Greenhouse Gas Technology Verification Center
A USEPA Sponsored Environmental Technology Verification (ETV) Organization
       Test/QA Plan For A&A Environmental Seals'
                 Seal Assist System (SAS)
                         Prepared By:
                    Southern Research Institute
            Greenhouse Gas Technology Verification Center
                        For Review By:
                 U. S. EPA Quality Assurance Team
                       December 18, 1998

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Test/QA Plan For A&A Environmental Seals'
            Seal Assist System (SAS)
                    Prepared By:
               Southern Research Institute
      Greenhouse Gas Technology Verification Center
                   For Review By:
             A&A Environmental Seals, Inc.
               Enron Gas Pipeline Group
          Oil and Gas Industry Stakeholder Group
       U. S. EPA Office of Research and Development
                  December 18, 1998

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                           TABLE OF CONTENTS
                                                                          Page

1.0   BACKGROUND AND INTRODUCTION	1

2.0   TECHNOLOGY DESCRIPTION AND VERIFICATION APPROACH	2
     2.1.   SEAL ASSIST SYSTEM DESCRIPTION	2
     2.2.   SITE SELECTION, DESCRIPTION, AND SAS INSTALLATION	4
           2.2.1.  Site Selection and Description	4
           2.2.2.  Seal Assist System Installation and Operation	7
     2.3.   VERIFICATION PARAMETERS AND THEIR DETERMINATION	8
           2.3.1.  Phase I SAS Evaluation	9
                 2.3.
                 2.3.
                 2.3.
                 2.3.
                 2.3.
. 1.   Verify Initial Leak Capture Performance	9
.2.   Verify Initial Gas Recovery and Use Performance	9
.3.   Verify Initial Methane Emission Reduction	10
.4.   Document Installation and Shakedown Requirements	11
.5.   Document Capital and Installation Costs	11
          2.3.2.  Phase II SAS Evaluation	14
                 2.3.2.1.   Verify Long-term Leak Capture Performance	14
                 2.3.2.2.   Verify Long-term Gas Recovery and Use Performance	14
                 2.3.2.3.   Estimate Annual Methane Emission Reduction	15
                 2.3.2.4.   Document Long-term SAS Operational Requirements	17
                 2.3.2.5.   Calculate SAS Payback Period	18
     2.4.  FIELD TEST OVERVIEW	19
          2.4.1.  High Volume Gas Sampling	22
          2.4.2.  In-line Gas Flow and Pressure Measurement	23
          2.4.3.  Oxygen Concentration in SAS Discharge	24
     2.5.  SCHEDULE OF ACTIVITIES	24

3.0   DATA QUALITY OBJECTIVES	25
     3.1.  PAYBACK PERIOD	25
     3.2.  OXYGEN MONITORING	27
     3.3.  PRESSURE MONITORING	27
     3.4.  HVS SAMPLING AND LEAK MONITORING	27

4.0   DATA QUALITY INDICATORS	28

5.0   SAMPLING AND ANALYTICAL PROCEDURES	29
     5.1.  LEAK RATE-HVS MEASUREMENTS	29
          5.1.1.  Description	29
          5.1.2.  Test Procedures	32
          5.1.3.  QA/QC Procedures	35
     5.2.  FLOW MEASUREMENTS	36
          5.2.1.  Test Procedures	39
          5.2.2.  QA/QC Procedures	39
     5.3.  PRESSURE MEASUREMENTS	39
          5.3.1.  Test Procedures	40
          5.3.2.  QA/QC Procedures	40
     5.4.  OXYGEN MONITORING	40
          5.4.1.  Description	40
          5.4.2.  Test Procedures	41

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          5.4.3.  QA/QC Procedures	41
          5.4.4.  Data Acquisition System	41
          5.4.5.  Description	41
          5.4.6.  Test Procedures	42
          5.4.7.  QA/QC Procedures	44

6.0   DATA REDUCTION, VALIDATION, AND REPORTING	44
     6.1.  DATA REDUCTION	44
     6.2.  DATA REVIEW AND VALIDATION	45
     6.3.  DATA ANALYSIS AND REPORTING	47

7.0   AUDITS	48

8.0   CORRECTIVE ACTION	48

9.0   PROJECT ORGANIZATION	50

10.0  TEST PROGRAM HEALTH AND SAFETY	51

11.0  REFERENCES	51

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                        1.0    BACKGROUND AND INTRODUCTION

The Environmental Technology Verification (ETV) program was established by the United States
Environmental Protection Agency  (EPA) in response to the belief that there are many viable
environmental technologies which are  not being  used for the lack of credible  third-party
performance testing.  With the performance data developed under the program, technology buyers
and permitters  in the  United States  and abroad will be  better equipped to make informed
environmental technology purchase decisions. In late 1997,  EPA selected the  Southern Research
Institute  to  manage  1 of 12 ETV  verification  entities:   The  Greenhouse Gas  Technology
Verification Center (the Center).  Eleven other ETV entities are  currently operating throughout
the United States conducting third-party verification in a wide range of environmental media and
industries.

In March of 1997, the Center met with  members of the Executive Stakeholder Group.  In that
meeting, it was decided  that the oil  and gas industries were good  candidates for third-party
verification of methane mitigation and monitoring technologies.  As a consequence, in June  1998,
the Center hosted a meeting in Houston, Texas with operators and vendors in the oil  and natural
gas industries. The objectives of the meeting were to:  (1) gauge the need for verification testing
in these industries,  (2)  identify specific technology testing  priorities,  (3) identify  broadly
acceptable verification and testing strategies,  and (4) recruit  industry stakeholders.  Industry
participants voiced support for the Center's mission, identified a need for independent third-party
verification, and prioritized specific technologies and verification strategies.  Since the Houston
meeting, a 19 member Oil and Gas Industries Stakeholder Group was  formed, vendors of GHG
mitigation devices were solicited in several top-rated technology areas, and verification tests of
two compressor leak mitigation devices are starting.

In an August 1998 letter to the Oil and Gas Industries Stakeholder Group, plans were outlined for
a verification test of compressor rod seal leak capture and utilization systems.  One vendor,  A&A
Environmental Seals, Inc.,  committed to participate in a long-term independent verification of
their technology.  A&A's Seal Assist  System (SAS) is designed to capture methane from leaking
compressor rod seals, and route the captured gas into the compressor engine fuel line  for use.
With over 13,000 natural gas compressors operating in the  United States  alone, compressor rod
seal leaks represent a major source  of methane  emissions, and a significant loss of economic and
natural resources.

A test of the SAS device is scheduled to begin in January 1999, and will be carried out  at a gas
transmission  station operated by Transwestern Pipeline  Company - Enron Gas Pipeline Group
(Transwestern). The  station is located in northeastern Arizona.

This document is the full test/QA plan for the  A&A Seals'  SAS  verification test.  It contains a
detailed rationale for the experimental  design and lays out specific test and QA/QC procedures to
be implemented.  This plan (once approved) meets the requirements  of the Center's approved
Quality Management Plan (QMP) and thereby satisfies the ETV QMP and conforms  with EPA's
standard for environmental testing (E-4).  This plan has been prepared to guide implementation of
the test and to document planned test operations for the purposes of review and audit.

The A&A device will be  tested for an 8-month time frame,  during which the  Center will issue a
Phase I Report containing initial installation and measurements data (early 1999) and a Phase II
Report containing longer-term technical and economic performance data (late 1999). The  specific
verification goals associated with the Phase I and Phase II verification efforts are outlined  below.

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                  Phase I SAS Evaluation:
                  •   Verify initial leak capture performance
                  •   Verify initial gas recovery and use performance
                  •   Verify initial methane emission reduction
                  •   Document installation and shakedown requirements
                  •   Document capital and installation costs

                  Phase II SAS Evaluation:
                  •   Verify long-term leak capture performance
                  •   Verify long-term gas recovery and use performance
                  •   Estimate annual methane emission reduction
                  •   Document long-term SAS operational requirements
                  •   Calculate SAS payback period
Phase I goals will be achieved through collection and analysis of direct gas measurements, and
the use of site operator logs and vendor supplied cost information. A primary goal of Phase II is
determination of the SAS payback period. As a practical matter, the Center cannot conduct direct
testing for the several years that would be required to determine payback entirely through direct
gas and other measurements.  Thus, several Phase II goals  will be accomplished through a
combination of  medium-term measurements  (8-months)  and data extrapolation techniques.
Extrapolation and other assumptions will be transparent in the final report, allowing readers to
make alternate assumptions and assessments if they wish.
           2.0   TECHNOLOGY DESCRIPTION AND VERIFICATION APPROACH
2.1.    SEAL ASSIST SYSTEM DESCRIPTION

The SAS is a secondary containment device designed to prevent rod packing leaks from escaping
into the atmosphere.  With the SAS system, existing rod packing can continue to leak, but the
leaked gas is contained within a secondary containment gland.  This allows the contained gas to
be collected, re-compressed,  and  routed into the compressor engine fuel  line for use. A key
component of the SAS is the Emissions Containment Gland (ECG). The ECG, which is installed
over the existing rod and behind the rod packing, is depicted in Figure 1. The figure also shows a
doghouse which contains the rod and packing flange over which the ECG will be installed for this
study.

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Figure 1. SAS gland (top) and installation location (bottom).

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Figure 2 contains a schematic drawing of the SAS system, and shows some of the monitoring and
sampling system that will be used in the test. The ECG has an annulus area that is swept with
natural gas provided from an on-site gas line.  The annulus area normally operates at a slightly
negative pressure created by a series of methane jets.   The jets operate based on the  Coanda
effect, which describes the turbulent boundary layer from  fluid flow  over a curved or inclined
surface. The surface adherence phenomenon of the Coanda effect allows the  entrained emissions
to be  delivered to a re-circulation and re-compression system (Croll Reynolds Eductor).  Natural
gas is circulated from the discharge of the jets to the annulus area to  ensure that the annulus is
constantly supplied with gas, ensuring a continuous purge of the annulus area. In order to prevent
aspiration of air that might occur from negative pressure in the  SAS,  a tertiary seal is provided
that is maintained at a slight positive pressure.

Natural gas  captured   by the  "sweep" gas   is  discharged  through   a   Croll   Reynolds
Eductor/Compressor.  The  Croll Reynolds Eductor/Compressor boosts the  captured  emissions
and motive gas up to sufficient pressure for introduction into the engine fuel supply.  The SAS
has been  engineered  to  meet  site-specific conditions,  although  the  fundamental  design  and
operation of the SAS, as described here, remains unchanged.
2.2.    SITE SELECTION, DESCRIPTION, AND SAS INSTALLATION
2.2.1.  Site Selection and Description

The natural gas transmission engine/compressor selected to host this evaluation is  Unit 401  at
Station 4 operated by Transwestern Pipeline Company - Enron Gas Pipeline Group.  Station 4 is
located near Klagatoh,  Arizona, north of Interstate  40, off Exit 333.  A photograph of the
engine/compressor building, and a simplified floor plan are presented in Figure 3.  This station
operates 3 Clark gas-fired 1C engines (12 cylinder, 4000 Hp), and each is equipped with 3 integral
cylinder-type compressors operating in series (4-1/2" rods).  Geographic location was not seen  as
a significant factor in the evaluation, but extremes of environment, very hot or very cold, were
avoided.

The engines at Station 4 are not typical of newer high speed engines in use, but the rods and
packings have the same basic design and functionality as many reciprocating compressors used
now and planned for use in the future. Reciprocating  compressors are the dominant types in use,
although newer compressor designs, such as screw-type, are beginning to be placed into service.
The rod packing system used at this station is typical of those being built or retrofitted within the
industry.  The rod packing at Station 4 is a dry seal system. Traditionally, wet seals, which use
high-pressure oil to form a barrier against escaping gas, have been employed.  According to the
Natural Gas STAR partners,  dry seal systems have come  into favor recently because  of lower
power requirements, improved compressor and pipeline operating efficiency and performance,
enhanced compressor reliability,  and  reduced maintenance.  The STAR industry partners report
that about 50 percent of new seal replacements consist of dry  seals.  This is consistent with the
experience  at Station 4, where wet seals were replaced  with dry seals 10 months ago.

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Figure 2.  SAS test system schematic - monitoring locations.
        SASTest System Schematic - Monitoring Locations
                          flacyete
                                                      (-lows - Gas Recovery
                                                      Total - QT - 08
                                                      Gland l - 01 u?
                                                      Gland 2-03-04
                                                      Gland 3= Q5-06

                                                      Pressures • System Monitoring
                                                      P1, P2, P3 - Gland Pi-easu re
                                                      P4 - Recycle Linn Pressure
                                                      PS - SucUon Line Pressure

                                                      Concentration (O2) - Air Enlrainmenl
                                                      C-1o 0.1 percent

                                                      Pre««urea - (readout only)
                                                      P6- Recycle Line Piessuie
                                                      P ? - Suctean Line PrassLire

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Figure 3. Photograph and floor plan for the host gas transmission line compressor station.
Engine &
Compressor
Monitoring 1
! Panel
• Compressor and ;
I Rod System (rods
enclosed in a
vented doghouse)
0
D

Engine 1
(Test Unit)
rfU J
ft i p
j
D
I Locations of the 3 A&A Glands j
j in the Engine 1 Doghouses j


Engine 2
6 6
i
Engine 3
D U
i
                                                     6

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2.2.2.   Seal Assist System Installation and Operation

The SAS will be installed on all three compressor rods of Unit 1. The installation is depicted in
Figure 3.  It will include 3 glands, 3 gas jet assemblies, pressure and flow monitoring devices, the
Croll  Reynolds Eductor motive gas  system, safety  systems (oxygen monitor and pressure relief
valves), system and  sampling valves, automated data acquisition,  and steel and stainless  steel
tubing.   Specifications  for several  key  SAS  components  are shown on the  SAS  schematic
presented earlier in Figure 2.   Specifications for the  monitors required to verify the SAS are
described later.

