[Federal Register Volume 80, Number 153 (Monday, August 10, 2015)]
[Notices]
[Pages 47914-47916]
[FR Doc No: 2015-19559]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. RD14-14-000]

Commission Information Collection Activities; (FERC-725G1);
Comment Request

AGENCY: Federal Energy Regulatory Commission.

ACTION: Comment request.

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SUMMARY: In compliance with the requirements of the Paperwork Reduction
Act of 1995, 44 U.S.C. 3507(a)(1)(D), the Federal Energy Regulatory
Commission (Commission or FERC) is submitting its information
collections FERC-725G1 to the Office of Management and Budget (OMB) for
review of the information collection requirements. Any interested
person may file comments directly with OMB and should address a copy of
those comments to the Commission as explained below. The Commission
previously issued a Notice in the Federal Register on 5/13/2015
requesting public comments. The Commission received no comments on
FERC-725G1 and is making this notation in its submittal to OMB.

DATES: Comments on the collection of information are due by September
9, 2015.

ADDRESSES: Comments filed with OMB, identified by the FERC-725G1
information should be sent via email to the Office of Information and
Regulatory Affairs<EMAIL_ADDRESS>Attention: Federal Energy
Regulatory Commission Desk Officer. The Desk Officer may also be
reached via telephone at<PHONE_NUMBER>.
    A copy of the comments should also be sent to the Commission, in
Docket No. RD14-14-000, by either of the following methods:
     eFiling at Commission's Web site: http://www.ferc.gov/docs-filing/efiling.asp.
     Mail/Hand Delivery/Courier: Federal Energy Regulatory
Commission, Secretary of the Commission, 888 First Street NE.,
Washington, DC 20426.
    Instructions: All submissions must be formatted and filed in
accordance with submission guidelines at: http://www.ferc.gov/help/submission-guide.asp. For user assistance contact FERC Online Support
by email at<EMAIL_ADDRESS>or by phone at:<PHONE_NUMBER>
(toll-free), or<PHONE_NUMBER> for TTY.
    Docket: Users interested in receiving automatic notification of
activity in this docket or in viewing/downloading comments and
issuances in this docket may do so at http://www.ferc.gov/docs-filing/docs-filing.asp.

FOR FURTHER INFORMATION CONTACT: Ellen Brown may be reached by email at
<EMAIL_ADDRESS>by telephone at<PHONE_NUMBER>, and by fax at
(202) 273-0873.

SUPPLEMENTARY INFORMATION:
    Type of Request: Three-year extension of the information collection
requirements for all collections described below with no changes to the
current reporting requirements. Please note that each collection is
distinct from the next.
    Comments: Comments are invited on: (1) Whether the collections of
information are necessary for the proper performance of the functions
of the Commission, including whether the information will have
practical utility; (2) the accuracy of the agency's estimates of the
burden and cost of the collections of information, including the
validity of the methodology and assumptions used; (3) ways to enhance
the quality, utility and clarity of the information collections; and
(4) ways to minimize the burden of the collections of information on
those who are to

respond, including the use of automated collection techniques or other
forms of information technology.
    Title: Proposed revisions FERC-725; proposed new collection FERC-
725G1 (Certification of the Electric Reliability Organization and
Procedures for the Establishment, Approval and Enforcement of Electric
Reliability Standards; Mandatory Reliability Standards for the Bulk-
Power System: Reliability Standard PRC-004-3).
    OMB Control No.: 1902-0269 (FERC-725); TBD (FERC-725G1).
    Abstract: On September 15, 2014, the North American Electric
Reliability Corporation (NERC) submitted a petition seeking approval of
a revised Protection and Control (PRC) Reliability Standard PRC-004-3--
Protection System Misoperation Identification and Correction, pursuant
to section 215(d)(1) of the Federal Power Act (FPA) \1\ and section
39.5 of the Commission's regulations.\2\ The revised Reliability
Standard, which replaces Reliability Standards PRC-004-2.1a (Analysis
and Mitigation of Transmission and Generation Protection System
Misoperations) and PRC-003-1 (Regional Procedures for Analysis of
Misoperations of Transmission and Generation Protection System),
requires transmission owners, generator owners, and distribution
providers to identify and correct causes of misoperations of certain
protection systems. NERC also requests approval of two new terms
utilized in the proposed Reliability Standard, to be included in NERC's
Glossary of Terms Used in NERC Reliability Standards (NERC Glossary).
Finally, NERC requests approval of its implementation plan for
Reliability Standard PRC-004-3, including the retirement of Reliability
Standards PRC-004-2.1a and PRC-003-1, as well as approval of the
associated Violation Risk Factors (VRFs) and Violation Severity Levels
(VSLs). FERC determined that revised Reliability Standard PRC-004-3,
including the associated new Glossary terms and implementation plan, is
just, reasonable, not unduly discriminatory or preferential and in the
public interest. We accept the violation severity levels associated
with the standard as proposed by NERC, however, we direct NERC to
submit a compliance filing, within 60 days of issuance of this order,
to address the Commission's concerns with the VRF designations for
Requirements R1 through R6.
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    \1\ 16 U.S.C. Sec.  824o(d)(1) (2012).
    \2\ 18 CFR Sec.  39.5 (2014).
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    Type of Respondent: Businesses or other for-profit institutions;
not-for-profit institutions.
    Estimate of Annual Burden: Reliability Standard PRC-004-3 requires
each transmission owner, generator owner, and distribution provider to
provide notification of BES interrupting devices that operated in
accordance with the Requirement R2.\3\ Our estimate below regarding the
number of respondents is based on the NERC Compliance Registry as of
January 30, 2015. According to the NERC Compliance Registry, NERC has
registered in the United States 326 transmission owners (TO), 914
generator owners (GO), and 471 distribution providers (DP). However,
under NERC's compliance registration program, entities may be
registered for multiple functions, so these numbers incorporate some
double counting. The total number of unique entities that may be
identified as a notification provider (e.g., applicable entity) in
accordance with Reliability Standard PRC-004-3 will be approximately
659 entities registered in the United States as a transmission owner,
generator owner, and/or distribution provider.
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    \3\ Requirement R2--Each Transmission Owner, Generator Owner,
and Distribution Provider that owns a BES interrupting device that
operated shall, within 120 calendar days of the BES interrupting
device operation, provide notification as described in Parts 2.1 and
2.2.

