emissions test report compliance test of two natural - MurCal, Inc.

ENVIRONMENTAL MANAGEMENT SOLUTIONS Inc. 

EMISSIONS TEST REPORT 

COMPLIANCE TEST OF 

TWO NATURAL GAS FIRED 

INTERNAL COMBUSTION ENGINES 

RUSS SCHOTT FARMS 

PIXLEY, CA. 

Test Date: 

April 16-17, 2009 

Prepared By: 

Environmental Management Solutions Inc. 

2809 Unicorn Road, Suite 105 

Bakersfield, CA. 93308 

Prepared for: 

MurCal Inc. 

6383 Lochinvar Way, Suite 101 

Sacramento, CA. 95823


Russ Schott Farm 

PREFACE 

Environmental Management Solutions, Inc. (EMS) was contracted by MurCal Inc. to 

provide emissions source testing at the exhaust stacks of two rich-burn, natural gasfired, 

internal combustion engines owned and operated by Russ Schott Farms. Each 

engine has been retrofitted with a MurCal “Emissionator” emission control system. 

Testing was performed to determine compliance with The San Joaquin Valley Air 

Pollution Control District (SJVAPCD) Rule 4702. In addition this program was designed 

to determine the destruction efficiency of the control system. All testing was completed 

April 16 -17, 2009. 

The Project Manager for EMS was Mr. Steve Croghan. The testing was performed by 

Mr. Jim McSweeney of TRC Environmental Corp. The representative and witness for 

SJVAPCD was Mr. Greg Lafore. The Project Coordinator for MurCal was Mr. Tyrone 

Hunter. All calculations and raw data are located in the Appendices. The following 

tables summarize the Compliance Test results and the applicable emission limits listed 

in Rule 4702 for rich burn engines used exclusively in agricultural operations. 

Executive Summary 

Engine 

Model 

Test Date 

NO X 

ppmdv 

NO X ppmvd 

@ 15% O 2 

CO 

ppmdv 

VOC 1 

CO 

15 % O 2 C 3 -C 6 

ppmvd @ ppm 

VOC 

ppm @ 

15% O 2 

Cummins 

G855 

Caterpillar 

3406 

4/16-17/09 18.76 5.30 77.64 21.92 ND



TABLE OF CONTENTS 

1.0 GENERAL INFORMATION.................................................................................. 1 

1.1 Name and Location of Facility 1 

1.2 Scope and Objectives 1 

1.3 Parameters and Pollutants 1 

1.4 Program Schedule 1 

1.5 Test Program Organization 2 

2.0 DETAILED ENGINEERING DESCRIPTION ........................................................ 3 

2.1 Plant and Process Description 3 

2.2 Sampling Locations 3 

3.0 INSTRUMENTATION AND EQUIPMENT DESCRIPTION................................... 4 

3.1 CEMS 4 

3.2 Calibration Gas Blending 4 

3.3 Oxygen 4 

3.4 Oxides of Nitrogen 4 

3.5 Carbon Monoxide 4 

3.6 Volatile Organic Compounds 5 

3.7 Data Acquisition System 5 

4.0 DESCRIPTION OF SAMPLING AND ANALYTICAL PROCEDURES................. 6 

4.1 Pre-Sampling Activities and Equipment Calibration 6 

4.2 Testing and Analytical Methods for Instrumental Sampling 6 

4.3 Engine Operational Parameters 7 

5.0 SUMMARY OF RESULTS ................................................................................... 8 

6.0 QUALITY ASSURANCE/QUALITY CONTROL................................................. 10 

6.1 Introduction 10 

6.2 Data Reduction, Validation, and Reporting 10 

6.3 Data Reporting 11 

i



LIST OF TABLES 

Table 1 Program Schedule 1 

Table 2 Emission Control Summary 3 

Table 3 Compliance Test Matrix 7 

Table 4 Cummins G855 Pre-Catalyst Test Run Results 8 

Table 5 Cummins G855 Catalyst Outlet Test Run Results 8 

Table 6 Caterpillar 3406 Pre-Catalyst Test Run Results 9 

Table 7 Caterpillar 3406 Catalyst Outlet Test Run Results 9 

ii



1.1 Name and Location of Facility 

1.0 GENERAL INFORMATION 

Russ Schott Farm owns and operates two rich burn, natural gas fired, internal 

combustion engines located in Pixley, CA. The engines are located West of Road 152, 

N/S of Avenue 120, E/W of Road 144. 