During installation of SAS components and monitoring devices, tie-in's to the existing Station 4
data acquisition system will be made.  This will allow both Station  operators and Center staff to
collect, display, record, and assess all monitored SAS variables in real-time.  Output signals from
each monitoring device shown earlier in Figure 2 will  be  converted into  digital signals and
transmitted to the site control room via the control panel shown in Figure 3.  These signals will be
converted into  actual reporting units, and stored  in  the on-site computer  for routine remote
download and on-line monitoring. A dedicated and  password-protected computer in the Southern
Research office in Research Triangle Park, NC, will automatically download data daily.

Monitored rod temperature is an indicator of the amount of sag in the rod, the need to schedule
required maintenance/repair, and perhaps,  the need to replace the seals.  The SAS will be installed
where  rod temperature was previously monitored, necessitating movement  of the temperature
probe to a location immediately behind the SAS. Since the SAS generates heat as its seals seat,
the temperature sensors during start-up could indicate a sag condition.  This may require manual
monitoring during  start-up  of the SAS.   In addition,  the SAS  has a net cooling effect  during
normal operation (after the SAS seals are seated), necessitating re-evaluation of the appropriate
rod temperature set point.

The SAS  ECG's were installed on all three compressor rods on November 23.  There were no
significant increases in rod temperature after startup and, after temperatures stabilized, there was
no need to adjust rod temperature set points.

An A&A  engineer  will provide an operator's manual  and on-site training  at the time  of
installation.   In  addition, efforts  to anticipate unplanned site-specific operational  events have
produced specifications for safe and appropriate operational responses to these events. Although
Engine 1 is expected to operate throughout the study period, the unplanned operational events and
the resultant actions identified so far are outlined below.

        •   Units 2 and/or 3 shutdown with or without depressurization. In this case, the
           SAS continues to operate normally, supplementing the fuel feed to Engine 1.

        •   Unit 1  shutdown occurs in a pressurized state,  and Engines 2 and/or 3 remain
           operational.  In this case, the  SAS continues normal  operation, capturing
           natural  gas that  continues  to leak in  response to the  pressure  in the
           compressor. The fuel is provided to Engines 2 and/or 3.

        •   Unit 1  shutdown and depressurization occurs.  The SAS may be shutdown.
           (No gas is leaking, so the SAS has nothing to capture.)

        •   Normal  shutdown   of  all   three  engines  occur,   with  or  without
           depressurization.  The SAS should be shutdown,  as there is no place for the

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           captured and motive gasses to be used. In this case, rod emissions will return
           to their state prior to SAS installation (released to the atmosphere).

       •   An emergency or remote  shutdown of all three units occurs.  The SAS is
           designed to shutdown automatically in this instance.

       •   A catastrophic rod failure occurs on Engine 1.  The SAS should be shutdown
           to the compressor experiencing the failure (assuming it depressurizes).  If the
           non-damaged compressors remain pressurized, the SAS  serving each should
           remain operational, and the other engines will use the collected gas.

The SAS designed for Station 4 has an upper limit of about 35 scfrn of leaking gas that can be
recovered (total of all 3 glands).  When the SAS is operating above the normal recovery rate
(which can be varied up to the recovery rate limitation),  this will be  indicated by a positive
pressure developing in the SAS gland.  The system will continue to capture leaking gas, up to a
limit,  although some gas may begin to leak through the SAS tertiary seal as the pressure in the
SAS continues to  increase.  To avoid potential damage to the SAS, it is designed with a pressure
relief device set at 20 psig. If the SAS is checked and found to be operating properly, this will be
an indicator of a major leak having developed in the primary rod seal, perhaps  necessitating
repair.

Specific  operational parameters  to be  monitored  and logged in  the  verification testing are
described later in Section 2.
2.3.    VERIFICATION PARAMETERS AND THEIR DETERMINATION

Verification testing of the SAS is scheduled to begin at Transwestern Compressor Station 4 in
January 1999, and will continue for an 8-month period. After initial testing is complete, the
Center will issue a Phase I Report, containing installation and initial verification measurements
data (early 1999). After all testing is complete, a Phase II Report will be issued  which contains
longer-term technical and economic performance verification  data  (late  1999). The specific
verification parameters associated with the Phase 1 and Phase II efforts are listed below. Each
parameter is discussed separately in the Sections that follow.

               •   Phase I SAS Evaluation:
                  •   Verify initial leak capture performance
                  •   Verify initial gas recovery and use performance
                  •   Verify initial methane emission reduction
                  •   Document installation and shakedown requirements
                  •   Document capital and installation costs

               •   Phase II SAS Evaluation:
                  •   Verify long-term leak capture performance
                  •   Verify long-term gas recovery and use performance
                  •   Estimate annual methane emission reduction
                  •   Document long-term SAS operational requirements
                  •   Calculate SAS payback period

Phase I verification parameters will  be determined through the collection and analyses of direct
measurements, and use of site operator logs and vendor-supplied cost information.   A primary

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goal of Phase II is to determine the SAS payback period. Unfortunately, the Center is unable to
conduct multi-year testing in an effort to  determine payback using direct  measurements only.
Thus, several  Phase II verification parameters  will be determined through a  combination of
medium-term measurements (8-months) and data extrapolation techniques.
2.3.1.  Phase I SAS Evaluation
2.3.1.1.   Verify Initial Leak Capture Performance

Unless unusually large leaks develop on a compressor rod seal, the SAS is designed to completely
capture all of the leak (up to about 35 scfm total).   The  SAS glands and auxiliary  systems
installed at Station 4 were designed to  accommodate the leaks anticipated there, and as normal
increases  in  leak rates occur,  operators  will  perform system  adjustments  to  optimize  SAS
performance, and ensure full gas containment.

Leak capture performance will be measured directly using a customized High Volume  Sampler
(HVS). The HVS will verify ECG integrity by drawing gas samples from each  of the three
doghouse  vents.  The integrity of the  following system components will be tested with  soap
solution and the HVS:   fittings, valves, joints, and  any other components that could develop a
leak. For the first three weeks of operation, these  leak check tests will be  performed  weekly.
Thereafter, they will be performed  bi-monthly for  the  SAS glands, and monthly for all other
components.

The HVS's design, performance, and operational specifications are  described in more detail in
Section 2.4 and Section 5. The HVS provides sufficient suction to  draw the  entire leak from a
single  component into the device for real-time methane leak rate quantification.  The HVS can
quantify leaks of up to about 50 cfrn of natural gas. Gas composition is measured with a Bascom-
Turner hydrocarbon analyzer calibrated  specifically to methane (range 300 ppm to 100%).  Flow
through the HVS is provided  by a compressed air driven venturi, and is metered by an internal
vane anemometer located in a  long, straight pipe.
2.3.1.2.   Verify Initial Gas Recovery and Use Performance

The amount of gas recovered by the SAS and routed to the engines for use is a critical parameter
in determining economic performance.  Initial gas recovery will be determined, and reported in
the Phase I Report, after at least three weeks of continuous monitoring data have been collected
and analyzed.  Gas recovery data will  be  reported as a  series  of hourly, daily, and weekly
averages. The strategy for determining these values is discussed below.

Earlier in Figure 2, the locations of eight in-line gas flow measuring devices  were identified.  Six
of these devices will be used to measure the gas flow immediately upstream  and downstream
from each of the three SAS glands installed on Engine 1. The remaining two meters will be used
to measure the combined  flow upstream and downstream of the  three SAS glands.  With this
configuration, it will be possible to continuously monitor the gas  recovery associated with each
gland, and as an independent check, to continuously monitor the total gas recovery. If the sum of
the recoveries from each  gland  does not agree  with the  total recovery determined  from  the

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independent check, an effort to identify and rectify the disagreement will be  conducted in the
early stages of the program.

The flow measurement device planned for use is the mass flow meter.  The design, performance,
and operational specifications for the meters are outlined in described in Section 2.4.  Specific
operational procedures are given in Section  5.2. These meters will provide accurate and stable
flow measurement under the conditions  expected,  and will transmit  data to  the  local data
acquisition system for near  real-time quantification and monitoring. SAS gland pressures and
system line pressures will also be monitored to provide additional  data on system performance,
and early warning on system problems  to  site operators. These  pressures  will be monitored
continuously and recorded at the same intervals as the flow data, and will be  stored on the site's
data acquisition system.

To verify that atmospheric  air is not  entrained in the system, monitoring  for oxygen in the
recycled fuel flow will be conducted as shown earlier in Figure 2.  If air is present in significant
quantities, this monitor will alarm, allowing corrective action to be taken.

Rod  emissions are expected to increase over time as seals  wear normally or  suffer damage.
Among other uses, the gland-specific gas recovery measurements will allow emission anomalies
associated with individual rod seals to be identified and quantified. If one seal experiences an
uncharacteristically large and rapid  increase in emissions, it can be detected  and  taken into
account when assessing overall  SAS system performance  and payback.  This feature  is most
important for the longer-term Phase II evaluations discussed later. These data will also be used to
assess the representativness of the Engine  1 rod seal emissions  relative to industry  averages.
2.3.1.3.   Verify Initial Methane Emission Reduction

It is possible that a distinction must be made between the amount of gas recovered by the SAS
(described  in the previous  Section),  and  the  atmospheric emissions  reduced by  the  SAS
(described in this Section).  If installation of the SAS does  not alter rod seal leak rates, and if
entrained air is not present within the SAS; then the initial methane emission reduction  should be
equal to the initial gas recovery measured as described in the previous Section.  On the  other
hand, if rod  seal leak rates either increase  or decrease due to SAS installation, or significant
entrained air is  present, then emission reductions  and  gas recovery values will differ.   For
example, if the  SAS reduces leak rates after installation, then  the measured leak rate would
understate actual SAS emission reductions  (i.e., use recovered gas measurements to  represent
emission reductions).

Since the SAS  gland is designed to  operate  near ambient pressure,  it is unlikely  it  will
significantly increase or decrease rod seal leak rates.  However, this will be verified by disabling
the SAS soon after installation, then independently monitoring rod seal leak rates for comparison
with the gas recovery rates described earlier. If the SAS does not impact leak rates, these values
should be the same.  The SAS will be disabled by stopping the flow of motive gas, and opening
the valve downstream from each SAS gland to expose the gland's  annulus area to normal ambient
conditions (conditions experienced when the gland is not present). This will allow the HVS to
measure the rod seal leak rate directly as it  flows from the sample port at the open valve. This
measured leak rate will be  compared with HVS data collected just before the SAS installation,
and with gas flow measurements collected by the mass flow meters immediately after installation.
If little  or no difference is  observed between the gas recovery measurements and the leak rate
                                            10

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experienced with the SAS disabled, then the continuous mass flow meter data will be used to
characterize initial emission reductions.

If differences are found, a decision on how to measure and characterize the differences will be
made and implemented early in the program.  A continuation of the HVS measurement process is
the  most likely  option, but  if the differences  are  large, alternate  strategies may  be more
appropriate. In any event, initial emission reductions,  corrected using the HVS data if necessary,
will be determined and reported in the  Phase I Report after at least three weeks of continuous
monitoring data have been collected and analyzed,  and after the  HVS data collection effort
described above have been completed.

The SAS is designed to be air tight, but if air intrusion does occur, the data from the oxygen
monitor will be used to identify this condition and  quantify  the  volume of air present in the
system. In all likelyhood, the  leak will be repaired quickly, and the  data where significant air is
present, will be ignored.

2.3.1.4.    Document Installation and Shakedown Requirements

A&A has prepared installation instructions for the SAS system.  These instructions are outlined in
Table 1.  The SAS will be installed by a Transwestern approved contractor, with supervision and
guidance  provided by A&A engineers.   The contractors will also conduct leak checks on the
complete  system, and correct loose fittings or valves.  Center personnel will be on-site throughout
the installation and shakedown process, and will document any modifications made or difficulties
encountered.  The  Center will also document  key  decisions made regarding placement of
equipment or adjustments made for site-specific conditions.

A&A will provide an Operator's Manual which provides instructions on start-up  activities and
routine monitoring and maintenance requirements. For the start-up instructions, the manual lists
step-by-step procedures  for: initiating SAS gland start-up, obtaining design re-circulation rate and
pressure,  initiating jet manifold pressure and flow rates, initiating Croll Reynolds  Eductor and
checking  for  it's design  discharge pressure  and flow  rate, and verifying  functionality of
monitoring sensors and  data  recording equipment.   The Center will document any  problems
encountered or changes made to  the  start-up and shakedown activities, and report  the  final
procedures in the Verification Report.

