Providing Environmental Technical Support Since 1989 

# E C 

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R Incorporated

1 MEMORANDUM

TO: Melanie King, EPA OAQPS/SPPD/ESG

FROM: Bradley Nelson, EC/R, Inc.

DATE: January 21, 2010

SUBJECT: Summary of the October 14, 2009 Tel econference with the American Petroleum

Institute and the U.S. Environmental Prot ection Agency to discuss the Proposed Test Plan for Existing Stationary Sp ark Ignition Recipr ocating Internal Combustion Engines

1.0 INTRODUCTION

The American Petroleum Institute (API) requested this teleconference with EPA to discuss the proposed national emission standard s for hazardous air po llutants (NESHAP) for existing stationary reciprocati ng internal combustion engines (R ICE), and to propose a plan to gather additional test data for spark ignition (S I) RICE. This meeting summary will be available in the docket for this rulemaking (Docke t ID No. EPA-HQ-OAR-2008-0708). The proposed NESHAP for existing stationary RICE was pub lished in the Federal Register on March 5, 2009 (74 FR 9698).

2.0 ATTENDEES

U.S. Environmental Protection Agency

Melanie King, OAQPS/SPPD/ESG Michael Horowitz, OGC Gary McAlister, OAQPS/AQAD/MTG

American Petroleum Institute

Jeff Panek, IES Roger Zygmunt, Shell Jenny Yang, Marathon Tom McGrath, IES Paul Little, Air Hygiene Jeff Adams, BP Tom Monahan, ExxonMobil Jim McCarthy, IES Lynn Reed, ONEOK2 Janet Bounds, Chevron Tim Helbig, ONEOK Matt Todd, API

EC/R Incorporated

Bradley Nelson

3.0 SUMMARY OF MEETING

API started the teleconference by asking what the status was on the extension for the SI engine portion of the final NESHAP. EPA res ponded that it is currently in discussions and expects a response on the extension in the near future.

API stated that it was in the process of developing “white papers” on the following topics: above the floor cost analysis, work prac tices for area sources, an d maintenance intervals for work practices. The papers will be submitte d to EPA when they are complete. API stated that the test data collection pr ocess for SI engines is ongoing and that it is curre ntly looking for test contractors to perform the testing. API stated that testin g would not begin until November 2009 and API plans to look at emission variabilit y during the testing campaign. EPA asked how many tests would be provided from the testing, in which API responded approximately 100 tests. The test plan for the proposed testing for SI engi nes is presented as Attachment A at the end of this meeting summary.

API asked EPA if there had been any additi onal discussions on the urban/rural issue for existing stationary SI engines at area sources. API proposed only work practice standards for rural SI engines located at area sources in comm ents on the proposed rule. EPA indicated that no

final decisions have been made on this issue. API also brought up the is sue of variability of emissions test data. EPA stated that it would prefer to have variability data for all engines in the data set. API responded that it does not have th e resources to test for variability for so many engines and stated that it could perhaps provide test data for the top 20 percent. API stated it is finalizing a technical paper on test data usi ng Method 323 and will forward to EPA when the paper is completed.

API asked EPA if it had received additional CI engine test data. API stated that the MACT floor for CI engines was based on test data from a single engine tested at various loads, which was inappropriate in API’s opinion. EPA responded that no CI engine test reports were received during the comment period, but emissi ons data was referenced in a few of the comments. EPA intends to follow up with the co mmenters to see if the referenced emissions data is available as a test report and will include in the MACT floor determinations. API also asked EPA if any decisions were made regarding the emission standards for cyclical engines, and

whether the urban/rural classificat ion would be extended to diesel engines. EPA responded that the options are being looked at and no final decisions have been made.3 API stated that next steps were to wait for the decision on the final rule extension for SI engines, and to send EPA the technical papers fo r the Method 323 testing and the variability of emissions from SI engines.4 Attachment A

40 CFR 63 Subpart ZZZZ Natural Gas Fired Engine MACT Floor Test Plan

& Equipment / Operations Information Gathering

## 40 CFR 63 Subpart ZZZZ Natural Gas Fired Engine MACT Floor Test Plan

& Equipment / Operations Information Gathering

PREPARED FOR:

Stephanie Meadows Upstream Senior Policy Analyst

American Petroleum Institute 1220 L Street, NW Washington, D.C. 20005



### PREPARED BY:

innovative environmental solutions, inc.