                                                                     FERC-725G1 \4\
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                                                                          Annual  number                      Average      Total annual
                                                             Number of     of  responses   Total  number   burden & cost   burden hours      Cost per
                                                            respondents         per        of  responses   per response   & total annual  respondent ($)
                                                                            respondent                          \5\            cost
                                                                     (1)             (2)     (1)*(2)=(3)             (4)     (3)*(4)=(5)         (5)/(1)
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Notifications to TO/GO/DP per Requirement R2............             659               1             659               8           5,272             584
                                                                                $584        $384,856
One-time review and adjustment of existing program......             659               1             659               2           1,318             146
                                                                                $146         $96,214
Evidence Retention......................................             659               1             659              12           7,908             384
                                                                                $384        $253,056
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    Total...............................................  ..............  ..............  ..............  ..............          14,498           1,114
                                                                                $734,126
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    \4\ FERC-725G is a currently pending request at OMB. Only one
submittal can be pending OMB review under each control number,
therefore, FERC-725G1 will be used for timely submittal.
    \5\ The estimates for cost per response are derived using the
following formula: Average Burden Hours per Response * $n per Hour =
Average Cost per Response. The $73 hourly cost figure is the average
of the salary plus benefits for a manager and an engineer (rounded
to the nearest dollar); $32/hour is the salary plus benefits for
information and record clerks. The figures are taken from the Bureau
of Labor Statistics at http://bls.gov/oes/current/naics3_221000.htm.

    Dated: August 4, 2015.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2015-19559 Filed 8-7-15; 8:45 am]
 BILLING CODE 6717-01-P


4.6 TEST SPECIFICS  EMISSION ANALYZER GENERAL TEST PROCEDURES Introduction The following general test procedures and calibration checks guaranteed the integrity of our sampling system and the accuracy of our data. The testing was conducted in basic accordance with approved Environmental Protection Agency ( EPA) test methods as described in the Code of Federal Regulations, Title 40, Part 60, Appendix A.

General Procedure Exhaust oxygen and oxides of nitrogen concentrations from the engine were determined in basic compliance with EPA Method 20, " Determination of Nitrogen Oxides, Sulfur Dioxide, and Diluent Emissions From Stationary Gas Turbines'knd EPA Method 7E, " Determination of Nitrogen Oxides Emissions From Stationary Sources ( Instrumental Analyzer Procedure)". The sampling procedure for CO concentrations was based on EPA Method 10, " Determination of Carbon Monoxide Emissions from Stationary Sources." EPA Method 25A, " Determination of Total Gaseous Organic Concentration Using a Flame Ionization Analyzer" was the sample procedure used to determine THC emission concentrations. A modified EPA Method 18A was used for the sampling procedures for Methane/ Non Methane Analysis. The method for calculating mass emissions levels was based upon an EPA Method 19 " Determination of Sulfur Dioxide Removal Efficiency and Particulate Matter, Sulfur Dioxide, and Nitrogen Oxides Emission Rates" calculation. Mass emissions were also calculated using carbon balance calculations developed by Southwest Research Institute specifically for the American Gas Association. Calibration and test procedures are detailed under their respective sections of the TEST SPECIFICS portion of this report.

