United States Office of Air Quality Environmental Protection Planning and Standards Agency Research Triangle Park, NC 27711 EPA 454/ R 00 037 September 2001 AIR Final Report  Volume I of I Testing of a 4 Stroke Lean Burn Gas fired Reciprocating Internal Combustion Engine to Determine the Effectiveness of an Oxidation Reduction Catalyst System for Reduction of Hazardous Air Pollutant Emissions __ _ ._.. ____ _. _"^__ I. I_"~ __ .  _. ___ ._..~.   __ __  ll_____ l_._ ..  __~ FINAL REPORT TESTING OF A 4dTROKE LEAN BURN GAS FIRED RECIPROCATING INTERNAL COMBUSTION ENGINE TO DETERMINE THE EFFECTIVENESS OF AN OXIDATION CATALYST SYSTEM FOR REDUCTION OF HAZARDOUS AIR POLLUTANT EMISSIONS Prepared for:

Terry Harrison ( MD 19) Work Assignment Manager SMTG, EMC, EMAD, OAQPS U. S . Environmental Protection Agency Research Triangle Park, NC 277 11 September 2001 Submitted by:

PACIFIC ENVIRONMENTAL SERVICES, INC. 5001 S. Miami Blvd., Suite 300 Research Triangle Park, NC 27709 2077 ( 919) 941 0333 FAX ( 919) 941 0234 DISCLAIMER Pacific Environmental Services, Inc. ( PES) prepared this document under EPA Contract No. 68 D 01 003, Work Assignment No. l 04. PES reviewed this document in accordance with its internal quality assurance procedures and approved it for distribution. The contents of this document do not necessarily reflect the views and policies of the U. S. EPA. Mention of trade names does not constitute endorsement by the EPA or PES.

ii 1.0 2.0 3.0 4.0 5.0 TABLE OF CONTENTS INTRODUCTION.. ................................................... l l SUMMARY OF RESULTS ............................................. 2 l 2.1 EMISSIONS TEST LOG .......................................... 2 l 2.2 ENGINE PARAMETERS AND EXHAUST GAS FLOW RATES ......... 2 3 2.3 FTIRS AND CEM MEASUREMENTS .............................. 2 3 2.4 DESTRUCTION OF HAP BY THE CATALYST ...................... 2 8 SOURCE DESCRIPTION AND OPERATION ............................... 3 l 3.1 ENGINE DESCRIPTION ......................................... 3 1 3.2 ENGINE OPERATION DURING TESTING .......................... 3 4 SAMPLING LOCATIONS .............................................. 4 l SAMPLING AND ANALYSIS METHODS. ................................ 5 l 5.1 5.2 5.3 5.4 5.5 5.6 5.7 ` 5.8 5.9 DETERMINATION OF STACK GAS VOLUMETRIC FLOW RATE ...... 5 l DETERMINATION OF STACK GAS OXYGEN AND CARBON DIOXIDE CONTENT ..................................................... 5 3 DETERMINATION OF STACK GAS MOISTURE CONTENT .......... 5 3 DETERMINATION OF NITROGEN OXIDES ........................ 5 3 DETERMINATION OF CARBON MONOXIDE ...................... 5 5 DETERMINATION OF TOTAL HYDROCARBONS .................. 5 5 DETERMINATION OF METHANE AND NON METHANE HYDROCARBONS ............................................. 5 6 DETERMINATION OF GASEOUS ORGANIC HAPS USING FTIRS ..... 5 6 DETERMINATION OF NATURAL GAS COMPOSITION .............. 5 7 . . . 111 TABLE OF CONTENTS ( Concluded)

Page 6.0 QUALITY ASSURANCE/ QUALITY CONTROL PROCEDURES ~ RES~ TS....................................................... 6 1 6.1 FTIRS QA/ QC PROCEDURES .................................... 6 l 6.2 CEMS QA/ QC PROCEDURES .................................... 6 5 6.3 DATA QUALITY ASSESSMENT ................................. 6 12 APPENDIX A SUBCONTRWTOR TEST REPORT  COLORADO STATE UNIVERSITY ENGINES AND ENERGY CONVERSION LABORATORY, " EMISSIONS TESTING OF CONTROL DEVICES FOR RECIPROCATING INTERNAL COMBUSTION ENGINES IN SUPPORT OF REGULATORY DEVELOPMENT BY THE U. S. ENVIRONMENTAL PROTECTION AGENCY ( EPA) PHASE 2: FOUR STROKE, LEAN BURN, NATURAL GAS FIRED INTERNAL COMBUSTION ENGINES"

APPENDIXB EXAMPLE CALCULATIONS RELATED CORRESPONDENCE iv LIST OF TABLES Page Table 2.1 Emissions Test Log .............................................. 2 2 Table 2.2 Summary of Exhaust Gas Flow Rates ................................ 2 4 Table 2.3 Emission Rates of Detected FTIRS and CEMS Compounds .............. 2 6 Table 2.4 Mass Flow Scenarios ............................................. 2 9 Table 2.5 Catalyst HAP Removal Efficiencies ................................ 2 10 Table 3.1 Engine and Catalyst Specifications .................................. 3 2 Table 3.2 Summary of Nominal Engine Parameters ............................. 3 3 Table 3.3 Target Engine Operating Conditions During Testing .................... 3 5 Table 3.4 Summary of Engine Parameters  Waukesha 3521GL. ................... 3 6 Table 3.5 Summary of Engine Parameters During Baseline Runs. .................. 3 8 Table 5.1 Summary of Sampling and Analysis Methods .......................... 5 2 Table 5.2 FTIRS Analyzer Specifications ..................................... 5 7 Table 6.1 Detection Limits of FTIRS and CEMS Compounds ..................... 6 6 Table 6.2 Types and Frequencies of CEMS Analyzer Calibrations ................. 6 8 Table 6.3 Summary of Fuel Factor Values ................................... 6 l 1 Table 6.4 Summary of CEMS Analytical Detection Limits ...................... 6 12 Table 6.5 Summary of Engine and Method Performance ........................ 6 15 V LIST OF FIGURES Figure 1.1 Test Program Organization and Major Lines of Communication . . . . . . . . . . . l 3 Figure 4.1 Exhaust Piping Schematic . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2 Figure 5.1 Schematic Diagram of EECL FTIRWEMS Sampling and AnalysisSystem................................................. 5 4 vi 1.0 INTRODUCTION The United States Environmental Protection Agency ( EPA) is investigating Reciprocating Internal Combustion Engines ( RICE) to characterize engine emissions and catalyst control efficiencies of hazardous air pollutants ( HAP). This document describes the results of emissions testing conducted on a Waukesha 3521 GL natural gas fired 4 stroke, lean burn ( 4SLB) engine. Early in 1998, several industry and EPA representatives agreed that the Waukesha 3521GL engine at the Colorado State University's Engine and Energy Conversion Laboratory ( CSU EECL) is adequately representative of existing and new natural gas fired 4SLB engines. The group agreed that a matrix of test results from testing conducted at the EECL could be used to develop Maximum Achievable Control Technology ( MACT) standards for RICE. The group further agreed that an oxidation catalyst installed on the Waukesha 3521 GL could be used to determine the effectiveness of oxidation catalysts for these engines, and that the EPA could use the results from testing at the 4SLB matrix conditions at CSU as the basis for developing the MACT standard for natural gas fired 4SLB engines.

Emissions testing was conducted to estimate HAP emissions before and after the oxidation catalyst. Miratech Corporation manufactured the catalyst and EECL personnel installed it on the engine. Fourier transform infrared spectroscopy ( FTIRS) was used to measure formaldehyde, acetaldehyde, and acrolein. Continuous emission monitoring systems ( CEMS) were used to measure oxygen ( 0,), carbon dioxide ( CO,), nitrogen oxides ( NO,& carbon monoxide ( CO), total hydrocarbons ( THC), methane, and non methane hydrocarbons WC)*

Operating as a subcontractor to PES, the CSU EECL provided the facility and the engine for the test program, operated the engine at predefined conditions, and recorded engine operational data during the testing. In addition, CSU EECL personnel operated two FTIRS sampling and analysis systems and two CEMS that measured pollutants and diluents in the exhaust gas. Under a separate work assignment, Eastern Research Group ( ERG) of Morrisville, North Carolina operated an EPA owned dynamic spiking system for the validation of the FTIRS systems for formaldehyde, acetaldehyde, and acrolein.

Final Report Waukesha 352 1 GL l l September 2001 The test program organization and major lines of communication for this project are presented in Figure 1.1. The balance of this report contains the following Sections:

Section 2.0 Summary of Results Section 3 . O Source Description and Operation Section 4.0 Sampling Locations Section 5 . O Sampling and Analysis Methods Section 6.0 Quality A ssurance/ Quality Control Procedures and Results Appendix A presents the 4SLB report issued by CSU EECL on April 28,200O. Appendix B contains example calculations used by PES to calculate results, and background correspondence pertaining to the Waukesha test program.

Final Report Waukesha 352 1GL l 2 September 200 1 EPAIEMC Quality Assurance Of& xx Lara P. Autry ( 919) 541 5544 EPAIEMC Work Assignment Manager Terry Harrison ( 919) 541 5233 PES Project Manager Dennis A. Falgout ( 703) 471 8383 PES QAIQC Officer Jeff Van Atten ( 703) 471 8383 I Pretest Site Survey PES I Quality= Project Plan PES L EPAIESD Lead Engineer Sims Roy ( 919) 541 5263 Site Specific Field Test Plan Testing PES PES I Subcontractor CSUEECL Report Preparation PES Subcontractor r CSUEECL I I Figure 1.1 Test Program Organization and Major Lines of Communication Final Report Waukesha 3 52 1 GL 1 3 September 200 1 2.0 SUMMARY OF RESULTS This section provides summaries of the stack gas parameters and HAP emissions measured during the test program. Testing of the Waukesha 3 521 GL engine was conducted August 4 through August 6,1999 at CSU's Engines and Energy Conversion Laboratory in Fort Collins, Colorado. The following sub sections present the test times and durations, engine and stack gas parameters, and HAP concentrations and mass flow rates before and after the oxidation catalyst. The end of this section contains a discussion of the efficiencies at which the catalyst removed HAP.

CSU submitted a report documenting the results of the test program to PES. This report is reproduced in its entirety in Appendix A. PES discovered errors in the combustion products ( Fd) factors calculated by CSU, which resulted in errors in the calculations of pollutant mass flow rates. PES requested that CSU correct the errors and re submit the emissions calculations so that the final report could be completed. The corrected results submitted by CSU showed that only 9 of the sixteen runs used the correct'Fd values. Slight errors still exist in CSU's calculated results for Runs 2,4,7,8,10,11, and 12. In the tables that follow, the correct Fd values are used for each run. PES believes that the values expressed in these tables are correct representations of pollutant mass flow rates during the test program.

2.1 EMISSIONS TElST LOG During the test period, the test team conducted thirty four test runs using FTIRS and CEMS. These test runs consisted of sixteen 5 minute Quality Control ( QC) runs, sixteen 33 minute sampling runs for collection of FTIRS and CEMS data, and two S minute baseline runs. Table 2.1 presents the emissions test log. The test log summarizes the date and time that each run was conducted. Additional discussions regarding the engine operating parameters may be found in Section 3.0 of this document.

In Table 2.1, the sampling runs are presented in the order that they were conducted. In the tables that follow Table 2.1, the sampling runs are presented in numerical order. During the test program, engine conditions were set by making small changes in engine operation from run to run rather than large changes. The purpose of this approach was to reduce both the times between test runs to change an engine condition and the time required for the engine to stabilize after each change. The effect on the test program was that the engine load conditions for which emissions data were sought were not conducted in the same Final Report Waukesha 3521GL 2 l September 2001 TABLE 2.1 EMISSIONS TEST LOG c Date 1 Run Time 1 Run ID 1 Date 1 RunTime 1 Run ID 814199 1521 1526 Run9QC 8/ 5/ 99 2230 2235 Run6QC 814199 1552 1625 Run9 8/ S/ 99 2252 2325 . Run6 8/ 4/ 99 1 1747 1752 1 RunlQC 1 8/ 6/ 99 1 004 l 0046 1 Run7QC 814199 1812 1845 Run1 816199 02 1 O 0243 Run7 814199 2020 2025 Run 14 QC 816199 03 15 0320 Run2QC 8/ 4/ 99 2039 2 112 Run 14 816199 0328 040 1 Run2 815199 1302 1307 Run3QC 816199 0520 052s Run4QC 8/ S/ 99 1323 1356 Run3 816199 0536 0609 Run4 8/ S/ 99 1511 1516 Baseline 1 816199 0714 0719 Run8QC 8/ S/ 99 1637 1642 Run 13 QC 816199 0727 0800 Run8 8/ 5/ 99 1 1657 1730 1 Run 13 1 8/ 6/ 99 1 0902 0907 1 Run 12 QC 8/ 5/ 99 1 1805 1810 1 Run 15 QC 1 8/ 6/ 99 1 0936 1009 1 Run 12 8/ S/ 99 1815 1848 Run 15 816199 1119 1124 Run 10 QC 8/ S/ 99 1935 1940 Run 16 QC 816199 1136 1209 Run 10 815199 1952 2025 Run 16 816199 1304 1309 RunllQC 8/ 5/ 99 1 2101 2106 1 RunSQC 1 8/ 6/ 99 1 1317 1350 1 Run 11 8/ S/ 99 2117 2150 RUIl5 8/ 6/ 99 1416 1421 Baseline 2 Final Report Waukesha 3 52 1 GL 2 2 September 200 1 order that they were presented in the Quality Assurance Project Plan ( QAPP). To maintain consistency with the QAPP, the numbers denoting the engine test conditions were not changed.

2.2 ENGINE PARAMETERS AND EXHAUST GAS FLOW RATES Table 2.2 summarizes some engine and exhaust gas parameters measured and calculated during the test program. The EECL's Data Acquisition System @ AS), monitored and recorded approximately 200 engine operating parameters, and gas temperatures, and concentrations of 02, CO,, and moisture at the catalyst inlet and exhaust.

The exhaust gas volumetric flow rates upstream and downstream of the catalyst are presented for each sample run. These flow rates were calculated using a combustion products ( Fd) factor. The flows thus calculated were corrected for excess air based on the measurements of O2 concentration at each location. A new fuel factor was calculated each day based upon daily analysis of the composition of the natural gas fuel.

On August $, the oxygen monitor at the catalyst inlet failed during Run No. 3, and during the Baseline Run 1. The oxygen concentration at the catalyst inlet was reported to be 100% during these runs. Since this value is an obvious error, the oxygen concentration at the catalyst outlet was substituted for the catalyst inlet value, and used to calculate volumetric flow. The oxygen value at the catalyst inlet location during Run No. 13 of 10.44% appears higher than the other oxygen values. The monitor and the DAS data were examined. Although the value appears higher than normal, justification for invalidating the data point could not be found.

