction will be selected, and the cross section of the stack will be divided into a 

number of equal areas. A traverse point will then be located within each of these equal areas. 

The sampling traverse points for EPA Method 1 will only need to be determined once. Copies of 

the stack schematics with the actual traverse points will be included in the final report. 

4.2 Stack Gas Velocity and Volumetric Flow Rate (EPA Method 2)

This method is applicable for the determination of the average velocity and volumetric flow rate

of a gas stream. The average gas velocity in a stack will be determined from the gas density and 

from measurement of the average velocity head with a Type S (Stausscheibe or reverse type) 

pitot tube.

4.3 O2 & CO2 Concentrations (EPA Method 3A)

During each Method 5 test period, percent dry O2 and CO2 emission concentration data will be 

collected for use in supporting flow rate, emission concentration, and emission rate calculations. 
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For each test run, the molecular weight of the stack gas will be calculated per Method 3 based on 

concurrent O2 and CO2 stack gas concentrations. 

4.4 Moisture Content (EPA Method 4)

The moisture content of the stack gas will be determined gravimetrically from the weight gain in 

each impinger and the weight gain of the silica gel impinger from the Method 5/202 sampling 

trains. If PM sampling is not performed, then EPA Method 4 sample trains will be used to 

determine the stack gas moisture content, or alternatively the appropriate Method 19 F-factor 

will be used to determine the exhaust flow rate.

4.5 Filterable and Condensable Particulate Matter Emissions

(EPA Method 5/202)

4.5.1 Sample Collection

Samples will be collected isokinetically from the stack using an EPA Method 5 sampling train. 

The sampling train consists of a stainless steel or glass/quartz nozzle, and a stainless steel or 

glass-lined probe and a quartz fiber filter supported by a Teflon® frit and maintained at a 

temperature of 248oF ± 25oF, chilled impingers, and a metering console. Condensable 

particulate matter (CPM) emissions will be determined using Method 202 procedures. 

This procedure for determining CPM involves recovering the back-half of the sampling train. As 

specified in EPA Method 202, the CPM will be collected in the two empty impingers which will 

be maintained at 85°F or less by use of a chilled water recirculating pump and non-contact 

condenser. These two empty impingers are followed by a Teflon® membrane filter maintained 

between 65°F and 85°F or less. This Teflon® filter is the final sample fraction in the Method 202 

sample train. The filter is followed by two impingers in an ice bath which serve to condense any 

remaining moisture so that the stack gas moisture content can be determined. Organic 

condensable PM and inorganic condensable PM are quantified per EPA Method 202 procedures. 

Prior to sample train assembly, each of the impingers will be weighed. As previously noted, a 

Teflon® jumper may be used to connect the Method 5 front-half and the back-half Method 202 

trains. 

Prior to mobilizing for each test program, the glassware used for the Method 202 sample trains 

will be prepared by cleaning and baking as specified in EPA Method 202 in one of TRC’s 

laboratories. As an alternative to baking glassware, Method 202 allows the test crew to perform 

a proof blank of the sampling train while onsite. Field train proof blanks (FTPB) are recovered 

on-site from a clean, fully assembled sampling train prior to the first emissions test. Field train 

proof blanks will be used in lieu of the glassware baking when it is not practical to have baked 

glassware at remote locations. 

As required by Method 202, for each source category one field train recovery blank (FTRB) will 

be recovered from a sampling train after it has been used to collect emissions samples and has 

been rinsed in preparation for the second or third test in a series at a particular source. This 
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FTRB train will be purged with nitrogen. Prior to the purge, 100 ml of DI water will be added to 

the first impinger. TRC will collect and analyze a field train recovery blank (FTRB) and a field 

train proof blank (FTPB) onboard the Diamond BlackHawk. The appropriate blank value, up to 

the maximum value stated in the April 8th guidance, will be used to calculate the CPM emission 

rates. Since all of the eight engines are the same and the same fuel is used, only one FTRB will 

be collected on the drillship.

4.5.2 Sample Recovery

The front-half filter will be removed from the filter holder and placed in a petri dish. The nozzle, 

probe, and front-half of the filter holder will be rinsed with acetone into a glass jar. The filter 

and the front-half acetone rinse will be analyzed per Method 5 procedures to determine the 

filterable PM. Immediately following the test run, each of the impingers will be weighed to 

determine the post-test weight. The weight of water vapor condensed in the impingers and the 

weight of water vapor collected in the silica gel will be summed and subsequently entered into 

moisture content calculations. 