1.2 Scope and Objectives 

The test program was designed to determine compliance with SJVAPCD Rule 4702 and 

evaluate the efficiency of the MurCal emission control system. The engines were 

operated at a load condition representative of the manufacturer’s maximum rated 

capacity during all compliance test runs. 

Source testing employed the use of U.S Environmental Protection Agency (EPA) Test 

Methods 3A, 7E, 10, 18, and 205 as described under 40 CFR, Part 51, 60, Appendix A. 

This source testing program followed “The Source Test Protocol” document submitted 

by EMS to SJVAPCD on February 27, 2009 with no notable deviations. 

1.3 Parameters and Pollutants 

The parameters and pollutants monitored were: 

• Oxygen (O 2 % dry vol.); 

• Oxides of Nitrogen (NO X ppmdv); 

• Carbon Monoxide (CO ppmdv); 

• Volatile Organic Compounds (VOC ppm) 

1.4 Program Schedule 

Table 1 presents the schedule of the compliance and engineering source testing at 

Russ Schott Farm. 

Table 1 Program Schedule 

DATE 

April 16, 2009 

April 17, 2009 

ACTIVITY 

Travel to site, set up equipment and performed test run 1 on the 

Cummins G855. Move equipment. Test Caterpillar 3406 tests 1- 

3. Demobilized. 

Travel to site, set up equipment, performed test runs 2-3 on the 

Cummins G855. Demobilized. 

1



1.5 Test Program Organization 

The key representatives from the various organizations involved in the performance and 

evaluation of this test program are as follows: 

Environmental Management Solutions 

Mr. Steve Croghan 

Project Manager 

2809 Unicorn Rd., Suite 105 


661.303.8312 

MurCal Inc. 

Mr. Tyrone Hunter 

Regional Sales Manager 

6383 Lochinvar Way, Ste.101 

Sacramento, CA. 95823 

916.682.7352 

Environmental Management Solutions 

Mr. Jim Steiner 

Quality Assurance 

1214 Wigwam Park Way, Suite 100 

Las Vegas, NV. 89074 

702.592.4333 

San Joaquin Valley APCD 

Mr. Greg Lafore 

Sr. Air Quality Engineer 

Southern Region 

2700 M Street, Suite 275 


661.326.6500 

2



2.1 Plant and Process Description 

2.0 DETAILED ENGINEERING DESCRIPTION 

Russ Schott Farms owns and operates two rich burn, natural gas fired, internal 

combustion engines located in Pixley, CA. These engines are coupled to water pumps 

that provide irrigation water to the farm. The engines are one Cummins 200 HP Model 

G855, and one Caterpillar 365 HP Model 3406. The purpose of this test was to 

determine compliance with SJVAPCD Rule 4702 and to demonstrate the control 

efficiency of the MurCal “Emissionator” Control System. This system consists of a 

Miratech Model VXC Non-Selective 3 way catalytic converter, a Compliance Controls 

Model AFR1 air/fuel ratio controller, and a Compliance Controls Model HEGO Oxygen 

sensor. The following table presents the destruction efficiency for the measured 

parameters: 

Table 2 Emission Control Summary 

Unit 

Oxides of 

Nitrogen 

Carbon 

Monoxide 

Volatile Organic 

Compounds (C 3 -C 6+ ) 

(% DE) 

(% DE) 

(% DE) 

Cummins 

G855 

Caterpillar 

3406 

99.35% 98.30% 100% 

98.97% 98.83% 100% 

2.2 Sampling Locations 

Flue gas was extracted at the engine exhaust pipe upstream of the catalytic converter 

and at the outlet of the catalytic converter. A single sample point was used for this test 

program as allowed for exhaust diameters of 4 inches or less. 