2.3 FTIRS AND CEM MEASUREMENTS Table 2.3 summarizes the mass flow rates of the FTIRS target compounds ( formaldehyde, acetaldehyde, and acrolein) and the CEMS target compounds ( carbon monoxide, nitrogen oxides, THC, methane, and NMHC).

EECL operated two FTIRS sampling and analysis systems to quantify concentrations of the target compounds. Exhaust gas samples were extracted from locations upstream and downstream of the oxidation catalyst, conditioned, and transported to a Nicolet Rega 7000 FTIRS ( upstream location) and a Nicolet Magna 560 FTIRS ( downstream location). The upstream FTIRS also measured the moisture content in the exhaust gas. Moisture measurements by the downstream FTLRS were inaccurate. EECL used a carbon balance method to calculate the moisture concentration at the downstream sampling location.

Final Report Waukesha 3 52 1 GL 2 3 September 2001 TABLE 2.2 SUMMARY OFEXHAUST GAS FLOW RATES . Run ID Run 1 Run 2 Run 3 Run 4 Run 5 Run 6 Run 7 Run 8 Engine Speed, rpm 1197 1197 1002 1002 1197 1197 1197 1001 Engine Torque, tt lb 3236 2263 3234 3235 3234 2263 3234 Horsepower, bhp 737 516 432 617 737 737 516 617 Fuel Flow Rate, sclh 5416 4114 322% 4401 5564 5377 4070 4457 Equiwlence Ratio, + 0.56 0.56 0.56 0.56 0.52 0.5% 0.5% 0.53 Lower Heating Value, Btukf 1008 1024 1024 1024 1024 1024 1024 1024 Higher Heating Value, Btulcf 1135 1095 1152 1095 1152 1152 1095 1095 Heat Rate, MMBtulhr . 6.15 4.50 3.72 4.82 6.41 6.1% 4.46 4.66 Dry Fuel Factor, Fd dsdMMBtu 8654 6645 6655 6645 8655 8655 8645 8645 Catalyst Inlet Gas Temperature, ` F 735 706 677 665 711 75% 726 663 Oxygen, % d. b. 9.80 9.62 9.61 9.60 10.5 9.10 9.20 10.50 Carbon Dioxide, % d. b. 6.2% 6.23 6.37 6.24 5.66 6.65 6.65 5.86 Moisture, % 12.3 11.7 12.3 12.0 11.6 12.7 12.4 11.6 Gas Flow Rate, dsclhr 1670 1224 1011 1307 1660 1583 1147 1413 Catalyst Outlet Gas Temperature, ` F 740 710 67% 688 718 760 731 66%

Oxygen, % d. b. 9.60 9.63 9.61 9.80 10.4 9.01 9.0% 10.5 Carbon Dioxide, % d. b. 6.46 6.42 6.40 6.41 5.96 6.83 6.7% 5.9%

Moisture, % 12.4 11.9 12.3 12.2 11.6 12.9 12.5 11.7 Gas Flow Rate, dsckn 1670 1225 1011 1307 1646 1571 1136 1413 rpm rav pardllda hlMBtulhr miUion& iihlhemnlur& perhaw ft b  foot pounds dscfMt3tu dyrtmdwdcubicfmto( exhaustproductsper bhp brdmtlorsapower MCUl6tUdheethprt@ 0%~ CS! SS&

scfh standafdwbicfeatpahOur~~ ard~. 82h kb r& 3( pasFahmm + mipmcatd966ccassAlr Yvotd. b.% vm6ybasb BWcf BrkishIhwmtWspacubicfootdnatu~ gas Lcfm dyrtandadcubicfestper~ e~ 68rand29.92hHg NOES: oz matyzar fmrulctilm at C St IIltst binQ tam ND. 3. VdJa for catalyst altkt was rrrbstauted. F, v& esforRms2,4,7,8,10,11, end12diffarfromF, vaksraportedbyCSU. Seetexton~ 2 1 fordiscussbn.

Final Report Waukesha 3521GL 2 4 September 200 1 rpn revcMicnsper~ 0 bMtwhr mtlim6rlbhlhmmluntsparhour ft b  foot pound6 dscfhemtlJ 4yr crMefeatafex~ tpr~ ts~

bhp brdlehonepower mBcn8tucfheethputg) O% excessdr scfh stmdudcuMcfeetpahow@ 86Tnd29.92htQ r degrees

+ reciprcdd% kcessAt % vofd. b.% vohmm& ybmts B&& f Eritish7? mrmtWtsparcubkfoatdndurrlO# dpdm 6ys~ cubief~~ miatte~ 68rand29.92h~

tS) Tk F, vaWea far Runs 2,4,7,8,10,11, and 12diffarfromF, values mportedby CSU. Seetext m  2 l fordbcussim. TABLE 2.2 ( CONCLUDED)

SUMMARY OF EXHAUST GAS FIBW RATES I l feet Rate, MMBtuIhr 8.18 5.89 5.90 5.97 8.80 8.03 8.33 8.24 * "` Dry Fuel Factor, F,, dscffMMBtu 8854 8845 a845 8855 8854 8855 a855 Gas Temperature, ` F ,735 737 731 738 787 722 738 730 2 _ * Oxygen, % d. b. 9.89 9.80 9.81 9.90 10.4 9.81 9.90 9.82 Carbcm Dioxide, % d. b. 8.35 8.35 8.29 ` 8.29 8.27 8.24 8.22 8.2.3 Moisture, % 12.3 12.1 12.2 12.0 12.1 12.1 12.1 12.1 , . 1 Gas Fkw Rate, dscltn 1857 1598 1803 1834 1901 1839 1734 1897 Catlilyd Outlei Gas Temperature, ` F 740 741 738 740 771 718 742 733 Oxygen, % d b. 9.70 9.73 9.79 9.85 9.81 9.89 9.82 9.80 Carbon Dioxide, % d. b. 8.51 8.5 8.47 8.41 8.38 8.41 8.35 8.38 I, ..' Moisture, % 12.5 12.3 12.4 12.1 12.2 12.3 12.2 12.2 , Gas Flaw Rate, dsclhr 1859 1588 1800 1828 1793 1851 1722 1894 Final Report Waukesha 3521GL 2 S September 200 1 TABLE23 EMISSION RATES OF DETECTED FIIRS AND CEMS COMPOUNDS Run3 1 Run4 1 Run5 1 Run6 1 Run7 1 Run8 1 Catalyst Outld Formaldehyde Acetaldehyde Acrdein Nitrogen Oxides ( as NO3 mg/ bhp hr 99 . mlWhr 160 100 mglbhp hr ND ND mlb/ hr ND ib mgbhp hr ND ND mlWhr ND ND Blmpru O. OlP 0. W I IWhr 1.42 0.724 60.1 83.1 133 . 69.7 110 57.1 113 216 121 79.2 150 NU NU ND NU ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND 0.622 0. / alI 0.65/ 1 AX I . T" I in I. I" 0.469 0.592 1.06 1.03 2.41 1.25 0.665 Carbon Monoxide glbhp hr 0.165 . 0.101 0.127 0266 0.16/ 0 115 0 * 163 IWhr 0.301 0.143 0.097 0.172 01433 0.271 0: 131 0.221 .

g/ bnp hr 2  I2 3.20 346 . 4.04 4.20 3.11 4 / 5 Methane IWhr 5.23 4.59 4.00 5.04 7: 72 4.42 3.64 4: 70 glbhp hr 0.95 1.10 1.22 0.849 1.3/ 0  692 0.662 1.23 Non methane Hydrocarbons IWhr 1.54 1.25 1.16 1.15 2.22 1.13 0.98 1.70 glbhp hr 4 / 9 563 6 51 8: 20 5 19 7: 05 f 02 ii. 4 364 4 59 6 74 Total Hydrocarbons IWhr 7: 78 8: 83 6: 24 5: 22 9: 1s Final Report Waukesha 3 52 1 GL 2 6 September 200 1 TABLE 23 ( CONCLUDED)

EMISSION RATES OF DETECTED FI'IRS AND CEMS COMPOUNDS Final Report Waukesha 3521GL 2 7 September 200 1 Formaldehyde was detected at the upstream and downstream locations during every sampling run. Neither acetaldehyde nor acrolein were detected on any sampling run either before or after the catalyst. Run by run detection limits for the FTIRS compounds are presented in Table 6.1.

EECL personnel operated two CEMS sampling and analysis systems. Engine exhaust gas samples were extracted from locations before and after the catalyst, conditioned, and transported to the CEMS analyzer racks. Moisture was removed from the gas sample before introduction to the OS, CO*, CO, and NOx analyzers. All of the CEMS target compounds were detected at the catalyst inlet and catalyst outlet.

The reported concentration of NMHC at the catalyst outlet for Run No. 8 was 284 ppmv as methane. The reported concentration at the catalyst inlet was 17 1 parts per million by volume ( ppmv) as methane. CSU examine the NMHC data and invalidated the data for this run. At the direction of the WAM? the NMHC values obtained during the 5 minute QC run conducted just prior to Run No. 8 were substituted at both locations. The NMHC concentrations were 168 ppmv as methane and 155 ppmv as methane at the catalyst inlet and outlet locations, respectively. These values are presented in Appendix C of the CSU test report.

2.4 DESTRUCTION OF HAP BY THE CATALYST There are five possible HAP mass flow rate combinations that can occur across the oxidation catalyst. Table 2.4 presents these combinations, and notes whether a destruction efficiency is reported. Out of the five possible combinations, there are two instances where the destruction efficiency of the target pollutant is reported. If the mass flow rate of a pollutant into the catalyst ( Qi3 is greater than the mass flow rate exiting the catalyst ( QO,, J, % DE is calcula ted. If the pollutant is detected entering the catalyst, but is not detected exiting the catalyst, % DE is estimated using the measured mass flow rate at the inlet, and the mass flow rate corresponding to the analytical detection limit at the outlet.

The removal efficiency of HAP for various target compounds is presented ` in Table 2.5. Formaldehyde was detected on every run that was attempted. In every case, the mass flow rate of formaldehyde into the catalyst was greater than the mass flow rate of formaldehyde leaving the catalyst. Therefore sixteen formaIdehyde removal effkiencies were reported. Neither acetaldehyde nor acrolein were detected on any run at either location. There are no removal efficiency data to present for either of these compounds.

The removal efficiency of NOx is not presented for any run. In every case, the measured concentration of NOx at the catalyst exit was greater than the measured concentration of NOx at the catalyst inlet. The difference between the outlet and the inlet Final Report Waukesha 3521GL 2 8 September 200 1 TABLE 2.4 MASS FLOW SCENARIOS I Scenario No. Result DE Reported?

1 Qin ' 0; Qout ' 0; Qin ' Qout YES 2 Qin' 0; Q,= l'+ JD YES 3 Qin < Qout NO 4 Qh= ND; Q,,> O NO 5 Qin= m; Qout= m NO values ranged from 5 parts per million by volume, dry basis ( ppmvd) to 11 ppmvd, which is 1 . O to 2.2% of the measurement range ( 0  500 ppmvd) of the NOx analyzers. The apparent increase in NOx across the catalyst may be due to uncertainty inherent in using two analyzers, and not due to any increase in the mass flow rate of NOx. Carbon monoxide was detected at the catalyst inlet and outlet on every run. The mass flow rate of carbon monoxide showed a marked decrease across the catalyst. Carbon monoxide destruction efficiencies are presented for every run.

Methane and NMHC were detected by each methane/ NMHC analyzer at both locations for every run. There are sixteen removal efficiencies calculated. The difference in methane concentrations across the catalyst averaged approximately 160 ppm for all of the runs. This corresponds to about 3% of the methane analytical range of 0  5,000 ppmv. The small difference makes it difficult to determine if there was a reduction in methane across the catalyst, or if the differences are due to uncertainty inherent in using two analyzers. The difference between the NMHC concentrations measured at the catalyst inlet and the catalyst outlet averaged about 30 ppm for all of the runs. This difference is about 6% of the NMHC analytical range of 0  500 ppmv. The data indicates that some NMHC was probably removed by the catalyst.

There are no destruction efficiencies presented for total hydocarbons. In fifteen of sixteen cases, the mass flow rate of THC exiting the catalyst was greater than the mass flow rate of THC entering the catalyst. The difference in the concentration measurements at these locations approached 1% of the THC analytical range of 0  5,000 ppmv. Therefore, there was most likely no removal of THC across the catalyst. Since THC is made up mostly of methane, this seems to indicate that the difference in methane values was most likely due to inherent measurement errors.

Final Report Waukesha 3521GL 2 9 September 2001 TABLE 2.5 CATALYST HAP REMOVAL EFFICIENCIES Non methane Hydrocarbons 12% 2% 4% 6% 14% 12% 11% 11%

21% 12% 8% 16% 38% 18% 29% 21%

Final Report Waukesha 352 1 GL 2 10 September 200 1 3.0 SOURCE DESCRIPTION AND OPERATION This section presents discussions of the candidate engine and the catalyst used for the test program. The sections that follow describe the engine and the operation of the engine . during testing.

3.1 ENGINE DESCRIPTION The Waukesha 3521GL is a 4 stroke stationary internal combustion engine. The engine has six inline cylinders; the total piston displacement is 3520 cubic inches. Each cylinder is 9.375 inches in diameter, and has an 8.5~ inch stroke. The compression ratio is 10.5: 1. Air is delivered to the engine via the EECL's pressurized air delivery system; air manifold pressures are controlled by the EECL process control system. Engine loading is controlled by a computer controlled water brake dynamometer. Before the test program EECL installed an oxidation catalyst, manufactured by MiraTech Corporation, on the engine. EECL aged the catalyst under its normal operating condition ( i. e., burned in the catalyst) before the test program. This procedure ensured that the catalyst's HAP destruction efficiency approximated the HAP destruction efficiency of mature catalysts installed on 4 stroke engines in industry. Table 3.1 presents specifications of the engine and the catalyst. Table 3.2 presents nominal engine operating parameters.

The 4 stroke cycle requires two revolutions of the engine crankshaft for each power stroke. During the intake stroke, the piston moves down the cylinder and an air/ fuel mixture is injected into the piston chamber. On the compression stroke, the piston moves back up the chamber, and the mixture is compressed and ignited. The expanding gas generated upon combustion forces the piston back down the chamber. This stroke is the power stroke. The last stroke of the 4 stroke cycle is the exhaust stroke. The piston travels back up the chamber and the combustion products are vented through the exhaust manifold.

The 3 52 1 GL engine was outfitted with lean burn technology, which controls NO, emissions. The lean bum system uses pre combustion chambers to ignite a lean air/ fuel mixture in the main combustion chambers. A rich mixture of air and fuel is drawn into the pre combustion chamber and is ignited by a spark plug. The resulting flame is then directed into the main combustion chamber, which contains a lean mixture of air and fuel. The flame jet from the pre combustion chamber ignites the air/ fuel mixture in the main chamber.