Emissions Testing 4 8 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. Sampling System Dedicated analyzers were used to determine the NO,, CO, THC, CO2, and 02 emissions level on a dry basis for both pre and post catalyst emissions. Dedicated analyzers were used to determine the Methane/ Non Methane emissions on a wet basis for both pre and post catalyst emissions. FTIR analyzers were used to determine aldehyde emissions on a wet basis for both pre and post catalyst emissions. Refer to Table 7 for the analyzers and the methods of analysis.

Exhaust gas entered the system through a 318" stainless steel multi point probe. Sample points were located in accordance with procedures described in Method 1. Exhaust gas then passed through a heated 3 way sample valve and glass wool filter assembly. The sample was transported via a heat traced Teflon sample lines and heated sample distribution manifold. Sample for the " dry" gas analyzers then passed through a 4 pass minimum contact condenser specifically designed to dry the sample. The " dry" sample then entered a stainless steel sample pump. The discharge of the pump passed through 318" Teflon tubing to a Balston Microfibre coalescing filter, moisture sensor, and then to the sample manifold. The sample manifold was maintained at a'constant pressure by means of a pressure bypass regulator. A flow meter, placed in line at the exhaust of each analyzer, monitored exact sample flows. Heated sample flow for all " wet" measurement analyzers will be provided by means of a heated sample distribution manifold prior to sample gas entering the " dry" gas analyzer platform. Each heated analyzer had a dedicated sample pump and heat traced line from the main sample train to the analyzer.

Emissions Testing 4 9 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEWIVERSITY TABLE 7 CURRENT, INSTRIJMENT. ATION

n  F (

E r I r I z I 1 ( 1 I 1 I ,

(

I Post catalyst Emissions danufacturer and Model Parameters losemount NGA 2000 NO or NO, ZLD Analyzer < osemount NGA 2000 CO DIR Analyzer < osemount NGA 2000 COZ WIR Analyzer < osemount NGA 2000 THC TD Analyzer Detection Principle Thermal reduction of NO2 to NO. Chemiluminescent reaction NO with 03. NDIR with Gas Filter Correlation NDIR Flame Ionization RwF Variable to 10000 PPM Variable to 2000 PPM Variable to 20%

Variable to 10,000 PPM $ osemount NGA 2000 02 Paramagnetic Variable to ? MD Analyzer 100% & estar Baseline 1030H CH4 Gas Chromatograph Variable to HeatedGC / FID Non CH4 Flame Ionization 5000 PPM qicolet Magna 560 Multiple FTIR analysis utilizing a Variable See Attached medium range IR source. Pre catalyst Emissions Manufacturer and Model 1 Parameters 1 Detection Principle I Range DECO Model 42H CLD Analyzer TECO Model 48H NDIR Analyzer NO or NO,

co Thermal reduction of NO2 to Variable to NO. Chemiluminescent 5000 PPM reaction NO with 03. NDR with Gas Filter Variable to Correlation 20000 PPM I Servomex NDIR Analyzer CO2 NDIR O 25% TECO Model 5 1 THC Flame Ionization Variable to FID Analyzer 10000 PPM Servomex 02 Paramagnetic O 5% PMD Analyzer O 25% Questar Baseline 103 OH CH4 Gas Chromatograph Variable to HeatedGC / FID Non CH4 Flame Ionization 50000 PPM Nicolet Rega 7000 Multiple FTIR analysis utilizing a Variable See Attached medium range IR source.

Emissions Testing 4 10 Pacific Environmentd Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. TABLE 8 COMPONENTS MEASURED BY NICOLET FTIR Component Formula Component Name H20 CO co2 NO NO2 NO NH3 NOX C&

C2H2 c2Hs C2&

c3Hs H2C0 CH30H C3Ha w& o N G& o CH& HO so2 TIE Water Carbon Monoxide Carbon Dioxide Nitric Oxide Nitrogen Dioxide Nitrous Oxide Ammonia Oxides of Nitrogen Methane Acetylene Ethylene Ethane Propane Formaldehyde Methanol Propane Iso Butylene . Normal Butane Acetaldehyde Sulti Dioxide Total Hydrocarbons Emissions Testing 4 11 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. 4.7 TEST SPECIFICS  EMISSION ANALYZERS CHECKS AND CALIBRATIONS The following instrument checks and calibrations guaranteed the integrity of our sampling system and the accuracy of our data.

Analyzer Calibration Gases Standard calibration gases used at the facility are Scott Specialty Gases EPA Protocol Gas Standard calibration gases with a kl . O% or k2.0% accuracy. For this program, EPA Protocol 1 calibration gases ( RATA Class) were used. Manufacturer supplied certification sheets were available during the testing procedure and copies of the current inventory of gases, which were used for calibration and integrity checks on the reference method and FTIR analyzers, are provided within this document.