3



3.0 INSTRUMENTATION AND EQUIPMENT DESCRIPTION 

3.1 CEMS 

The gas samples from each engine exhaust sample location were extracted through a 

316L stainless steel probe and particulate filter assembly. The sample was then 

transported through a heat-traced Teflon ® line to a Universal Analyzer Model 1060 

sample conditioner. The sample line was maintained at a temperature of 250°F. The 

Model 1060 is thermo-electrically cooled and maintained at the factory set point of 3-4 o 

C. The sample conditioner removes the moisture from the gas stream. The sample 

pump then transports the dry gas samples through a length of Teflon tubing to the 

analyzer distribution manifold located in the lab trailer. 

3.2 Calibration Gas Blending 

An Environics 2020 Series Gas Blender was used to create the proper gas 

concentrations during the calibration of the CEMS instruments. The Environics Model 

2020 is a microprocessor-controlled device that meets or exceeds EPA Method 205 

specifications. This device uses 4 temperature and pressure compensated mass flow 

controllers to blend high purity nitrogen with high concentration gases to deliver the 

proper concentration of gas during calibrations. An audit of the instrument was 

performed before use on this project. The result of this audit is located in the 

Appendices of this report. 

3.3 Oxygen 

A Servomex Model 1440 O 2 analyzer was used to measure O 2 concentrations in the 

flue gas. The Servomex Model 1440 uses a paramagnetic detector to measure O 2 

percent volume on a dry basis. 

3.4 Oxides of Nitrogen 

A Teledyne-API Model 300EH was used to measure the concentration of NO X in the 

flue gas stream. The Model 300EH utilizes a photo-multiplier tube to detect the chemiluminescent 

reaction to measure NO x parts per million dry (ppmdv). A NO 2 converter 

check was performed during the initial calibration of the analyzer by introducing a 

Nitrogen Dioxide gas directly to the analyzer. The result of the check verified ≥90% 

NO 2 →NO conversion efficiency. 

3.5 Carbon Monoxide 

A Thermo-Fischer Corporation Model 48C was used to measure the concentration of 

carbon monoxide in the flue gas stream. The 48C utilizes infrared gas filter correlation 

to measure carbon monoxide parts per million dry (ppmdv). 

4



3.6 Volatile Organic Compounds 

A 316L stainless steel probe and Teflon tube were used to fill a Tedlar gas sampling 

bag. The exhaust gas pressure was enough to fill the bags without the use of a lung 

sampler and sample pump. The samples were analyzed by a SRI Gas Chromatograph 

utilizing a flame ionization detector (FID). The samples were analyzed for C 1 -C 6 . Only 

Non-Methane Hydrocarbons were reported (C 3 -C 6 ) as methane. 

3.7 Data Acquisition System 

Output from the instrumental analyzers was directed to a Data Shuttle analog to digital 

converter (DAC) card and to a Standard analog strip chart recorder. The DAC and strip 

chart recorder is multi-channeled. Each channel is independently programmable for 

range and voltage input. 

The Data Shuttle ® was monitored via the parallel port to a laptop computer utilizing 

Strata ® commercial data acquisition software. Data from each of the analyzers was 

integrated during a 60-second interval. The one-minute average readings were 

electronically recorded. These data were further averaged over the test period and 

corrected for calibration error, sample system bias, and drift using an audited computer 

program. 

5



4.0 DESCRIPTION OF SAMPLING AND ANALYTICAL PROCEDURES 

4.1 Pre-Sampling Activities and Equipment Calibration 

Pre-sampling activities included equipment calibration, pre-cleaning of the sample lines, 

and other miscellaneous tasks. Each of these activities are described or referenced in 

the following subsections. Other pre-sampling activities included team meetings, 

equipment packing, and finalization of all details leading up to the coordinated initiation 

of the sampling program. 