2.3.1.5.    Document Capital and Installation Costs

To determine technology payback period, it will be necessary to accurately document SAS capital
and installation costs.  Table  2 is a listing of the capital  equipment required to assemble  and
install all SAS equipment.  It also  includes preliminary cost data, and identifies where  final data
will be obtained.  The list is specific to the conditions encountered at Station 4 (e.g., fuel  line
distances), with the exception of the SAS gland and the Croll Reynolds Eductor.  The contractors
retained to perform the installation will provide the piping,  valves,  and fittings. Although the list
is believed to be complete, the  contractors may add or  delete items necessary to accommodate site
specific conditions.  The Center will obtain the "as-built" equipment list from the contractors and
A&A after installation  is complete, and  will document total equipment and installation costs
based on contractor's invoices and labor logs.  The Center will multiply the logged hours by the
hourly rates charged by all participating contractors to calculate total installation cost.  The sum
of the capital equipment costs  and  installation costs will represent the net SAS initial cost.  This
cost will not include  the flow monitors and other devices required for the verification test.
                                            11

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         Table 1. Preliminary installation instructions for the SAS system.
SAS Gland:
1
Lay out all parts.
     Note that the gaskets are on the split lines of the gland, carrier, and carrier housing.
     Make sure that the existing seal gland is tight and aligned with the shaft.
     Take the gasket, place it around the shaft (behind the Emission Containment Gland- ECG)
     with the flats of the gasket.	
     Take the two parts of the ECG, install the carbon alignment halves into the ECG.
     Place the two halves around the shaft, install the bolts, do not tighten (leave %" gap
     between halves).	
     Bolt the gland and gasket on to the existing seal gland (leave the nuts loose).
     Place the U- cups around the shaft. Both with the "U" facing the stuffing box.
     Place the two halves of the split alignment busing, into the split carrier (middle groove).
10
Bolt carrier together with the "A" face towards the stuffing box using bolts around the
shaft so that the U-cup seals fit into the grooves. Tighten.
Note - seal carrier has two faces "A" and "B". The holes in the O.D. are closest to "A"
face.
11
Install the split O-rings into the side grooves of the carrier.
12
Slide the carrier with seals up into the cavity of the ECG.
13
Bolt the carrier housing together around the shaft with bolts. Tighten.
14
Cut the O-Ring and press into carrier housing groove all the way around until ends meet,
cut off excess.
15
Bolt housing to the ECG on one side only using 4 bolts.
16
Tighten evenly the two bolts drawing the ECG together.
17
Install the other 4 bolts.
18
Tighten the ECG to the existing packing gland.
Piping and Manifold System:
1
Mount the jet manifold.
2
Connect the suction of the jet to the ECG (port S to port 2 of the ECG) using the !/2" SS
tubing.	
3
Connect the recycle of the jet to the ECG (port R to port 1 of the ECG) using the !/2" SS
tubing. This step requires installation of the vacuum gauge, ball valve and the rising stem
valve in this line.
Note: Rising stem valve should be between the jet and the vacuum gauge. Ball valve just
below vacuum gauge. Parts needed include one !/2" rising stem valve, one !/2" x  %"
reducing tee, one vacuum gauge, and one %" ball valve.	
     Install motive gas line. Use a reducing union tee here and the regulator with gauge (for
     purge). Additional parts needed: two %" x %"male connectors.
     Note:  motive gas line should always be at least Yi".	
5
Connect %" purge line from regulator to the ECG using %" SS tubing.
6
Connect the discharge of the jet to the Croll Reynolds Eductor.
                                          12

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Table 2.  Documentation of initial capital and installation costs.
Description
Units Required
Price/Unit
Source of
Data
Capital Equipment Costs:
SAS Gland Apparatus
Croll Reynolds #22 Eductor
Piping, Valves, Fittings (stainless steel)
1 " Tubing Cross
1" Tubing T
l/2"Txl" Tube Red.
1/2"T x 3/8" MNPT
1/2" Tube BV
1/2" Tube T
1/2" Tube Plug
45 Degree Male Elbow (1")
2" xl" Pipe Adapter
45 Degree Male Elbow (1/2")
1/2" T x 1/2" T MNPT
1/2" T x 1/8" T MNPT
2" TD Ball Valve
1"TD Ball Valve
1" Pipe T
1/2" Txl" MNPT
1/2" Tubing
1" Tubing
1/8" Headers
1/2" Headers
1" Headers
2" Pipe
3
1

1
3
6
12
9
14
6
2
1
1
2
3
1
1
1
1
40 feet/rod (est.)
60 feet/rod (est.)
30 feet (est.)
30 feet (est.)
30 feet (est.)
6 feet (est.)
$4,500
$3,000

$127.10
$100.10
$18.10
$10.20
$156.50
$31.20
$6.40
$104.00
$133.80
$37.70
$11.30
$12.10
$501.50
$268.30
$107.90
$28.40
$2.50
$7.50
$1.75
$2.50
$3.50
$9.00
A&A Seals
A&A Seals







Obtained From
Transwestern
Approved
Contractor
Logs











Installation Costs:
SAS Gland Assembly Installation
(includes time required to remove cover
plates; remove/install studs, gasket, SAS
Gland, thermocouple; and tightening the
system)
Piping Installation
(includes time required to install all tubing,
valves, headers, and sensors; system checks
for leaks; and start-up/shake -down activities)


2 hours/gland
(est.)



100 hours (est.)




$45 - $65




$45 - $65



Obtained From
Station 4
Operator
Logs

Obtained From
Transwestern
Approved
Contractor
Logs
                             13

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2.3.2.  Phase II SAS Evaluation
2.3.2.1.   Verify Long-term Leak Capture Performance

Long-term leak capture performance will be measured directly using the HVS and the sampling
strategy discussed earlier in Section 2.3.1.1 (Verify Initial Leak Capture Performance).  After the
initial leak capture determinations are complete, testing will be performed bi-monthly for the SAS
glands, and monthly for all other components.  If leaks are discovered over the duration of the
testing program, either the site operators or A&A Seals will be given the option of repairing the
leak. If repairs are made, the level of effort required will be recorded and included in the payback
cost analysis, and the dates of repair will be recorded.

2.3.2.2.   Verify Long-term Gas Recovery and Use Performance

The basic strategy used to measure and record gas recovery performance was described earlier in
Section 2.3.1.2 (Verify Initial Gas Recovery and Use Performance). The same methods will be
used to measure long-term gas recovery, and will not be repeated here.  Using these methods, gas
recovery will be measured continuously throughout the 8-month measurement period. However,
to calculate the payback period for the SAS, estimates of gas recovery over periods longer than 8-
months  will  be needed.  This  necessitates the  use of gas recovery  extrapolation/projection
techniques, and mandates that the assumptions used  in those extrapolations are reasonable and
available for evaluation.  Based on preliminary cost estimates and industry average leak rates, a
rough approximation of the Station 4 payback period was estimated for planning purposes. A
payback  of about 2 years was estimated,  so  it  is assumed that measurements and extrapolations
will be needed covering at least a two year period.

It is recognized within the industry that rod  seal  leaks increase over time as they wear, and that
seals generally remain functional for several years after replacement.  The rod seals on Engine 1
were replaced about ten months  ago, and station operators expect the seals to remain functional
for  at least three-years.  Figure 4 presents a  hypothetical leak profile for all of the Engine 1 rod
seals over the anticipated study period.  As the  figure  shows, leak rates are low immediately after
installation, then  gradually increase over time as the packing wears.  This is a hypothetical
example, and  it is recognized that leaks  may  increase more steeply, due to a catastrophic  seal
failure, or less steeply, due to early failure of the packing.

Figure 4 shows that monitoring will be conducted over about 1/3 of the anticipated study period.
Thus, projections of the amount  of gas recovered after the measurements are complete must be
estimated. Furthermore, the SAS device  will likely be installed on existing compressors at the
same time as rod seals are replaced, so the payback associated with installing the SAS during
packing replacement is of interest. Given this,  the potential gas recovered from the point of seal
replacement to the beginning of the measurement period must also be projected.

Strategies for projecting gas recovery both before  and after the measurement period have been
developed for use.  Each are  outlined separately below, and both contain a "conservative case"
and a "likely case" projection strategy.

Projected gas recovery after the measurement period.  Figure 4 shows that leak rates may increase
rapidly after the measurement period is complete. Thus, significant uncertainty could result if
projected leak rates in this steep  region of the  curve  are inaccurate. As a result, two projection
                                            14

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techniques will be used, one conservative and one based on straightforward data extrapolation.
The conservative technique is illustrated in the top portion of Figure 4. With this technique, it is
considered unlikely that leak rates will decrease after measurements have  concluded.  This allows
the assumption that a minimum recovery would occur if the leak rate monitored at the end of the
study continued  until device payback was achieved.  The  second technique is illustrated in the
lower portion of Figure 4, and is referred to as the  likely case.   This technique is based on
extrapolating the leak recovery data collected over the 8-month measurement period.  It produces
a shorter payback than the conservative method because  continued increases in leak rates are
permitted  after the study is concluded. Both techniques will be used to  determine gas recovery
and payback estimates for the post measurement period.

Projected  gas recovery before  the measurement period.  Unfortunately, the data available to
project pre-measurement leak rates  are more limited  than the data available to project  post-
measurement leak rates.  To project from the point of packing replacement to the  start of the
measurements, two  projection techniques  will  be applied.   The first technique  makes the
conservative  assumption  that  a  low  industry  average   (e.g.,  about  0.1  scfm/rod)  occurs
immediately after packing replacement, and that  leak rates will increase  linearly from this value
to the value measured at the beginning of the study.

The projected pre-measurement gas recovery associated with this conservative assumption will be
combined with the conservative post-measurement recovery estimate described above, yielding a
conservative recovery projection for  all periods in which monitoring was not conducted.  In the
second technique, an initial leak rate equal to a normal industry average (e.g., about 0.4 scfm/rod)
will be assumed and allowed to increase linearly to the value measured  at the beginning of this
study.  Again, this projected gas recovery will be  combined with the gas recovery  associated with
the likely  case post-measurement recovery estimate, to  yield a  likely case projected recovery for
all periods in which monitoring was not conducted.  The specific industry average  leak rates to be
used will be determined based on data and consultations with EPA STAR partners and other rod
leak measurement experts.

For the purpose of reporting  long-term  gas  recovery  and payback periods, the projected gas
recovery before and after the study period will be added to the recovery measured continuously
during the study.  This will represent  the total long-term gas recovery for the SAS.  Two recovery
values will be reported: the "conservative case" and the "likely case" scenarios described above.
Gas which is not collected or not used (e.g., is vented or leaked), will not  be included in  these
estimates.

2.3.2.3.    Estimate Annual Methane Emission Reduction

As described earlier, it is  possible that a distinction must be made between the  amount of gas
recovered by the SAS, and the atmospheric emissions reduced  by the SAS.  If installation of the
SAS does not alter rod seal leak rates, and if entrained air is  not present within the SAS; then
methane emission reductions should be  equal to the  gas  recovery estimates described in the
previous Section.  If rod seal  leak rates either increase or decrease due to SAS  installation, or
significant entrained air is present, then emission reductions and gas recovery values will differ. If
this occurs, the methods described earlier in Section 2.3.1.3 will be used  to correct the long-term
gas recoveries determined as described in the previous Sections.  If the  HVS method described
there is used to quantify the degree of difference, manual monitoring will be conducted at least
monthly (perhaps more if the difference is significant).
                                            15

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            Figure 4. Long-term gas recovery measurement and projection estimate.
   12
   10
   12
   10
Payback Period
Start Point:
Last Seal
Replacement
•s
v
IM
V
Payback Period
Assuming Projected
Recovery is Achieved
                   Likely Case
                                                                                      Minimum
                                                                                      Recovery When
                                                                                      Payback is
                                                                                      Achieved
                                                                      >
                                                                                      Projected
                                                                                      Recovery When
                                                                                      Payback is
                                                                                      Achieved
                                                                 16

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Annual average methane  emission  reductions will be calculated  for each  year  and will  be
included in the gas recovery calculations (i.e., from initial installation until payback is achieved).
Monthly and weekly emission reductions will also  be reported to  allow readers to assess the
trends observed and use alternate assumptions and data interpretations, if desired.

2.3.2.4.   Document Long-term SAS Operational Requirements

Based on the manufacturer's claims, the SAS  does not require frequent operational intervention
or maintenance, and should not adversely effect other compressor operation and  maintenance
(O&M) activities. The main operation requirements for the  SAS are  start-up, shutdown, periodic
checks on gland pressures, and adjustment of the SAS jet flow and recycle balance valves to
accommodate leak rate increases.

To  determine objectively  the level  of  O&M, complete O&M logs on both the SAS and the
compressor  will  be maintained.   This will  include  selected monitored  parameters for the
engine/compressor system, and manual logs of key O&M activities.  Table 3 lists the operational
parameters that will  be collected.
     Table 3. Operational and maintenance data to be collected during testing.
Description Source of Data
SAS, Compressor, and Engine Operating Parameters Logged:
Static pressures in the following SAS systems: glands (3),
recycle line, suction line, and jet manifold
Oxygen content in the SAS system
Compressor rod temperature (all 3 rods on Engine 1)
Actual engine rpm (Engines 1, 2, & 3)
Engine fuel line static pressure and fuel flow rate
Crosshead temperature
Compressor and SAS operating problems/adjustments (3)
Station suction pressure and temperature
Station discharge pressure and temperature
Site DAS1 (being installed)
Site DAS (being installed)
Site DAS (Channels 58, 59, 60)
Site DAS (Channel 102)
Site DAS (Channel 64, 97)
Site DAS (Channels 61, 62, 63)
Operator O&M logs/SAS log
Site DAS (Channels 108, 29)
Site DAS (Channels 107, 30)
Maintenance Requirements Logged:
Labor required to start/stop the system, conduct routine
leak checking on the entire SAS assembly, repair leaks,
respond to alarms, and perform SAS adjustments (e.g., jets)
Equipment replacement or repair costs for failed units
Labor required to replace or repair failed units
Compressor/Engine downtime costs caused by failures in
the SAS apparatus
Operator logs and/or
Transwestern approved
contractor logs
1. Data Acquisition System (DAS)
                                           17

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Periodic checks on gland pressures and adjustment of the SAS jet flow and recycle balance valves
may be  required as  leak rates increase  and the glands become pressurized.   After  initial
measurements are complete, the site operators will perform routine SAS system leak checks and
if significant leaks are present, the  Operator's  Manual will be followed to determine appropriate
action. The time required to conduct these activities will be logged. In the event that any of the
SAS components fail and need repair or replacement, Enron site personnel or Enron approved site
contractors will log the purchase cost of each component, and the time  and materials expended in
installing and checking the new components.   Although unlikely, if failure in the SAS system
causes malfunctioning of the compressor or the engine, Enron site operators will be consulted to
help quantify the costs associated with the failure.