EPA Protocol 1 gases ( Rata Class) were used to calibrate the reference method analyzers and FTIR analyzers. Formaldehyde standards with a concentration range between 5  20 PPM were obtained. Acetylaldehyde/ acrolein standards were also acquired. Any calibration standards which were not EPA Protocol 1 gases were the highest quality standard available.

Analyzer Specifications Vendor instrument data concerning interference response and analyzer specifications are available if requested. Information supplied by the manufacturer on the factory specification sheets will be furnished if requested.

Response Time Tests ( Prior to initiation of engine test program)

Response time tests were performed on each sample system. The response time tests were performed prior to the FTIR validation process for each sampling system. The response time of the slowest responding analyzer ( Questar Baseline) 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 ( slowest responding analyzer which continuously monitors) to stabilize to response output of the analyzer. The Questar Baseline Industries CH4/ Non CH4 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 550 minutes. When the CH4/ Non CH4 analyzer cycle time was initiated at a sample source change, the overall response time is 9: OO minutes. The response time was tested to assure that the analyzers' response was for exhaust gas entering the sample system from each of the test point conditions.

Emissions Testing 4 12 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUAWERUTY Calibration ( Daily)

Zero and mid level span calibration procedures were performed on the reference method analyzer prior to each test day. Zero and span drift checks were performed upon completion of each data point and upon completion of each test day. This procedure is referenced as ZSD ( zero and span drift check) in the CSU " Scope of Work". A zero and a mid level gas was introduced individually directly to the back of 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 voltage for each analyzer were recorded and used in the following formula:

Y= MX+ B Where: B = Intercept N= Slope X= Analyzer or transducer voltage Y = Engineering Units After each test point and upon completion of a test day, calibration checks were conducted by re introducing 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 will be used to determine a zero and span drift for each test point for the CO, COZ, 02, THC, CH4/ Non CH4, and NO, analyzers. The zero and span drift checks for each test point and each test day were less than X2.0% of the span value ( specific range setting) of each analyzer used during the daily test program. The calibration data sheets are presented in Appendix E of this document.

Linearity Check ( Prior to initiation of engine test program)

Prior to initiation of the test program, analyzer linearity checks were performed. This procedure is referenced as ACE ( analyzer calibration error check) in the CSU " Scope of Work". 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 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 voltages for each analyzer were recorded and used in the following formula:

Emissions Testing 4 13 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY .

Y= hW+ 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 analyzers' linearity was acceptable as 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 & 2.0% of the analyzer span value. The methane/ non methane analyzers' linearity was acceptable as the predicted values agreed with the actual response of the low level and high level calibration gases within & 5.0% of the actual calibration gas value. This procedure was performed for one range setting for each analyzer. The Linearity Check data sheets are presented in Appendix E of this document.

NO2 Converter Check ( Prior to initiation of engine test program)

Prior to initiation of the test program, NO2 converter checks were performed. A calibration gas mixture of known concentrations between 240 and 270 PPM nitrogen dioxide ( NO2) 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,) analyzer until a stable response was recorded.

The converter is considered acceptable if the instrument response indicated a 90 percent or greater NO2 to NO conversion. The NOz Converter Check data sheets are presented in Appendix E of this document.

Sample Line Leak Check ( Prior to initiation of engine test program)

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 involved closing the valve on the inlet to the sample filter located just downstream of the 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 in Appendix E of this document.

Ihissions Testing 4 14 Pacific Environmental Services Of Control Devices for Reciprocating Internal  Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADO STATE WIVEM~

Sample Line Integrity Check ( Daily)

A sample line integrity check was performed prior to and upon completion of each test day. This procedure is referenced as SSB ( Sampling System Bias Check) in the CSU " Scope of Work". The analyzer's response was tested by first introducing the 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 ( range setting).

The SSB procedure was to be performed for both the NO, and methane/ non methane analyzers. It was determined to perform the integrity check for the NO, analyzers only. The SSB procedure was performed for the methane/ non methane analyzers prior to and upon completion of the test program. The Sample Line Integrity Check data sheets are presented in Appendix E of this document.

Carbon Balance Check ( Continuous)

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. As part of a QC check, the calculations involve performing a theoretical 02 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 02 reading. The O2 balance was performed for every one minute average and the thirty three minute averaged value for each test point. The averaged value for each test point is included in the test point data in Appendix A.