EMS followed an orderly program of positive actions to prevent the failure of equipment 

or instruments during use. This preventative maintenance and careful calibration 

maximizes the readiness of, and assures the accurate measurements from field and 

laboratory instruments. 

Once equipment has gone through the cleaning and repair process it is then calibrated. 

Once the equipment had been calibrated, it was packed and stored to ensure the 

integrity of the equipment. 

4.2 Testing and Analytical Methods for Instrumental Sampling 

Sampling and analytical methods followed the source test protocol, and the methods 

outlined in 40 CFR, Part 60, Appendix A. The analyzers were calibrated using EPA 

protocol gas mixtures. The analyzers were initially calibrated directly. A system bias 

check was performed before and after the collection of test run data. The bias check 

used the mid-range gas mixture through the entire sampling system to check for line 

contamination and leaks. 

4.2.1 EPA Method 205 

Calibration gases were blended from a high level certified supply gases and high purity 

nitrogen. All quality checks and audits of the Environics 2020 Series Gas Blender were 

conducted per the procedures described in Method 205, 40 CFR Part 51, Appendix M. 

There were no modifications to this method. 

4.2.2 EPA Method 3A 

Sampling of the flue gas for the concentration of O 2 was performed according to the 

requirements and procedures of EPA Reference Method 3A, 40 CFR, Part 60, Appendix 

A. 


6



4.2.3 EPA Method 7E 

Sampling of the flue gas for NO x was performed as outlined by the procedures in EPA 

Method 7E, 40 CFR, Part 60, Appendix A. 



Sampling of the flue gas for Carbon Monoxide was performed as outlined by the 

procedures in EPA Method 10, 40 CFR, Part 60, Appendix A. 



Sampling of the flue gas for Non Methane Hydrocarbons was performed as outlined by 

the procedures in EPA Method 18, 40 CFR, Part 60, Appendix A. 


Table 4 summarizes the testing procedures that were used during this test program. 

Table 3 Compliance Test Matrix 

Parameters 

Sampling 

Method 

Number 

of Runs 

Sample 

Run Time 

Analytical 

Method 

Analytical 

Lab 

O 2 EPA 3A 3 30 minutes Instrumental EMS 

NO X EPA 7E 3 30 minutes Instrumental EMS 

CO EPA 10 3 30 minutes Instrumental EMS 

VOC EPA 18 3 30 minutes GC-FID TRC 

4.3 Engine Operational Parameters 

The engines were operated at a maximum load condition determined by engine and 

pump shaft RPM. 

7



5.0 SUMMARY OF RESULTS 

EMS performed compliance Test Run 1 of the Cummins G855 on April 16, 2009. After 

this test run the engine was shut down due to a spark plug failure. Test Runs 2 and 3 

were performed on April 17, 2009 after the spark plug was replaced. All test runs 

demonstrated that the Cummins G855 was in compliance with Rule 4702. The testing 

of the Caterpillar 3406 was performed and completed April 16, 2009. The testing of this 

engine was only for determining control system efficiency as the engine had previously 

been tested for compliance. Each engine was operated at a maximum of 100% of load 

capacity verified by RPM. Appendices A through C contain the results of the testing. 

Appendix A presents the Emissions Calculations. Appendix B contains EMS’s raw field 

data and CEMS data package. Appendix C contains the VOC Laboratory Analysis. 

Appendix D contains the equipment calibration data package and gas certifications. 

Appendix E contains the SJVAPCD COM 2030 worksheets. The following tables 

present the compliance test results of each engine. 