The impinger trains will be purged with filtered ultra-pure nitrogen for 60 minutes at a 

minimum rate of 14 liters per minute. The material collected in the two empty impingers of the 

Method 202 sample train will be placed in a glass sample jar. The back-half of the filter holder, 

impingers, and connecting glassware will be rinsed twice with DI water into the jar containing 

the back-half impinger catch. Next the back portion of the filter holder, the two impingers, and 

the connecting glassware will be rinsed once with acetone and then twice with hexane. These 

solvent rinses placed into a separate glass jar. In cases where a split sample train is used, the 

Teflon® jumper will be rinsed and recovered along with the components of the back-half sample 

train.

4.5.3 Sample Analysis

EPA Method 5 analytical procedures will be used to analyze the filter and front-half acetone 

rinse for filterable particulate. If a quick turnaround is needed, an onsite TRC Air 

Measurements lab may perform the Method 5 gravimetric analyses. EPA Method 5 analytical 

procedures (gravimetric) will be used to analyze the front-half PM catch, which consists of the filter 

and acetone rinse of the nozzle, probe liner, and front portion of the filter housing. EPA 202

analytical procedures will be used to analyze the combined DI water reagent/DI water rinses and 

the acetone/hexane rinses for condensable particulate matter. The water fraction will be extracted 

with hexane to separate organic material from the aqueous phase. The aqueous phase (after 

solvent extraction) will be dried down and the remaining residue weighed and reported as the 

inorganic condensable PM. The hexane rinse fraction and solvent extract will be evaporated and 

the remaining residue weighed and reported as the organic condensable PM. Resolution Analytics, 

Inc. in Fuquay-Varina, North Carolina, will perform the Method 5 and Method 202 gravimetric 

analyses, sample extractions and separations.

4.6 TRC CEMS
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Gaseous measurements will be conducted with continuous emissions monitors (CEMS). Each 

TRC CEM system includes the reference method (RM) instrumentation and a data acquisition 

system necessary to support continuous stack gas measurements. TRC uses an extractive 

system for sample gas collection and measurement, and reports pollutant concentration data on 

a dry basis. 

4.6.1 Instrument Checks and System Integrity; Setup Day

EPA Methods 3A, 7E, 10, and 25A include strict quality control performance specifications for 

the CEMS measurement system. EPA Methods 3A and 10 reference EPA Method 7E for 

applicable CEMS calibration specifications. Prior to the initiation of the field sampling, TRC will 

conduct a “setup period” that will involve a number of initial system checks, site evaluations, 

and general acceptance runs. All of these checks will be guided by TRC Standard Operating 

Procedures and will be completed prior to conducting the official test runs. 

4.6.2 CEMS Calibrations - Methods 3A, 7E, 10 & 25A

The following sequence of operations will be conducted to calibrate each Method 3A, 7E, 10, and 

25A analyzer. This activity will precede the system bias, response time, stratification, or other 

measurements made through the CEMS. 

 Complete the analyzer setup as described by the manufacturer’s specifications 

and allow the instruments to stabilize. Adjust each analyzer by introducing zero 

and calibration gases in any sequence making all necessary adjustments. 

 After the measurement system for the Method 3A, 7E, 10, and 25A analyzers have 

been prepared for use, perform a calibration error test by introducing the zero or 

low-range (< 20% of the analyzer span), mid-range (40 to 60 percent of the 

analyzer span), and high-range (100 percent of the analyzer span) calibration 

gases to each analyzer. During this check, no adjustments are made to the system 

except those necessary to achieve the correct calibration gas flow rate to the 

analyzers. Allow the analyzers to stabilize and record the result.

 Calculate the analyzer percent difference or calibration error. Calibration 

responses for the Method 3A, 7E, 10, and 25A analyzers must be within 2 percent 

of the span value for the analyzers.

4.6.3 Bias Checks - Methods 3A, 7E, 10 & 25A

The following sequence of operations will be conducted to determine the bias of the sampling 

system for the specific source and setup configuration. This activity will precede the system 

calibration and will be conducted before the response time or other measurements made 

through the CEMS.

 Align the sampling system for calibration.
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 Document the system bias checks using the DAS. 