Final Report Waukesha 3521GL 3 l September 2001 TABLE 3.1 ENGINE AND CATALYST SPECIFICATIONS hgine Classification Four stroke, lean burn, natural gas fired Manufacturer and Type Waukesha 3521 GL Number of Cylinders 6 Bore and Stroke 9.375" x 8.5"

Nominal Engine Speed 1200 RPM gnition System Classification Spark Ignited Pre combustion Chamber Ignition System Altronic Pre combustion Chamber Type Standard OEM Product Number of Pre combustion Chambers 1 Per Cylinder Zatalyst Classification Oxidation Type Manufacturer Miratech Corporation Date of Manufacture: May 1999 Model Number: None. Custom designed unit Serial Number: None. Custom designed unit Item Number: CSU RE 12160 Platinum/ Palladium on Stainless Steel Catalyst Material: Substrate. Manufactured in Finland by Kemira Element Size: 12" x 16" x 3" Effective Area: 11" x 14 7/ 8"

Number of Elements 2 Final Report Waukesha 352 1 GL 3 2 September 2001 TABLE 3.2 SUMMARY OF NOMINAL ENGINE PARAMETERS .

Parameter Torque speed lacket Water Temp ( Outlet)

Oil Temperature Air Manifold Temperature Air Manifold Pressure Exhaust Manifold Pressure Ignition Timing Overall Air/ Fuel Ratio Inlet Air Humidity Absolute Fuel Flow Oil Pressure Inlet Inlet Air Flow Average Exhaust Temp Nominal Value 3236 ft lb 1200 rpm 180 ` F 185 ` F 100 ` F 5 inches Hg over ambient pressure ( i. e., * a level)

5 inches Hg less than Air Manifold Pressure 10' BTDC 28/ l 0.0 15 lb HzO/ lb Air 5460 scfh 52 psig 1730 scfin 700 ` F Acceptable Deviation Designation f 2% of value  w f 5% of value = Y f 5% of value * str f 5% of value pri v f 5% of value primary f 5% of value primary f 5% of value pl imary f 5% of value * ary f 5% of value * ary f 10% of value primary f 5% of value F+ i Y f 10% of value Secondary f 5% of value secomialy f 5% of value secoxldaIy

& lb  foot pounds rpm  revolutions per minute ` F  degrees Fahrenheit BTDC  Before Top Dead Center lb H, O/ lb Air  pounds water vapor per pound of air scfh  standard cubic feet per hour psig  pounds per square inch, gauge scfin  standard cubic feet per minute Final Report Waukesha 352 1 GL 3 3 September 200 1 3.2 ENGINE OPERATION DURING TESTING As stated in Section 2 of this document, three types of test runs were conducted during the test program: quality control runs, sampling runs for FTIRS and CEMS, and baseline runs. The operation of the engine during these various runs is discussed in the following pages and tables. The four stroke engine test matrix described in the QAPP was based upon estimated operating parameters for a candidate engine to be installed and operated at the EECL. When the engine was received and first operated by EECL the actual operating parameters differed fi= om the estimates. Table 3.3 presents the test matrix for the Waukesha engine based upon the actual engine parameters. During the test program, the six engine operating parameters expected to have the greatest impact on pollutant formation were varied from their baseline values. These parameters were: engine speed ( measured in revolutions per minute or rpm), engine torque ( measured in foot pounds or f& lb), air to fuel ratio ( calculated as an equivalence factor), engine timing ( the location of the piston, relative to top dead center, at the time of spark in the pre combustion chamber, measured in degrees), air manifold temperature ( measured in degrees Fahrenheit), and jacket water outlet temperature ( measured in degrees Fahrenheit).

Table 3.4 presents engine parameters recorded during each test run and their percent deviation from the target values. Sixteen sampling runs were conducted on the engine during the two day period. Except for air/ fuel ratios, the actual parameters agreed with the target parameters to within 5%. Although the calculated air/ fuel ratios were not within 5% of the target air/ fuel ratios, testing was conducted while operating at rich air/ fuel ratios ( Runs 5 and 8) and at lean air/ fuel ratios ( Runs 6 and 7). The air/ fuel ratio was varied to simulate the range of air/ fuel ratios that typcial in field applications. '

Before starting Run 7, the humidity control system failed. The humidity system could not be repaired quickly so the run was conducted without inlet air humidity control. Run 2 was also conducted without inlet air humidity control. The set point for the humidity ratio for all test points was 0.015 lb. water / lb. air. The actual humidity ratios for Runs 2 and 7 were 0.0126 and 0.0127 lb. water / lb. air respectively. The engine emissions for Runs 2 and 7 should be similar to engine emissions at the specified humidity ratio. The most dramatic effect will be on NO, emissions as can be seen from the data and the graphs presented in Appendix S of the CSU test report. At a constant humidity ratio, it would be expected that formaldehyde emissions would either remain constant or increase slightly with similar changes in CO and THC emissions.

Final Report Waukesha 3521GL 3 4 September 2001 TABLE 3.3 TARGET ENGINE OPERATING CONDITIONS DURING TESTING N = Normal Value L = Low value H = High Value S = Set point Value Final Report Waukesha 352 1 GL 3 5 September 2001 TABLE 3.4 SUMMARY OF ENGINE PARAMETERS  WAUKESHA 3521 GL RunO 1197 1200  0.26%

3234 3236  0.1%

0.56 0.61  7.6%

10 10 0.0%

119 120  0.1%

179 180  0.6%

737 5389 1024 5.52 Gx 1197 1200  0.26%

3237 3236 0.0% Run 1197 1200  0.26%

3238 3236 0.1% Run xi7 1200  0.25%

2263 2265  0.1% RunS Xii

1000 0.16%

2264 2265  0.1% Run TiiiZ

1000 0.15%

3234 3236  0.1% Run 1197 1200  0.26%

3235 3236 0.0% Run 1197 1200  0.26%

3234 3236 0.0% Runl 7r 1200  0.26%

2263 2265 4.1% Run 1001 1000 0.15%

3234 3236  0.1% Run 1197 1200  0.26%

3236 3236 0.0% 1197 1197 1197 1200 1200 1200  0.29%  0.26%  0.26Y 1197 1200  0.26%

3236 3236 0.0% EngineToqueR tb EquiwlenceRatio,+

IntercoolerWater fpm  rmolutlons per minute It lb foot pounds l BIDC degrwsBeforeTopDeadCente8 3235 3236 0.0%

0.56 0.61  8.5% 3236 3236 0.0%

0.55 0.61  9.2%

10 10 0.0%

128 130  0.3%

179 180  0.7%

737 5452 1040 5.67 8655 3235 3236 0.0%

0.56 0.61  8.6% 0.56 0.56 0.52 0.59 0.59 0.53 0.61 0.61 0.56 0.62 0.62 0.56  8.6%  6.4% 8.3%  4.6%  5.4%  6.2% 0.56 0.61  8.5% 0.56 0.61  8.5% 0.55 0.61  9.3% 0.53 0.61  13.7% 0.56 0.61 8.6%

10 10 0.0%

128 130  0.4% 10 10 0.0% 6 6 0.0% 10 10 10 10 0.0% 0.0%

128 129 130 130  0.3%  0.2%

180 179 180 180 0.2% 4.5%

737 516 5337 4040 1040 1040 5.55 4.20 10 10 0.0%

130 130 0.1%

179 180  0.6% 10 10 0.0%

129 130  0.3% 10 10 0.0%

130 130 0.1%

179 180  0.3% 10 10 0.0%

130 130 0.0%

180 160 0.1%

737 5372 1040 5.58 8655 14 14 0.0%

132 130 0.3%

179 180  0.5%

737 5272 1024 5.40 141 140 0.2%

180 180 0.3%

738 5341 1040 5.55 8645 I 129 130  0.2%

179 180  0.7%

617 4424 1040 4.60 8645 130 130 0.0%

190 190 0.1%

738 5411 1040 5.63 8645 128 130  0.3%

163 180 1.7%

737 5683 1040 5.91 8655 179 180  0.5% 179 180  0.3%

432 617 737 3205 4368 5523 1040 1040 1040 3.33 4.54 5.74 665, 8645 8655 516 1040 4.24 8645 ' F degrwsFahnwheit bhp brakehorsepower scth standafdcubicfaetperhour Btukf British'Ihermal Units percubic M ofnatwalgas MMBtuIhr million Btu perhour Final Report Waukesha 352 1 GL 3 6 September 200 1 Table 3.5 presents engine parameters measured during two baseline test runs. There were two testing periods. On August 4, testing was conducted over a six hour period. The engine was shut down and testing resumed on August 5. The testing was completed over the next 26 hours of continuous engine operation. Test accuracy required that the overall engine operation did not change. The stability of the engine over this period was demonstrated by operating the engine at the baseline condition for one Sminute period early in the 26 hour period and a second S minute period at the end of the testing. Changes to the baseline parameters would have indicated a change in the overall operating characteristics of the engine. It would not have been possible to distinguish between emission rate changes attributable to changes in the independent variables and emission rate changes attributable to random changes in the performance of the engine. Table 3.5 compares the values of 13 engine parameters measured during the baseline runs to the manufacturer's recommended settings that were presented in Table 3.2. Deviations are calculated in percent. Temperatures were converted to degrees Rankine, then the percent deviation was calculated.

Final Report Waukesha 3521GL 3 7 September 200 1 TABLE 3.5 SUMMARY OF ENGINE PARAMETERS DURING BASELINE RUNS Engine Speed, rpm Engine Torque, & lb Air/ Fuel Ratio, lb air / lb fuel Ignition Trming, " BTDC Jacket Water Temperature, " F Exhaust Manifold Pressure, in. Hg Inlet Air Humidity, lb H, O/ lb air Inlet Air Flow, scth Exhaust Temperature,

rpm  rewlutions per minute in. Hg  inches of mercury ft lb  foot pounds lb H20 / lb air  pounds water wpor per pound of air lb air / lb fuel  pounds air per pound of fuel scfh  standard cubic feet per hour " BTDC  degrees Before Top Dead Center psig  pounds per square inch, gauge " F  degrees Fahrenheit scfm  standard cubic feet per minute Final Report Waukesha 352 1GL 3 8 September 200 1 4.0 SAMPLING LOCATIONS A schematic drawing of the exhaust gas piping on the Waukesha 3521GL engine is shown in Figure 4.1. The engine exhaust manifold was connected to the inlet of the catalyst with an & inch internal diameter ( ID) pipe. The pipe extended vertically from the exhaust manifold, made a 90' bend, and was connected to the inlet of the catalyst. A 120inch diameter pipe connected the outlet of the catalyst to a back pressure valve, and then to the exhaust header. EECL personnel used two sampling ports to extract samples for analysis by FTIRS and CEMS. One port was located before the catalyst and one port was located after the catalyst.

Final Report Waukesha 3 52 1 GL 4 l September 200 1 22' 1 I"

., Back Pressure Valve 3 Post Catalyst Sampling Port ' 1: = m x 7 Pre Catalyst Sampling Port Expansion Joint Figure 4.1 Exhaust Piping Schematic Final Report Waukesha 352 1 GL 4 2 September 200 1 5.0 SAMPLING AND ANALYSIS METHODS This section discusses the various sampling and analysis methods employed by PES and EECL to quantify the HAP emission rates upstream and downstream of the oxidation catalyst. PES selected the sampling and analysis procedures that would provide the information required during the planning stages of the project. The methods were selected to provide the required data in the most economical fashion, while providing the quality required by EPA's Emissions Standards Division ( ESD).

Table 5.1 summarizes the parameters measured, the sampling methods, and measurement principle. The text that follows presents brief descriptions of the sampling and analysis procedures used.

PES and EECL used QA and calibration procedures described in 40 CFR 60, Appendix A ( or other references as appropriate) as a guideline for instrument calibrations and drift checks. The instrumental methods as written in 40 CFR 60 Appendix A are designed by EPA to be portable, field test procedures. Because these instruments are maintained in a laboratory type environment ( the control room at EECL), fewer QA activities and calibrations are required to adequately show their continuing accuracy. The only significant change to the quality assurance activities was that fewer instrument calibrations were done to quantify instrument drift. Historical calibration data for the instruments shows their stable operation over extended, e. g., 24 hour, periods. Multipoint calibrations' were conducted ( including the sampling system bias checks) on these instruments once at the beginning of each engine test series.

5.1 DETERMINATION OF STACK GAS VOLUMETRIC FLOW RATE PES used EPA Method 19 to calculate the volumetric flow rate of the exhaust gases for Runs 1 through 16. The mass flow rates of pollutants measured by FTLRS and CEMS were calculated using the Method 19 flow data. EPA Method 19, Determination of Sulfur Dioxide Removal Eflciency and Particulate Matter, Sulfir Dioxide, and Nitrogen Oxides Emissions Rates, uses a fuel factor to calculate the volume of combustion products generated upon combustion of specific fuel types. EECL personnel analyzed a sample of the natural gas fuel during each day of testing. The results of the compositional analysis were used to calculate the upper heating value and oxygen based F factor, Fd. The EECL Engine Control and Monitoring System recorded stack gas O2 concentrations and the fuel consumption rate during testing. These data were used to calculate the exhaust gas flow rates by multiplying the fuel consumption by the fuel factor, and correcting for excess air. Exhaust gas flow rates were calculated upstream and downstream of the catalyst for each run.

Final Report Waukesha 352 1GL 5 l * September 200 I TABLE 5.1 SUMMARY OF SAMPLING AND ANALYSIS METHODS Parameter Test Method I Measurement Principle Volumetric Flow I EPA Method 19 I Stoichiometry Oxygen and Carbon Dioxide EPA Method 3A Paramagnetic and Non dispersive Infrared Analyzers Moisture GRI Protocol'

Carbon Balance2 FTIR Analyzer Stoichiometry Nitrogen Oxides I EPA Method 7E I Chemihuninescent Analyzer ~~ Carbon Monoxide I EPA Method 10 I GFCMDIR Analyzer Formaldehyde, Acetaldehyde, Acrolein Methane GRI Protocol FTIRAnalyzer '

EPA Method 25A ( modified) GC FID Analyzer Non methane hydrocarbons 1 EPA Method 25A ( modified) 1 GC FID Analyzer Total Hvdrocarbons I EPA Method 25A I FID Analyzer ' Measurement of Select Hazardous Air Pollutants, Criteria Pollutants, and Moisture Using Fourier Transform Infrared ( FTIR) Spectroscopy. Presented as an Appendix to Fourier Transform Infrared ( FTIR) Method Validation at a Natural Gas Fired Internal Combustion Engine ( GRI 95/ 027 l), Gas Research Institute, December 1995:

2 Derivation of General Equation for Obtaining Engine Exhaust Emissions on a Mass Basis Using the " Total Carbon" Method.