Table 4 Cummins G855 Pre-Catalyst Test Run Results 

Test 

Oxygen 

(%dry) 

NO X 

ppmvd 

NO X 

ppm @ 

15% O 2 

CO 

ppmvd 

CO ppm VOC 1 

@ 15% O 2 ppmv 

VOC 

ppm @ 

15% O 2 

1 0.52 2755.66 797.74 4391.13 1271.20 53.38 15.45 

2 0.42 2832.62 815.86 4502.61 1296.85 74.76 21.54 

3 0.44 2837.20 818.09 4504.62 1298.89 55.92 16.12 

Average 0.46 2808.49 810.56 4466.12 1288.98 61.35 17.70 

1 

VOC reported as methane (C 3 -C 6+ ). ND= Not Detected



Table 6 Caterpillar 3406 Pre-Catalyst Test Run Results 

Test 

Oxygen 

(%dry) 

NO X 

ppmvd 

NO X 

ppm @ 

15% O 2 

CO 

ppmvd 

CO ppm VOC 1 

@ 15% O 2 ppmv 

VOC 

ppm @ 

15% O 2 

1 0.37 2433.06 699.27 2678.66 769.86 16.54 4.75 

2 0.35 2477.90 711.47 2762.58 793.21 18.58 5.33 

3 0.36 2477.97 711.79 2707.49 777.72 12.70 3.65 

Average 0.36 2462.98 707.51 2716.24 780.26 15.94 4.58 

1 

VOC reported as methane (C 3 -C 6+ ). ND= Not Detected



6.0 QUALITY ASSURANCE/QUALITY CONTROL 

6.1 Introduction 

Quality Assurance/Quality Control (QA/QC) protocols followed during this program were 

based on the procedures of the methods employed. Results of the QA/QC activities 

employed during this program are provided in this section. 

All calculations are done using standardized EPA equations as part of EMS's ongoing 

quality control for data reduction and reporting. EMS routinely reduces field data on a 

daily basis using a personal computer with software containing the EPA equations. 

6.1.1 Calibration Gases 

All calibration gases used to conduct instrument calibrations on EMS’s continuous 

oxygen (O 2 ), nitrogen oxide (NO X ), and carbon monoxide (CO) emission monitors were 

prepared in accordance with EPA Protocol 1, or are traceable to the National Institute of 

Standards and Technology (NIST). 

6.1.2 Instrument Calibrations 

EMS’s oxygen instrument calibrations met the performance criteria defined in 40 CFR 

60 Appendix A, Method 3A. The NO X instrument calibrations met the performance 

criteria defined in 40 CFR 60 Appendix A, Method 7E and the carbon monoxide 

instrument calibrations met the performance criteria defined in 40 CFR 60 Appendix A, 

Method 10. 

6.1.3 Equipment Leak Checks 

Prior to sampling the sampling system was leak checked under 15” Hg. for 2 minutes. 

During the course of each test run, a leak check was conducted before and after 

sampling. Final leak checks were performed to ensure that no leaks developed in the 

system during the course of the test run. 

6.2 Data Reduction, Validation, and Reporting 

Specific QC measures were used to ensure the generation of reliable data from 

sampling and analysis activities. The proper collection and organization of accurate 

information, followed by clear and concise reporting of the data, was the primary goal in 

this program. 

10



6.2.1 Data Validation 

EMS supervisory and QC personnel used validation methods and criteria appropriate to 

the type of data and the purpose of the measurement. Records of all data were 

maintained, including that judged to be an "outlying" or spurious value. The persons 

validating the data have sufficient knowledge of the technical work to identify 

questionable values. 

The field sampling data was validated by the Field Team Leader and the QC 

Coordinator. This decision was based on their review of the adherence to the approved 

sampling protocol and written sample collection procedures. 

The following criteria were used to evaluate the field sampling data: 

• Use of approved test procedures; 

• Proper operation of the process being tested; 

• Use of properly operating and calibrated equipment; 

• Leak checks conducted before and after tests; 

The criteria listed below were used to evaluate the analytical data: 

• Use of approved analytical procedures; 

• Use of properly operating and calibrated instrumentation; 

• Acceptable results from analyses of QC samples. 

6.3 Data Reporting 

All data was reported in standard units depending on the measurement and the ultimate 

use of the data. 

11

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