P.O. Box 177 Cary, IL 60013-0177

September 30, 2009 Version 1October 2, 2009

Final Draft Test Plan

1 

### MACT Floor Test Program Background and Objectives

The March 2009 proposed revisions to the Federa l National Emission Standards for Hazardous Air Pollutants (NESHAP) for reciprocating internal combustion (IC) engines (74 FR 9698) include

emission standards based on insuffici ent and technically flawed emissi ons data. The resulting paucity of data makes it impractical to complete a MACT floor analysis representative of the affected engine populations. Flaws in the existing data include em ission test methods with known negative biases and inappropriate engine operation during the testing. Based on industry comments, EPA has acknowledged that additional emissions data and anal ysis is needed to define emission limits for the

Final Rule. To address the data deficiency and inform the MACT fl oor analysis, API and a consortium of engine rental companies are coordinating an emi ssion test project on existi ng reciprocating internal combustion engines at oil and natura l gas (O&G) facilities. This docum ent identifies the Test Plan for that project to ensure accepted and consistent methods are used for the testing. The test results will be integrated into a single emissions test re port at the completion of the test program.

For major source engines and most area source engi nes, the Proposed Rule includes emission limits.

The emission limits are based on the “MACT floor” , and the technology basis is an “uncontrolled” engine. In some cases, the emission limit is the MA CT floor emission level, while in other cases EPA

assumed that “above the floor” catal ytic control is warrant ed and based the emission limit on the floor level less a 90% reduction from catalytic control. These emission limits will not be achievable by the vast majority of uncontrolled existing engines; that is, for an uncontrolled unit to meet the emission

level associated with the “best performing” MACT floor limit, catal ytic control will be required for nearly all units. Refer to API Comments 5.1 and 6.2 for additional detail.

This test program is designed to obtain uncontrolled “as found” emission data to support revisions to the MACT floor limits in the upcoming Final Rule that will amend the NES HAP for reciprocating IC engines 40 CFR, Part 63, Subpart ZZZZ. Data collected as part of this intensive effort are needed to develop technically defens ible emission standards.

The MACT floor emissions test project objectives include:

1. Establish a test program to consistently obt ain emission data for developing MACT floor emission limits that address the size, type, and ope ration of affected engines. The focus of the MACT floor testing program is primarily directed toward smaller natural gas fired engines (< 500hp).

2. Obtain operational variability data from engines th at are expected to be in the MACT floor data set (i.e. engines in the best performing 12 percent of engines in each category/subcategory) to
allow determination of emission limits that in clude normal operational va riability. Variability parameters may include:

 Excess O 2 from 4SRB;

 Percent load;

 Multiple engines of identical make / model;

 Fuel quality; and

 Ambient affects includin g temperature, relative humidity, & elevation.October 2, 2009

Final Draft Test Plan

2 Variability is an important consideration beca use it allows considera tion of operating factors when establishing the MACT floor emission limit. Thus, these data are a key component of the test program. For example, when establishing the standard, our understa nding is that EPA is not required to use an average of the best performing twelve percent of units as the MACT floor emission limit. Rather, EPA has the latitude to select the limits at the worst reasonable condition for the best controlled similar unit . [“EPA would be justified in setting the floors at a level that is a reasonable estimate of the performance of the ‘best controlled similar unit’ under the worst reasonably foreseeable circumstances.” Sierra Club v.EPA , 167 F.3d 658 (D.C. Cir. 1999)].

In addition, in Mossville Environmental Action Now v. EPA , 370 F.3d 1232 (D.C. Cir. 2004), the Court held that floors may legitimately acc ount for variability because “each [source] must meet the [specified] standard every day and under all operating conditi ons.” Thus, emission variability can be considered in setting emi ssion limits, and MACT floor emission limit can be based on the highest emissions for MACT floor engines considering operational variation.