Final Report Waukesha 352 1 GL 5 2 September 2001 5.2 DETERMINATION OF STACK GAS OXYGEN AND CARBON DIOXIDE CONTENT EECL used EPA Method 3A, Determination of Oxygen and Carbon Dioxide Concentrations in Emissions from Stationary Sources ( Instrumental Analyzer Procedure), to measure oxygen and carbon dioxide content of the exhaust gas during testing. EECL's sample gas extraction and transport system extracted a gas sample from locations upstream and downstream of the catalyst. Each sample was conditioned to remove moisture and entrained particulate matter and directed to the CEMS.. Oxygen was measured using the paramagnetic detection principle. Carbon dioxide was measured using non dispersive infrared ( NDIR) analyzers. The oxygen and carbon dioxide monitors were calibrated with a pre purified zero gas and three upscale gas standards corresponding to approximately 30,55 and 85 percent of the instruments' analytical ranges. EECL used only EPA Protocol gas standards certified by the gas manufacturer. The calibration gases that were used and the calibration responses of the instruments are discussed in Section 6.0 of this document. A schematic diagram of the FTIIWCEMS sampling and analysis system is presented in Figure 5.1.

5.3 DETERMINATION OF STACK GAS MOISTURE CON'tENT EECL used two methods to determine the moisture concentration in the exhaust gas upstream and downstream of the catalyst. Moisture content downstream of the catalyst was calculated using a carbon balance method. This method is summarized in the EECL test report, which may be found in Appendix A. During the testing, EECL personnel determined that the moisture concentrations downstream of the catalyst, as measured by the Nicolet Magna 560 FTIR analyzer, were about 6 percent higher than actual. Therefore the carbon balance method was used to calculate moisture content at this location.

EECL used methodology described in the document Measurement of Select Hazardous Air Pollutants, Criteria Pollutants, and Moisture Using Fourier Transform Infrared ( FTIR) Spectroscopy to measure moisture concentrations upstream of the catalyst. This document, called the GRI Protocol in this report, is presented as Appendix B of a report published by the Gas Research Institute: Fourier Transform Infiared ( FUR) Method Validation at a Natural Gas Fired Internal Combustion Engine. A sample of the gas was extracted from the exhaust, filtered and directed to a Nicolet Rega 7000 FTIR analyzer to measure the moisture concentration. The gas sample was transported to the analyzer via a heated Teflon@ sample line. Further discussion of the FTIRS sampling and analysis method may be found in the report generated by the EECL.

5.4 DETERMINATION OF NITROGEN OXIDES EPA Method 7E, Determination of Nitrogen Oxide Emissions from Stationary Sources ( Instrumental Analyzer Procedure), determined nitrogen oxide content of the exhaust gases.

Final Report Waukesha 352 1 GL 5 3 September 200 1 5.7 DETERMINATION OF METHANE AND NON METHANE HYDROCARBONS A modification of EPA Method 25A determined the methane and non methane concentrations at the inlet and the outlet of the catalyst. Gas samples extracted from each gas stream were transported to Questar Baseline 1030H Methane/ Non Methane Analyzers. These analyzers are single purpose gas chromatographs that separate methane from the other organic compounds in the sample by passing the sample through a separation column. The methane elutes from the column first and is directed to the flame ionization detector. Then, the analyzer reverses the flow through the column and the remaining organic compounds are back flushed to the same detector. The analyzer sums the two fractions to yield the concentration of total organic compounds. Because this unit is a gas chromatograph, it cannot measure methane and non methane concentrations continuously. During testing, each analyzer determined concentrations once every five minutes. This frequency is sufficient for testing on RICE, because the operating conditions were maintained within close constraints. Each analyzer was calibrated before each week of testing using methane and propane calibration standards corresponding to approximately 30,50, and 85 percent of the instrument span. The calibration gases that were used and the calibration responses of the instruments are discussed in Section 6.0 of this document. A schematic diagram of the CEMWFTIRS sampling and analysis system is presented in Figure 5.1.

5.8 DETERMINATIOllJ OF GASEOUS ORGANIC HAPS USING FTIRS EECL used two FTIRS systems that met the sampling and analysis requirements set forth in the GRI Protocol. Table 5.2 summarizes the specifications of each FTIRS analyzer. GRI validated extractive FTIRS systems successfully for an analysis of emissions from natural gas fired RICE. The extractive FTIRS continuously extracts a sample gas from the stack, transports the sample to the FTIRS system, and does spectral analysis of the sample gas. The computer system analyzes sample gas spectra for target analytes continuously and archives them for possible later re analysis.

The sampling and measurement system consists of the following components:

l heated probe;

l heated filter;

l heat traced Teflon@ sample line;

l Teflon@ coated, heated head sample pump;

l FTIRS spectrometer; and l QA/ QC . apparatus.

Final Report Waukesha 352 1 GL 5 6 September 200 1 TABLE 5.2 FTIRS ANALYZER SPECIFICATIONS I Parameter I Pre catalyst I Post catalyst II Manufacturer and Type I Nicolet Rega 7000 Nicolet Magna 560 Spectral Resolution 0.5 cm  l 0.5 cm  l Detector Type MCT A MCT A Cell Type 4.2 Meter  Fixed Path Length 2.0 Meter  Fixed Path Length II Cell Temperature I 185 " C I 165 ` C II Cell Pressure I 600 Torr I 600 Ton:

11 Cell Window Material 1 Zinc Cellinide I KBr EECL validated each sample extraction and analysis system for formaldehyde, acetaldehyde, and acrolein before testing. The results of the FTIRS validation are discussed in Section 6. The basic sampling procedure consisted of EECL taking an initial interferogram of the stack gas with the FTIRS measurement and analysis system before each test to describe the sample matrix. This measured the concentrations of moisture and the target pollutants and allowed for adjustments to the cell pathlength and the spectral analysis regions if the concentrations differ from expectations. Sample conditioning was not necessary at the EECL test site.

After QA/ QC procedures and initial adjustments were completed for a given test day, a gas sample was drawn continuously through the heated FTIRS cell while the system collected spectral data. The spectrometer collected one complete spectrum of the sample, as an interferogram, per second and averaged interferograms over l minute periods. The FTIRS computer converted these time integrated interferogram into conventional wave number spectra, analyzed for the target compounds and archived the data. Sample collection was 33 minutes in duration, coinciding with the test runs.

5.9 DETERMINATION OF NATURAL GAS COMPOSITION The composition of the fuel gas combusted in the engine was determined daily using a dedicated Daniels Industries gas chromatograph ( GC). The GC was calibrated each day using a Final Report Waukesha 352 1GL 5 7 September 2001 known standard. From the results of the daily analyses, the specific gravity, mole fractions, and BTU content of the fuel were calculated. Fuel flow measurements were determined using an American Gas Association ( AGA) specified orifice meter run equipped with high accuracy pressure and temperature transmitters. All fuel flow calculations were in accordance with AGA Report # 3. Stoichiometric air to fuel ratio calculations were also made using the results of the fuel gas analysis. The results of fuel gas calibrations and analysis are presented in the EECL report, which is attached in Appendix A. .

Final Report Waukesha 352 1 GL 5 8 September 200 1 6.0 QUALITY ASSURANCE/ QUALITY CONTROL PROCEDURES AND RESULTS Summarized in this section are the specific QA/ QC procedures that PES and EECL personnel employed during the performance of this source testing program. PIES' quality assurance program was based upon the procedures and guidelines contained in the " Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods," EPA/ 6OO/ R 94/ 03& z, as well as in the test methods. These procedures ensure the collection, analysis, and reporting of reliable source test data.

6.1 FTIRS QA/ QC PROCEDURES EECL calibrated the FTIRS instruments before each engine test series and at the beginning and end of each test day. The calibration procedures employed were consistent with procedures found in the following documents:

Gas Research Institute Report Number GRI 95/ 027 1 entitled, " Fourier Transform Infrared ( FTIRS) Method Validation at a Natural Gas Fired Internal Combustion Engine ."

This report was prepared for the Gas Research Institute by Radian Corporation. Included as appendices are two additional documents, which also have relevance in the test program:

" Measurement of Select Hazardous Air Pollutants, Criteria Pollutants, and Moisture Using Fourier Transform Infrared ( FTIRS) Spectroscopy"  Prepared by Radian Corporation for the Gas Research Institute.

" Protocol for Performing Extractive FTIRS Measurements to Characterize Various Gas Industry Sources for Air Toxics"  Prepared by Radian Corporation for the Gas Research Institute.

Final Report Waukesha 352 1 GL 6 1 September 200 1 6.1.1 FTIRS Svstem PreDaration Both FTIRS sampling systems ( before and after the catalyst) were subjected to an EPA Method 3 0 1 validation process for formaldehyde, acetaldehyde, and acrolein. The validation process quantified the precision and accuracy of each FTIRS analyzer for these compounds. Besides the validation program, EECL personnel performed the following calibration procedures before each engine test series.

1. Source Evaluation  Initial source data were acquired to verify concentration ranges of target compounds and possible interferences. This was completed before and during the Method 301 validation process for formaldehyde, acetaldehyde, and acrolein, and during the test program for moisture.

2. Sample System Leak Check  A leak check was done on the portions of the system between the sample filter and the pump outlet. A rotameter was connected to the discharge side of the sample pump. The indicated sample flow rate was recorded with the sample system operating at typical temperatures and pressures ( the sample pump pulled a slight vacuum on the suction side). The inlet was closed off just downstream of the sample probe. The rotameter monitored the flow rate. If the leakage rate is found to be no greater than 500 ml/ min or 4% of the average sampling rate ( whichever is less) the system is considered to be acceptable for use. The leak checks conducted by EECL personnel indicated that the system was acceptable for use.

3. Analyzer Leak Check  Both FTIRS analyzers were checked to ensure that they were operating at normal operating temperatures and pressures. The operating pressures were recorded. The automatic pressure control device was disabled and the inlet to the FTIRS was closed. The cell was evacuated to 20% or less of the normal operating pressure. After the cell was evacuated, it was isolated and the cell pressure was monitored with a dedicated pressure sensor. The leakage rate of the measurement cell is acceptable if it is less than 10 Torr per minute. All analyzer leak checks performed by EECL were within the acceptable range.

4. Cell Pathlength Determination  The FTIRS cell pathlengths were to be determined using the procedure outlined in the Field Procedure Section the document entitled " Protocol for Performing Extractive FTIRS Measurements to Characterize Various Gas Industry Sources for Air Toxics." Because each FTIRS was a fixed pathlength unit ( i. e., the pathlengths were not adjustable) measurements of the cell pathlengths were deemed unnecessary. The cell pathlengths specified by the manufacturer were used in the measurement algorithms.

Final Report Waukesha 352 1 GL 6 2 September 200 1 6.1.2 FTIRS Daily Calibrations and OA Procedures Before each day of testing, EECL personnel calibrated each FTIRS system following the procedures outlined below.

1. Instrument Stabilization  Each of the following components were checked for proper operation to ensure the stability of the operation of the FTIRS instruments:

a> Instrument heaters and temperature controllers.

b) Pressure sensors and pressure controllers.

C> Sample system ( pump, filters, flow meters, and water knockouts).

2. The FTIRS analyzers were purged with conditioned air for a minimum of 30 minutes before conducting background spectrum analysis. During periods when the instruments were in stand by mode ( i. e., between sampling runs or between test days), they were maintained at normal operating temperatures and purged with conditioned air.

3. Background Spectrum Procedures  Each instrument was allowed to stabilize while being purged with Ultrahigh Purity ( UHP) nitrogen for 10 minutes. The FTIRS spectra were monitored during, this time, until CO and HZ0 concentrations reached a steady state. The following procedures were then done:

a> The interferogram signal was checked using signal alignment software.

b) A single beam spectrum was collected and inspected for irregularities.

c) Using the single beam spectrum, the detector was checked for non linearity and corrected if necessary.

d) The instrument alignment procedure was done.

e> A background spectrum consisting of 256 scans was collected.

4. Analyzer Diagnostics  Analyzer diagnostics were done by analyzing a diagnostic standard. The standard was a 109 ppm CO EPA Protocol gas standard. EECL uses CO because it has distinct spectral features that are sensitive to variations in system operation and performance. The standard was introduced directly into . each instrument, and instrument readings were allowed to stabilize for 5 minutes. The accuracy and precision of each instrument were calculated. The pass/ fail criterion for accuracy and precision was 10% of the concentration of the standard Final Report Waukesha 3 52 1 GL 6 3 September 200 1 gas. A second diagnostic standard consisting of a blend of CO,, CO, CHI, and NOx was analyzed using the same procedure. Each instrument met the precision and accuracy requirements. Analyzer diagnostic data are presented in the report generated by EECL.

5. Indicator Check & Sample Integrity Check  An indicator check was done by analyzing an indicator standard. A 10.66 ppm formaldehyde standard was introduced directly into each instrument. The instrument readings were allowed to stabilize and a 5 minute data set was collected. The indicator standard was then introduced into the sample system at the sample probe, just upstream of the filter. The instrument readings were allowed to stabilize and a 5minute set of data was collected. The accuracy, precision, and recovery were calculated based on equations in the document entitled " Protocol for Performing Extractive FTIRS Measurements to Characterize Various Gas Industry Sources for Air Toxics", prepared by Radian Corporation for the Gas Research Institute. The pass/ fail criterion for accuracy, precision, and recovery is 100 f 10% of the known standard ( recovery shall be 100 f 10% of the instrument reading when the indicator gas is introduced directly into the instrument.) Each instrument met these criteria. Indicator check and sample integrity data sheets are included with the EECL report.

6.1.3 Background Assessment During data acquisition procedures, the baseline absorbance was continually monitored. If at any time the baseline spectrum changed by more than 0.1 absorbance units, the instrument's interferometer was realigned and a new background spectrum collected.

6.1.4 Post Test Checks Upon completion of the daily test program steps 4 and 5 of the pre test calibration procedures were repeated. Both of the FTIRS analyzers met all of the acceptance criteria for the calibration and QA procedures. Post test calibration data sheets are included in the EECL report.

6.1.5 FTIRS Validation Before the test program, both FTIRS sampling and analysis systems were validated for formaldehyde, acrolein, and acetaldehyde. The validation was conducted by personnel from ERG, using procedures outlined in EPA Method 30 1 " Field Validation of Pollutant Measurement Methods from Various Waste Media." The validation was conducted by spiking the sample gas with known concentrations of formaldehyde, acrolein, and acetaldehyde. The carrier gas was a mixture of acrolein and acetaldehyde and was introduced into the spiking system from a compressed gas cylinder. Formaldehyde was added to the Final Report Waukesha 352 1GL 6 4 September 200 1 carrier gas by injecting a stock formalin solution onto a heated block at a fixed rate. The acrolein/ acetaldehyde gas standard was used as a carrier gas for the vaporized formaldehyde. The three component mixture was injected into each FTIRS sampling system at a point upstream of each system's filter. Further discussions of the validation procedures employed may be found in the report generated by EECL.

6.1.6 FTIRS Detection Limits Table 6.1 presents the in stack detection limits for formaldehyde, acetaldehyde, and acrolein as reported by CSU EECL. These detection limits have been used to calculate the run by run mass detection limits for each of the target pollutants.

