Attachment_I_-_CO_Emissions_Test_Protocols_Redacted.pdf

Pace Analytical Services, LLC 1700 Elm Street SE

Minneapolis, MN 55414 Phone: 612.607.1700 www.pacelabs.com

Plant Name:

Protocol Date: May 26, 2020 Revision Date: No revisions to date Testing Dates: July 7 and 8, 2020

Subject Facility:

U.S. Geological Survey EROS Center 47914 252nd Street Sioux Falls, SD 57198 Telephone No.: (605) 594-2520

E-mail Address: tmichael@usgs.gov

Regulatory Permit No.:

28.000061

Subject Emission Sources:

Non-emergency Generator Unit 1

Non-emergency Generator Unit 2

Non-emergency Generator Unit 3

Test Locations:

Catalyst Exhaust Telephone No.: (612) 607-6374

Facsimile No.: (612) 607-6388 E-mail Address:

Carbon Monoxide Emissions Testing

EROS Center

Protocol

U.S. Geological Survey

Client Test Coordinator:

U.S. Geological Survey

Minneapolis, MN 55414 terry.borgerding@pacelabs.com

47914 252nd Street Sioux Falls, SD 57198

Testing Firm Coordinator:

Terry Borgerding Pace Analytical Services, LLC

1700 Elm Street, Suite 200

U.S. Geological Survey Test Protocol Page 1 of 24

Table of Contents

Cover Page

Table of Contents

Plant Contact Information

Testing Firm Information

Regulatory Contact Information

Pace Project Organization

Facility and Process Description

Testing Schedule

Individual Source Requirements

Units 1, 2, & 3 - Non-emergency Generators

Test Report

Safety Consideration

Attachments

Attachment 1 - Test Location Schematics

Attachment 2 - Abbreviations, Symbols, and Nomenclature

Attachment 3 - Calculation Equations

Attachment 4 - Test Method Summaries

Attachment 5 - Quality Statement

U.S. Geological Survey Test Protocol Page 2 of 24

Subject Facility:

EROS Center 47914 252nd Street

Plant Contact:

Company Affiliation:

Office Address:

Telephone Number:

Facsimile Number:

E-mail Address:

Reason for Test:

40 CFR Part 63 Subpart ZZZZ

Project Contact:

Testing Firm:

Office Location:

Telephone Number:

Facsimile Number:

E-mail Address

Subcontractors:

Regulatory Agency:

Testing Contact:

Office Location:

Telephone Number:

Facsimile Number:

E-mail Address

Plant/Source Information

U.S. Geological Survey

Sioux Falls, SD 57198

U.S. Geological Survey EROS Center 47914 252nd Street Sioux Falls, SD 57198

Emissions Permit Requirement

South Dakota Department of Environment and Natural Resources

Testing Firm Information

Terry Borgerding Pace Analytical Services, LLC 1700 Elm Street, Suite 200 Minneapolis, MN 55414

(612) 607-6374

(612) 607-6388 terry.borgerding@pacelabs.com

No subcontractors to be used.

Regulatory Contact Information

AirQualityReporting@state.sd.us

PMB 2020, Air Quality Program Joe Foss Building 523 East Capitol Pierre, SD 57501

U.S. Geological Survey Test Protocol Page 3 of 24

Project Organization

Management Regulatory

General Manager SDDENR

Don Stock Air Quality Program

(612) 607-6370 -don.stock@pacelabs.com AirQualityReporting@state.sd.us

Quality Manager Project Manager

Pace Pace

Erin Evans Terry Borgerding

(612) 910-7607 (612) 607-6374 erin.evans@pacelabs.com terry.borgerding@pacelabs.com

Pretest Survey Test Protocol Field Testing Analyses Reporting

Pace

Pace Pace Pace MN Laboratory Pace

Field Services Field Services Field Services (612) 607-1700 Field Services

Subcontract Lab

No sub lab on this project.

Note: Chart based on anticipated participants at the time of protocol development and is subject to change.