 The DAS will record the start and stop of the CEMS bias check procedure. Zero 

air or calibration gas will be introduced into the sampling system. The 

analyzer(s) will then be allowed to reach a stable output. The analyzer response 

for the zero gas will be recorded on the DAS printout.

 An upscale calibration gas (either the high-range or mid-range calibration, 

whichever most closely matches the stack gas concentration for that parameter) 

will be introduced to the sampling system. The analyzer will be allowed to reach 

a stable output. The analyzer response will be recorded on the DAS printout for 

the upscale calibration gas.

 The procedures will be repeated for each parameter. It should be noted that zero 

gas can be used as a zero for multiple analyzers, and it is not necessary to repeat 

this procedure as long as the zero measurement is made for each analyzer.

 The CEMS bias will be calculated for each analyzer. The system bias for each 

Method 3A, 7E, 10, and 25A analyzer must be within ± 5 percent of the span 

value. 

 Method 3A, 7E, 10, and 25A CEMS system drifts will be calculated by comparing 

the system response to the zero and upscale calibration gas from the system 

response during the previous bias check. Zero and calibration drift must be 

within ± 3 percent of the analyzer span value.

4.6.4 CEMS Data Acquisition System

The TRC CEMS DAS is a PC-based system with hard disk storage and an external 8-channel 

analog-to-digital converter. The specific instrument voltage inputs are linear and directly 

proportional to the concentration of the specific gas being measured. In addition to providing 

an instantaneous display of analyzer responses, the DAS compiles and averages the analyzer 

data collected once each second and prints one-minute data averages. Data for the test period 

will be averaged and corrected for calibration error and drift using the DAS software and a 

Microsoft Excel spreadsheet program. The CEMS calibrations and run summaries are 

documented with DAS printout.

4.6.5 CEMS Components

The CEMS sample collection system for O2 and CO2 (EPA Method 3A), NO2 and NOx (EPA 

Method 7E), CO (Method 10), and VOC (Method 25A) will consist of a (heated, if necessary) 

stainless steel probe with a heated particulate filter, heated sample lines, a moisture removal 

trap, and a sample pump. All samples are routed through a distribution manifold board for 
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delivery to the analyzers. The gas sample is distributed to the individual gas analyzers at near 

atmospheric pressure and excess sample flow from the system is vented outside the system.

Calibration gases from the control panel inside the trailer are delivered through a separate line 

to the exit of the probe. During calibration, the gas flow is adjusted to be slightly greater than 

the total sample collection system flow and the small amount of excess calibration gas is vented 

through the probe assembly. The configuration of the sampling system allows for the injection 

of calibration gases either directly to the analyzers or through the entire sampling system. 

4.6.5.1 O2 and CO2 Measurements (EPA Method 3A)

O2 concentrations will be determined using a paramagnetic oxygen analyzer. The analyzer 

measures the paramagnetic susceptibility of the sample gas by means of a magneto-dynamic 

type-measuring cell. The measuring cell consists of a dumbbell of diamagnetic material, which 

is temperature controlled electronically at 50oC. The higher the oxygen concentration, the 

greater the dumbbell is deflected from its rest position. This deflection is detected by an optical 

system connected to an amplifier. Surrounding the dumbbell is a coil of wire. A current is 

passed through this coil to return the dumbbell to its original position. The current applied is 

linearly proportional to the percent oxygen concentration in the sample gas.

CO2 concentration will be measured using a NDIR analyzer. The analyzer measures gas 

concentration based on the principal that each type of gas component shows a unique 

absorption line spectrum in the infrared region. The instrument consists of an infrared light 

source, a chopper, a measuring cell and a detector filled with a gas mixture containing the gas 

component to be measured. The infrared light source emits infrared light in all directions. The 

light emitted forward is transmitted and reflected into the detectors.

The infrared light emitted backward is reflected be a reflecting surface and is added to the 

infrared light emitted forward. Arranged between the infrared light source and measuring cell is 

a chopper blade which rotates to modulate the infrared light beam at regular frequency. The 

modulated infrared light beam thus formed passes through the measuring cell filled with a 

sample gas where the light energy is partially absorbed or attenuated before it reaches the front 

chamber of the detector. Both the front and the rear chambers of the detector are filled with the 

gas component to be measured.

The infrared light energy is partially absorbed in the front chamber and residual light is 

absorbed in the rear chamber, thereby increasing pressures in both the chambers, respectively. 