Fuel Gas Analysis & Fuel Flow Measurements Natural Gas Fuel Gas: Engine fuel gas was analyzed on a real time basis with a dedicated Daniels Industries GC. The GC was calibrated on a daily basis against a known standard. A daily gas analysis was acquired for each test day. This analysis gave the actual specific gravity, mole fractions of specific hydrocarbons and BTU content so that fuel flow and mass emissions could be accurately calculated. Fuel flow measurements were made using an AGA specified orifice meter run equipped with dedicated high accuracy pressure and temperature transmitters. All fuel flow calculations were in accordance with AGA Emissions Testing 4 15 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. CoLok4~ 0 STATE uiwmsm Report # 3. Additionally, stoichiometric air to fuel ratio calculations were made using the fuel gas analysis. From this information, the equivalence ratios for each day of testing were determined. All fuel gas calibrations and analysis are presented in Appendix 0 and Appendix N, respectively. Stoichiometric air to fuel ratio calculations are presented in Appendix Q. Calculations for fuel flow, stoichiometric air to fuel ratio calculations, and fuel specific F Factor are presented in Appendix V, Appendix Q, and Appendix P, respectively.

A blind sample provided by PES was analyzed. The results are included in Appendix N of this report.

4.8 TEST SPECIFICS: FTIR CALIBRATION PROCEDURES Calibration was performed on the FTIR instrument prior to each phase of the test program and at the beginning and end of each test day. The calibration procedures described within this document are consistent with procedures found in the following documents:

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

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

Both documents are contained with the Gas Research Institute Report Number GRI 9510271 entitled, " Fourier Transform Infrared ( FTIR) Method Validation at a Natural Gas Fired Internal Combustion Engine"  Prepared by Radian International for the Gas Research Institute.

Instrument Description Dedicated FTIR analyzers and sampling conditioning systems were used to measure pre catalyst and post catalyst exhaust emissions. A description of each unit is presented in Table 9:

Emissions Testing 4 16 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY TABLE 9 FTIR EQUIPMENT DESCRIPTION 1 Pre catalyst Analyzer I Manufacturer and Type 1 Nicolet Rega 7000 Spectral Resolution OScm" Detector Type MCT A Cell Type 4.2 Meter  Fixed Path Length Cell Temperature 185OC Cell Pressure 600 Ton: Cell Window Material Zinc Cellmide Post catalyst Analyzer Manufacturer and Type Nicolet Magna 560 I Spectral Resolution I 0.5cm' 1 Detector Type Cell Type MCT A 2.0 Meter  Fixed Path Length Cell Temperature Cell Pressure Cell Window Material 165 ° C 600 Torr KBr Each unit and the associated test method have been designed for measurement of raw exhaust gases from internal combustion engines. Dedicated temperature controllers maintained cell temperature and associated sample lines at the appropriate the design temperature. Pressure was controlled by means of an MKS pressure controller for each system. Sample flow to each analyzer was between 8  15 liters/ minute. The units utilized a high energy mid range IR source and are equipped with modulating, potassium bromide beamsplitters with MCT A liquid nitrogen cooled detectors. The cells have been equipped with specific optical windows to prevent signal degradation from damaged optics due to moisture and corrosive gases present in the exhaust stream.

Pre Engine Test Calibration Prior to initiation of an engine specific test program, the FTIR sampling systems, both pre and post catalyst sample trains underwent an EPA Method 301 validation process. The validation process was to verify the sample and analytical system performance in relation to precision and accuracy of data collected. Additional calibration procedures prior to testing of the engine were as follows:

Emissions Testing 4 17 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATELNWERSITY 1.) Source Evaluation  Acquired initial source data to verify concentration ranges of target compounds and possible interfits. This was accomplished prior to and during the Method 30 1 validation process 2.) Sample System Leak Check  Sample system leak checks were performed. The leak check procedure encompassed the sample train from the sample filter to the pump outlet. A dedicated rotameter was installed on the discharge side of the sample pump. With the sample system operating at typical temperatures and pressures ( sample pump will pull a slight vacuum on the suction side), the sample flow rate from the rotameter was recorded. The inlet to the sample filter located just downstream of the sample probe was closed and the flow rate through the rotameter was monitored. The flow rate through the rotameter went to zero. The leak checks were determined to be acceptable, as the leak rate was less than 4% of the standard sampling rate or SOOml/ min, whichever is less. Sample system leak check data sheets are provided in Appendix F of this document. 3.) Analyzer Leak Check  With the FTIR analyzers operating at normal operating temperatures and pressures, the operating pressures were recorded. The automatic pressure controllers were then disabled, and the inlet valves to the FTIR analyzers were then closed. The measurement cells were then evacuated to 20% or less of their normal operating pressure. After the measurement cells were evacuated, each measurement cell was then isolated and the cell pressure monitored with a dedicated pressure sensor. The leak rate of each measurement cell was less than 10 Tour per minute for a one minute period. The analyzer leak rate was determined to be acceptable. Analyzer leak check data sheets are provided in Appendix F of this document. 4.) Cell Pathlength Determination  The cell pathlength was to be determined using the measurement procedures as outlined in the Field Procedure Section of the document entitled " Protocol For Performing Extractive FTIR Measurements To Characterize Various Gas Industry Sources For Air Toxics", prepared by Radian International for the . Gas Research Institute. Because the units are fixed pathlength ( non adjustable) measurement cells which are stationary units dedicated to a specific task, the pathlength determination process was determined not to be necessary. The units are " as specified" from the manufacturer, and have passed all validation and calibration procedures at this fixed pathlength.