Subject Facility

U.S. Geological Survey

EROS Center

47914 252nd Street

Sioux Falls, SD 57198

Client Coordinator

U.S. Geological Survey tmichael@usgs.gov

U.S. Geological Survey Test Protocol Page 4 of 24

Facility and Process Description

Target Operating Conditions: Single Condition at 90+% Capacity

U.S. Geological Survey, EROS Center located in Sioux Falls, South Dakota operates three non-emergency generators. The generators are Cummins model DFGE (846 kW /

1135 HP) and are fitted with a catalyst for controlling carbon monoxide emissions.

Test related process and operational details will be recorded by U.S. Geological Survey, EROS Center personnel and included in the final report.

U.S. Geological Survey Test Protocol Page 5 of 24

Test Report

A final test report will be compiled by Pace Analytical at the completion of testing. The report will be submitted to the client within 30 days of the last day of sampling. The client will be responsible for submitting report copies as required by regulatory agencies. An electronic copy of the test report will be delivered via e-mail. The final test report will include the following information:

• Name and location of emission facility.

• Identification of emission unit.

• Date of tests.

• Name and address of testing company.

• Certification of project information (client signatures also required).

• Reasons and constituents for test.

• Names of observers and witnesses

• Emission results expressed in the units of the emission limitation criteria.

• Process descriptions as provided by the client.

• Process rate information as provided by the client.

• Descriptions of maintenance activities as provided by the client.

• Discussions of problems or errors encountered.

• Sampling and analytical procedures.

• Analytical results of fuels or process samples as appropriate.

• Dimensioned drawing of sampling location.

• Copies of raw field data.

• Copies of laboratory analytical reports.

• Calculation equations.

• Sampling train calibration data

• Laboratory quality assurance information as appropriate

• Copy of this test plan and other pertinent pretest correspondence.

U.S. Geological Survey Test Protocol Page 8 of 24

Attachments

Attachment 1 Test Location Schematics

Attachment 2 Abbreviations, Symbols, and Nomenclature

Attachment 3 Calculation Equations

Attachment 4 Test Method Summaries

Attachment 5 Quality Statement

U.S. Geological Survey Test Protocol Page 10 of 24

Attachment 1 Test Location Schematics

Test site details are not currently available. The test location will be verified on-site and documented in the final report.

U.S. Geological Survey Test Protocol Page 11 of 24

Attachment 2 Abbreviations, Symbols, and Nomenclature

U.S. Geological Survey Test Protocol Page 12 of 24

“Hg Inches of Mercury (pressure) “WC Inches Water Column (pressure) °C Degrees Centigrade or Celsius °F Degrees Fahrenheit °K Degrees Kelvin (absolute) °R Degrees Rankin (absolute) % v/v Percent by volume % w/w Percent by weight ACFM Actual Cubic Feet per Minute AP-42 Compilation of Air Pollutant Emission

Factors, Volume I, Stationary Point and Area Sources.

BACT Best Available Control Technology BH Baghouse BHP Brake Horsepower BTU British Thermal Unit c Centimeter c3 Cubic Centimeter cc Cubic Centimeter CAA Clean Air Act CAAA Clean Air Act Amendments CE Control Equipment (in Reg. ID Nos.)

CE Control Efficiency CEM Continuous Emissions Monitor CEMS Continuous Emissions Monitoring

System CF Cubic Feet CFR Code of Federal Regulations C1 Carbon (as carbon) CH4 Methane C3H8 Propane cm Cubic Meter CO Carbon Monoxide CO2 Carbon Dioxide DGS Distiller’s Grains with Solubles DDGS Dry Distiller’s Grains with Solubles DRE Destruction/Reduction Efficiency DSCF Dry Standard Cubic Feet DSCFM Dry Standard Cubic Feet per Minute dscm Dry Standard Cubic Meter dscmm Dry Standard Cubic Meter per Minute dsl Dry Standard Liter EPA Environmental Protection Agency EP Emission Point ESP Electrostatic Precipitator EU Emission Unit FID Flame Ionization Detector FGR Flue Gas Recirculation FPD Flame Photometric Detector FPM Feet Per Minute FPS Feet Per Second FR Federal Register FT or ft Foot or Feet FT3 Cubic Feet