At the conclusion of the test period, the Center will calculate net O&M costs by adding the capital
costs of all equipment replaced, multiplying Transwestern's actual labor rates by the total number
of hours spent performing new equipment installation and routine monitoring and other activities.
2.3.2.5.   Calculate SAS Payback Period

A primary objective of the verification test is to calculate  the payback period for the SAS.
Payback occurs when the  total cost of the  SAS (amortized capital, amortized installation,  and
operation and maintenance) equals the savings that the  system provides (in this case, the gas
recovered as fuel).

The  SAS is capable of capturing leaking gas at any time, including when compressors are not
operating (i.e., the  SAS recovers gas during  all operational and  stand-by  periods).  During
compressor stand-by mode, gas leaks  may increase which allow the SAS to recover additional
gas.  In such cases, the economics for the SAS can be enhanced if the recovered gas can be used
as engine fuel.  At the host site, the recovered gas will be used as engine fuel, but when none of
the three engines are running, gas can be recovered but not used. In this case, the recovered gas
will not be counted in determining the payback period.

To calculate payback, two computational procedures will be executed, as shown below.

1.  Total cost will be  determined by adding the SAS capital costs, installation costs, and  O&M
    costs determined as outlined in Sections 2.3.1.5 and 2.3.2.4. Capital costs will be amortized
    over the pay period assuming a discount rate of return of 10%.  To achieve payback on these
    amortized costs, the following equation must hold true.

                     Total Costs  = (Total Gas Saved) (GP)

    Where:  Total Costs = sum of amortized capital, amortized installation, and O&M costs ($)
            Total Gas Saved = net volume of methane (SCF) required to achieve payback
                 (see Step 2)
            GP = gas price ($2/MCF)

2.  Assuming that  an operator will  install the  SAS  at the  time of rod  seal replacement,
    extrapolation  of  the  measured  gas  recovery data  is  required  because  the  8-month
    measurement period does not allow full characterization of total  gas recovered before  and
    after the measurement period. Sections 2.3.1.2 and 2.3.2.2 describe how these extrapolations
    will be accomplished,  and the equation below shows the math that will be applied. Recall
                                           18

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    from Section 2.3.1.2 , that two methods will be used to estimate the gas recovered before and

                Total Gas Saved = Gas Savec/|rest + Gas Saved\Est
    after the measurement; a conservative case estimate and a projected or likely case estimate.
                           Saved|Test
                             measurement period, SCF
              Gas      Est
                             and after the measurement period, SCF
   Conservative Case :
              Gas Saved\Est
(Ts-To)
+  [GRrf (Pay Back - Tr)]
     Likely Case:
                                                                T=PayBack
                 Gas Saved\Est =
   (Ts-T0)
        \f(GR,T)
                                                                  T=Tf
Where:     To = low industry average leak rate (-0.1 SCFM/rod) after packing is replaced,
       NIATo
               scfm
       GR   = leak rate at the beginning  of the measurement period, measured by in-line
               devices,
       GRTf = leak rate at the end of the measurement period, measured by in-line devices, scfm
       T0 = time at which rod seals were installed, HR (T0 = 0)
       Ts = measurement period start time, HR
       Tf = measurement period finish time, HR
       Pay Back = time at which payback is achieved, HR
            , T) = function that characterizes gas recovery profile for period after measurements
               end, SCF, determined statistically
2.4.    FIELD TEST OVERVIEW

The previous Section identifies the verification parameters to be characterized.  It describes the
strategies for quantifying each parameter, the monitoring equipment needed to execute those
strategies, the monitoring frequencies and durations planned,  and data analysis and interpretation
approaches.   Table  4 presents a summary matrix of the verification plans described in the
previous Section.

The previous Section provides few details on the equipment and procedures planned for the field
study.  Thus, the following Sections provide an overview of the primary measurement systems
planned for use at Station 4 (more  detailed specifications and field procedures are provided in
Section 5). Table 5 summarizes specifications for the key devices planned for use.
                                          19

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                          Table 4. Verification testing matrix.
SAS Verification
Parameter
Phase I
Evaluation:
Verify initial leak
capture performance
Verify initial gas
recovery & use
performance
Verify initial
methane emission
reduction
Document
installation and
shakedown
requirements
Document initial
capital and
installation costs
Phase II
Evaluation:
Verify long-term leak
capture performance
Verify long-term gas
recovery and use
performance
Verify long-term
emission reduction
Document long-term
operation
requirements
Calculate SAS
payback period
Approach

Check for and quantify
system leaks
Monitor gas flow within
the system
Monitor gas flow within
the system a
Observe and document
installation process at the
site
Obtain site-specific cost
inputs from various
sources

Check for and quantify
system leaks
Monitor gas flow within
the system
Monitor gas flow within
the system a
Log resources required,
problems encountered,
etc.
See Section 2. 3. 2. 5
Method

High Volume Sampler
(HVS)
8 Mass flow meters
8 Mass flow meters3
Visual inspection,
contractor interviews
and logs
Vendor input,
contractor logs, other
sources

High Volume Sampler
(HVS)
8 Mass flow meters
8 Mass flow meters a
Log sheets
See Section 2. 3.2. 5
Frequency/Duration
(number/weeks)

Gland: weekly/3 weeks
Other components: same
Continuous/3 weeks
Continuous/3 weeks a



Gland: bi-monthly/7
months
Other components:
monthly 11 months
Continuous/8-months
Continuous/8-months a
Continuous/8-months

a.   The HVS will be used to verify that the SAS does not perturb leak rates from the seals, and the oxygen
    monitor will verify that no  increase  in oxygen content occurs  in the system.  If perturbations are
    observed, HVS monitoring will likely be conducted on at least a monthly basis.
                                             20

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                 Table 5.  Field monitoring equipment specifications.
Parameter
Pressure



Flow


Leak Rate

Oxygen

Location1 &
Range
P1,P2,P3,P5
-4 to + 20 psig
P4
0 to 20 psig
Ql, Q3, Q5, Q7
field re-rangeable
0 to 8 scfm
0 to 50 scfm
Q2, Q4, Q6
0 to 20 scfm
Doghouse vent and
ECG discharge - plus
other leak locations
0 to 50 cfm methane
C
0 to 5% & 0 to 25%
(0 to 25% range for
calibration)
Type
Transducer

Transducer

Mass Flow -
Orifice

Mass Flow -
Laminar
Flow: Vane
Anemometer
CH4: Thermal
Conductivity
Galvanic Fuel Cell

Vendor
Model
Rosemount
3051


Rosemount
3095

Universal P.M.
OFS-4-M
Omega
HH30
Bascom-Turner
CGI 201
Advanced Inst.
GPR-25

Accuracy
(minimum)
+ 0.5% fs

+ 0.5% fs

+ 1.0%fs

+ 1.0%fs
0.75%
2.0%
+ 0.5% fs

1.  Locations correspond to locations shown on Figure 2 SAS schematic.
2.  Notes: Output signals are 4-20 mA DC.
         Connections are NPT
         Pressure limit is 1000 psig or higher (where applicable)
         Intrinsically safe, Class I, Division 2 or better
                                            21

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2.4.1.  High Volume Gas Sampling

In general, the HVS provides sufficient suction to capture the entire leak from a single component
into the device for real-time methane leak rate quantification. Gas composition is measured with a
Bascom-Turner hydrocarbon  analyzer  calibrated  specifically to methane  (range  300 ppm  to
100%), and flow through the HVS is provided by a compressed air driven venturi.  A precision
internal vane anemometer located inside a long, straight run of pipe measures flow rate.

The high flow principal utilized by the  HVS  has  been used for quantifying  leaks from valves,
flanges, open-ended lines,  etc. in natural gas  production  facilities, processing facilities, and
transmission facilities.  There are currently two devices that have been constructed and used for
this type of  measurement.  The  first device is  called the High Volume  Collection  System
(HVCS).  The second is the  Gas Research Institute  Hi-Flow™  System.  The HVCS was the
subject of a successful EPA-sponsored verification study comparing its performance against EPA
approved methods (SRI, 1995).  The Hi-Flow system has been the subject of recent development
and testing by GRI  (Lott et. al, 1995).  During the pre-test site survey at Station 4, an attempt
was made to  quantify emissions  using both devices.  It was concluded that increased flow
capacity may be needed to address  a wide range  of potentially different testing configurations.
For this reason, the HVS  was developed and  will be independently tested for accuracy and
stability initially, and verified at several intervals during the study. These results will be included
in the  Phase  II Report.  Both the HVCS and GRI instruments are identical  in principle to the
device planned for use in this study, but the specific technique used for inducing and measuring
flow differs (see specifications in Table 5).

Currently emissions from the rod packing are released primarily from the doghouse  vent, and
potentially, the doghouse oil drain.  All gas leaking from  the  primary  seal must  enter the
doghouse, and the doghouse is vented only at these two points.  This is the case for all three rod-
seals to be tested.

Emissions may be captured by pulling a sufficient volume of gas through the  vent,  and allowing
ambient air to enter through the drain and replace the gas removed from the doghouse.  The leak
rate may be accurately quantified by  metering  the sampling  rate (cfm) and analyzing the gas
(methane) concentration (%) in the metered flow after equilibrium is established.  The product of
these two values gives the methane leak rate (in cfm).

This procedure requires disconnecting manifold piping used to vent the doghouse  vents. It is
recognized that ambient air will be used as the  dilution gas, and that this air will contain some
low levels of methane.  For the leak rates expected, this would be insignificant, even at fairly high
ambient methane levels. However, background methane levels will be monitored during all high
volume sampling,  and a correction applied  if background levels are  significant  (see Section
5.1.2).

Prior  to installing  the  SAS, the doghouse vent will be  sampled with the HVS to determine
uncontrolled emissions from each rod.  After installation, HVS sampling will be conducted in two
configurations.  The first configuration is identical to the pre-installation testing, except that now
the SAS is operating and the measurement is of the fugitive emissions not captured by the SAS.
The second configuration measures the gas  emitted through the SAS gland with the gland
disconnected  from the SAS purge gas supply.  This measures the rod packing leak  rate without
any potential influence of the SAS  system.
                                           22

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During high volume sampling, it is possible that the diluted methane in the sample stream could
reach the lower or upper explosive limits.  HVS electrical components are intrinsically safe (the
methane analyzer and anamometer readout) and HVS moving parts (the anemometer vane) pose
no  spark hazard.  Nonetheless, methane  concentrations  in the  high  volume  sample will  be
monitored carefully during measurements to avoid  explosive conditions.  When  sampling to
confirm zero or near-zero  leak rate from the SAS gland, methane concentrations in the  sample
flow are expected to be low; however, concentrations may be  higher at first as accumulated
methane is removed from the doghouse.   It is possible that the methane concentration would
remain briefly within  explosive limits during this  initial purge.  Once concentrations have
stabilized, high volume flow will be adjusted to keep the methane concentration below  2.5
percent or one-half the lower explosive limit.

The second purpose of the high volume sampling is to provide  an independent check on the leak
rate with the SAS gland disabled.  In this case, methane concentration in the sample flow  will be
high.  To avoid reaching  the upper explosive limit, sample flow will be started low and the
methane  concentration  monitored continuously  as  the  flow  is  increased.   The  methane
concentration in the sample stream will not be allowed at any time to go  below 30 percent - or
twice the upper explosive limit.
2.4.2.  In-line Gas Flow and Pressure Measurement

Emissions from the SAS gland installed on each of the three compressor rods will be discharged
to a Croll-Reynolds Eductor/Compressor (CREC) where the pressure will be increased to 80 psig
to enter the fuel manifold.  The total gas recovery from  the SAS is the difference between the
SAS motive gas used and the total gas recovered from the system. This total gas recovery will be
determined by measuring both gas flow rates continuously at these two locations (see Figure 2
locations Q7 and Q8) using accurate mass flow meters.  The flow metering devices will:

       •   provide minimal pressure drop in order not to disrupt the system;

       •   provide precision and accuracy sufficient to satisfy data quality objectives;

       •   meet Transwestern piping and pressure surge standards; and

       •   be rugged and reliable to withstand field use  and provide good data capture
           efficiency.
The contribution to total gas recovery from each SAS gland will also be measured directly (see
earlier Figure 2 locations Ql through Q6).  The contribution from each rod is being quantified
individually because measurements  conducted during  the  site  survey suggest there  may  be
considerable variability in the leak rates from the three rods.  The rod-specific gas recoveries will
be determined using  similar instrumentation to that described above for total system flow, and
these data will be used to assess SAS performance for varying leak rates.

Figure 2, presented earlier, shows all pressure monitoring locations and indicates how total gas
recovery and individual rod gas recovery values will be calculated from the direct measurements.
In order to reduce the burden on  local operators  and increase  data capture,  the  local data
acquisition  system (DAS) will be used to acquire data from the flow meters, oxygen monitor, and
                                           23

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pressure transducers. Hourly averaged flow and pressure data will be collected over the duration
of the study.  These data will be automatically downloaded to the SRI remote  computer and
reviewed daily.
2.4.3.   Oxygen Concentration in SAS Discharge

Given that the SAS is handling near pure methane, significant quantities of air in-leakage would
be required to approach the upper explosive  limit of natural gas and air within the system. To
address the concern that the SAS  could produce an explosion or fire hazard, the SAS has design
features that  minimize this possibility.  First, the SAS normally operates at or near (-10  inch
water)  atmospheric pressure, minimizing the chances that  significant quantities of ambient air
would enter the system rapidly. In addition, a natural gas purge is applied, and a positive pressure
is maintained in the outer sealing ring of the SAS gland. This helps ensure that any gas aspirated
into the system is natural gas only.