Emissions Testing 4 18 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. Daily Calibration Procedures  Pre Test The following daily calibration procedures were performed prior to the initiation of each day's testing.

I.> Instrument Stabilization  To ensure the FTIR instruments were operating in a stable manner, verification of the operation of the following components at the beginning of each day was performed: a.) All instrument heated devices and temperature controller were at operating temperature and performing properly. b.) Pressure sensor and pressure controllers were at operating conditions and performing properly. c.) Sample systems ( pumps, filters, flow meters, and water knockouts) were functioning properly. 2.) Instruments were operated on a conditioned air source for a minimum of 30 minutes prior to conducting background spectrum procedures. When the instruments were in standby mode, between test days, the analyzers and all components were kept at normal operating temperatures. The analyzers operated on conditioned air at all times when not involved with data acquisition. 3 .> Background spectrum procedures  After purging with a conditioned air source for a minimum of 30 minutes, the instruments were allowed to stabilize by flowing an ultra high purity Nz gas through the measurement cell for a minimum of ten minutes. During the stabilization process, the PTIR spectra were monitored until the concentrations of CO and Hz0 were reduced and normal steady state background levels had been achieved. The following procedures were then performed: a.) Check for proper interferogram signal using alignment software b.) Collect a single beam spectrum and inspect for irregularities c.) Check the single beam spectrum for detector non linearity and correct if necessary d.) Perform an instrument alignment procedure e.) Collect a background spectrum  The background spectrum was comprised 256 scans, which was equal to or greater than the number of scans used for sample analysis. 4.) Analyzer Diagnostics  Perform an analyzer diagnostic procedure by analyzing a diagnostic standard. The standard was a EPA Protocol 1 CO gas standard at concentration levels indicative of the emissions source, 109 ppm. A CO standard was recommended due to the distinct spectral features, which are sensitive to variations in system operation and performance. The standard was introduced directly into the instrument. The instrument readings were allowed to stabilize and a Emissions Testing 4 19 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTA.~ UNIVERSITY five minute set of data was acquired. The calculated accuracy and precision based on equations from the document entitled " Protocol for Performing Extractive FTIR Measurements To Characterize Various Gas Industry Sources for Air Toxics", prepared by Radian International for the Gas Research Institute, was acceptable. The pass/ fail criteria for accuracy and precision was f 10% of the known standard for the instrument to be. acceptable. Each instrument meets this criteria for all daily calibrations. Analyzer diagnostic data sheets are provided in Appendix F of this document. 5.) Additional Analyzer Diagnostic  An additional diagnostic check was performed to ensure system operation and performance. A second diagnostic standard comprised of a multi gas composition was analyzed by the same procedure. The gas consisted of COZ, CO, C&, and NO, in concentrations similar to exhaust gas composition. The same pass/ fail criteria was used to evaluate each analyzer's performance when analyzing the multi gas standard. Each instrument meets this criteria for all daily calibrations. Analyzer diagnostic data sheets are provided in Appendix F of this document. 6.) Indicator Check & Sample Integrity Check  An indicator check procedure was performed on each analyzer by analyzing a certified indicator standard. The standard was either a NIST traceable, EPA Protocol 1 gas standard, or highest grade standard available of a surrogate/ analyte gas concentration at levels indicative of the emissions source. A formaldehyde standard ( concentration of 10.66 ppm) was used due to the fact that formaldehyde represents a sampling challenge because of its solubility in water. The standard was introduced directly into the instrument. The instrument readings were allowed to stabilize and a five minute set of data was acquired. Next, the indicator standard was introduced into the sample system at the sample filter located just downstream of the sample probe. The instrument readings were allowed to stabilize and a five minute set of data was acquired. The calculated accuracy and precision based on equations from the document entitled " Protocol For Performing Extractive FTIR Measurements To Characterize Various Gas Industry Sources For Air Toxics", prepared by Radian International for the Gas Research Institute. The pass/ fail criteria for accuracy, precision, and recovery was f 10% of the known standard ( recovery was f 10% of the instrument reading with the indicator gas introduced directly into the instrument.) for the instrument to be acceptable. Each instrument meets this criteria for all daily calibrations. Indicator check and sample integrity check data sheets are provided in Appendix F of this document.