FTIR Fourier Transform Infrared g Gram GC Gas Chromatograph(y) GPD Gallons Per Day GPH Gallons Per Hour GR Grains H2O Water H2S Hydrogen Sulfide HAP Hazardous Air Pollutant HAPs Hazardous Air Pollutants Hg Mercury HP Horsepower HR Hour In. Inch or Inches KLB Thousand Pounds kW Kilowatt kWH Kilowatt Hour l liter LB Pound or Pounds LDAR Leak Detection and Repair m Meter m3 Cubic Meter MACT Maximum Achievable Control

Technology MC Moisture Content µg Microgram µl Microliter µm Micrometer (micron) mg Milligram MGAL Thousand Gallons Min. Minute or Minutes ml Milliliter mm Millimeter MMBTU Million British Thermal Units MMSCF Million Standard Cubic Feet MS Mass Spectrometry MSDS Material Safety Data Sheet mW Megawatt MW Molecular Weight N2 Nitrogen NA Not Applicable NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for

Hazardous Air Pollutants NO2 Nitrogen Dioxide NOx Nitrogen Oxides (quantified as NO2) NSPS New Source Performance Standard O2 Oxygen PEMS Parametric (or Predictive) Emissions

Monitoring System PID Photo Ionization Detector PM Particulate Matter

U.S. Geological Survey Test Protocol Page 13 of 24

PM10 Particulate Matter with an aerodynamic diameter equal to or less than 10 microns

PM-10 PM10

PM2 5 Particulate Matter with an aerodynamic diameter equal to or less than 2.5 microns

PM-2.5 PM2 5

PPB Parts Per Billion (see variation below) PPM Parts Per Million PPMv Part Per Million by volume PPMv-dry Parts Per Million by volume, dry basis PPMv-wet Parts Per Million by volume, wet basis PPMw Parts Per Million by Weight (mg/l) PSIA Pounds per Square Inch, Absolute PSIG Pounds per Square Inch, Gauge PTE Permanent Total Enclosure RA Relative Accuracy RATA Relative Accuracy Test Audit rH Relative Humidity RTO Regenerative Thermal Oxidizer or

Recuperative Thermal Oxidizer SCF Standard Cubic Feet SCFM Standard Cubic Feet per Minute scm Standard Cubic Meter scmm Standard Cubic Meter per Minute Scr. Scrubber SIC Standard Industrial Classification SO2 Sulfur Dioxide SOx Sulfur Oxides Sq. Ft. Square Feet TCD Thermal Conductivity Detector TO Thermal Oxidizer TPD Tons Per Day TPH Tons Per Hour TPY Tons per year TRS Total Reduced Sulfur TSP Total Suspended Particulate Matter TTE Temporary Total Enclosure USEPA United States Environmental Protection

Agency VHAP Volatile Hazardous Air Pollutant VOC Volatile Organic Compound VOCs Volatile Organic Compounds WC Water Column WDGS Wet Distiller’s Grains with Solubles

U.S. Geological Survey Test Protocol Page 14 of 24

State Environmental Agency Acronyms

ADEM Alabama Department of Environmental

Management ADEC Alaska Department of Environmental

Conservation ADEQ Arizona Department of Environmental

Quality ADEQ Arkansas Department of Environmental

Quality CARB California Air Resources Board CDPHE Colorado Department of Public Health

& Environment CDEP Connecticut Department of

Environmental Protection DNREC Delaware Natural Resources &

Environmental Control FDEP Florida Department of Environmental

Protection GEPD Georgia Environmental Protection

Division IDEQ Idaho Department of Environmental

Quality IEPA Illinois Environmental Protection

Agency IDNR Iowa Department of Natural Resources KDHE Kansas Department of Health &

Environment KDEP Kentucky Department for

Environmental Protection LDEQ Louisiana Department of

Environmental Quality MDEP Maine Department of Environmental

Protection MDE Maryland Department of the

Environment MDEP Massachusetts Department of

Environmental Protection EGLE Michigan Department of Environment, Great Lakes, and Energy MPCA Minnesota Pollution Control Agency MDEQ Mississippi Department of