Since the detector is designed to produce a pressure difference between the front and rear 

chambers, a slight gas flow is produced through a path correcting these chambers with each 

other.

The slight flow is converted into an AC electrical signal by a microflow sensor arranged in the 

communicating path. The AC signal is amplified and rectified to a DC voltage supplied to the 

output terminals and indicator.
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Table 4.6.5.1 - TRC O2/CO2 CEMS Zero and Span Gas Ranges

RANGE O2 ANALYZER CO2 ANALYZER

Zero-range Nitrogen gas Nitrogen gas

Mid-range 40 to 60% of calibration span 40 to 60% of calibration span

High-range equal to calibration span equal to calibration span

All readings will be reported within EPA Method 3A criteria. 

4.6.5.2 NOx Measurements (EPA Method 7E)

The analyzer used to measure NOx will be a chemiluminescent NO/NOx monitor. The 

instrument operation is based on the principal of the chemiluminescent reaction of NO and O3. 

When NO and O3 react light is emitted and the amount of light emitted is proportional to the 

concentration of NO in the sample gas stream. To measure NO concentrations, the gas sample 

to be analyzed is blended with O3 in the instrument's reaction chamber. The resulting 

chemiluminescence is monitored through an optical filter by a highly sensitive photomultiplier 

tube (PMT) positioned at one end of the reaction chamber. The filter/photomultiplier 

combination responds to light in a narrow wavelength band unique to this chemiluminescent 

reaction (detailed below) the filter assists and eliminates interferences in this wavelength:

NO + O3 → NO2 + O2 + hv

To measure NOx concentrations (NO plus NO2), the sample gas flow is diverted through a NO2-

to-NO converter. The chemiluminescent response in the reaction chamber to the converter 

effluent is linearly proportional to the NOx concentration entering the converter (sample gas). 

Table 4.6.5.2 - TRC NOx CEMS Zero and Span Gas Ranges

RANGE NOx ANALYZER

Zero-range Nitrogen gas

Mid-range 40 to 60% of calibration span

High-range equal to calibration span

The calibration gases for the NOX analyzer will have Protocol certified values for NO and NOX. 

An NO2 to NO Conversion Efficiency Test per Section 8.2.4 of EPA Method 7E will be conducted 

to verify that the analyzer accurately converts NO2 to NO in the NOx mode. All readings will be 

reported within EPA Method 7E criteria. 

4.6.5.3 CO Measurements (EPA Method 10)

An analyzer based on the principle of GFC will be utilized for the measurement of CO. GFC 

offers improved specificity and sensitivity over conventional NDIR techniques. GFC 

spectroscopy is based upon comparison of the detailed structure of the infrared absorption 

spectrum of the measured gas to that of other gases also present in the sample being analyzed. 
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The technique is implemented by using a high concentration sample of the measured gas, 

through the analyzer, hence the term GFC. 

Radiation from an IR source is chopped and then passed through a gas filter alternating between 

CO and N2 due to rotation of the filter wheel. The radiation then passes through a narrow 

bandpass interference filter and enters a multiple optical pass cell where absorption by the 

sample gas occurs. The IR radiation then exits the sample cell and falls on an IR detector.

The CO gas filter acts to produce a reference beam, which cannot be further attenuated by CO in 

the sample cell. The N2 side of the filter wheel is transparent to the IR radiation and therefore 

produces a measure beam that can be absorbed by CO in the cell. The chopped detector signal is 

modulated by the alternation between the two gas filters with amplitude related to the 

concentration of CO in the sample cell. Other gases do not cause modulation of the detector 

signal since they absorb the reference and measure beams equally. In this way, the GFC system 

responds specifically to CO.

Table 4.6.5.3 - TRC CO CEMS Zero and Span Gas Ranges

RANGE CO ANALYZER

Zero-range Nitrogen gas

Mid-range 40% – 60% of Span

High-range 100% of Span

4.6.5.4 VOC Measurements (EPA Method 25A)

An analyzer based on the principle of Flame Ionization will be utilized for the measurement of 

VOC. Heated flame ionization detectors (FID) and the procedures described in EPA Method 25A 

will be used to simultaneously measure the total hydrocarbon emission concentration from the 

engines. The engine exhaust gas will be transported to the analyzer through heated sample lines. 