Table 1 presents a draft test matrix template for the primary engine categories. The engine category priorities discussed in this plan are based upon the RICE fleet used by natural gas production and gathering facilities and test data reviewed in the RICE NESHAP pr oposal. As testing commitments, locations, schedules, and engine types are finalized, Table 1 will be completed as a stand alone supplementary document that identifies engine make s/models and counts. At present, industry and trade associations anticipate on th e order of 100 tests will be complete d over a range of engine types, sizes, and operating conditions.

Additional subcategories or furthe r refinement of the horsepower ra nges can be completed based on participant direction and engine types available for testing. Since the MACT floor is based on an uncontrolled engine, NSCR and oxidati on catalyst equipped engines are not preferred for the purpose of establishing the MACT floor. Should controlled engines be included in the measurement program, pre-catalyst testing is re commended. In addition, proper consider ation of air fuel ratio (AFR) system test impacts should be made. Potential test c onsiderations includes di sconnecting the AFR and reverting to manual adjustments or AFR system bypass (see 4SRB O 2 considerations below).

Similar to the proposed draft test matrix, Table 2 pres ents a table to summarize emissions data that is compiled from previously completed tests (i.e., avai lable test results from O&G companies). These data may be used to establish or confirm MACT floor emission limits or further the understanding of emissions variability. These data are expected to be very limited for smaller burn engines (i.e., where formaldehyde is needed) and primarily encompass larger lean burn units.October 2, 2009Final Draft Test Plan3Table 1. Test Matrix and Test Engine Count (MACT floor basis is 12% of the engines tested)Size Category(HP)Number of4SRBEnginesNumber of2SLBEnginesNumber of4SLBEnginesSubcategory-Specific(e.g. cranes, aircompressors, etc.)50-100 hpMACT FloorEngine CountXXXX100-250 hpMACT FloorEngine CountXXXX250-500 hpe.g. ...5 (Ajax DPC 280)MACT FloorEngine CountXXXX>500 hpTotalX Y Z AAOctober 2, 2009Final Draft Test Plan4Table 2. Existing Test Data toSupport MACT Floor DeterminationSize Category(HP)Number of4SRBEnginesNumber of2SLBEnginesNumber of4SLBEnginesSubcategory-Specific(e.g. cranes, aircompressors, etc.)50-100 hpMACT FloorEngine CountXXXX100-250 hpMACT FloorEngine CountXXXX250-500 hpMACT FloorEngine CountXXXX>500 hpe.g. ...1 - (Clark TLA-6)TotalX Y Z AAOctober 2, 2009

Final Draft Test Plan

5 

### Reference Test Methods and Procedures

Testing should be conducted in accordance with EPA/ASTM reference test methods and procedures; however, due to time constraints an d limited resources, data will typically not be specifically conform to performance or complia nce test criteria (e.g., th ree one-hour tests are not recommended for the purpose of gathering MACT floor engine performance data on multiple units when continuous test method (e.g., FTIR) is used). Because these data will be submitted to EPA for regulatory development, adherence to the test met hods is necessary. Any ex ceptions or deviations to the reference method procedures must be doc umented to assess the ap propriateness, quality, adequacy, and representativen ess of the emission data.

The testing will include a single one hour test on an “as-found” engine (i.e. no adjustment to the engine will be made – excluding 4SRB O 2 exhaust levels as discussed below). For units identified as MACT Floor engines, subse quent tests at varied load c onditions, possible varied ambient condition (e.g. early morning vs. mid-day opera tion), and, for 4SRB units, varied exhaust O 2 levels should be conducted to gather data that characterizes emi ssions variability.