Emissions Testing 4 20 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. Daily Calibration Procedures  Background assessment The baseline absorbance was continually monitored during da& acquisition procedures. If it was determined by PES, ERG, and CSU personnel that the baseline had changed by more than 0.1 absorbance units, the instrument interferometer was realigned and a background spectrum collected.

Daily Calibration Procedures  Post Test Upon completion of the daily test program steps 4  6 of the pre test calibration procedures were repeated. Both analyzers meet all acceptance criteria for calibration procedures. All post test calibration data sheets are presented in Appendix F of this document.

4.9 TEST SPECIFIC  FTIR VALIDATION PROCEDURES To ensure the accuracy of data collected during testing, the test program required procedures to evaluate instrument performance. Prior to collecting test data, a validation procedure was performed on each FTIR sample train, both pre catalyst and post catalyst, for the natural gas fueled engine classification. The specific sample trains are as follows:

1.) Precatalyst emissions sample trains from the exhaust of natural gas fueled engines. This comprises the two stroke lean burn engine class and four stroke lean burn engine. 2.) Post catalyst emissions sample trains from the exhaust of natural gas fueled engines. This comprises the two stroke lean burn engine and four stroke lean burn engine.

Each sample train was validated for the following target compounds:

1.) Formaldehyde 2.) Acetaldehyde 3.) Acrolein Instrument Description Refer to FTR calibration procedures for FTR instrument description.

Emissions Testing 4 2 1 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADO STATE CRvIvERsm Procedures Eastern Research Group, ERG, performed the validation for the target aldehyde compounds. The validation procedure was conducted in basic accordance with procedures outlined in Method 30 1" Field Validation of Pollutant Measurement Methods from Various Waste Media". Validation procedures for aldehydes utilized an analyte spiking technique as specified in Method ' 301. The procedures for the validation process are as follows:

Analyte Spiking: The process was carried out by means of dynamic analyte spiking of the sample gas. The sample stream of the exhaust gas was spiked with the specific analyte after the sample probe, and before the sample filter. Spike levels for the specific aldehydes were determined and the spike gas concentrations were generated for the specific aldehydes using the following methods:

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 injected into a heated vaporization block. The vaporized formalin solution was mixed with a acetylaldehyde/ acrolein carrier gas and carried into the sample exhaust stream. Carrier gas flow rate was measured by a mass flow meter equipped with readout Acetlyaldehyde/ Acrolein: Acetlyaldehyde and acrolein spike samples were generated from a certified gas standard ( Scott Specialty Gases, ti% analytical accuracy) which contained both analyte species and a sulfur hexaflouride ( SF6) tracer gas. Carrier gas flow rate was measured by a mass flow meter equipped with readout.

Analyte specific spike gas was introduced to the FTTR sample train upstream of the sample system filter. The spike gas was introduced at a known flow rate. The spike gas flow was controlled by a three way solenoid valve, which directed gas either into the sample stream or diverted the spike gas to the atmosphere. This allowed for uninterrupted flow of the analyte spike gas source during the validation procedures.

The formaldehyde and acetylaldehyde/ acrolein validation runs were conducted simultaneously. The validation test runs consisted of 24 test runs, 12 spiked and 12 unspiked runs, which were paired and grouped further into s& groups of 2 spiked/ unspiked pairs to simulate the " quad train" approach used for Method 301 Emissions Testing 4 22 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. CoLoh4~ 0 STATE: UN~ ERSI~ Y statistical calculations. Samples were one minute in duration. Measurement procedures for acquiring the spiked/ unspiked pairs are as follows:

1.) Verify stable engine operation 2.) Begin measurement of the unspiked native exhaust stack gas. 3.) Upon completion of acquiring the unspiked sample, initiate spike gas flow into sample stream. 4.) Let system equilibrate. 5.) Begin measurement of the spiked exhaust gas sample. 6.) Upon completion of acquiring the spiked sample, divert spike gas flow to atmosphere. 7.) Let system equilibrate. 8.) Repeat items 2 through 7.

This procedure was performed twelve times to acquire the appropriate number ` of spiked/ unspiked pairs. To ensure stable engine operation during the validation procedure, engine operating data was collected during the spiking process.

4.10 TEST SPECIFIC  GENERAL CALIBRATION To ensure the accuracy of data collected during testing, the test procedure required that all instrumentation be routinely calibrated. Calibrations and/ or calibration checks were dormed within one week before initiation of testing, and upon completion of the entire test program to ensure that no " drift" has occurred. The devices calibrated included the dynamometer 5000 lb. load cell and amplifier, all thermocouples, pressure transducers, and all pressure transmitters.