To  evaluate  the ability  of the SAS  to prevent air  entrainment,  oxygen  will  be monitored
continuously  in the total gas recovery flow just prior to entering the Croll Reynolds Eductor (see
Figure  2). In order to indicate the  presence of ambient air entrainment well before a safety hazard
develops, it is necessary to reliably detect a low concentration of oxygen (at  least 0.1%).  With
the  location selected, low levels of air in-leakage could be detected  within 1.25 seconds of in-
leakage onset.

Oxygen  values  will be  monitored continuously using a  galvanic  fuel cell-based instrument
provided  by  Advanced  Instruments.   This  instrument  is  capable of detecting  oxygen  at
concentrations of 0.03% or less.  These data will be transmitted to the DAS and reviewed daily.
In addition, the oxygen level will be provided with an alarm to alert operators to the development
of a potentially unsafe condition.
2.5.     SCHEDULE OF ACTIVITIES

Figure 5 outlines the tentative schedule of activities for the verification test.  Several activities
identified in  the figure have  already  been  completed  including  site  selection,  strategy
development, and initial equipment fabrication.  Field and laboratory testing are  scheduled to
begin in January of 1999,  but the exact date of start-up  is uncertain, and will depend on the
availability of certain equipment and the extent to which difficulties are encountered during start-
up and  shakedown.   Uncertainty  in the start-up date may impact the  dates for the subsequent
activities in the schedule.

If testing begins in early January 1999, all field activity should be completed by September  1999.
Allowing time for data analysis to be completed, a draft Phase I Report should be available for
review in April  1999. Figure 5 illustrates the  schedule and sequencing of the various reviews
planned, including the vendor and host site review, the EPA quality assurance review, and the
external peer review (i.e., Stakeholder review).  A draft Phase II Report should be available in
November 1999, and the same sequence of review will begin at that point. If all goes according
to plan, a final Phase I Report should be available for distribution in June 1999, and a final Phase
II Report should be available for distribution in December 1999.
                                            24

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This test is a complex undertaking, involving participants from three separate organizations, and
evaluation of a technology never before used at natural gas compressor stations. Complications
are likely to occur, and  some of these complications  may impact the schedule.   As schedule
changes become necessary, the schedule presented in Figure 5 will be updated, and copies of the
revised schedule will be made available upon request.
                          3.0   DATA QUALITY OBJECTIVES

Data quality objectives state the values of key data quality indicators that must be achieved in
order to  draw conclusions from the measurements with the desired level of confidence.  The
process of establishing  data  quality objectives for measurements starts with determining the
desired level of confidence in the primary verification parameters (e.g., confidence level in the
verified payback period).  The next  step  is  to identify  all  measured variables impacting the
primary verification parameters, and determine the error allowed in each using error propagation.
With  error propagation, the cumulative effect of all  measured  variables on the primary data
quality objective can be determined.  This allows individual measurement methods to be chosen
which perform well enough  to  satisfy the data quality objective  for the primary verification
parameter.
3.1.    PAYBACK PERIOD

The primary quantitative objective for this study is to establish the  payback period associated
with installation and use of the SAS.  Inherent in this objective is documentation of the SAS's gas
recovery and use performance. Based on meetings with the Stakeholders, a payback period of
three years would represent acceptable performance.  An error in this value of about +/- 3 to 4
months, or about 10 percent, is used to determine the data quality requirements.

Payback  occurs when the total cost of the  SAS  (amortized capital  and installation costs,  and
operation and maintenance costs) equals the savings that the system provides (gas  recovery as
fuel).   For the field test, the  costs will be based  on actual costs and the errors  are zero.   Gas
recovery will be measured directly during the study, then projected for the periods immediately
before  and  after the  test is  done.   Data quality  objectives address the error in the  direct
measurements only; however, a discussion of the errors in the projections is also provided below.

As previously discussed, the total recovered gas flow from all three  rods and  from each rod
individually will  be measured directly using mass flow meters. The  propagation of errors is
straightforward. The cumulative gas collected over the 8-month study period is the integral under
the  curve of flow measured over time; which is  very  closely approximated as the sum of the
hourly flow measurements over the duration of the test.  The data quality objective specifies a
maximum desirable error in the payback period of 10 percent, so the  flow meters would have to
be accurate to within +/- 10 percent IF they were used to monitor the gas recovery over the entire
payback  period. Of course they will not, and a substantial portion of the total gas recovery over
the payback period will be based on projections of these data, so it is desirable to make the direct
measurements as  accurate as  possible.  Accordingly, mass flow meters accurate to within  + 1
percent will be used.
                                           25

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Figure 5.  Tentative schedule.

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Site Selection & Strategy Development

Test Plan Development & Review


Equipment Fabrication, Installiation, Shakedown


Field and Laboratory Testing

Data Analysis and Validation


Draft Development (Phase 1)
Final Development (Phase 1)
Vendor Review
EPA QA and Peer Review
Final EPA Review (B.W. & Blair)
Distribution of Results



Draft Development (Phase 2)

Final Development (Phase 2)
Vendor Review
EPA QA and Peer Review
Final EPA Review (B.W. & Blair)
Distribution of Results



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             26

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To project emissions outside the range of the test period, measured flows and other data will be
used to approximate leak rate changes expected to occur on rod seals.  In general, there are two
projection scenarios that will be considered; the conservative case projection  and the likely case
projection (see Section 2.3.2.2). Each will yield the same total gas recovery estimate, although
over different time periods, but each will contain  significantly different degrees of uncertainty.
With the conservative case, projected recovery rates in the post-study time frame will be fixed at
the  value measured at  the  end of  the study.  This value  will be based on  mass flow rate
measurements, and it is improbably that the post-study recovery would be below this value.  As a
result,  confidence  in the conservative payback estimate should be  high. Although the pre-study
recovery projection will contain greater percent uncertainty  than the post-study projection,  it's
influence on the total recovery  is expected to be relatively small (about 20  % of total recovery),
thus, it's impact on overall uncertainty will be relatively small. With the conservative case, we
should be able to state with high confidence that estimated payback will not exceed the reported
value.

Projections associated with the likely case scenario will contain greater  uncertainty than the
conservative  case,  primarily because of the greater uncertainty associated with the post-study
projection.  This projection will be based on curve  fitting to the  measured data,  and will  be
buffered by  a consideration of operational parameters (e.g.,  rod  temperature, gland  specific
performance, system pressures, observations during the  test, etc.).  As  a practical matter, it will
not be possible to  completely  characterize the error in this projection, so the analysis approach
will  strive to constrain errors within reasonable bounds.  These constraints  will be developed as
the data are analyzed and the specific processes and emission relationships are  better understood.
3.2.     OXYGEN MONITORING

Oxygen concentration will be monitored at the SAS system discharge in order to confirm that the
SAS does not introduce  ambient air into  the system. As  discussed in Section 2.5.3, the sensor
must be capable of measuring 0.1 percent oxygen or less in order to provide adequate safety. It is
unlikely that this measured parameter will impact the quality  of the payback period estimates
because if oxygen is detected in the system, the source of the leak will be quickly identified and
repaired.  Nevertheless,  high quality  and accurate readings will be  collected  to  ensure  high
confidence in this critical safety check.
3.3.     PRESSURE MONITORING

Pressures will  be monitored at various locations  throughout the SAS  system.   These are
diagnostic measurements to be used for evaluating SAS performance characteristics and are not
expected to play a quantitative role  in determining the payback period.  The pressure transducers
selected for this study are accurate to 0.5 percent full scale. As  with the oxygen monitoring, it is
unlikely that this measured parameter will impact the quality of the payback period estimates.
Nevertheless, high quality and accurate readings  will be collected to ensure high confidence in
the diagnostic utility of monitoring pressures.
3.4.     HVS SAMPLING AND LEAK MONITORING

One of the purposes of the high volume sampling will be to measure any residual leaks produced
by the SAS components after installation.  As such, the minimum detectable leak rate for the

                                            27

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 system is the key data quality indicator of interest for this measurement.  The methane analyzer
 used in the high volume system can detect concentrations as low as 300 ppm +/-  100 ppm.  A
 value of 1000 ppm or 0.1 percent methane  is a practical lower quantifiable limit.  The lowest
 quantifiable flow through the high volume sampler is about 4 cfm (better than +/- 1 percent). At
 this minimum concentration and flow, a leak rate of less than  0.01 cfm (1 percent of 1 cfm) would
 be reliably detected with an  error of+/- 11 percent in the leak rate. Note that this error (+/- 11
 percent) is at the lower quantifiable limit.  Over most of its range, the high  volume sampler
 should be  accurate to  within  about 3  to  6 percent (based on  the  errors  in the  flow and
 concentration measurements).

 The second use of the high volume sampler is to provide an independent check on the leak rate
 before the SAS is installed and, after installation, with the  SAS disabled. In this case, the sampler
 will be operating well above the minimum detectable levels and the precision and accuracy of the
 leak rate should remain within 3 to 6 percent of the actual leak rate.
                           4.0   DATA QUALITY INDICATORS

 Table 6 summarizes data quality indicators for all measurements and briefly indicates how those
 indicators will  be determined or verified. A detailed description  of sampling and  analytical
 procedures - including calibrations and  QC checks  used to  derive  measured  data quality
 indicators can be found in Section 5.
                            Table 6. Data quality indicators
Measurement
Fugitive Leak Rate
Flow
Concentration (4% to 100% methane)
Concentration (0.5% to to 4% methane)
Concentration (1000 to 5000 ppm)
Flow Check
SAS Flows 0 to 8 and 0 to 50 scfm Q1,Q3,Q5,Q7
SAS Flows 0 to 20 scfm Q2,Q4,Q6,Q8
SAS Pressures -4 to + 20 psig P1-P3, P5
SAS Pressures 0 to 20 psig P4
O2 Concentration
Method
Fligh Volume
Vane
Anemometer
CGI-201
CGI-201
CGI-201
Digital
Manometer
Mass Flow -
Orifice
Mass Flow -
Laminar
Transducer
Transducer
Galvanic Fuel
Cell
Precision/
Accuracy
3% - (4 to 100 percent
methane) 6% (5000
ppm to 4 percent
methane) !!%(<
5000 ppm methane)
1% of reading
2% FS
5 % of reading
10 % of reading
0.2% FS
1% FS
1% FS
0.5% FS
0.5% FS
0.5% FS
How Verified/
Determined
Propagated from Flow
and Concentration
Checked against
Manometer
Zero/span checks
Zero/span checks
Zero/span checks
Performance Checks (a)
Performance Checks
Performance Checks
Performance Checks
Performance Checks
Performance Checks /
Single Point Calibration
a.   Note:  Performance  checks  as  a means  of  verification implies  that we  will use the
    manufacturer's specification  for precision/accuracy unless a check of sensor performance
    indicates a problem.  Specific performance checks are given in the sampling and analytical
    procedures of the final test plan.
                                            28

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                 5.0   SAMPLING AND ANALYTICAL PROCEDURES
5.1.    LEAK RATE-HVS MEASUREMENTS
5.1.1.  Description

The rationale and design principles for the high volume sampler to be used in this test have been
discussed above (Section 2.4.1).  This Section provides details on the construction and acceptance
testing, operating procedures, and QA/QC procedures.

Apparatus
A high volume sampler was specially constructed for this test.  Air flow is provided by a
compressed air driven venturi air amplifier and metered by a vane anemometer fitted within a 30
inch long, 3" ID straight pipe. Sample concentration is determined using a Bascom-Turner model
CGA-201 hydrocarbon analyzer calibrated specific to methane.  The analytical  range of this
device is 300 ppm to -100%.  Since the vane anemometer is sensitive and could  be damaged, the
system is also  fitted with a removable  orifice plate that  is used to periodically  check  the
performance of the anemoneter by measuring the pressure differential across the orifice.

The complete system will quantify leak rates from near zero to over 50 cfm and is designed to be
sufficiently accurate  and precise over this entire range (see  data quality objective Section 3.4).
Verification of HVS accuracy and precision is  discussed below  (Section 5.1.3).  Figure 6 is a
diagram of the apparatus.
                          Figure 6. High volume sampler.
                          High Volume Sampler
                                                                Site Compressed
                                                                   AirSupply
                                                               -90 psi, upto 9scfm),
                OrificeAssembly
 VaneAnemometer
(2.75"ID,0-7800fpm)
  'IDSampleLine
             High
               Manometer
                Readout
    Anemometer
      Readout
                            VACCONCDF1000
                           Variable AirAmplifier:
                        Oto145scfmat80psi(9cfm).
                             1.25"NPTatinlet
                               1/4"NPTfeed
B-TCGA-201 HCAnalyzer
300 ppm to ~1 00% methane
                                         29

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Sampling Locations and Numbers

Figure 7 shows the high volume sampling configurations that will be used in the test.  Prior to
installing the SAS, the first configuration will be used.  It measures the rod packing leak rate
through the doghouse vent and drain. During the test, high volume sampling will be conducted in
two locations. The first configuration is identical to the pre-installation testing, except that now
the SAS is operating and the measurement is of the fugitive emissions not captured by the SAS.
The second configuration samples the ECG discharge with the SAS  disabled and isolated from
the system. This measures the rod packing leak rate  without influence of the SAS system.  The
rod packing leak rate and SAS fugitives will be determined weekly for 3 weeks after installation
and then twice per month for the duration of the test. These data will be  used for determining the
rod packing emissions profile and for quantifying the capture efficiency of the SAS.
                  Figure 7. High volume sampling configurations.
          High  Volume Sampling  Configurations
                                    i
                                      I
  Drain
                                                   Configuration 1
                                                   Used prior to installing SAS and
                                                   during test with SAS Enabled
                                                   Configuration 2
                                                   SAS Disabled
Sampling Method

The  following discussion presents  the  rationale for the  sampling method  in  each  of the
configurations (ECG and doghouse sampling).  Step be step procedures are given in Section
5.1.2.