Environmental Quality

MDNR Missouri Department of Natural

Resources MDEQ Montana Department of Environmental

Quality NDEE Nebraska Department of Environment and Energy NDEP Nevada Division of Environmental

Protection NHDES New Hampshire Department of

Environmental Services NJDEP New Jersey Department of

Environmental Protection NMED New Mexico Environment Department NYSDEC New York State Department of

Environmental Conservation NCDENR North Carolina Department of

Environment & Natural Resources NDDEQ North Dakota Department of

Environmental Quality OEPA Ohio Environmental Protection Agency ODEQ Oklahoma Department of

Environmental Quality ODEQ Oregon Department of Environmental

Quality PDEP Pennsylvania Department of

Environmental Protection RIDEM Rhode Island Department of

Environmental Management SCDHEC South Carolina Department of Health &

Environmental Control SDDENR South Dakota Department of

Environment & Natural Resources TDEC Tennessee Department of Environment

& Conservation TCEQ Texas Commission on Environmental

Quality UDEQ Utah Department of Environmental

Quality VANR Vermont Agency of Natural Resources VDEQ Virginia Department of Environmental

Quality WSDNR Washington State Department of

Natural Resources WVDEP West Virginia Division of Environmental

Protection WDNR Wisconsin Department of Natural

Resources

U.S. Geological Survey Test Protocol Page 15 of 24

Attachment 3 Calculation Equations

U.S. Geological Survey Test Protocol Page 16 of 24

Combustion Source Emissions Concentration Correction Factors

Concentration Correction for Oxygen Basis

% %9.20

%9.20 2 O

O CC Basis

POxP

Concentration Correction for Carbon Dioxide Basis

2 CO

CO

CC Basis

PCOxP

Where:

CP = Pollutant concentration in units of the emission standard.

CP(x% O2) = Pollutant concentration corrected to the target percent oxygen basis in units of the emission standard.

CP(x% CO2) = Pollutant concentration corrected to the target percent carbon dioxide basis in units of the emission standard.

%CO2 = Carbon dioxide in gas stream (percent).

%CO2_Basis = Target correction basis for carbon dioxide (percent).

%O2 = Oxygen in gas stream (percent).

%O2-Basis = Target correction basis for oxygen (percent).

20.9 = Average concentration of oxygen in the atmosphere.

U.S. Geological Survey Test Protocol Page 17 of 24

Instrumental Analyzer Calculations EPA Methods 3A, 6C, 7E and 10

Analyzer Calibration Error

FS

CylAR E S

CC

A

System Calibration Bias

ARSR

Sys S

B

System Drift

SRSR

Sys S

D IF

Gas Concentration Corrected for System Bias

SR

FI

SR

C

CC

C

CCC

SRSR

Cyl

PPM

Conversion to Weight/Volume Units

04.24/

Gas PPMdscmmg

M

Emission Rate Calculation

6010243.6 / 8 DSCFMCE dscmmgR

Where:

AE = Analyzer calibration error, percent of span.

BSys = System calibration bias, percent of span.

DSys = System calibration drift, percent of span.

C = Average gas concentration response from analyzer, PPM (or %).

C0SR = Average of initial and final system calibration bias check responses for the zero gas, PPM (or %).

CAR = Analyzer direct calibration response, PPM (or %).

CCyl = Actual concentration of calibration gas, PPM (or %).

CSR = System calibration response, PPM (or %).

CSRF = Final system calibration response, PPM (or %).

CSRI = Initial system calibration response, PPM (or %).

CPPM = Concentration adjusted for system bias, PPM (or %).

Cmg/dscm = Constituent concentration converted to mg/dscm.

MGas = Molecular weight of target constituent, lb/lb-mole.

ER = Emission rate of constituent, LB/HR.

SFS = System measurement span, full scale.

DSCFM = Dry standard cubic feet per minute.

6.243x10-8 = Conversion factor, mg/cm to LB/CF.

60 = Conversion factor, minutes to hours.