6.2 CEMS QA/ QC PROCEDURES The following paragraphs describe the CEMS quality assurance procedures that EECL personnel used during the test program. The calibration and QC frequencies far exceeded those required for permanently installed, compliance analyzers, but are less than those specified for compliance tests by EPA ( 40 CFR 60, Appendix A). EECL operates their CEMS in a way that is more similar to permanently installed analyzers.

6.2.1 Analmer Calibration Gases EECL used EPA Protocol calibration gases. The calibration gases were manufactured by Scott Specialty Gases. For this program, EPA Protocol 1 calibration gases ( RATA Class) were used. Formaldehyde and acetaldehyde/ acrolein standards with concentration ranges between 5  20 ppm were obtained for FTIRS calibrations. These gases are not available as EPA Protocol Gases, so EECL specified the highest quality available. Scott supplied certification sheets, which may be found in the Appendices of EECL's test report.

6.2.2 ResDonse Time Tests Response time tests were done on each sample system before initiation of the engine test program. The response time tests were performed before the FTIRS validation process for each sampling system. The response time of the slowest responding analyzer ( Questar Baseline Methane/ Non methane hydrocarbon GC) was determined. Response time tests conducted at the EECL indicated sampling system response times of 1: 10 minutes. This is the time for the Rosemount Oxygen analyzer ( the slowest responding continuous analyzer) to stabilize to response output of the analyzer. The Questar Baseline analyzers have a minimum cycle time of 450 minutes. The overall response time for these analyzers when their cycle is started 1: 10 minutes after a sample source change is 5 : 50 minutes.

Final Report WauJcesha 352 1GL 6 5 September 200 1 TABLE 6.1 DETECTION LIMITS OF Fl'IRS AND CEMS COMPOUNDS mplbhphr miNlgmmsperbmkehonepovwrhou 6.2.3 Analvzer Calibrations Zero and mid level span calibration procedures were done on the CO, CO*, 02, NO,, THC, and methane/ non methane analyzers before each test day. Zero and span drift checks were performed upon completion of each data point and upon completion of each test day. A zero and mid level gas was introduced directly to the analyzers before testing for carbon monoxide, carbon dioxide, oxygen, total hydrocarbons, methane/ non methane, and oxides of nitrogen. The analyzers' output response was set to the appropriate levels. Each analyzer's stable response was recorded. From this data a linear fit was developed for each analyzer. The voltages for each analyzer were recorded and used in the following formula:

Y= MX+ B where: B = Intercept M= Slope X= Analyzer or transducer voltage Y= Engineering Units '

After each test point and upon completion of a test day, calibrations were conducted by reintroducing the zero and span gases directly to the back of the analyzers. The analyzers' stabilized responses were recorded. No adjustments were made during testing or during the f5na. l calibration check. Initial calibration values and all calibration checks were recorded for each analyzer during the daily test program.

The before and after calibrations checks were used to determine zero and span drift for each test point for the CO, COZ, 02, NO,, THC, and methane/ non methane, and analyzers. The zero and span drift checks for all test points and all test days were less than = t2.0% of the span value of each analyzer used during the daily test program. The calibration data sheets are presented in the test report generated by EECL. Table 6.2 presents the types and frequencies of the analyzer calibrations conducted by EECL.

Final Report Waukesha 352 1GL 6 7 September 2001 TABLE 6.1 DETECTION LIMITS OF FIIRS AND CEMS COMPOUNDS Fonnaidehyde Acetaldehyde mgibhp hr 432 . 472 . 465 * 542 mlblhr 7.02 5.37 4.42 388 5: 27 s: a1 406 . 463 5: 29 448 6109 421 . 404 . 4.08 412 6.59 8.70 482 6.65 6.57 6.64 7: 63 418 6: 60 442 ' 432 7.19 7: 03 mglbhp hr 201 32: 7 219 24: 9 216 SO: 6 24: 6 181 250 40: 6 189 30: 6 214 24: 3 208 19/ 188 191 192 mlb/ hr 28: 3 32: 0 30: 6 31: o 31: 2 zb 36: 5 195 31: 7 206 33: 5 201 32: 7 Acrolein mglbtphr 15.5 163 . 166 ' 142 . 114 28: 3 15  / 164 ' 149 20: 3 136 ' 153 24: 9 155 25: 3 134 25: 1 169 153 * 166 163 * mlb/ hr 25.2 18.5 15.8 19.3 25.5 18.7 25.7 30: 7 24.9 27: l 26.4 NitrogenOxides ( as N02) ww m O. Wl 0.001 0.001 0.001 0.001 0.001 0.001 O. Wl 0.001 oxxn ClsRn 0.001 0.001 O. Wl o. ouT lb/ hr 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001 CarbonMonoxide amhbnr w l . . . . 0.05 004 . 004 . 0.05 004 004 004 004 005 . otJ4  005 * ( 105 * lblhr 0.07 0.05 0.04 0.08 0.06 0.07 0.05 0.06 0: 07 0: 07 0: 07 0: 07 0.08 0.07 0.08 0.07 Methane WJp hr . . 0.2 . . . . . 0.1 0.1 0.1 0.1 . . . . IWhr 0.2 0.2 0.1 0.2 0.3 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.3 0.2 0.2 0.2 ~ NorrmethanewdocaM glbhp hr 0.04 0.04 0.04 0.04 0.04 0. w 0.04 0.04 0.04 0.04   * "  0.04 Total Hydrocarbons Formaldehyde Acetaldehyde Mu 0.07 0.05 0.04 0.05 0.07 0.06 0.04 0.05 0.08 0.08 iii ; I:; i:: ii KG 0.07 lhh Q w~ Ib/ hr 0.0002 0.0001 0.0001 0.0001 0.0002 0.0002 0.0001 0.0001 0.0002 0.0002 0.0002 0.0002 0.0002 0.0002 0.0002 0.0002 Catalyst Outlet mg/ bhp hr 3.64 3 . 14 3 33 2 . 86 2.85 3 19 2 99 3 11 3.04 mlWhr 4.94 3.57 3: 17 2.91 342 . 2.80 2 88 3.20 3.03 2.86 3.95 5.57 4.56 3: 28 4.36 4.92 4.64 4.66 4.63 5119 4186 5: 05 4.95 mglbhphr 12.6 129 137 13: l 120 * 14.2 116 18: 8 119 . 132 . lz5 II8 mlb/ hr 20.4 14: 7 16.3 23.0 13.5 18.0 20: 3 19: 2 118 19: 3 ` I8 . 132 lz3 lz8 . 12 6 19.1 21: 4 20: o 20.8 20.4 Acrolein mg/ bhp+ I r 59.1 524 * 540 51: 4 490 66: s 581 91: 1 510 mlb/ hr 97 59.6 82: 8 506 57: s 50 1 52l . 50* 8 b0o 81: 4 502 81: 6 584 91: 7 523 68.9 84.6 82.6 85: O 543 66: 3 534 66: 8 0001 0001 0001 0001 0001 owl owl . 0001 0001 owl 0001 0001 0001 * 0001 NittqenOxides( as NO2) cmho tu 001 w l  It& 0.001 0: 001 0: 001 Ok1 0: OOl 0: 001 0: 001 0: 001 0.001 0: 001 0: tm 0: 001 0: 001 0: m 0.001 0: OOl 001 0: 01 001 0: 01 001 0: 01 001 0: Ol 001 io2 001 001 001 061 001 061 CarbonMonoxide Whr 0: 01 0: Ol 0: 01 0: 01 0: 01 0: 01 001 0: 01 001 0: 02 001 0: 01 001 0: 02 001 0: 01 glm+ r 014 0.16 0.14 014 015 015 * O 14 014 0: 23 O 14 016 0: 25 014 0: 23 015 0: 24 013 Methane Ib/ hr 0: 19 0.26 0.22 0: 16 0: 20 0.24 0.23 0.23 0: 24 wpty 004 0: 07 004 . 004 . 0.04 ocJ4 004 004 oofJ . 004 . 004 . 0 W 004 . 004 004 004 004 NonmethaneHydocarbons IWhr 0.05 0.04 0.05 0: 07 0: 05 0: w 0.05 0.08 0.08 0.08 0.06 0: 07 0: 08 0: 07 0: 07 TotalHydrocarbons 0morwwnm1 oum oam omm oo? m Oa. Kll o? Jm OolJm IJoiJol lJ om1 l, J mol Owol o aJm o( Jmi . . . . . . . . ii o: ooo2 .0: wo, . . . . o. cHm 0.0001 0.0002 0.0002 0.0001 0.0001 0.0002 o. wO2 0.0002 0.0002 0.0002 0.0002 0: 0002 0: 0002 mgb# yhr miiigmmsperbrabhomepomrhou 6.2.3 Analvzer Calibrations Zero and mid level span calibration procedures were done on the CO, CO*, 02, NO,, THC, and methane/ non methane analyzers before each test day. Zero and span drift checks were performed upon completion of each data point and upon completion of each test day. A zero and mid level gas was introduced directly to the analyzers before testing for carbon monoxide, carbon dioxide, oxygen, total hydrocarbons, methane/ non methane, and oxides of nitrogen. The analyzers' output response was set to the appropriate levels. Each analyzer's stable response was recorded. From this data a linear fit was developed for each analyzer. The voltages for each analyzer were recorded and used in the following formula:

Y = MX+ B where: B = Intercept M= Slope X= Analyzer or transducer voltage Y = Engineering Units '

After each test point and upon completion of a test day, calibrations were conducted by reintroducing the zero and span gases directly to the back of the analyzers. The analyzers' stabilized responses were recorded. No adjustments were made during testing or during the final calibration check. Initial calibration values and all calibration checks were recorded for each analyzer during the daily test program.

The before and after calibrations checks were used to determine zero and span drift for each test point for the CO, COz, OS, NO, THC, and methane/ non methane, and analyzers. The zero and span drift checks for all test points and all test days were less than ~ 2.0% of the span value of each analyzer used during the daily test program. The calibration data sheets are presented in the test report generated by EECL. Table 6.2 presents the types and frequencies of the analyzer calibrations conducted by EECL.

Final Report Waukesha 352 1GL 6 7 September 2001 TABLE 6.2 TYPES AND FREQUENCIES OF CEMS ANALYZER CALIBRATIONS Calibration Type Gas Calibration Gas Calibrant Concentration ( units Frequency Injection Validation of % of span (` 1) Point Criterion ACE (* I 02, co*, co, NO,

MethaneMon Methane Hydrocarbons 0 to 0.25, 40 to 60, 80 to 100 0 to 0.1, 25 to 35, 45 to 55, 80 to 90 c2% of analyzer span for each gas Before each Directly into engine test the analyzer < 5% of respective cal. gas value ZSD ( 3) 02, co*, co, NO,

Methane/ Non Methane Hydrocarbons 0 to 0.25, 40 to 60 or 80 to 100 w 25 to 35, 45 to 55 Before and after each test run Directly into the analyzer All errors < 3% of span All errors < 3% of span SSB (` I NO,

Methane/ Non Methane Hydrocarbons 0 to 0.25, 40 to 60 or 80 to 90 (` 1 0 to 0.25, 25 to 35, 45 to 55 or 80 to 90 (`) Before and after each Both directly test day into the analyzer and Both errors into the inlet < 5% of Before and analyzer spar after each of the sample line test day (* I  The span must be 1.5 to 2.5 the concentration expected for each pollutant (* I  Analyzer calibration error check t3)  Zero and span drift check t4)  Sampling system bias check @)  Whichever is closer to the exhaust gas concentration Final Report Waukesha 352 1 GL 6 8 September 200 1 6.2.4 Analvzer Linearitv Check Analyzer linearity checks were done before beginning the test program. The oxygen, carbon monoxide, total hydrocarbon, methane/ non methane, and oxides of nitrogen analyzers were " zeroed" using either zero grade nitrogen or hydrocarbon free air. The analyzers were allowed to stabilize and their output recorded. The analyzers were then " spanned" using the mid level calibration gases. The analyzers were allowed to stabilize and their output recorded. From this data a linear fit was developed for each analyzer. The voltage for each analyzer was recorded and used in the following formula:

Y = MX+ B where: B = Intercept M = Slope X = Analyzer or transducer voltage Y = Engineering Units Using the linear fit, the linear response of the analyzer was calculated. Low level and high level calibration gases were individually introduced to the analyzers. For each calibration gas, the analyzers were allowed to stabilize and their outputs were recorded. Each analyzer's linearity was acceptable. The predicted values of a linear curve determined from the zero and mid level calibration gas responses agreed with the actual responses of the low level and high level calibration gases within Tf52.0% of the analyzer span value. The methane/ non methane analyzers' linearity was acceptable as the predicted valued agreed with the actual response of the low level and high level calibration gases within G. O% of the actual calibration gas value. This procedure was done for one range setting for each analyzer. The Linearity Check data sheets are presented the test report generated by EECL.

6.2.5 NO, Converter Check EECL did NO2 converter checks before the test program began. A calibration gas mixture of known concentration between 240 and 270 ppm nitrogen dioxide ( NO3 and 160 to 190 ppm nitric oxide ( NO) with a balance of nitrogen was used. The calibration gas mixture was introduced to the oxides of nitrogen ( NO, J analyzer until a stable response was recorded. The converter was considered acceptable if the instrument response indicated a 90 percent or greater NO2 to NO conversion. The NO* Converter Check data sheets are presented in the test report generated by EECL.

6.2.6 Samde Line Leak Check The sample lines were leak checked before the engine test program. The leak check procedure was performed for both pre catalyst and post catalyst sample trains. The procedure was to close the valve on the inlet to the sample filter found just downstream of the Final Report Waukesha 352 1GL 6 9 September 2001 exhaust stack probe. With the sample pump operating, a vacuum was pulled on the exhaust sample train. Once the maximum vacuum was reached, the valve on the pressure side of the pump was closed, thus sealing off the vacuum section of the sampling system. The pump was turned off and the pressure in the sample system was monitored. The leak test was acceptable as the vacuum gauge reading dropped by an amount less than 1 inch of mercury over a period of 1 minute. The Sample Line Leak Check data sheets are presented the test report generated by EECL.

6.2.7 Samde Line Inteeritv Check A sample line integrity check was done before and upon completion of each test day. The analyzers' response was tested by first introducing a mid level calibration gas directly to the NO, analyzer. The analyzer was allowed to stabilize and the response recorded. The same mid level calibration gas was then introduced to the analyzer through the sampling system. The calibration gas was introduced into the sample line at the stack, upstream of the inlet sample filter. The analyzer was allowed to stabilize and the response recorded. The analyzer response values were compared and the percent difference did not to exceed & 5% of the analyzer span value.

The sample line integrity check was to be done for both the NO, and methane/ non methane analyzers. Due to time constraints, EECL performed the integrity check for the NO, analyzers only. The SSB procedure was performed for the methane/ non methane analyzers before and upon completion of the test program. The Sample Line Integrity Check data sheets are presented in the test report generated by EECL.