The FIDs will be California Analytical Instruments Model 200 HFID analyzers or a similar heated 

FID. The FID will be calibrated with EPA Protocol propane calibration gases. Heated sample lines, 

designed to eliminate possible condensation of the gas stream, will be utilized to transport the 

sample streams to the analyzer. The length of heated sample line from the sampling location to the 

TRC analyzer will be approximately 100 feet or less. All of the exposed connections between the 

sample line and probe will be insulated to prevent any cold spots in the sample transport system. 

The temperature of the sample transport system will be maintained above 250 F at all times.

The THC concentration data as measured by the FIDs will be processed and gathered by a digital 

data logger and 1-minute averages will be stored on a personal computer. The data logger will 

record the output from the FIDs at a rate of once per second and these 1-second values will be used 

to form one-minute averages, which will be stored in an electronic data file for each test run. At the 

end of each one-hour test, the 60 separate one-minute averages will be stored in a spreadsheet and 
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output to a printer and the one-hour average THC concentration will be computed for each 

sampling location. Method 7E equations will be used to correct the VOC data for bias and drift. 

The VOC analyzer will be calibrated with compressed gas cylinder standards. The zero reference 

will be established with ultra high purity (UHP) hydrocarbon-free nitrogen. The instrument 

response will be established using propane EPA Protocol gases. Three calibration standards 

(zero, mid-range, and span) will be used. The zero and span response of the THC analyzer will 

be checked before and after the test program. The system bias will be checked by introducing 

zero and span gas standards at the end of the sample probe. The entire sampling system 

calibration bias will be checked by routing the calibration gases through a separate Teflon line to 

the sample probe and back through the heated sample line to the FID. A calibration check will 

be conducted before and after each test run to insure the sample line integrity and to evaluate 

analyzer drift during each test run. Records of all calibrations and calibration checks will be 

provided in an appendix to the Test Report. The VOC emissions are expected to be between zero 

and 100 ppmv.

Table 4.6.5.4 - TRC VOC CEMS Zero and Span Gas Ranges

RANGE CO ANALYZER

Zero-range Nitrogen gas

Mid-range 40% – 60% of Span

High-range 100% of Span

4.6.6 Gaseous Pollutant Sampling with 3 Point Traverse

EPA recently revised its requirements for gaseous pollutant sampling in engine stacks. The 

waiver of the requirement for stratification checks on engine stacks was withdrawn. Per the 

March 10, 2014 guidance issued by Steffan Johnson of EPA’s Emission Measurement Center, 

the gaseous pollutant sampling will be conducted at 3 traverse points. The engine stacks are 

greater than 12 inched in diameter and are located more than the minimum of 2 duct diameters 

downstream from flow disturbances.
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5.0 – QUALITY ASSURANCE PLAN

5.1 QA/QC Organization and Procedures

TRC’s air measurements services are backed by a proven Quality Assurance and Quality 

Control (QA/QC) Program which has the full support of corporate management. 

Implementation of the QA/QC Program is accomplished through the use of approved 

procedures that define the systems and practices that will be used to ensure quality and 

reliability of the test data. 

TRC’s AMS complies with the criteria specified in ASTM D7036-04, and each TRC test 

crew will include at least one person with QSTI or QI credentials. 

The TRC Quality Assurance organization consists of three levels: 

 Corporate Quality Assurance Director, who is responsible for establishing and 

overseeing the company’s quality management systems, assisting practice groups 

in setting up area-specific programs, and serving as a company resource on 

quality-related issues. Ms. Robin Nelson is the TRC Corporate QA Director.

 Air Measurements Quality Assurance Director, who is responsible for 

establishing and implementing the Air Measurements Quality Program, 

overseeing the self-assessment and quality training programs, and serving as a 

resource for addressing quality-related issues from group managers and project 

managers. Mr. Ed MacKinnon is the TRC Air Measurements QA Director.

 Project Quality Assurance Manager, who will be directly responsible for the QA 

procedures and data quality of this testing program. Mr. Carl Fink will serve as 

the Project QA Manager.

5.2 Calibration Procedures and Frequency

5.2.1 Calibration Gases

All calibration gases used to conduct instrument calibrations are prepared in accordance 

with EPA Protocol 1 and are traceable to National Institute of Standards and Technology

Reference Materials. Copies of the pertinent calibration gas certifications will be 

included in the test reports. 

5.2.2 Reagent Certifications

All reagents used for this project will conform to the specifications established by the 

Committee on Analytical Reagents or the ACS, or the best available grade. 