Dynamometer Load Cell and Amplifier ( Daily)

The 5000 pound load cell and amplifier was calibrated prior to the engine test section. The calibration procedure is outlined in a document contained in Appendix M of this document. Calibration of the load cell and amplifier were then be verified by applying the full range of load without any adjustments to the offset or gain of the instrumentation. Calibration checks were performed on a daily basis prior to starting the engine to identify and correct any drift in the load cell or amplifier. These checks used the same procedure as the calibration verification. Jf the daily calibration check showed an indicated load that exceeded fl. O% of the torque applied by the standard weights, the full calibration procedure was performed. The dynamometer was within acceptable limits during the test program. Dynamometer calibration data sheets are * provided in Appendix L of this document.

Emissions Testing 4 23 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. COLORADOSTATEUNIVERSITY Thermocouples ( Within one week prior to initiation of each engine test program)

K type insertion thermocouples are used throughout the Large Bore Engine Testbed with compensation performed through the engine control and data acquisition hardware. The thermocouples were calibrated using a Ronan X88 portable calibrator calibrated within kl. O ° F of N. I. S. T. standard by an independent laboratory. The thermocouple signal was zeroed and the gain adjusted at full span until the value displayed by the NetCon 5000 matched the setting of the Ronan X88 within & 2.0 ° F. Once the zero and gain have been set a minimum of two mid point temperatures were checked to verify the calibration. Thermocouple calibration data sheets are provided in Appendix J of this report.

Pressure Transducers ( Within one week prior to initiation of each engine test program)

A 3 way valve has been installed to allow pressure transducer calibration without removing the sensor from the system. The Model 320 Beta calibrator used for transducers calibration provides an accuracy of 0.05% of reading or 0.02% of full span and is calibrated to N. I. S. T. standards by an independent laboratory. The transducer was zeroed and the gain adjusted at full span until the value displayed by the NetCon 5000 was within * l . O psig of the pressure supplied by the pressure calibration standard. A minimum of two midpoints was checked to verify calibration. Pressure transducer calibration data sheets are provided in Appendix J of this report.

Pressure Transmitters ( Within one week prior to initiation of each engine test program)

Pressures, which were critical to control, and emissions calculations were measured using Rosemount@ 305 1C transmitters. The calibration was performed at the transmitter and no adjustments are made to the current loop. A known pressure was supplied to the sensing port of the transmitter using the Model 320 Beta calibrator. The transmitter was zeroed and then spanned at the full range value of the system. Once spanned, the value displayed by the NetCon 5000 within ItO. 5% of the full range value. A minimum of two mid span points was checked to verify calibration. Pressure transmitter calibration data sheets are provided in Appendix J of this report.

4.11 TEST SPECIFICS  TEST BED GENERAL DESCRIPTION Colorado State University's Engines & Energy Conversion ~ Laboratory The continued operation of stationary reciprocating internal combustion engines is faced with tremendous challenges in meeting ever tightening restrictions on air borne pollutants. The regulatory environment continues to evolve toward lower allowable limits for criteria pollutants, including new limitations on hazardous air pollutants ( HAPS), even as current statutes are being Emissions Testing 4 24 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA. implemented. Although ominous the task of meeting compliance, difficulties involved in complying with tightening emissions regulations have advanced the knowledge and understanding of engine emissions and performance. The mechanism, which has elevated the understanding of exhaust emissions, is research and development. To aid in this effort the Engines & Energy Conversion Laboratory was established at Colorado State University. The engines located at the Engines & Energy Conversion Laboratory ( EECL) located at Colorado State University, and are representative of the types used by the oil and gas industries as well as power generation markets. The CSU facility currently comprises the only independent large bore industrial engine test facility in North America. Engines that are located at the facility are as follows:

l Cooper  Bessemer GMV+ TF , Two Stroke Lean Burn Natural Gas Fired Engine l Waukesha 3 52 1 GL, Four Stroke Lean Burn Natural Gas Fired Engine l White Superior 66825, Four Stroke, Rich Burn Natural Gas Fired Engine l Caterpillar 3508, Four Stroke, Lean Burn Diesel Fueled Engine The natural gas pipeline' industry has supported the installation of three four stroke engines in the same manner as the original engine installation. The program sponsor for the installation of the engines is the Gas Research Institute ( GRJ). The additional engines have been installed at the facility to assist research efforts in addressing needs, both emissions and performance related, on multiple engine types. The high speed, four cycle, industrial engines ( approximately 1000 l 800 r pm) represent a large portion of the current horsepower in operation within the oil and gas industry and power generation markets.

Emissions Testing 4 25 Pacific Environmental Services Of Control Devices for Reciprocating Internal Combustion Engines In Support of Regulatory Development By the U. S. EPA.