6.2.8 Carbon Balance Check One of the methods used to calculate mass emissions was a carbon balance calculation developed by Southwest Research Institute specifically for the American Gas Association. The calculations consist of a theoretical O2 calculation based upon measured exhaust stack constituents and fuel gas composition. The theoretical exhaust O2 is then compared to the measured exhaust OZ. The percent difference between the actual and theoretical O2 measurements was within * 5 % of the measured O2 reading. The O2 balance was performed for every l minute average and the 33 minute averaged valued for each test point.

6.2.9 Fuel Factor Oualitv Assurance Checks Besides the CEMS calibration and QC checks, carbon dioxide and oxygen measurements were validated by calculating the fuel factor, F,, using the following equation:

Final Report Waukesha 352 1 GL 6 10 September 200 1 F,' 20.9 % 02 % CO,

The values of F, at the inlet and the outlet for each sampling run are presented in Table 6.3. From the fuel gas analysis, the calculated F, was 1.69, 1.68, and 1.70 for August 4,5, and 6 respectively. The F, values were within 6% of the calculated F, for all of the sampling runs conducted. Based upon the results, the integrity of the CEMS sample stream was not compromised due to leaks in the sampling system.

TABLE 6.3 SUMMARY OF FUEL FACTOR VALUES Run Number 1 2 3 4 5 6 7 8 Inlet F, Outlet F,

1.76 1.72 1.78 1.72 1.71 1.73 1.78 1.73 1.77 1.76 1.77 1.74 1.76 1.74 1.77 1.74 Run Number Inlet F, Outlet F,

9 1.77 1.72 10 1.75 1.72 11 1.76 1.72 * 12 1.75 1.72 13 1.67. 1.74 1 14 1.78 1.72 15 1.77 1.74 16 1.78 1.75 Final Report Waukesha 352 1 GL 6 11 September 2001 6.2.10 CEMS Detection Limits For each of the sample runs, the mass detection limits of the CEMS were presented previously in Table 6.1. For each run, the detection limit was calculated using analytical detection limit data supplied by EECL. Table 6.4 summarizes these values.

TABLE 6.4 SUMMARY OF CEMS ANALYTICAL DETECTION LIMITS Parameter I Inlet Detection I Outlet Detection Limit Limit Oxygen I ~~~ 0.01 % volume I 0.01 % volume Carbon Dioxide I 0.25 % volume I 0.1 % volume Nitrogen Oxides I 0.1 ppm I 0.1 ppm Carbon Monoxide I 2 PPm I 2 PPm Methane  7 20 PPm I 20 PPm , Non methane Hydrocarbons I 2 PPm I 2 PPm Total Hydrocarbons 0.04 ppm 0.04 ppm 6.3 DATA QUALITY ASSESSMENT EPA used the Data Quality Objective ( DQO) Process to plan the test program. The DQO Process consists of seven distinct steps.

1. State the problem. 2. Identify the decision. 3. Define inputs to the decision. 4. Define the study boundaries. 5. Develop the decision rule. 6. Specify tolerable limits on decision errors. 7. Optimize the, design for obtaining data.

Final Report Waukesha 352 1GL 6 12 September 200 1 The DQO outputs for this test program were presented in the Quality Assurance Project Plan. The problem was defined in the QAPP and is restated below.

EPA believes that there is a need to conduct emission tests on a subset of engines of differing designs to evaluate the following issues:

0 the effectiveness of after combustion control systems on hYP emissions, and 0 the effectiveness of combustion modifications ( engine operating parameters) on h54P emissions.

EPA then developed a decision statement. The decision statement defined the process that would be used to answers& he stated problem. The decision statement is restated below: h*

IfEPA can ident@ a range of engine operating conditions for a defined set of engines with specified after combustion treatment systems and a list ofpollutants of interest, and EPA collects data to determine emissions of those pollutants for each engine operated at each engine operating condition, then EPA can make a determination of the control effectiveness of after combustion and combustion modifications. In addition, EPA can obtain information on I UP emissions throughout the engine operating range.

PES and EECL conducted the test program on the Waukesha 3521GL, natural gas fired, 4 stroke, lean burn, reciprocating internal combustion engine. The MiraTech oxidation catalyst was designed to provide the information required by the decision statement. Based upon the inputs, EPA will make decisions that will be used to regulate this engine subcategory. Inputs to the decision were defined, agreed to, and documented in the QAPP. These inputs consisted of agreement on a finite list of engines to test, the after combustion control systems to test, the range of engine operating conditions, the catalyst conditioning process, the target list of pollutants, and the sampling and analysis methods, and sample durations.

During conduct of the test program, there were deviations from the QAPP. These deviations are discussed in Section 3.0 for deviations in engine operation, and Section 5.0 for deviations in Sampling and Analysis procedures.

Table 6.5 presents a summary of engine and sample method performance compared to the QAPP requirements. Outlier and data validation issues have been discussed in previous sections. Based upon the engine and method performance, the data quality is evaluated on a run by run basis for suitability in the assessment of pollutant emissions and destruction efficiency of HAP by the catalyst.

Six engine parameters were varied over the course of the test program. The parameters were changed so that emissions data and HAP destruction efficiency could be Final Report Waukesha 3 52 1 GL 6 13 September 2001 evaluated at a range of engine operating conditions. These conditions are expected to simulate the range of engine operating conditions in industry. Table 6.5 identifies the number of engine parameters that were within the tolerances prescribed in the QAPP. The target engine operating conditions were estimates based upon manufacturer's recommendations. There are differences between these recommendations and the nominal engine operating parameters of the Waukesha 3 52 1 GL engine located at the EECL. When testing was conducted some of the prescribed engine parameters could not be met. The fact that a pre set engine parameter could not be met is considered to be minor. The testing was conducted over a range of engine operating conditions, and these operating conditions are documented.

The remainder of the table assesses data quality using a three tiered system. A ( J +) indicates that all method performance parameters defined in the QAPP and/ or the sampling method were met. A ( J) indicates that at least 90% of the method performance parameters were met. In the case of FTIRS and CEMS detection limits, there were no detection limits specified in the QAPP. The calculated detection limits are reasonable for this test program. A ( J ) would indicate that fewer than 90% of the method performance parameters were met. There were no cases where less than 90% of the method performance parameters were met.

Final Report Waukesha 352 1 GL 6 14 September 200 1 TABLE 6.5 SUMMARY OF ENGINE AND METHOD PERFORMANCE FTlR QA Requirements FTfRQARequirements J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+

FIR Detection Limits a J J J J J J J J J J J J J J J J CEMSQARequirements J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+ J+

CEMS Detection Limits a J J J J J J J J J J J J J J J J Assessment of Data QuaI@

l Neither FFRS nor CBvlS detection hits were specified in the WFP Final Report Waukesha 352 1GL 6 15 September 200 1 APPENDIX A SUBCONTRACTOR TEST REPORT COLORADO STATE UNIVERSITY ENGINES AND ENERGY CONVERSION LABORATORY EMISSIONS TESTING OF CONTROL DEVICES FOR RECIPROCATING INTERNAL COMBUSTION ENGINES IN SUPPORT OF REGULATORY DEVELOPMENT BY THE U. S. ENVIRONMENTAL PROTECTION AGENCY ( EPA)

PHASE 2: FOUR STROKE, LEAN BURN, NATURAL GAS FIRED INTERNAL COMBUSTION ENGINES EMISSIONS TESTING OF CONTROL DEVICES FOR RECIPROCATING INTERNAL COMBUSTION ENGINES IN SUPPORT OF REGULATORY DEVELOPMENT BYTHE U. S. ENVIRONMENTAL PROTECTION AGENCY ( EPA)

PHASE 2: FOUR STROKE, LEAN BURN, NATURAL GAS FIRED INTERNAL COMBUSTION ENGINES Prepared for:

PACIFIC ENVIRONMENTAL SERVICES Submitted by:

Engines & Energy Conversion Laboratory Colorado State University Mechanical Engineering Department April 28,200O Statement of Confidntiaiity 7Iis report has been submitted for the sole and exclusive use of Pacific Environmental Services, and shall not be disclosed or provided to any other entity, corporation, or third part for purposes beyond the specific scope or intent of this document without the express written consent of Colorado State University. TABLE OF CONTENTS 1.0 INTRODUCTION 1.1 Overview 1.2 Background 2.0 TEST PROGRAM 2.1 Objective 2.2 Incentives 2.3 Work Plan 3.0 DEVIATIONS TO TEST PROGRAM 3.1 FTIR Validation 3.2 FTIR Post catalyst Water Analysis 3.3 Baseline Engine Operating Conditions 3.4 Four Stroke engine Test Matrix 4.0 TEST SAMPLING PROCEDURES 4.1 General Test Procedures 4.2 Test Specifics Data Collection 4.3 Test Specifics Engine Stability 4.4 Test Specifics Data Collection Hardware 4.5 Test Specifics Data Collection Process 4.6 Test Specifics Emissions Analyzer General Test Procedures 4.7 Test Specifics Emissions Analyzer Checks and Calibrations 4.8 Test Specifics m Calibration Procedures 4.9 Test Specifics FTIR Validation Procedures 4.10 Test Specifics General Calibration 4.11 Test Specifics Test Bed General Description Statement of Conjidurtiality This report has been submitted for the sole and exclusive use of Pacific Environmental Services, and shall not be disclosed or provided to any other entity, corporation, or third part for putposes bqond the s~ ijk scope or intent of this document without the exprus written consent of Colorado State University I COLORADO STATE UNIVERSITY Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K Appendix L Appendix M Appendix N Appendix 0 Appendix P Appendix Q Appendix R Appendix S Appendix T Appendix U Appendix V Appendix W Appendix X APPENDIX Engine Test Data Daily Baseline Data Points Test Point QC Checks Test Points Reference Method Analyzers Calibrations FTIR Calibration FTIR Validation Calibration Gas Certification Sheets Baseline Methane/ Non Methane Analyzer Pressure and Temperature Calibrations Equipment Certification Sheets Dynamometer Calibration Dynamometer Calibration Procedure Gas Analysis Gas Analysis Calibrations Gas Analysis Calculations  Fuel Specific F Factor Stoichiometric Air/ Fuel Calculations Computing Air/ Fuel Ratio from Exhaust Composition " An Investigation on Inlet Air Humidity Effects on a Large Bore, Two Stroke Natural Gas Fired Engine" " Derivation of General Equation for Obtaining Engine Exhaust Emissions on a Mass Basis Using the " Total Carbon" Method" Annubar Flow Calculations Additional Calculations Exhaust Piping Schematic Catalyst Schematic Statement of Confidentiality This report has been submitted for the sole and exclusive use of Pa@ Environmental Services, and shall not be disclosed or provided to any other entity, corporation, or third part for purposes beyond the specific scope or intent of this document without the express written consent of Colorado State University. 1.0 INTRODUCTION 1.1 OVERVIEW Natural gas fueled and diesel fueled reciprocating engines represent a large portion of the horsepower in operation within the oil and gas industry and power generation markets. With stringent emissions regulations being required by federal, state, and local agencies, accurate data on current engine emission levels and development of new technologies to reduce and control emissions levels has become essential for federal agencies, engine manufacturers, and equipment operators. Criteria pollutants and Hazardous Air Pollutants ( HAPS) issues are of major concern for operators of both two stroke and four stroke engines. Current Environmental Protection Agency ( EPA) and natural gas industry funded test programs are directed toward evaluating emission levels from existing engines, determining formation mechanisms for the exhaust gas constituents of interest, and developing new technologies to reduce the emissions levels of these constituents.

The investigation of the application of commercially available techniques designed to address the HAPS emissions from reciprocating internal combustion engines ( RICES) will allow the EPA to quantify the effectiveness of current commercially available control devices. These devices have been identified as having the potential to reduce HAPS emissions from stationary RICE sources. Information gained through this program will assist the EPA in the regulatory development effort.

Accurate information on emission levels from operational facilities is difficult to obtain. Based upon a recommendation from the Internal Combustion Coordinating Rulemaking Committee ( ICCR) to the EPA, a series of tests were conducted on industrial class engines at Colorado State University's Engines & Energy Conversion Laboratory. Testing was being conducted on both two stroke and four stroke natural gas engines and a four stroke diesel engine. The test program for four stroke, lean bum, natural gas fueled internal combustion engine was performed during Phase Two of this test program. The results of Phase Two testing are contained within this document.

1.2 BACKGROUND The 1990 Amendments to the Clean Air Act include provisions that significantly impact the operation of stationary reciprocating internal combustion engines. Of the ten titles to these amendments, four have direct bearing. They are as follows:

Title I  Attainment of Air Quality Standards Defines ambient air quality standards, defines non attainment areas based, imposes emissions reductions to achieve attainment per specified timeline per reasonably available control technology ( RACT).

Emissions Testing l l Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. Title III  Hazardous Air Pollutants Defines 189 pollutants classified as hazardous air pollutants ( HAPS), specifies thresholds in tons per year ( TPY) for any one of these pollutants or a combination of these compounds, introduces maximum achievable control technology ( MACT) for sources triggering thresholds.

Title V  Operating Permits Imposes requirement to obtain federal operating permits for major sources, imposes requirement to provide annual certification of compliance, defines emissions fees based on actual emissions.

Title VII  Enforcement Establish mechanisms to enhance and strengthen enforcement of CM, establishes criminal penalties, gives authority to issue administrative orders ( fines / penalties) without going to federal court for certain violations.

The EPA in conjunction with the RICE Work Group of the ICCR process determined that additional emissions data for HAPS exhaust gas constituents is required to support the regulatory development process. In a RICE Emissions Test Plan Document dated November 1997, a five component test plan to acquire additional HAPS emissions test data was set forth. The five components include the following:

Engines, Fuels, and Emissions Controls to be tested Matrix of Operating Conditions to be tested Pollutants to be Measured During Testing Test Methods to Quantify Emissions Prioritization Eight HAPS pollutants are included in the test plan. These compounds are: formaldehyde, acetaldehyde, acrolein, the BTEX compounds ( benzene, toluene, ethylbenzene, xylene) and 1 3 butadiene. Polyaromatic hydrocarbon ( PAH.) compounds were measured on the two stroke lean burn gas engine, but were not measured during the test program for the four stroke lean burn gas engine.

Insight gained through the test program will provide information on the engine operating conditions that affect the formation / reduction mechanisms of HAPS. The investigation of the application of commercially available techniques designed to address the HAPS emissions from RICES will allow the EPA to quantify the effectiveness of current commercially available control devices. These devices have been identified as having the potential to reduce HAPS emissions from stationary RICE sources. Information gained through this program will assist the EPA in the regulatory development effort.

Emissions Testing 1 2 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. 2.0 TEST PROGRAM 2.1 OBJECTIVE The objective of this program is to evaluate commercially available catalyst technologies which have been identified as having the potential to control both formaldehyde and other Hazardous Air Pollutants ( HAPS) as well as existing criteria pollutants from reciprocating internal combustion engines ( RICE). The specific internal combustion engine class tested under the Phase Two test program was the four stroke, lean burn, natural gas fueled internal combustion engines. The catalyst hardware was evaluated according to the 16 point test matrix developed by the EPA, and the Reciprocating Internal Combustion Engine ( RICE) Work Group of the ICCR process. Investigation of catalyst performance during operation at various engine operating conditions provides insight into the effectiveness of catalysts at various conditions. The information gained through the test program will assist the EPA in regulatory development efforts for control of HAPS emissions and criteria pollutants from RICE sources.