Preferred Test Methods and Notes

 Although Fourier Transform Infrared spectro scopy (FTIR) – [EPA Method 320 or ASTM D6348] is more costly and resource intensiv e than the alternative Method 323 acetylacetone method, it provides near real time measurements and flexibility for assessing formaldehyde

emissions from rich burn MACT floor candidate units. Alternatives to FTIR are discussed below. FTIR species include:

- CO

- CO 2

- NO and NO 2

- Formaldehyde

- C1 – C6 speciated hydrocarbons (e.g., to determine VOCs)

- Ammonia

- Moisture

FTIR provides near real time instrument respon se and the ability to judge test results (e.g., whether the unit is a MACT floor engine). On e-minute average data should be logged and archived for all FTIR measured compounds. If Method 323 formaldehyde data are obtained, care must be taken to ensure that sample flow rates are within the pres cribed range (0.2 to 0.4 liters per minute) and three one hour test runs are re quired. A potential list of FTIR testing companies is provided as Attachment 2.

 O 2 and CO 2 by instrumentation – [EPA Method 3A] - Determination of Oxygen and Carbon

Dioxide Concentrations in Emissions from Stationary Sources (Instrumental Analyzer Procedure)] or portable analyzer [ASTM D6522-00].

 Moisture by FTIR or im pingers [EPA Method 4].October 2, 2009

Final Draft Test Plan

6  Exhaust gas flowrate by F- factor [EPA Method 19].

 Sample Ports and Location [EPA Method 1 or 1A]. Two sample ports should be located at 90 degrees apart and at least two, and ideally eight , stack or duct diameters downstream from and at least one half, and ideally two, diameters ups tream of any process ch ange or exhaust to atmosphere. One port will be used for a thermocouple measurement and the second for the heated FTIR sample probe.

 For 2SLB and 4SLB engines, the NESHAP em ission limits are based on the surrogate compound CO and a simplified gas measurement approach can be used. CO, NOx and O 2 can be measured using [ASTM D6522] - Determination of Nitrogen Oxides, Carbon Monoxide, and Oxygen Concentrations in Emissions from Natural Gas-Fired Reciprocating Engines, Combustion Turbines, Boilers, and Proce ss Heaters Using Portable Analyzers.

Quality Assurance / Quality Control

All testing should be conducted in adherence with the reference te st methods. Method deviations should be documented and explained (e.g. sample port location). Because formaldehyde is highly water soluble, sample line temperature maintena nce is required to avoid moisture condensation. Recommended additional procedures to ensure data quality include:

 Low concentration O 2 calibration gases for measuring oxygen in rich burn engines exhaust.

From EPA Method 7E/3A “to the ex tent possible, the measured emissions should be between 20 to 100 percent of the selected calibra tion span.” Thus, to measure 0.5% O 2 , the calibrated range

should be about 0 – 2%.

 Similarly, a range of CO 2 calibration gases will be required to measure CO 2 from both rich burn and lean burn engines.

 QA Spikes for the FTIR systems are recommende d for each engine using formaldehyde and the spiking compound. Stack gas formaldehyde con centrations should be measured immediately before and after the QA spike.

 CO 2 measurements by both continuous analyzer (E PA Method 3A) and by FTIR can be used to gauge the uncertainty in the FTIR emission measurements.

 The operator must identify the test load and re port the basis for determ ining the operating load

for the test.

Reporting

Emissions should be reported in units of ppmvd, ppmvd @ 15% O 2 , lb/hr, and g/hp-hr. Test reports should be provided to IES to fac ilitate review and validation of MACT floor units. Multiple test reports are not required for test campaigns on multiple engines. A single summary report is preferred.October 2, 2009

Final Draft Test Plan

7 Additional Test Considerations

Engines should be tested “as found”, and engine oper ation should not be altered or adjusted prior to initial testing other than to adjust the “baseline O 2 ” for 4SRB engines as discussed below. Operating conditions should be logg ed (see Attachment 1). Engine exhaust temperature should be

monitored for the duration of all tests. For 4S RB engines, emissions are dependent on the amount of excess oxygen (i.e., related to the air-to-fuel ratio). Thus,

Four-stroke rich burn en gine considerations:

 If the “as-found” excess O 2 is higher than 0.5%, then a shor t term test will be completed before adjusting to a “baseline O 2 level”. In this case, test the 4SRB for approximately 10 minutes at the "as found" oxygen measured value and record the data. Stable operation of the engine over this timeframe can be documented based on 1-minute test data.

