RWQCP_EMISSIONS_TESTING_SCOPE_OF_SERVICES.pdf

ATTACHMENT A

RWQCP EMISSIONS TESTING

SCOPE OF SERVICES

The City of Palo Alto Regional Water Quality Control Plant (City or RWQCP) has a new odor control scrubber and a new emergency standby generator that require routine emissions testing per the Bay Area Air District (BAAD).

To meet the compliance requirements, the CITY is seeking a CONSULTANT to conduct and report required emissions testing for non-methane hydrocarbon (NMHC), hydrogen sulfide (H2S), and other parameters as outlined below. CONSULTANT shall prepare reports to be submitted to regulatory agencies.

CONSULTANT shall maintain all necessary qualifications and certifications required by BAAD for emissions testing.

TASK DESCRIPTIONS

Task 1.0 Planning, Test Preparation, and Mobilization

CONSULTANT shall plan and schedule testing in coordination with the CITY at least at the start of every calendar year. CONSULTANT shall prepare notifications to BAAD as required per below tasks.

The CITY will provide the following:

• Access to sampling sites and provide adequate stack sampling ports;

• A suitable area for the mobile laboratory that will be no more than 100 feet from the sampling site;

• Any needed operating data (including required urea usage and average kW during generator testing); and

• A minimum of two (2) uninterrupted and dedicated 110-volt, 20-amp, electrical outlets within 100 feet of the mobile laboratory.

Task 2.0 Ongoing NMHC Testing

CONSULTANT shall conduct routine emissions testing to prove compliance with the following Authority to Construct (ATC) condition and its counterpart when transitioned into the CITY’s Permit to Operate (PTO). As of this writing, the frequency of testing is anticipated to be quarterly with the first test required in the third quarter of 2026, but this is subject to change:

The owner/operator shall ensure that the abated non-menthane hydrocarbon (NMHC) emissions from S-110, do not exceed 10 ppmv, measured as methane, at the exhaust of A- 110 on an annual average basis.

The owner/operator can reduce the monitoring frequency from monthly to quarterly if all readings are below one half of the emission limits of the respective devices [<5ppmv] for three months and the results of this testing are submitted to the Engineering Division. If readings rise above the emission limits, monitoring frequency will return to daily until five days of consecutive compliance can be demonstrated, at which point testing shall again be submitted to the Engineering Division to reduce testing frequency from daily to monthly.

Testing can transition from monthly to quarterly once readings for three consecutive months are below one half of the emission limits. The reduction in monitoring frequency will be handled administratively by the BAAD Engineering Section.

CONSULTANT shall measure NMHC emissions from the odor control exhaust using the EPA Method 25A/18. CONSULTANT shall provide the CITY with NMHC volumetric concentration records for direct comparison to the aforementioned permit limit. CONSULTANT shall prepare a report to capture all results collected to date for the calendar year for submittal to the CITY. CONSULTANT shall include in the report details regarding dates of testing, methods used, setup of testing apparatus’, observations during testing, results, copies of chain of custodies, any QA/QC conducted, associated operational data, and anything else required to validate the reported results. Test reports do not need to be submitted to BAAD Source Test Section.

Task 3.0 Initial and Ongoing Emissions Testing for Emergency Diesel Generator

CONSULTANT shall provide the CITY with draft notifications for review and approval at least 2 weeks prior to submission to BAAD. CONSULTANT shall notify BAAD Source Test Section at least 30 days prior to each generator emission test. Testing is required within 60 days of initial startup and every three years after that; as of this writing, initial testing is expected to occur in 2027 or 2028 pending construction schedules.

CONSULTANT shall conduct emissions testing to prove compliance with the following conditions:

The owner/operator shall ensure engine emissions do not exceed the following limits:

• nitrous oxides (NOx): 0.50 g/bhp-hour

• precursor organic compounds (POC): 0.14 g/bhp-hour

• carbon monoxide (CO): 2.60 g/bhp-hour

The owner/operator shall conduct an initial Air District-approved source test within 60 days of startup and once every three years thereafter at the normal or expected load during emergency operation using Air District approved source test methods.

CONSULTANT shall use the following methods of testing for each pollutant:

• NOx: EPA Method 7E or Air District-approved equivalent

• POC: EPA Method 25A and EPA Method 18 or Air-District approved equivalent

• CO: EPA Method 10 or Air-District approved equivalent

CONSULTANT shall provide the CITY with a draft test report to review at least 3 weeks before the report is due to BAAD. CONSULTANT shall include in the report details regarding dates of testing, methods used, setup of testing apparatus’, observations during testing, results, copies of chain of custodies, any QA/QC conducted, associated operational data, and anything else required to validate the reported results. CITY will provide comments and/or approval of report at least a week before the report is due to BAAD. CONSULTANT shall incorporate/address comments and submit test report to BAAD Source Test Section no later than 60 days after test completion.

Task 4.0 Ongoing H2S Testing (OPTIONAL)

H2S testing will be handled primarily by the CITY. However, in the instance that the CITY is not able to complete testing, the CONSULTANT shall do the testing on behalf of the CITY. In these instances, the CITY will provide at least 2 weeks notice via email notification and coordinate scheduling with the CONSULTANT. The CONSULTANT shall conduct emissions testing to prove compliance with the following ATC condition and its PTO counterpart:

The owner/operator shall ensure that the abated hydrogen sulfide (H2S) emissions from S- 110 do not exceed 1.0 ppmv, measured at the exhaust of A-110.

The owner/operator can reduce the monitoring frequency from weekly to monthly if all readings are below one half of the emission limits of the respective devices [<0.5 ppmv] for two months and the results of this testing are submitted to the Engineering Division. If readings rise above the emission limits, monitoring frequency will return to daily until two months of consecutive compliance can be demonstrated, at which point testing shall again be submitted to the Engineering Division to reduce testing frequency from daily to weekly.

The reduction in monitoring frequency will be handled administratively.

CONSULTANT shall measure H2S using Drager Tubes, or other BAAD-approved method, from the odor control exhaust. CONSULTANT shall provide the CITY with volumetric concentration records for H2S measured under this task in an excel spreadsheet upon request by the CITY that captures the date, time, result, and method of testing; no formal report is required for testing under this task.

Task 5.0 Testing Postponement

Under certain circumstances the CITY may need to postpone and reschedule the emissions testing. In which case, a daily standby rate shall be applicable in the event that testing must be postponed. CONSULTANT shall include a daily standby rate and/or rescheduling fee in their proposal for this work.