2.2 INCENTIVES Title III of the 1990 Clean Air Act Amendment requires the development of Maximum Achievable Control Technology ( MACT) standards for major sources of Hazardous Air Pollutants ( HAPS) emissions. A MACT major source is defined as one that emits greater than 10 tons per year of any single HAP or 25 tons per year for all HAPS. For most source categories ( RICE included), the MACT standards will require existing major sources apply HAPS emissions control technologies that reduce emissions to a level achieved by the best performing existing sources. In some cases, depending upon the cost of the control technology and the amount and toxicity of the HAPS removed, more stringent standards may be set. The MACT standards for RICES are scheduled to be promulgated by the year 2000.

Of the HAPS listed, the EPA in conjunction with the Internal Combustion Coordinating Rulemaking Committee ( ICCR) have identified compounds which may be present in the exhaust of reciprocating internal combustion engines. Existing test data indicates that the only HAP present in the exhaust of RICES at levels approaching 10 tons per year is formaldehyde. Commercially available after treatment technologies ( catalysts) for the control of organic compound emissions are currently in operation on RICES. These technologies have demonstrated performance for control of volatile organic compounds ( VOCs) and products of incomplete combustion. However, there is limited information on the effectiveness of these technologies for reducing organic HAPS emissions. Determining the effectiveness and longevity of exhaust catalyst will aid the EPA in evaluating current technologies for control of HAPS emissions from RICE sources as well as provide information in support of regulatory development by the EPA for these sources.

Emissions Testing 2 1 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY 2.3 WORK PLAN Pacific Environmental Services ( PES) serves as the prime contractor responsible for providing information to the EPA. CSU is a subcontractor to PES. Testing was conducted at the Colorado State University ` s Engines and Energy Conversion Laboratory. The engine and catalyst type tested is described in Table 1.

TABLE 1 ENGINE AND CATALYST TYPE Engine Classification Four Stroke, Lean Bum, Natural Gas Fueled Manufacturer and type Waukesha 3521 GL I Number of Cylinders I 6 I Bore and Stroke Engine Speed Ignition System Classification 9.375" X 8.5" 1200 RPM Spark Ignited Precombustion Chamber Ignition System Precombustion Chamber Type  Number of Precombustion Chambers Catalyst Classification Altronic Standard OEM Product 1 Per Cylinder Oxidation Type Manufacturer Element Size Number of Elements Miratech Corporation 12" xl6" x3" 2 I Substrate Stainless steel, alternating corrugated & flat layers I The test matrix as originally defined is presented in Table 2, with engine baseline conditions shown in Table 3. Deviations from the described test conditions are detailed in Section 3 of this report. Each test point consisted of collecting thirty three minutes of data. The raw data was averaged into thirty three one minute data points. The data points were then averaged to provide the results for the single test point. The results are presented in tabular form in Appendix A of this report.

Emissions Testing 2 2 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY TABLE 2 ENGINE OPERATING CONDITIONS DURING TESTING WAUKESHA 3521 GL ( 4 STROKE LEAN BURN, NATURAL GAS FIRED) US EPA ICCR RICE HAP EMISSIONS TESTING Operating Torque I ntercooler Jacket Conditions to Speed (% of Air to Fuel Water Water be Tested: ( rpm) baseline) Ratio Timing Temp. Temp.

? un 1 H H N S S S tun 2 H L N S S S ? un 3 L L / N S S S ? un 4 L H N S S S ? un 5 H H L S S S ? un 6 H H H S S S Qn 7 H L H S S S ? un a L H L S S S ? un 9 H H N S L S Xun 10 H H N S H S Run II H , H N S S L Run 12 H H N S S H ,

Run 13 H H N L S S Run 14 H H N H S S Run 15 H H N S S S Run 16 H H N S S S L= 1000 L = 70 N = 0.61 s= IO s= 130 s= lao H = 1200 H= lOO ( 9.8 % 02) L = 6 L= 12Q L= 17u L = 0.56 H= 14 H = 140 H= 19C ( 10.7 % 02) H = 0.62 ( a. 9 % 02)

l Note: Air/ he1 ratio calculations based on Appendix Q and Appendix R.

Emissions Testing 2 3 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLOMDOSTATEUNIVERSITY TABLE 3 WAUKESHA 3521 GL BASELINE CONDITIONS 1 Engine Operating Parameters Nominal Value Acceptable Range Designation 1 4 Engine Torque 3383 ft lb. to 3230 + 2% of value Primary ft lb.

1 Engine Speed I 1000 RPM I * 5% of value I Primary I 1 Jacket Water Temperature Outlet ( 180 ° F I * 5% of value 1 Primary I 1 Engine Oil Temperature Header I 180 ° F I * 5% of value I Primary I I ~~~~ Arr Manifold Temperature I 85 ° F to 130 ° F I f 5% of value I Primary I 30.0" Hg above Atm. + 5% of value Primary I Exhaust Manifold Pressure I 5.0" Hg below AMP I f 5% of value I Primary I i

I Overall Air: Fuel Ratio Ignition Timing I I 28: l 1O" BTDC I I + 5% of value + 5% of value I I Primary Primary I I Inlet Air Humidity Absolute Engine Fuel Flow SCFH .0015 lb HzO/ lb Air + 10% of value Primary 4460 to 4360 f 5% of value Primary SCFH Engine Oil Pressure Inlet Inlet Air Flow .

Average Engine Exhaust Temperature 45 lb. +, 10% of value Secondary 1400 1500 SCFM f 5% of value Secondary 660" F * 5% of value Secondary Emissions Testing 2 4 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. Cotou~ o STATE WNERTITY 3.0 DEVIATIONS TO TEST PROGRAM Testing on the four stroke, lean burn, natural gas fired IC engine was originally scheduled for mid June, but a main bearing failure occurred on June 16. The engine was rebuilt by Pamco / Stewart & Stevenson under Waukesha's direction. The actual test program was conducted between August 4, 1999 and August 6, 1999. Prior to initiation of the 16 point test matrix, a validation procedure was performed on the two FTIR analyzers. The analyzers were validated for formaldehyde, acrolein, and acetaldehyde. Modifications to the baseline engine operating conditions were made prior to the beginning of the test matrix. The variances from the original test program are described below:

3.1 FTIR VALIDATION A validation procedure was performed on the two FTIR analyzers. Eastern Research Group ( ERG) performed the validation procedures on March 30,1999. The validation procedure was conducted in basic accordance with procedures outlined in EPA Method 301" Field Validation of Pollutant Measurement Methods from Various Waste Media". Validation procedures for aldehydes utilized an analyte spiking technique as specified in Method 301. Deviations from the described procedures are as follows:

Analyte Spiking: The validation for the target aldehyde compounds was carried out by means of dynamic analyte spiking of the sample gas. The sample stream of the exhaust gas was spiked with all of the specific analytes simultaneously. This change had no impact on the test procedure or results.

Formaldehyde:

Formaldehyde spike gas was generated by volatilization of a formalin solution prepared from a stock formalin solution of 37% formaldehyde by weight. The solution was vaporized by means of a heated vaporization block. The vaporized formalin solution then mixed with a carrier gas and flowed into the sample exhaust stream. Carrier gas flow rate was measured by a mass flow meter equipped with readout. The carrier gas was to be Nitrogen; however, since it was determined to perform the validation process for all aldehyde compounds simultaneously, the Acetaldehyde/ Acrolein blend calibration gas was used as a carrier gas for the vaporized Formaldehyde. No impact on the quality of the validation data resulted from this deviation in procedure.

Acetlyaldehyde/ Acrolein Acetlyaldehyde and acrolein spiked samples were generated from a certified gas standard ( Scott Specialty Gases, ti% analytical accuracy) which contain both analyte species and Emissions Testing 3 1 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY a sulfur hexaflouride ( SFa) tracer gas. The gas flow rate was measured by a mass flow meter equipped with readout. The validation of Acetaldehyde/ Acrolein was conducted in conjunction with the Formaldehyde validation. No impact on the quality of the validation data resulted from this deviation in procedure.

Upon investigation, it was determined that the Acetaldehyde calibration gas standards supplied by Scott Specialty Gases were inaccurate. The Nicolet Rega 7000 FTIR, which had previously been validated for Acetaldehyde, showed that the calibration gases for Acetaldehyde were reading lower ppm values than the certification indicated. The spectra for the Acetaldehyde were analyzed and the calibration gases were found to have an impurity in the standard. A method was developed to compensate for the impurity so that the Acetaldehyde standards could be analyzed on the Nicolet Magna 560 FTIR.

The two component standard for Acetaldehyde/ Acrolein was used to perform the validation process. The concentration of the Acetaldehyde in the two component standard was determined by analyzing the spectra with both FTIRs. Both units were in agreement on the value of the Acetaldehyde concentration in the calibration standard. The validation process was conducted, and upon completion, the calibration gas standard was shipped to PES for evaluation. Scott Specialty Gases was contacted and informed of the situation. The other calibration standards for Acetaldehyde were returned to Scott Specialty Gases for analysis. PES will provide information on the two component standard used for the validation process.

Imnact on the validation process:

1. The calibration gas standard is analyzed and found to be in' agreement with the field evaluation. The validation for the Acetaldehyde will be complete. 2. The calibration gas standard is analyzed and found to not be in agreement with the field evaluation. In this event, several options are available:

 The validation for the Acetaldehyde will need to be performed and data adjusted if the initial validation is deemed inaccurate.  Third party analysis of the spectra to determine if the Acetaldehyde concentration values are correct. It is anticipated that this would be performed by ERG.  Other options may exist and should be explored with the assistance of EPA, PES, ERG, and CSU.  Acceptance of data based upon analysis of the calibration gas by the Nicolet Rega 7000, which has previously been validated for Acetaldehyde, Acrolein, and Formaldehyde.

Emissions Testing 3 2 Pacific Environmental Sexvices Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEWIVERSITY 3.2 FTIR POST CATALYST WATER ANALYSIS Analysis method on the Nicolet Magna 560 FTIR analyzer gave water measurements that were excessively high for post catalyst emissions measurements. The spectra for HZO, provided by Nicolet, on the Magna 560 calculated water content to be approximately 6% higher than actual exhaust gas concentrations. Carbon balance calculations for each one minute data point, at all test conditions, agreed with the Hz0 readings from the Rega 7000 FT. IR analyzer, precatalyst emissions measurement. The measurements agreed within * OS% to kl% water content. The carbon balance calculations for the post catalyst water content agreed with the precatalyst measurements within & OS% to kl% water content at all test conditions. The carbon balance measurements are based upon the precatalyst and post catalyst reference method analyzers. Since the pre catalyst and post catalyst measurements were made with separate analyzers, the variability in the H20 calculation could be caused by variability in emissions analyzers.

The changes in the water content were calculated by the carbon balance method and detected by the FTIR analyzer. Based on the agreement between the pre catalyst FMR measurements and the carbon balance calculation for water content at every test condition, and between the precatalyst and post catalyst calculations, the water content from the post catalyst FTIR measurements were used to convert the wet FTIR measurements to dry measurements. As both FTTR analyzers passed the validation process and passed all QC checks, the variation in water readings from the Nicolet Magna 560 analyzer has no impact on the results of the testing conducted during Phase Two of the overall test program.

Emissions Testing 3 3 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. 3.3 BASELINE ENGINE OPERATING CONDITIONS Baseline engine operating conditions as described in the Scope of Work are presented in Table 3 of this report. These conditions were estimates. After running the engines, these values were found to be inaccurate. Deviations from the Baseline engine operating conditions as presented are as follows:

TABLE 4 WAUKESHA 3521GL BASELINE CONDITIONS Acceptable Engine Operating Parameters Nominal Value Range Designation Engine Torque 3236 ft lb. + 2% of value Primary Engine Speed 1200 RPM + 5% of value Primary Jacket Water Temperature Outlet 180 ° F f 5% of value Primary Engine Oil Temperature Header 185 ° F +, 5% of value Primary Air Manifold Temperature 100 ° F + 5% of value Primary Air Manifold Pressure 5.0" Hg above Atm. +, 5% of value Primary Exhaust Manifold Pressure 5.0" Hg below AMP + 5% of value Primary Ignition Timing 1O" BTDC +, 5% of value Primary Overall Air: Fuel Ratio 28: l + 5% of value Primary Inlet Air Humidity Absolute .015 lb H* O/ lb Air * 10% of value Primary Engine Fuel Flow SCFH 5460 SCFH * 5% of value Primary Engine Oil Pressure Inlet 52 lb. + IO% of value Secondary Inlet Air Flow 1730 SCFM + 5% of value Secondary Average Engine Exhaust 700 ° F f 5% of value Secondary Temperature Humidity Ratio: Baseline humidity ratio is 0.015lb. HzO/ lb. air. The baseline humidity ratio was stated as 0.0015lb. HzO/ lb. air . This is a misprint. Documentation should be corrected to show 0.015lb. H* O/ lb. air as baseline humidity ratio.

August 6,1999 Baseline: The air/ fuel ratio appears to be wrong because it is calculated from the output of the pre catalyst O2 monitor. The monitor failed during this baseline. The air/ fuel ratio is 28: l when the O2 is 9.8%. The catalyst outlet O2 is 9.9%, so the air/ fuel ratio is correct.

Emissions Testing 3 4 Pacifk Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADO STATE~ IVER~~

3.4 FOUR STROKE ENGINE TEST MATRIX The four stroke engine sixteen point test matrix and associated engine operating conditions as described in the Scope of Work are presented in Table 2 of this report. During testing discrepancies between the CSU " Scope of Work" and the QAPP in relation to engine operating conditions were identified. The QAPP referenced engine operating data in relation to field engines originally proposed in the ICCR process and not the engines at Colorado State University. Deviations Tom the engine operating conditions described in the sixteen point test matrix are referenced to the CSU " Scope of Work". Deviation from the described engine operating conditions are as follows:

Global Deviation in Engine Operating Conditions Speed: The baseline speed condition was changed to 1200 rpm as indicated. This value was used for the high speed points. The value used for the low speed points was 1000 rpm.

Air/ Fuel Ratio: The baseline air/ fuel ratio condition is 28: 1. This corresponds to an equivalence ratio of 0.57 and an oxygen concentration of 9.8% in the exhaust. This value was used for the normal points. The low condition corresponds to an equivalence ratio of 0.53 and an oxygen concentration of 10.7%. The high condition corresponds to an equivalence ratio of 0.62 and an oxygen concentration of 8.9%.

Test Point Specific Variances Only deviations which were not previously described in the " Global Deviation" section will be described.