U.S. Geological Survey Test Protocol Page 18 of 24

Attachment 4 Method Summaries

U.S. Geological Survey Test Protocol Page 19 of 24

EPA Method 1 specifies test location acceptability criteria and defines the minimum number of traverse points for representative sampling. Linear measurements from upstream and downstream flow disturbances and the duct equivalent diameter are compared and the distances related to number of diameters. A flow disturbance can be defined as anything that changes or upsets the direction of flow within the duct including bends, dampers, fans, shape or size transitions, and open flames. Method 1 stipulates that test ports should be located at least eight diameters downstream and two diameters upstream of any flow disturbance. The minimum acceptable criteria are two diameters downstream and 0.5 diameters upstream of flow disturbances. The test location must also be free of cyclonic or multidirectional flow. Once the distances have been determined, the values are used to select the minimum number of traverse points for representative sampling. Shorter distances require a greater number of traverse points.

The test site configuration and measurement details are documented on EPA Method 1 Field Data Sheet.

Pace FSD conducts the method as written with no routine deviations.

Project situational deviations are documented at the time of the test.

EPA Method 3A defines procedures to measure carbon dioxide (CO2) and oxygen (O2) concentrations from stationary sources. A stainless steel sampling probe and a sampling line draw a sample of the gas stream from the duct to a thermo-electric gas conditioner to remove moisture. The conditioned gas stream is delivered to an infrared gas analyzer to quantify CO2 concentrations and paramagnetic gas analyzer to quantify O2 concentrations. Zero grade cylinder air or a zero gas generator provides zero gas.

Span gases include varying concentrations of EPA Protocol 1 CO2/O2 mixed standards specific to the target calibration range. A computerized data acquisition system logs CO2/O2 concentrations for one-minute averages. The logged results are integrated to test periods and tabulated with standardized and validated spreadsheets in Microsoft Excel. The operator also maintains comprehensive test records in the electronic Project Results Instrumental Workbook. Equipment used for CO2/O2 testing includes:

Probe Material: Stainless Steel Moisture Removal: Thermo-electric Transfer Line: Teflon™

Analytical Technique: Non-dispersive Infrared Detector (CO2) Paramagnetic Detector (O2)

Calibration Gas: EPA Protocol 1

Method Defined Quality Control:

- Sampling system leak-checks are performed before each test and following any component change. Absence of leaks is confirmed through the bias check after each run.

- Calibration gas standards of the highest quality, Protocol 1 or traceable to NIST, are used in calibrations.

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- Analyzer calibration error is determined before initial run and after any failed bias or drift test.

- Analyzer bias is verified once per test.

- System bias check is performed before and after each test.

- Calibration drift test is performed after each test run.

- System response time is determined during initial sampling system bias test.

- Stratification test is performed prior to first run.

- Purge time of ≥ 2x the response time observed before starting data collection and recording stratification traverse point values.

Pace FSD conducts the method as written with no routine deviations.

Project situational deviations are documented at the time of the test.

In-Stack Method: Method 10 defines procedures to measure carbon monoxide (CO) emissions from stationary sources. A stainless steel sampling probe and a heat-traced Teflon™ sampling line draw a sample of the gas stream from the duct to a thermo-electric gas conditioner to remove moisture. The sample gas stream is delivered to a gas filter correlation non-dispersive infrared analyzer to quantify CO concentrations. Zero grade cylinder air or a zero gas generator provides zero gas. Span gases include varying concentrations of EPA Protocol 1 CO standards specific to the target calibration range. A computerized data acquisition system logs CO concentrations for one-minute averages.

The logged results are integrated to test periods and tabulated with standardized and validated spreadsheets in Microsoft Excel. The operator also maintains comprehensive test records in the electronic Project Results Instrumental Workbook. Equipment used to conduct Method 10 stack method testing includes:

Probe Material: Stainless Steel Moisture Removal: Thermo-electric Transfer Line: Teflon™

Analytical Technique: Non-dispersive Infrared Calibration Gas: EPA Protocol 1

Method Defined Quality Control:

- Sampling system leak-checks are performed before each test and following any component change. Absence of leaks is confirmed through the bias check after each run.