 Baseline O 2 level : If the as found excess O2 is greater than 0.5%, after the step above is completed adjust the fuel regulator or carburetor setting to obtain an exhaust O 2 concentration of approximately 0.5% or lower (baseline test condition for 4SRB engines). The manual adjustment is necessary because these engines are unsophisticated and do not include active control of excess air. Complete a one hour test at this condition. This test point is likely to be the “best performing level” for that partic ular test condition (i.e., load, ambient conditions, etc.). If exhaust oxygen is at 0.5% or lower "as found", the one hour test will be completed at the as found c ondition. As found units greater than 0.5% O 2 are unlikely to be MACT floor engines – thus the excess air adjust will provide more valuable data for the analysis and the range of “as found” O 2 levels is also pertinent information.

 Subsequent fuel pressure adju stments or carburetor settings (e.g. for variability testing)

should result in exhaust O 2 concentrations less than 2 per cent for consistency with the EPA definition of a rich burn engine. The “as found” conditions should be documented as

indicated above.

Two- and four-stroke lean burn engine considerations:

 CO as surrogate for lean burn engines;

 O 2 calibrations should be within the expected range of opera tion (e.g. approximately 10 to

18 % O 2 ).

Variability Testing

If a particular engine appears to be a candidate “MACT floor” engine (i.e., within the best performing 12% based on the number of engines in th e test program), then a dditional testing will be completed on that engine. These tests will vary the excess O 2 level (via carburetor or fuel pressure adjustment) over multiple test points and also vary lo ad, as feasible. If the “as found” test was at reduced load, load adjustment to a higher load wi ll be attempted. Lower load tests will also be attempted. Multiple excess O 2 levels will be tested at each loa d. The number of data points to conduct this testing introduces test timing issues, b ecause there is not time or resources available to spend multiple days testing a single engines. Thus , abbreviated run times will be used for most testOctober 2, 2009

Final Draft Test Plan

8 conditions – i.e., ten minutes of FTIR data with stable operation and emissions stability ensured for that period.

1. Excess O 2 from 4SRB – Measure emissions for MA CT floor units to establish emission range. Simplest matrix could be lowest excess O 2 (nominally 0.5% or lower) and ~2%

excess O 2 . Additional excess air an d load conditions could be tested as time permits.

2. Percent Load – Engine load can be change d by adjusting the suc tion, restricting the discharge, and/or changing the bypass valves. Target test loads are 50%, 75%, and 100% of

maximum achievable load. These load le vels are pertinent because the “maximum achievable” load in practice for production engine s will often be less than the rated load.

When load is changed to a different test condition, obtain a ten minute test run for most

excess O 2 tests, with the 0.5% excess O 2 test and interim excess O 2 test runs lasting 10 minutes. For each load, the higher excess O 2 test run at 2% O 2 will acquire one hour of data. The higher O 2 test condition may bound the upper end of the emissions variability range, so a one hour test run is proposed for these test s. These data should provide insight on formaldehyde variability for “MACT floor” 4SRB engines. Test data should be continuously recorded during load transitions.

3. Identical Make / Model – Document informa tion on identical or “similar” MACT floor units. “Location-based” issues that may a ffect emissions such as altitude and ambient temperature may need to consider data from an engine that is the same make and model as MACT floor engines. (For example, MACT fl oor data in Texas; altitude and temperature data may be available for an identica l engine in New Mexico or Colorado.)

4. Fuel Variability – Obtain and document fuel analyses for evaluating effect on emissions.

5. Ambient parameters temperature, barometric pressure, relative hum idity, and altitude – should be documented during testing fo r evaluating the effect on emissions

6. Other

The dataset will be reviewed to evaluate whet her ambient effects can be discerned. Depending upon that review, it may be necessary to consider da ta from engines that are not MACT floor units,

but identical make and model to MACT floor units, to assess variability from external environmental factors. Fuel analysis records wi ll be collected and the da ta analyzed to assess potential impacts of varied fuel quality on emissions.