Sampling the ECG. Sampling the ECG is a straightforward application of the basic high volume
sampling method  that has been  widely used to quantify  leak rates  in  the  oil,  gas,  and
petrochemical industries  (see Section  2.4.1).  The  ECG is  isolated from  the system and  a
sampling port is opened on the discharge side.  The rod packing leak is captured by the ECG and
directed to the sampling port. The leak rate equilibrates fairly rapidly  due to the small volume of
piping between the sampling port and the emissions annulus. Figure 8 shows a special FfVS inlet
constructed for this application. The inlet uses a "T" connection to mix dilution  air and gas
sampled from the ECG port.  The ratio of dilution air to sampled gas can be adjusted using an
                                         30

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adjustable orifice at the dilution air inlet.  The  dilution air inlet can be fitted with a hose if
necessary to ensure a supply of clean air.  Background methane  is measured at the dilution air
inlet.  A pressure tap is used to  ensure that a slightly negative pressure is maintained at the HVS
inlet, indicating that the flow is sufficient to capture all of the leaking gas.
                        Figure 8. HVS inlet for ECG sampling.
                                  HVS Inlet for ECG Sampling

                                             Pressure Tap

7
HVS
Sample
Line
/
*




r1
FCR
Sample
Port
                                        Dilution Air Inlet
                                       (adjustable orifice)
Sampling the Doghouse.  Without the SAS, there are normally two emissions points for rod
packing leaks - the doghouse vent and oil drain.  The leak rate may be determined by capturing
the leaking  methane gas in a known volume of dilution air and determining the  percentage
methane in the sample. The leak rate (in cfin) is the product of the sample flow rate (in cfm) and
the percentage methane.

Under normal circumstances, the doghouse starts out filled with ambient air (e.g., immediately
after startup or following maintenance).  Over time, the air  in the doghouse is replaced with
methane from the rod packing leak  so that the doghouse becomes filled with near 100 percent
methane.  Once  equilibrium is established,  excess methane is vented from the doghouse at the
same rate as the rod packing leak.

Ideally, the leak rate could be determined exactly as for the ECG by capturing the gas leaving the
doghouse vent pipe in a metered volume of dilution air and determining the leak rate as described
above. In practice, however, high volume sampling at the vent pipe tends to draw in accumulated
methane from within the doghouse as well as the leaking gas (over-sampling) and give a reading
in excess of the actual leak rate.  During this process, ambient air enters the doghouse to replace
the methane withdrawn (through the drain pipe). To get an  accurate determination  of the  leak
rate, it is then necessary to continue sampling until the accumulated methane has been withdrawn
from the doghouse and the leaking methane  is well mixed and in equilibrium with the dilution air
in the sample.
                                           31

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This equilibrium may be accomplished more rapidly and effectively, by opening the drain pipe to
the atmosphere and allowing ambient air to enter through the drain, replacing the accumulated
methane.  This procedure requires disconnecting manifold  piping used to vent and drain the
doghouse (procedure approved by host site).
Background Methane

Ambient air is used as the dilution gas in the method described above.  Since the air inside the
engine room may contain methane, the effect of this on the measurements must be considered.

The difference between the measured leak rate and the "actual" leak rate is simply the volume of
background methane that is sampled.  This depends on the  concentration of methane in the
background and the sampled volume of ambient air.

The concentration of methane in the background (k) is given by:

k = B/(B+A)

where  B is the sampled background methane volume (cfm) and A  is the sampled volume of
ambient air (cfm).  This yields the following expression for the background volume:

B = kA/(l-k)

Recall that 1000 ppm is the  lowest quantifiable methane concentration for the HVS and the
lowest measureable flow is about 4 cfm.  This gives a lowest quantifiable leak rate of 0.004 cfm.
If B is lower than this, it is not detectable.  That is, if the background is less than 1000 ppm, it
will add no more than this lower detectable limit to the result. Since the Bascom Turner analyzer
will detect 1000 ppm (+/- lOOppm), it can be used to measure the  background at  the start of
sampling.  A background  correction is  necessary  only when the  background  concentration
exceeds 1000 ppm.


5.1.2.  Test Procedures

A blank field data sheet is provided at the end of this Section (Figure 9).  All  references in the
following procedure to recording data refer to this data sheet.
SETUP AND CHECKOUT

       •   Conduct setup and checkout procedures prior to each set of measurements
           (leak rates on 3 rods^
(leak rates on 3 rods)
           Verify that the Bascom-Turner methane analyzer has been calibrated within
           the last 60 days.  The calibration date will be written on a label attached to
           the analyzer - initialed by the calibrating technician. Record date of analyzer
           calibration.  If the analyzer calibration is older than 60 days, check the box
           on the field data sheet, perform measurements, then ship analyzer for re-
           calibration (see below).
                                           32

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           Send analyzer to:
           Southern Research Institute
           6320 Quadrangle Drive
           Suite 100
           Chapel Hill, NC 27514
           (919)403-0282

           Zero the methane analyzer by setting the selector switch to "zero" position
           and allowing the analyzer to complete it's zero checks.  This must be done
           away from the engine  room in a location that is free from methane levels in
           excess of normal atmospheric background.

           Check the anemometer against the 1" orifice plate (see Table	later in this
           Section).   This  procedure will be  done for three consecutive sets of
           measurements, and  then periodically thereafter (this  will be  determined
           during shakedown).  See Section 5.1.3 for procedure.  Record check results
           on data sheet. The 1" orifice plate can remain in the HVS during sampling.
PROCEDURE FOR SAMPLING CONFIGURATION 1, FUGITIVE LEAK RATE

This procedure measures the leak rate through the doghouse and is repeated for each rod.

       •   Record start time for sampling.

       •   Measure and record background methane concentration in the vicinity of the
           HVS inlet (the doghouse drain).

       •   Connect sample tube from the methane analyzer to the sampling port on the
           HVS.

       •   Disconnect doghouse vent pipe, drain pipe, and open to the atmosphere.

       •   Attach sample hose to doghouse vent pipe. Use duct tape to seal sample hose
           to vent pipe.

       •   Connect air supply (if not already connected) and adjust flow to at least 1000
           fpm on anemometer readout.

       •   Verify that dilution air is entering drain pipe (use a strip of paper as an
           indicator).  Increase flow if necessary. Verify a negative pressure of-5 to -
           15 inches water at the HVS inlet

       •   Wait  for flow reading to stabilize, and  then record anemometer  reading
           (fpm).

       •   The methane  analyzer  reading should begin declining as gas is vented from
           the doghouse. Depending on the flow and the leak rate, it may take 15 to 30
           minutes to completely  stabilize.  Once the reading has stabilized, record the
           methane concentration. If the concentration falls below about 5000 ppm (0.5
           percent), then decrease the flow and allow reading to stabilize again. Be sure
           to  allow sufficient time for stabilization.  An  early reading may be biased
           significantly high.
                                          33

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           Once a reading is obtained, repeat the measurement at a decreased flow - at
           least 20 percent less than starting flow. The methane reading should increase
           proportionately.   Record the second set of stable flow and concentration
           readings.

           The inside diameter of the of the anemometer duct is 2.75 inches.  This gives
           an area of 0.04125 square feet.  This factor multiplied by the anemometer
           reading (fpm) gives the total sample flow.  The sample flow multiplied by
           the percent concentration gives the methane leak rate in CFM. For example,
           if the  anemometer reading  is 1200  fpm, this indicates a flow of 49.5  cfrn
           (1200  X  0.04125).   If the  methane concentration is 2 percent, then the
           methane leak rate is 0.99 cfm (49.5 X 0.02).

           Record barometric pressure and temperature.

           Record sampling end time

           Repeat for second and third compressors.
PROCEDURE FOR  SAMPLING  CONFIGURATION 2, LEAK RATE  MEASURED
THROUGH ECG

This procedure measures the leak rate through the  SAS  gland with the system disabled. The
procedure is repeated for each of the three SAS emissions containment glands.

       •   Record start time for sampling.

       •   Measure and record background methane concentration in the vicinity of the
           HVS inlet.

       •   Connect sample tube from the methane analyzer to the sampling port on the
           HVS.

       •   Shut down gas recovery through the SAS ECG by closing the shutoff valves
           on the suction and discharge sides of the ECG.

       •   Open the sample port and allow time for leak rate to stabilize. If the leak is a
           small  leak, a few minutes may be needed.  A larger leak will  stabilize
           quickly.

       •   Attach high volume sampler inlet to ECG sample port.

       •   Adjust air/sample ratio to the starting set point for the rod (to be determined
           during shakedown).

       •   Start with a relatively small HVS sample flow (about 500 fpm anemometer
           reading  or  20  cfm).  Allow methane reading to  stabilize  and then adjust
           sampling rate so that the methane concentration is within analyzer range.

       •   Check sample inlet pressure with zero to 20 inch digital manometer.  An inlet
           pressure of minus 5 to 15 inches water is good. If inlet pressure is too high (-
           5 to 0 inches water), then decrease air flow to compensate. If the pressure is
           too low (less than -15 inches water), then increase air flow to compensate.

       •   If necessary, re-adjust HVS sample flow rate.
                                          34

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       •   Wait  for flow  reading to  stabilize,  and then record anemometer reading
           (fpm).

       •   The methane analyzer reading should stabilize rapidly as there is not a large
           volume of accumulated gas to purge.  Once the reading has stabilized, record
           the methane concentration.  If the concentration falls below about 5000 ppm
           (0.5 percent), then decrease the flow and allow reading to stabilize again. Be
           sure to allow sufficient time for stabilization.

       •   Once  a reading is obtained, repeat the measurement at a decreased flow - at
           least 20 percent less than starting flow.  The methane reading should increase
           proportionately.  Record the second  set of stable flow  and concentration
           readings.

       •   Record barometric pressure and temperature.

       •   The inside diameter of the of the anemometer duct is 2.75 inches.  This gives
           an area of 0.04125  square  feet.  This factor multiplied by the anemometer
           reading (fpm) gives the total sample  flow.  The  sample flow multiplied by
           the percent concentration gives the methane leak rate in CFM. For example,
           if the anemometer reading is 1200 fpm, this indicates a flow of 49.5  cfrn
           (1200  X 0.04125).   If the methane  concentration is  2 percent, then the
           methane leak rate is 0.99 cfm (49.5 X  0.02).
5.1.3.  QA/QC Procedures


The following QA/QC procedures  are to be conducted as specified  - in addition to the checks
conducted as part of the sampling procedure.

Analyzer Calibration

The Bascom Turner methane analyzer calibration should remain stable for up to 90 days.  Each
60 days, the analyzer should be returned to Southern at the address given above for re-calibration.
Calibration will be performed according to manufacturer's specifications and using a certified gas
mixture and calibration apparatus provided by the manufacturer (Part numbers MC-105 and PCA-
001).

Calibrations will be performed and the analyzer shipped to arrive back on site within two weeks
after receipt.
Anemometer check procedure

       •   Verify that 1" orifice plate is installed.  Remove 3" PVC coupling at suction
           end of HVS. The orifice plate is a 1/4" plexiglass disk.  If the plate  is not
           installed, remove the split PVC retainer with fingers, install the orifice plate
           and replace the retainer and PVC coupling.

       •   Connect the digital differential manometer.  Verify that the high  pressure
           tube (marked  "high")  is connected to the  nipple marked  "high" on the
           manometer.

       •   Zero manometer using thumbwheel.

                                           35

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       •   Connect anemometer signal cable and turn on anemometer readout.  Set to
           fpm scale.

       •   The sample hose should also be connected for this check.

       •   Connect air supply line to the quick-disconnect on the venturi and adjust
           flow to around 500 rpm.  The flow adjust is not  precise, so adjust to  an
           approximate value. Record differential pressure.

       •   Similarly,  adjust flow to approximately 1000, 1500, and 2000 fpm.  Record
           differential pressures.  Refer to the lookup table on the anemometer check
           data form  (Figure 10).  Find nearest pressure differential in the table. If the
           corresponding velocity is within the range defined by  the  table  entries
           immediately above and below the velocity, the check passes.  Note  that the
           allowable  percentage error is larger for small flows.  The average table error
           is 5 percent.
Independent Verification of the FTVS

The designed performance of the FfVS is being experimentally verified by a third party.  The tests
will provide a total system calibration of known methane leak rate against FfVS  measured leak
rate over a range of system flow rates.
5.2.    FLOW MEASUREMENTS

SAS gas recovery is determined using pairs of mass flow meters upstream and downstream of
each ECG, and upstream and downstream of the SAS  gas recovery system. This provides gas
recovery values for each rod and for the  system as a whole.  The sum of the individual ECG
recoveries should be the same as the total system recovery (flow balance check).  This provides
an overall operational check on the flow metering system.  Figure  2 (see Section 2.1) identifies
flow  metering  points  and specifies  how gas  recovery  is  determined  from  each  pair  of
measurements.

Two types of mass flow meters are being used:  laminar flow element and orifice meters. The
laminar flow element meters are fixed range.  The orifice meters can be field re-ranged by
replacing the orifice plate and making adjustments to the transmitter software.  This versatility is
needed given the range of rod  packing leak rates that might be encountered.  When the  SAS
glands were installed , the leak rate for rod 3 increased dramatically (to over 30 scfm) for a period
of several days, before subsiding.