5.2.3 Instrument Calibrations

All instrument calibrations will meet the performance criteria defined in 40 CFR 60 

Appendix A, Method 3A, 7E, 10, and 25A.
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5.3 Sample Recovery and Chain of Custody Procedures

5.3.1 Shipping and Packing of Samples

All samples will be transported to a subcontract laboratory under custody and in 

accordance with IATA guidelines. The samples will be transported offsite on a daily 

basis, when possible, following completion of all testing. 

5.3.2 Sample Traceability

Custody records will trace a sample from the time of train setup through all transfers of 

custody until it is received by the analytical laboratory. Internal laboratory records then 

document the custody of the sample through its final disposition. These records will be 

presented with the final analytical data package.

5.3.3 Chain –of-Custody Documentation

5.3.3.1 Labeling

Preprinted sample identification labels will be used to ensure that the required 

information is entered in the field. When sample batches are shipped to the specified 

laboratory, a sample-packing list will accompany the shipment. This form is based on 

established laboratory format and will be used to document sample transfer in the field 

and from sampling personnel to the laboratory.

5.3.3.2 Integrity Seals

Integrity seals will be placed over the top of the sample shipment containers to detect 

unauthorized sample handling. Gummed labels or equivalent are acceptable for this 

purpose. The seal will include the following information: sample number and the 

signature of the person recovering the sample. 

5.3.3.3 Chain-of-Custody Procedures

All recovered samples will be recorded on the Chain-of-Custody Form. Each onsite 

recovery person will maintain a separate data sheet for the samples that he or she 

recovers. As each sample is recovered, the samples will be labeled and sealed. All chainof-custody sheets will be maintained by TRC.

5.3.3.4 Sampling Trains and Spare Equipment

TRC will have redundant equipment onsite in the event of equipment failure or 

breakage. Replacement for any equipment without on-site backup will be delivered 

within 24 hours, if possible. A complete inventory of spare equipment, reagents and 

other expendables will be onsite during the test campaign to reduce delays.

5.4 Data Handling & Reduction Procedures

The data collected in the field will be recorded on standardized data sheets or printed 

directly from the Reference CEMS system. The Field Team Leader will review the 
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collected data in the field and make note of any discrepancies or errors. The Project 

Quality Assurance Manager will review and validate the test data based on the test 

protocol and the standard operating procedures for each method. 

All data will be reported in standard units as follows:

Stack Exhaust (pollutants based on permit conditions)

1 Methods 1 & 2 - Stack exhaust flow rates (reported in dscfm and acfm)

2 Method 4 - Stack exhaust moisture content (percent)

3 Gas Diluents and Pollutants

a. Method 3A - O2 and CO2 - percent, dry, lb/hr, g/kw-hr

b. Method 5/202 – PM – gr/dscf, g/dscm, lb/hr, g/kW-hr

c. Method 7E – NO2, NOx – ppmv, lb/hr, g/kW-hr, lb/kW-hr

d. Method 10 – CO - ppmv, lb/hr, g/kW-hr, lb/kW-hr

e. Method 25A – VOC – ppmv, lb/hr, g/kW-hr, lb/kW-hr

Emission rate plots versus engine load will be provided. 

5.5 Report Content and Timing

Within 45 days of completion of the field effort, TRC will prepare and submit three (3) 

hard copies and an electronic version of the test report to Anadarko. It should be noted 

that sample transportation issues, beyond TRC’s control, from overseas projects may 

cause delays in the report preparation schedule.

Each test report will include an introduction, summary of results for each unit tested, 

descriptions of all sampling and analytical methods, QA/QC data, example calculations, 

and copies of all field and analytical data. Listed below is a minimum of the following 

reporting components:

1 Introduction

2 Summary of Results (narrative plus table of results in comparison to 

emissions limits)

3 Source Description

4 Sampling and Analytical Procedures

a. Overview

b. Field Program Description

c. Testing Methodology

d. TRC CEMS

5 Quality Assurance

a. Overview

b. Field Quality Control Summary

c. Data Reduction, Validation, and Reporting

Appendix A – Printouts of Results

Appendix B – Laboratory Analysis Results (PM)

Appendix C – Engine Operating and DEWT Data
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Appendix D – Manual Calculations & Field Data

Appendix E – Equipment Calibration & Gas Certification Information

Appendix F – Project Participants