### Schedule

Pending a potential extension request, EPA has re quested all supporting MACT floor data by the end of October. Industry responses on test engines completing Table 1 and available test reports for Table 2 should be accompanied with tentative sche dule(s) for completing the test or providing the

data.October 2, 2009

Final Draft Test Plan

9 

## Attachment 1 Supplemental Engine Data

In addition to the source test report, the following information will assist in the determination of whether an engine is a “best performing 12 perc ent MACT floor engine” [Clean Air Act mandated target from §112(d)(2)]. All emissions data should be reported as ppmvd @ 15% O 2

.October 2, 2009

Final Draft Test Plan

10 

### Required Supplemental Information

Company

Contact Name __________ email address __________ Phone number __________

Engine and Driven Equipment

Engine Make __________ Engine Model ___________ Installation Date __________

Engine serial number or unique identifier __________________________________________

Engine Age ________________________

Nameplate hp _________________ Site Rated hp __________

Circle One 4SRB 2SLB 4SLB

Location _________________________________ Elevation __________(feet above sea level)

Pollution Controls Y / N Descriptio n (including make and model): _____________

______________________________________________________________________________ Ignition system _______________ (e.g. Altronic)

Engine condition upon arrival: __________________________________________________

Date and description of last preventative maintenance: _______________________________

Maintenance interval and description: _____________________________________________

Engine life cycle (overhaul interval (yr) remaining life of overhaul (yr)) _________________

Aftermarket AFR __________ As Found Setting __________

Driven Equipment

Make __________ Model ___________

Compressor Cylinder Bore __________ Stroke __________

Generator Rating __________

Test Conditions & Murphy Panel Data

Percent Load __________ including parasitic hp __________

Description of how load was determined: ____________________________________________

________________________________________________________________________________

________________________________________________________________________________ RPM __________ Suction Pressure _____ _____ Suction Temperature __________

Discharge Pressure __________ Discharge Temperature __________October 2, 2009

Final Draft Test Plan

11 Manifold Temperature __________ Pressure __________

Water Jacket Temperature __________ Co mpressor VVCP position: _____________

Fuel Gas Analysis: include repres entative fuel gas analysis

Fuel Meter: make __________ model # __________ accuracy __________  %

Fuel Line: pressure _____________ (psig) temperature ____________ ° F

EPA Test Method deviations

Describe all deviations:

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________ Test Company ___________ email address ______________ Phone number __________

Contact

Ambient Test Conditions

Temperature __________ Atmospheric Pressu re __________ Relative Humidity _________

Optional Information

Exhaust Temperature __________

Measured Fuel __________

Sample Port Location Description __________________________________________________

________________________________________________________________________________

________________________________________________________________________________October 2, 2009

Final Draft Test Plan

12 

## Attachment 2

Selected FTIR Test Companies: Note that this list is for info rmational purposes only and does not represent an endorsement of any source test firm

ACCT a Division of CECO 5440 Alder, Houston, TX 77081-1798 (800) 836-7333 Fax (713) 664-6444

actt@ceconet.com Spectral Insights LLC 214 Argonne Drive Durham, NC 27704 (919) 620-6549 www.spectralinsights.com

Air Compliance Testing, Inc.

5525 Canal Road Cleveland, Ohio 44125

216-525-0900 www.aircomp.com TRC Environmental Corporation Ross A. Thompson Lead Project Manager - Operations Manager -

Lubbock Air Measurements 7902 Oakridge Avenue Suite One Lubbock, Texas 79424

806/ 744-8422 Office

806/ 744-8423 Fax

806/ 773-8851 Cell rthompson@trcsolutions.com Air Hygiene, Inc.

Paul Little

Director of Customer Service

5634 South 122 nd East Avenue, Suite F

Tulsa OK 74146 (918) 289-6378 www.airhygiene.com

Clean Air Engineering, Inc.

500 W. Wood Street Palatine, IL 60067, USA

800-627-0033

www.cleanair.com

Enthalpy Analytical, Inc. Bryan Tyler

2202 Ellis Road Durham, NC 27703

919.850.4392 bryan.tyler@enthalpy.com

Pace Analytical

1700 Elm Street SE Minneapolis, MN 55414 (612) 607-6398 www.pacelabs.com