Both types of flow meters are temperature and pressure compensated, providing mass flow output
at standard conditions.  The flow meters are sized according to the flow range expected at each
location  (an  internal memo dated 12/8/98 documents  sizing calculations).  The flow range,
accuracy and precision for each meter are given in Table 5 (see Section 2.4). The response time
is 1 second. Each meter is fitted with a transmitter providing 4 to 20 mA output over the meter's
range.  This output is  wired  to an  A/D  module attached to the site's monitoring and control
system.   This allows data to  be acquired and stored on the local data acquisition system and
transmitted daily to SRI for screening and archival.
                                           36

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           Figure 9.  HVS testing - field data sheet.
Setup and Checkout - Complete for each set of measurements.
Date of last methane analyzer calibration:	/	/	.
Date of last anemometer check:	/	/	.
Zero check pass (Y/N)
Barometric Pressure
"Hg  Temp
deg. C
Date
Configuration 1 -
Doghouse Sampling
Start time
Background methane
Velocity 1 (fpm)
CH41  (%)
Leak Rate 1 (acfm)
Leak Rate 1 (scfm)
CH4 2 (%)
Velocity 2 (fpm)
Leak Rate 2 (acfm)
Leak Rate 2 (scfm)
         Rod1
         Rod 2
              Rod 3
Note 1: To calculate leak rate (acfm). Leak rate (acfm)
= anemometer reading (fpm) * 0.04125 * %CH4/100
                     Note 2: To correct to standard conditions.
                     scfm = acfm * P/Pstd * Tstd/T.
Configuration 2 - ECG
Sampling
Start time
Background methane
Inlet Pressure (in H2O)
Velocity 1 (fpm)
CH41  (%)
Leak Rate 1 (acfm)
Leak Rate 1 (scfm)
CH4 2 (%)
Inlet Pressure (in H2O)
Velocity 2 (fpm)
Leak Rate 2 (acfm)
Leak Rate 2 (scfm)
         Rod1
         Rod 2
              Rod 3
                                      37

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      Figure 10. Anemometer check data form.

1 (-500 fpm)
2(~1000fpm)
3 (-1500 fpm)

delta_p
inches H2O



anemometer
(fpm)



Table check values
low
(fpm)



high
(fpm)



Pass?
Y/N
Y/N
Y/N
Lookup Table for Manometer Check of the HVS Vane Anemometer
delta p fpm delta p fpm delta p fpm delta p fpm delta p fpm
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
2
210
300
370
430
490
540
580
620
660
700
730
770
800
830
860
890
920
950
980
1000
This Table was generated
calculations
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
3
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
4
from data
1030
1050
1080
1100
1130
1150
1170
1190
1220
1240
1260
1280
1300
1320
1340
1360
1380
1400
1420
1440
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
5
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
6
collected with the
contained in the file "manometer check.
xls" -
1460
1470
1490
1510
1530
1550
1560
1580
1600
1610
1630
1650
1660
1680
1700
1710
1730
1740
1760
1780
HVS constructed
6.1
6.2
6.3
6.4
6.5
6.6
6.7
6.8
6.9
7
7.1
7.2
7.3
7.4
7.5
7.6
7.7
7.8
7.9
8
for the
1790
1810
1820
1840
1850
1870
1880
1900
1910
1920
1940
1950
1970
1980
1990
2010
2020
2040
2050
2060
test.The table
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
9
9.1
9.2
9.3
9.4
9.5
9.6
9.7
9.8
9.9
10
2080
2090
2100
2120
2130
2140
2150
2170
2180
2190
2210
2220
2230
2240
2260
2270
2280
2290
2300
2320
is traceable to
see project records.
                     38

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The  digital output for each meter is scaled over a range of 0 to 100 with resolution of 4096
increments (12 bit).  To obtain the meter reading in engineering units (scfm), it is necessary to
scale the output to the full scale range of the meter.
5.2.1.   Test Procedures

The flow meters operate unattended continuously after installation.  Configuration testing will be
completed during the intitial SAS shakedown. This will include the following:

        •   manufacturer's startup checks
        •   sensor function check - reasonableness and flow balance checks

Once the  system is operational,  hourly  flow data averaged from  15-minute readings  will be
reviewed daily.  The daily review will include reasonableness checks and flow balance as well as
emissions trends and changes that could indicate system problems.
5.2.2.   QA/QC Procedures

The manufacturer is providing a calibration certificate for each of the flow meters.  The meters
should not require re-calibration over the duration of the test. Any sensor failure within the meter
is reported with an out of range signal.  The overall function of the meters will be assessed during
the daily data review using  reasonableness and flow balance checks.
5.3.     PRESSURE MEASUREMENTS

SAS system pressures will be monitored continuously to provide an ongoing indication of overall
system function.  There are five pressure monitoring points in the system (PI - P5, see Figure 2).
PI through P3 monitor the  individual ECG pressures.   The ECG's should normally operate
slightly below atmospheric (about minus 10 inches water). Pressure above atmospheric indicates
an increased leak rate for the rod.  P4 monitors the recycle manifold pressure and also indicates
the SAS  discharge  pressure.   P4  also indicates whether the  SAS is producing sufficient
operational pressure for the CREC.  P5 monitors the SAS suction manifold pressure.  A pressure
increase in P5  indicates an increased leak rate from one or more ECGs. P5 is used to set an alarm
level for gland pressure.  The alarm level will initially be set at plus 5 psi.  This alarm does not
require immediate action, but indicates a need to assess the source of the increased pressure, and
possibly adjust the SAS jet flow and recirculation.

All pressures are monitored using Rosemount model 3051 "smart" pressure transmitters which
have a  very high degree  of stability over time (0.25%  in five years).   All pressure sensors
transmit a 4 to 20 mA linear signal over the range and with the accuracy given in Table 5. These
sensors have no significant bias or hysteresis (outside of the precision limits). The response time
is  very fast (> 20 Hz).   In the  data  acquisition  system, the digital output for each pressure
transmitter is arbitrarily scaled over a range of 0 to 100 with resolution of 4096 increments (12
bit).  To obtain the meter reading in engineering units (psi or inches water), it is necessary only to
scale the output to the full scale range of the meter.
                                            39

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5.3.1.   Test Procedures

The pressure transmitters are designed to operate continuously and unattended.  Configuration
testing will be completed during the intitial SAS shakedown. This will include the following:
        •   manufacturer's startup checks
        •   sensor function check - reasonableness checks
Once the system is operational, hourly aggregated flow data will be reviewed daily for trends,
spikes or any changes in normal, stable operation.
5.3.2.   QA/QC Procedures

The manufacturer is performing laboratory calibrations on each sensor and providing calibration
certificates.  Routine quality control consists of daily checks for reasonableness, trends, spikes, or
other changes in  operation that could indicate a system problem.  Any sensor malfunction is
reported as an out of range signal.
5.4.     OXYGEN MONITORING
5.4.1.  Description

Since the SAS operates at a slight negative pressure, there is a concern that ambient air could
enter the gas recovered by the SAS producing an explosion or fire hazard.  The SAS design
addresses this by providing a natural gas purge pressure to the tertiary seal  area so that, in the
event that gas does enter the emissions annulus from the tertiary seal area, only natural gas and
not air will be introduced.

The safety  and effectiveness of this system will be evaluated by continuously monitoring oxygen
levels in the total gas recovery flow (at the  SAS jet manifold  discharge).     Since the SAS
discharge is normally nearly pure methane, a large volume of air would have to be introduced to
dilute the gas stream down to the  upper explosive limit.  An explosive condition would occur
only when  80 to 85 percent of the gas  stream  had been replaced with air.  The  oxygen
concentration at the  upper explosive limit would be  17 to  18 percent. Since  any entrained air
could be an indication that a hazardous condition is developing, the oxygen  monitor to be used
for the test is sensitive to concentrations as low as 25 ppm (0.0025 percent).

The pipeline gas normally contains trace amounts of oxygen (<0.1%). An alarm will be set at
three times 0.1%. An automatic shutdown will be triggered if the oxygen sensors sees more than
2 percent oxygen.

Typical analysis of the pipeline gas includes the following major constituents (>0.1%):

           Methane           96.6%
           Carbon Dioxide     1.5%
           Ethane              1.1%
           Nitrogen            0.5%
           Propane             0.2%
                                           40

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In addition to oxygen, other trace (<0.1%) constituents include butane, pentane, and C+.

The oxygen sensor is a galvanic fuel cell which is a type of electrochemical cell  with long life,
high sensitivity, and fast response.  The sampler draws a small sample from the SAS disharge
manifold using system pressure.  The reading is insensitive to changes in pressure.  The range,
and accuracy of the oxygen sensor is given in Table 5.  The response time to 90 percent full scale
is 9 seconds; however,  the  sensor  will show  a marked response  to  an increase in  oxygen
concentration almost immediately (within 1 to 2 seconds). The sensor life is normally 32 months -
which exceeds the duration of the test.

The transmitter provides a 4 to 20 mA linear output from 0 to 5 percent oxygen.   The digital
output for each A/D module is arbitrarily scaled over a range of 0 to 100 with resolution  of 4096
increments (12 bit).  To obtain the meter reading in engineering units (psi or inches water), it is
necessary to  scale the output to the  full scale range of the meter.  The sensor response gives
oxygen  concentration by volume. It is not necessary to correct to standard conditions since the
sensor is being used only as a safety device.

Hourly oxygen data will be downloaded and reviewed daily.
5.4.2.   Test Procedures

The  oxygen  sensor  and  transmitter  are  designed  to  continuously  operate  unattended.
Configuration testing will be completed during the intitial SAS shakedown.  This will include the
following:

        •   manufacturer's startup checks
        •   sensor function check - reasonableness checks

Once the system is operational, hourly aggregated concentration data will be reviewed daily for
trends, spikes or any changes in normal, stable operation.  The sensor electronics provide an out
of range signal in the event of sensor failure.
5.4.3.   QA/QC Procedures

Every 90 to 120 days, the sensor requires a span check.  This is accomplished by selecting the 0
to 25 percent scale, sampling ambient air, and adjusting the span as needed.  The sensor will
produce an out of range signal in the event of failure.  Routine quality control  consists of daily
checks for reasonableness, trends, spikes, or other changes  in operation that  could indicate a
system problem.
5.4.4.   Data Acquisition System
5.4.5.   Description

Each sensor is fitted with a signal conditioner/transmitter that produces a 4 to 20 mA linear output
over the full scale range of the sensor.  Each signal is transmitted to a dedicated 4 to 20 mA,  12
bit analog to digital (A/D) conversion module which is integrated into the station monitoring and
control  system.  The station control software reads the data from each module every 15 minutes
                                            41

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and  provides  aggregation of  sampled data into hourly values.   Hourly values are stored in
delimited ASCII  data records on the station computer's hard drive.  A dedicated data storage
directory is assigned to store the SAS sensor data, as well as engine and compressor operational
parameters that relate to the test. Table 7 lists all parameters that will be collected and stored and
their purpose.
5.4.6.   Test Procedures

All data will be downloaded daily and summary statistics and trend plots will be generated to
check for unusual or changing conditions. Details of the daily review are given in Section 6.  A
dedicated computer located at Southern's Chapel Hill office will automatically receive data from
the station  computer each midnight and generate summary statistics and plots for review at the
start of each work  day.   On weekends and holidays, the data will be accessed and reviewed
remotely.

Alarms are set in the station monitoring and control software for the oxygen sensor (at 3X normal
O2 level) and for the SAS suction manifold pressure (sensor P5).  In  addition, SAS automatic
shutoff is triggered when the oxygen level reaches 2 percent.

The station uses a commercially available communications package called "ReachOut Enterprise"
for remote  data acquisition and  related communications.  This software has been tested at the
station and is suitable for this test. Prior to starting this test, this same software will be installed
on Southern's remote data acquisition computer and dial-up, security pass, and download will be
verified.

A storage directory will be assigned on the station computer which will contain a delimited
ASCII file containing fields for each  of the parameters of interest.  This file will contain a rolling
5 day data record for all sensors and station parameters.  Each day, the file will be downloaded to
the Southern project computer,  a central  database  updated with new records,  and summary
statistics and plots prepared for review.  This process will be automated so that the daily review
can take place efficiently.
                                            42

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 Table 7.  ASCII data record contents, purpose, and significance.
CONTINUOUS DATA TO BE COLLECTED FOR SAS EVALUATION
PARAMETER
Date
Time
Analog Input Point. PI. Value
Analog Input Point. P2. Value
Analog Input Point. P3. Value
Analog Input Point. P4. Value
Analog Input Point. P5. Value
Spare
Analog Input Point.Ql. Value
Analog Input Point.Q2.Value
Analog Input Point.QS. Value
Analog Input Point.Q4 .Value
Analog Input Point.QS .Value
Analog Input Point.Q6.Value
Analog Input Point.Q7.Value
Analog Input Point.QS. Value
Analog Input Point.O.Value
Float.RPM ENGINE (ACTUAL)
Float.HP FUEL
Analog Input Point
.COMPRESSOR ROD TEMP# 1 .V
alue
Analog Input Point
.COMPRESSOR ROD TEMP#2.V
alue
Analog Input Point
.COMPRESSOR ROD TEMP#3 .V
alue
Analog Input Point
.COMPRESSOR _SUCT PRESS.Va
lue
Analog Input Point
.COMPRESSOR DISCH PRESS. V
alue
Analog Input Point
.SUCTION TEMPERATURE.Value
Analog Input Point
.#1 COMP. CYL. TEMP .Value
Analog Input Point
.#2 COMP. CYL. TEMP .Value
Analog Input Point
#3 COMP. CYL. TEMP .Valve
Analog Input Point
.DISCHARGE TEMPERATURE.V
alue
PURPOSE*
D
D
P
P
P
P
P
N/A
P
P
P
P
P
P
P
P
P
D
D/S
D/S
D/S
D/S
D/S
D/S
D/S
D/S
D/S
D/S
D/S
SIGNIFICANCE
Documentation/comparison
Documentation/comparison
SAS system parameter - pressure
SAS system parameter - pressure
SAS system parameter - pressure
SAS system parameter - pressure
SAS system parameter - pressure
As/if needed
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
SAS system parameter - flow
Oxygen monitor-system operation & safety
Determines unit on/off status
Diagnostic
May indicate seal leak rate change
May indicate seal leak rate change
May indicate seal leak rate change
Motive pressure available for jets
Increases may explain an increased leak rate
Temperature of motive gas to jets
May indicate potential rod/seal degradation
May indicate potential rod/seal degradation
May indicate potential rod/seal degradation
May indicate potential rod/seal degradation
* D = Documentation/Diagnostic
P = Primary Value - Data points routinely evaluated
C = Unit Operating Parameter
S = Secondary Value - Used as needed to assess apparent anomalies
                          43

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Configuration testing will be conducted during SAS setup/shakedown. All sensor readings will
be examined for reasonableness, stability, and appropriate responses to changes in SAS operating
parameters as part of the adjustment process. Remote data transfer will also be tested.
5.4.7.  QA/QC Procedures

Once the system is setup and is running properly, daily review of monitoring data will be used as
an overall system check which includes the proper operation of the data acquisition system.
              6.0   DATA REDUCTION, VALIDATION, AND REPORTING
6.1.    DATA REDUCTION

This  Section documents calculations that will be  used to obtain final  results  from  raw
measurements.