- Calibration gas standards of the highest quality, Protocol 1 or traceable to NIST, are used in calibrations.

- Analyzer calibration error is determined before initial run and after any failed bias or drift test.

- System bias check is performed before and after each test.

- Analyzer bias is verified once per test.

- Calibration drift test is performed after each test run.

U.S. Geological Survey Test Protocol Page 21 of 24

- System response time is determined during initial sampling system bias test.

- Stratification test is performed prior to first run.

- Purge time of ≥ 2x the response time observed before starting data collection and recording stratification traverse point values.

Pace FSD conducts the method as written with no routine deviations.

Project situational deviations are documented at the time of the test.

Reference Standards. Pace implements a comprehensive program to verify and validate reference standards to further enhance and support method standards. Primary reference standards are directly comparable to a reference base. The National Institute of Standards and Technology (NIST) maintains primary reference materials or very closely traceable secondary standards. These materials are then used to certify secondary or transfer standards for use in quality management programs. Secondary reference standards are calibrated with primary standards using a high precision comparator. Materials that have a documented path to the primary standard are often referred to as traceable to NIST or NIST traceable. Where commercially and feasibly available, Pace uses primary reference standards to perform calibrations and verifications. In other cases, Pace maintains traceable secondary reference standards.

Primary and secondary reference standards are used to calibrate and verify equipment and materials. Pace reference standards are calibrated by external vendors that have a formal, registered quality system. Calibrations are performed with equipment and materials that are traceable to NIST.

Quality Controls (not defined in test methods):

Sampling/Recovery Reagents are Reagent Grade or better.

Reference Temperature Simulator is calibrated annually.

Reference Pressure Transducer is calibrated annually.

Reference DryCal airflow meter is calibrated annually.

Mercury Barometer is a primary reference standard.

Liquid Manometers are primary reference standards.

Angle Blocks, Gauge Blocks, and Measuring Rods are verified every five years.

Angle Gauges are verified each day of use.

Calipers are verified annually.

Stainless steel reference weights are verified every five years.

Analytical balances are calibrated annually and verified at each use.

Field balances are calibrated annually and verified at each use.

U.S. Geological Survey Test Protocol Page 22 of 24

Attachment 5 Quality Statement

U.S. Geological Survey Test Protocol Page 23 of 24

Quality Assurance/Quality Control

Quality Management System. To produce data that is complete, representative, and of known precision and accuracy, Pace Analytical Field Services Division has designed and implemented a rigorous and innovative quality management system. The system was initially based on the USEPA Quality Assurance Handbook for Air Pollution Measurement Systems and continually developed as procedural complexities and standards progressed. The Field Services Division Quality Management System (Pace FSD QMS) is now accredited by the American Association of Laboratory Accreditation (A2LA) to comply with three national accreditation standards:

ASTM D7036 - Standard Practice for Competence of Air Emission Testing Bodies

(AETB).

ISO 17025 - General Requirements for the Competence of Testing and Calibration

Laboratories The NELAC Institute - General Requirements for Field Sampling and

Measurement Organizations (FSMO)

The Pace FSD QMS includes:

Quality Programs

Ethics policy and training.

Corrective Action and Preventative Action (CAPA).

Continuous Process Improvement.

Documented Demonstrations of Capability.

Internal and third party proficiency testing.

Qualified Individual program (QI) Internal and external audits.

Annual management reviews.

Documentation and Traceability High quality traceable standards and reagents.

Reagent tracking and management system.

Use of matrix spikes, duplicate analysis, internal standards, and blanks.

Validated workbooks for data collection and results reporting.

Electronic quality, training, and safety documents available in-field.

Sample security and preservation procedures.

Chain of custody maintained from sample collection through laboratory analysis.

Equipment Calibration

Full time staff dedicated to equipment maintenance and calibration.

All equipment and instruments are calibrated by trained personnel on a frequency that meets or exceeds method requirements. Documentation of the Pace Analytical Quality Assurance Program will be available on-site.

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