Test Point 3: The air/ fuel ratio on test point 3 appears to be wrong because it is calculated from the output of the pre catalyst O2 monitor. The monitor falied during this test point. The air/ fuel ratio is 28: 1 when the 02 is 9.8%. The catalyst outlet 02 is 9.81%, so the air/ fuel ratio is correct.

Test Points 2 and 7:

The humidity system experienced a failure prior to initiation of the test point and it was determined to conduct the test points without inlet air humidity control. The set point for humidity ratio for all test points is 0.015 lbs. water / lbs. dry air. The actual humidity ratios for Test Point 2 and Test Point 7 were 0.0 126 and 0.0 127 lbs. water / lbs. dry air respectively.

Emissions Testing 3 5 Pacifx Environmental Services Of Control Devices for Reciprocating inter& Combustion Engines In Support of Regulatory Development By the U. S. EPA. Appendix S contains a paper entitled " An Investigation on Inlet Air Humidity Effects on a Large Bore, Two Stroke Natural Gas Fired Engine" presented at the 1998 Gas Machinery Conference. The paper presents work funded by the PRCI and GRI. The paper details the effects of variations in humidity on engine performance and emissions. Results from investigation into the effects of humidity on engine emissions show the following ( Appendix S: Figure 27  Figure 30):  With increasing humidity ratio, NO, emissions decrease.  With increasing humidity ratio formaldehyde production increases.  With increasing humidity ratio, CO emissions decrease slightly while THC emissions remain fairly constant.  With increasing humidity ratio exhaust temperatures increase slightly, approximately 5 ° F over the range of humidity ratios at the air manifold boost pressure for Test Points 2 and 7( Appendix S: Figure 9).

Over the range which the humidity ratio deviated from the test matrix for Test Points 2 and 7, the engine emissions should be similar to engine emissions at the specified humidity ratio. The most dramatic effect will be on NO, emissions as can be seen from the data and the graphs presented in Appendix S. At reduced air manifold temperatures ( with engine operating parameters remaining constant), reduction in NO, emissions would be the most noticeable change. NO, emissions would be reduced due to the lower inlet air temperature and increased inlet air density. At a constant humidity ratio, it would be expected that CHZO emissions would either remain constant or increase slightly with similar changes in CO and THC emissions.

The data collected at Test Point 2 and Test Point 7 is indicative of engine field data under similar operating conditions. The variation in humidity ratio represents minimal impact on the overall emissions obtained for this data point. The most noticeable impact would be increased NO, emissions due to changes in ambient conditions, which would result in elevated in cylinder temperatures and reducde heat capacity of the inlet air charge.

3.4 OTHER DEVIATIONS The Annubar mass flowmeter used for the exhaust flow measurement did not perform correctly during the test program. Analysis by the manufacturer showed the unit to be properly calibrated and the operation of the unit was confirmed in another location on our piping system. Although the flowmeter was installed well downstream from flow obstacles, the unit shows signs of operating in disturbed flow. The fuel flow measurement is the primary mass flow measurement on the system. The exhaust flow system was not required for the test program and was disconnected, showing a negative value on the data sheets.

Emissions Testing 3 6 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. 4.0 TEST SAMPLING PROCEDURES Engines & Energy Conversion Laboratory Industrial Engine Test Facility Colorado State University To aid industrial engine research, Colorado State University was commissioned to design and install a dedicated test facility for industrial class, reciprocating internal combustion engines. The Industrial Engine Test Facility was installed at the Engines & Energy Conversion Laboratory to provide a mechanism by which environmental and technological issues related to industrial class engines could be evaluated in an independent, economical and efficient manner. The facility would also provide a level of expertise and understanding not obtainable from field testing.

4.1 GENERAL TEST PROCEDURES As with any viable testing program, a procedure has been established which affords accurate and repeatable results. The test program developed for the Industrial Engine Test Facility located at the Colorado State University's Engines & Energy Conversion Laboratory is no exception to this rule. Testing criteria established for the test facility ensures that the data collected has a high degree of accuracy and can be repeated if warranted. However, since the Industrial Engine Test Facility was designed to allow for several different industrial engine types to be tested in a laboratory environment, testing procedures differ somewhat from field test procedures and are unique to this facility. The sampling procedure and calibration procedures are described under their respective sections of the TEST SPECIFICS portion of this report.

4.2 TEST SPECIFICS  DATA COLLECTION The data collection process has been standardized to afford accurate and repeatable results throughout a test program. The high degree of accuracy, which can be obtained at the Industrial Engine Test Facility, is due to the sophisticated level of instrumentation utilized at the facility. However, without proper implementation no amount of instrumentation can assure accurate or repeatable results. Therefore a specific outline of the data collection process has been developed for the Industrial Engine Test Facility.

Data Point Definition A typical data point consisted of engine operating data taken over a specified time period and averaged. During normal field operations, engine operating parameters will fluctuate. Variations in facility process conditions can effect engine speed and load. Minimal control equipment or equipment which is not specialized to provide precision control required for engine research, can also generate unstable operation. Changes in environmental Emissions Testing 4 1 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. CoLom~ o STATEUNIVERSITY conditions during the course of a test program will introduce additional unlaiowns into typical emissions field data. The Industrial Engine Test Facility was developed through an initiative to provide a facility which would provide accurate and repeatable data by reducing variations in engine operation. Under controlled conditions at the EECL, fluctuations of engine load, speed, environmental conditions, etc. have been minimized. This effort allows more accurate and repeatable engine data than possible with field research programs.

A standard data point collected at the EECL consists of engine operating data being gathered over either a three minute or five minute period and averaged. It has been determined, based on previous tests, that 3 5 minutes provides an acceptable time period required for an appropriate data set to be collected and an average for each parameter calculated.

The Large Bore, Engine Testbed, which has been functional since 1993, was used as a reference for the other test beds at the EECL. A data point at the LBET consists of 101 engine operating parameters, which are collected and averaged for each data point. The data point consists of 30 parameters which provide basic engine operating information, twenty parameters which are received from the emissions computer and the remaining 51 parameters are engine combustion parameters calculated with a combustion analysis system. For each data point an average value, minimum value, maximum value, and standard deviation are obtained for all engine operation and emissions parameters collected. The combustion analyses system was not used for this test due to the lack of sensor access ports on the Waukesha 3521 Engine.

For the work conducted under this test program, a test point consisted of a series of data points taken in succession and averaged. The data were gathered in l minute averages over a 33minute test period. Using a data set consisting of thirty three, one minute data points would highlight any large fluctuations in load and other parameters that would have a significant effect on emissions data. No fluctuations in data occurred during any test points. This demonstrated that the engine was operating at a steady condition and the data recorded in the individual data points was repeatable.

Table 5 provides information on the nominal number of samples collected under each data point / test run scenario for the LBET.

Emissions Testing 4 2 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEVNIVERSITY TABLE 5 SAMPLING SPECIFICATIONS Measured Number of Samples Collected Parameters 1 Minute 30 Minute Data Point Test Run Engine . 30 60 900 1800 Operation 43 TEST SPECIFICS  ENGINE STABILITY For data taken during testing to be reliable, the engine was operated in a state of equilibrium at each test point. The engine control system allowed for engine operation data to be monitored so that engine stability could be easily recognized.. The stability of each specific engine's operation was not only determined on a test point by test point basis, but also on a daily basis. Since combustion parameters for each engine type will vary, engine operating parameters were used to determine engine stability. Procedures used for determining acceptable engine stability are as follows:

Engine Stability: Engine Start Up Procedures Prior to the beginning of data collection each day, the engine was " warmed up" and a thermal equilibrium state established. This was nominally determined when the engine coolant water systems and lubricating oil reached a steady state temperature. Once steady state operation was achieved, a daily " baseline" data point was gathered. The length of time required to obtain steady state operation was highly dependent upon the ambient temperature and the temperature of the engine when started. Due to the dependence on these factors, there was no predetermined warm up time.

Engine Stability: Daily Baseline Data Point The Scope of Work for the project required that a specified number of test points be collected on the engine. The data collection process encompassed multiple days of testing. To ensure that the engine was operating in a similar manner on each test day, a set of engine " baseline" data was collected. An initial set of engine " baseline" data ( one five

Emissions Testing 4 3 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERUTY minute data point) was collected prior to the first data point. On the ensuing test days, a " baseline" data point was collected to verify the data collection for that day. The primary engine operating parameters of the data point must compare to within a specified acceptable range of the values of the primary engine operating parameters on the original ." baseline" data set for engine stability and to the baseline operating conditions specified in Table 4. If primary engine operating parameters did not compare to within the predetermined range, corrective measures were taken to isolate and correct the cause of the unacceptable values for the primary engine operating parameters. Both CSU and PES representatives initialized the daily " baseline" data set. All baseline data points were acceptable during the test program. The primary/ secondary engine operating parameters, acceptable ranges, and their nominal values for a " baseline" data set are presented above in Table 4.

Engine Stability: Pm Data Point Test Procedures As with the daily engine " baseline" data point, the engine must maintain a stable mode of operation prior to and during a test run. Changing various operating parameters to achieve the desired test condition will cause the engine to operate in an unstable mode during the transition period from one condition to the next. The engine parameter which has the most effect on engine equilibrium is engine load. Fluctuations in load will result in erratic and inaccurate emissions data and for this reason load was closely monitored during testing. Changes in load will also affect the engine's thermal equilibrium and will require the longest time for the engine to return to a thermal equilibrium state.

Although the effects are not as significant as those of changing engine load, any changes in air manifold pressure, temperature, exhaust back pressure, or ignition timing also affected the engine's equilibrium. As with load changes, the engine must be closely monitored for return to an equilibrium state after any changes are made. Typically, the engine will return to equilibrium, steady state condition within 30 45 minutes. Prior to initiating a test run, a pre test run data point was gathered. The data point was five minutes in length. For each pre test run data point, an average value, minimum value, maximum value, and standard deviation were obtained for all engine operation and emissions parameters collected. Primary engine operating parameters specified at a test condition must agree with the test condition value within +/ 2% to +/ lo% of the requested value dependent upon the engine parameter. The relative standard deviations of the primary operating variables were below 1 . O% for engine operating parameters and below 3.0% for the engine emissions parameters. The primary engine operating parameters and their nominal values for a " pre test run" data point are presented below in Table 6.

Emissions Testing 4 4 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEIRVNERITY If primary engine operating parameters did not agree with the requested test condition values within the predetermined range, corrective measures was taken to isolate and correct the cause of the unacceptable values for the primary engine operating parameters. All pre test run data points were acceptable for the test program. Both CSU and PES representatives initialized each " pre test run" data point.

Engine Stability: Test Run Stability A test run consisted of a set of one minute averaged data points taken consecutively over a 33minute time period. For each data point, the average value for each primary engine operating parameter must compare to within the acceptable range of the specified target value at the test condition for engine stability and the data collection process to be valid for the specific test condition. If primary engine operating parameters did not compare to within the predetermined range, the data point was invalid, and corrective measures were taken to isolate and correct the cause of the unacceptable values for the primary engine operating parameters.

Engine stability was maintained throughout the data collection process for each test run. The relative standard deviation of the primary operating variables was below 1.0% for engine operating parameters and below 3.0% for the engine emissions parameters at each data point.

Both CSU and PES representatives initialized each data point of a test run. The tabular format of the primary engine operating parameters, designation, and the acceptance criteria is presented in Table 6:

Emissions Testing 4 5 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADO STATE UNIVERSITY TABLE 6 TEST POINT  ENGINE STABILITY Engine Operating Parameters Acceptable Range Standard Deviation Designation Engine Torque f 2% of value Il. 0 Primary Engine Speed Jacket Water Temperature Outlet f 5% of value f 5% of value 6; 1.0 Il. 0 PliIllaIy Primary I Engine Oil Temperature Outlet 1 l 5% of value 1 Il. 0 I primary I I Air Manifold Temperature 1 f 5% of value 1 I 1.0 I firnary I I Air Manifold Pressure I f 5% of value I Il. 0 I pl+= Y I I Exhaust Manifold Pressure I * 5% of value I Il. 0 I primary I I Ignition Timing I f 5% of value I 51.0 I primary I I Overall Air/ Fuel Ratio I f 5% of value I Il. 0 I primary 1 I Inlet Air Humidity Absolute I f 10% of value I Il. 0 I Em= Y I Engine Fuel Flow SCFH / Gal./ Hr. Engine Oil Pressure Inlet Inlet Air Flow f 5% of value f 5% of value f 5% of value Il. 0 13.0 s3.0 w Y Secondary Secondary I Average Engine Exhaust Temperature I f 5% of value I 13.0 1 Secondaxy I I I NO, Emissions ( PPM) CO Emissions ( PPM) THC Emissions ( PPM) co2 (%) 02 (%) Exhaust Air Flow I f 5% of value I 5 3.0 1 Secondary I I f 5% of value 1 I 3.0 1 Secondary I l 5% of value f 5% of value f 5% of value f 5% of value 13.0 53.0 s3.0 s3.0 Secondary Secondary Secondary Secondary Emissions Testing 4 6 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. 4.4 TEST SPECIFICS  DATA COLLECTION HARDWARE The design of the test facility provides a platform for accurate and versatile performance and emission research on industrial engines. Control and measurement systems installed on the Industrial Engine Test Beds are as follows:

Waukesha 3521 GL: Two Stroke Lean Burn Engine Control and Monitoring: Bristol Babcock Control and Monitoring system Emission Analysis Systems: Pre catalyst Emissions Rosemount NGA 2000 Five Gas Analyzer Rack for NO,, CO, COz, 02, & THC Emission Analysis System: Precatalyst Emissions Nicolet Rega 7000 Fourier Transform Infrared ( FTIR) Exhaust Gas Analyzer Emission Analysis Systems: Post catalyst Emissions Five Gas Analyzer Rack TECO NO, CO, & THC Servomex CO* & O2 Emission Analysis System: Post catalyst Emissions Nicolet Magna 560 Fourier Transform Infrared ( FTIR) Exhaust Gas Analyzer Ignition Analysis System: Altronic Diagnostic Module . \

4.5 TEST SPECIFICS  DATA COLLECTION PROCESS The data collection process consisted of acquiring information from the various control and monitoring systems. The engine control and monitoring system ( ECMS) collected all engine operating and emissions parameters ( criteria pollutants only). All engine operating parameters were direct measurements of the ECMS, while emissions parameters ( criteria pollutants) were passed by communication link from a computer dedicated to emissions hardware control and monitoring. All emissions parameters measured with an FTIR were collected and stored on a computer dedicated to individual FTIR operation.

After engine stability had been confirmed, the data collection process for a test run condition commenced. The data collection process was performed as follows:

Emissions Testing 4 7 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADO STATE~ IVERSITY Data Collection Process: 1.) Verification of engine stability confirmed, accepted, and initialized by PES and CSU representatives. 2.) Proper file names are assigned to all data acquisition hardware. 3.) Commence acquisition of data point for specified test condition 4.) At completion of data point, electronic files are saved and hard copies are printed out. 5.) PES and CSU representatives initialize hard copies verifying acceptable data point. 6.) Move engine operation to next test condition.