The following quantities will be calculated:

Sensor engineering units (flow, pressure and oxygen concentration)

The digital records for each sensor are arbitrarily scaled from 0 to  100 with  12 bit resolution.
Sensor readings (in engineering units) are obtained as follows:

For P1-P3 and P5, the range is minus 4 to 20 inches psig.  The pressure value (psig) is obtained as
follows:
                      Gauge Pressure (psig) = 24/100 * (Reading - 4)

For P4, the range is 0 to 20 psig.  The pressure (in psig) is obtained as  follows:

                        Gauge Pressure (in psi) = 20/100 * Reading

For Q2, Q4, Q6, and Q8 the range is 0 to 20 scfin (mass flow).  The flow (in scfin) is obtained as
follows:

                             Flow (scfin) = 20/100 * Reading

For Ql, Q3, Q5  and Q7,  the high range  is 0 to 50 scfin (mass flow).  The flow is obtained as
follows:
                             Flow (scfin) = 50/100 * Reading

Ql, Q3, and Q5  can also be operated in  a  low range (0  to 8 scfin) in order to obtain sufficient
precision for small leak rates. In this case, the flow is obtained as follows:

                              Flow (scfin) = 8/100 * Reading

For O2, the range is 0 to  5  percent by volume.   The concentration (in % oxygen by volume) is
obtained as follows:
                         Oxygen Concentration = 5/100 * Reading

                                          44

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HVS leak rate

The HVCS leak rate is the product of the flow (cfm) and the concentration (percent by volume).
The leak rate (cfm) is obtained by multiplying the flow velocity obtained by the vane anemometer
(fpm) by the cross Section area of the anemometer duct (0.04125 square feet).  To correct to
standard conditions (1  atmosphere  and 278 degrees Kelvin),  the  temperature  and absolute
pressure of the sampled gas must be measured. The correction factor is given by:

     Gas Pressure (absolute - in atmospheres) / 1 Atm. * 278 deg. K / Gas Temperature (K)

The HVS is being independently  calibrated.  The calibration curve will be used to correct the
final data.
Gas recovery

Total Gas Recovery is obtained in two ways: (1) as the sum of the recoveries for each ECG, and
(2) from the total differential flow readings at Q7 and Q8.  That is,

Total Gas Recovery =
(1)  (Q1-Q2) + (Q3-Q4) + (Q5-Q6)
(2)  Q7 - Q8

The total gas recovery values from (1) and (2) should agree within the propogated error of the
quantities.
Payback period

Formulae for calculating the payback period have been given elsewhere in this plan (see Section
2.3).
Unit Conversions

Engineering units in common use at the test site and within the host industry will be used for
reporting and summarizing results.  For pressure, the units are psi or inches water column. For
flow, the units are cfm and scfm (1 atmosphere, 278 K).  For gas velocity, the units are fpm. For
concentration, percentage by volume or ppm are used.
6.2.    DATA REVIEW AND VALIDATION

Calibrations and quality  control checks for each measurement are described in Section  5 -
Sampling and Analytical Procedures.  Upon review, all data collected will be classed as either
valid, suspect or invalid.  In general, valid results  are  based on measurements meeting data
quality objectives.  All data are  considered valid unless a specific performance limit is exceeded
or operational check is failed.
                                           45

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    It is often the case that anomalous data are identified in the process of data review.  All outlying
    or unusual values will be investigated as fully as possible using test records and logs.  Anomalous
    data may be considered suspect if no specific operational cause to invalidate the data are found.
    All  data, valid,  invalid,  and suspect will  be included in the final report.   However,  report
    conclusions will be based on valid data only. The reasons for excluding any data will be justified
    in the report. Suspect data must be included in the analyses, but may be given special treatment as
    specifically indicated.
                    Table 8. Summary calibration and operation checks.
Measurement
High Volume Sampling
(Leak Rate)




SAS System Flows


SAS System Pressures

Oxygen Sensor

Cal/QC Check
Independent System Verification
(Mike Hartman)
Methane Analyzer Auto Zero
(Each measurement)
Methane Analyzer Span Check
(2.5 percent, 60 days)
Anemometer Check (pressure diff.
Across 1" orifice), each
measurement
Replicate measurements at
different flow.
"Normal" Operation
Total vs. Summed Flows
Sensor Diagnostics
"Normal" Operation
Sensor Diagnostics
"Normal" Operation
Sensor Diagnostics
Expected or
Allowable Result
Overall system
calibration
Analyzer diagnostics
successful
+/- 0.1 percent
Per Figure 10
+/- greater of 0.2 cfm or
6 percent
Based on shakedown
data
Within propagated
precision of meters
Pass
Based on shakedown
data
Pass
Based on shakedown
data
Pass
Response to Check
Failure or Out of
Control Condition
Apply calibration curve
Return analyzer for repair.
Return analyzer for repair.
Return HVS for repair.
Troubleshoot sampling
technique, call SRI support
System analysis
System analysis
Contact manufacturer,
repair/replace sensor
System analysis
Contact manufacturer,
repair/replace sensor
System analysis
Contact manufacturer,
repair/replace sensor
All sensor data will be reviewed on a daily basis. All anomalous or outlying values will be identified and
immediately investigated to find a cause for the unusual condition.  Table 9 lists summary statistics and
plots that will be generated and reviewed on a daily basis.
                                               46

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              Table 9. Summary statistics and charts for daily review.
Summary Statistics
Daily gas recovery - average and standard deviation - for each rod, and summed and measured
totals
Gas  recovery to date - cumulative gas recovery, average and standard deviation of cumulative
data - for each rod, and summed and measured totals
Daily pressures (PI - P5) - average and standard deviation
Daily oxygen - average and standard deviation

Time Series Charts
Daily gas recovery
Cumulative Gas recovery since start of test
Daily pressures
Pressures since start of test
6.3.    DATA ANALYSIS AND REPORTING

After data reduction, review and validation, the primary phase 1 data analyses will include the
following:

       •   Initial Leak Capture Performance

           Leak capture performance is based on the HVS measurements conducted to
           measure the fugitive leak rate (if any) with the SAS installed and operating.
           If the SAS leak capture is  100  percent, then the HVS should measure zero
           fugitive emissions.

       •   Initial Gas Recovery and Use Performance

           Gas recovery is based on the paired flow measurements for each ECG and
           for the system as a whole.  Use performance is determined by how much of
           the recovered gas was able to be used in the engine fuel during actual  system
           operations. SAS system and plant operational parameters will be evaluated
           to determine their effect on gas recovery.

       •   Initial Methane Emission Reduction

           Nominally, the methane emission reduction is equal to the total gas use.  In
           addition, it is possible that the ECG may act as a secondary seal and prevent
           some gas  from  leaking and being recovered by the system.  The  existence
           and magnitude of any secondary sealing will be determined from the periodic
           HVS measurements of the rod packing leak rate with the SAS disabled. The
           total emission reduction will be  determined from the total gas recovery less
           gas  recovered that may be vented due to  operational problems and plus any
           secondary sealing effect.
                                          47

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        •   Installation and Shakedown Requirements

           This is a broad assessment of effort and costs required to install the SAS and
           ensure that it is operating  properly.   Any problems encountered during
           installation and shakedown - and their resolutions will be described.

        •   Initial Capital and Installation Costs

           This will be based on the actual installed cost for the system.  For the test, a
           number of sensors are being installed that might not be installed in a normal
           situation.  Once   the  system is  operational,  host site personnel  will  be
           interviewed to determine which sensors they would consider necessary in a
           pernmanent installation.  The cost of these sensors only will be applied to the
           total installed cost.

        •   Data Quality Assessment

           Values of each of the data quality  indicators for each measurement will be
           determined and reported  based on calibrations and QC checks as described in
           Section 5.

The following is a preliminary outline of the content of the phase 1 verification report.

The Phase II  report will include key data from the  Phase I  report.  The Phase II  report will
incorporate the results from  the entire evaluation process, and will focus upon the evaluation
parameters from Section 3 of the Phase I report.
                                      7.0   AUDITS

An internal systems audit is planned for this test.  The audit will be conducted by Southern's
independently  managed QA  staff.   This will  include  field  verification, procedural, and
documentation  components using this plan as the basis for the audit.  An external audit may be
performed  at EPA's discretion by EPA QA staff or a qualified contractor. A performance audit
on sensors  used in the study is not considered necessary due to the ruggedness and reliability of
the devices to be used.  An internal audit of data quality will be conducted once data collection
and analyses are complete.  The final report will contain a summary of results from all audits.
                              8.0   CORRECTIVE ACTION

Table 8 in Section 6.2 lists  allowable values for each of the calibrations  and quality control
checks and also indicates actions to be taken in response to an out of control condition.  Other
issues may  arise that require corrective  actions or plan changes to ensure that data quality
objectives are  met.    Southern's quality  management  plan provides  general  procedures  for
corrective action that will be followed in all such instances.
                                            48

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                                  Preliminary Outline
                      A&A Environmental Seals' Seal Assist System
                               Phase I Verification Report

Verification Statement
Section 1 Executive Summary
               ETV Overview
               Verification Objectives
               Technology Description
               Verification Approach
               Verification Results and Performance Evaluation
                      Initial Leak Capture Performance
                      Initial Gas Recovery and Use Performance
                      Initial Methane Emission Reduction
                      Installation and Shakedown Requirements
                      Initial Capital and Installation Costs
               Data Quality Assessment

Section 2 Verification Test Design and Description
               Seal Assist System Description
               Site Selection, Description, and SAS Installation
               Verification Parameters and Their Determination
                      Initial Leak Capture Performance
                      Initial Gas Recovery and Use Performance
                      Initial Methane Emission Reduction
                      Installation and Shakedown Requirements
                      Initial Capital and Installation Costs
               Sampling and Analytical Procedures
                      High Volume Gas Sampling
                      Flow Measurements
                      Gas Composition
                      Data Acquisition System
               Quality Assurance and Quality Control Measures
                      Calibration Procedures
                      Quality Control  Checks, Audits, and Corrective Actions
                      Data Reduction
                      Data Validation
                      Data Analysis and Reporting

Section 3 Phase I Verification Results and Evaluation
               Initial Leak Capture Performance
               Initial Gas Recovery and Use Performance
               Initial Methane Emission Reduction
               Installation and Shakedown Requirements
               Initial Capital and Installation Costs
               Data Quality Assessment

Section 4 Additional Technical and Performance Data From A&A Seals, Inc.

References
                                          49

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                           9.0   PROJECT ORGANIZATION

This Section formally defines project organization and responsibilities.

Southern Research  Institute's  Greenhouse  Gas Technology  Verification  Center has overall
responsibility for planning and ensuring successful implementation of the verification test.  A&A
seals is providing the Seal  Assist System technology, equipment, and engineering for the test
installation.  Southern is coordinating closely with A&A to integrate special sensing and data
acquisition equipment that will be used in the test, but would not necessarily be part of a normal
installation.  Enron Crop, and their affiliate, Transwestern are  providing access to the host site,
and logistical and manpower assistance in  the  installation and operation of the SAS, and in
conducting the test.  Informally,  good working relationships have been established between the
Center, A&A, and Enron which have proved invaluable in the planning up to this  stage.  All
parties have signed a formal agreement (documented in the Letter of Commitment and associated
documents) specifying details of financial, technical, and managerial responsibilities.

EPA's APPCD is the sponsor of the ETV Greenhouse Gas Pilot and is providing broad oversight
and QA support for the project. The project organization is presented in Figure 11.

In addition to the parties listed in the  organizational chart, Southern has contracted with Faust &
Bursom (Farmington, NM)  to install the piping, conduit and  sensor connections for the  A&A
seals system at Station 4.  Faust & Bursom is an approved and certified Enron contractor.
                           Figure 11.  Project organization.
                               Southern Research Institute
   EPA
   L
       ETV GHG Pilot Mgr
       EPA-APPCD
       David Kirchgessner

        ETV GHG QA Mgr
        EPA-APPCD
        Richard Shores

1
)
J

J-

rETV GHG Center Director^
St.ephers Piccot
ETV GHG Deputy Director
Southern Researh Institute
, Sushma Masernore ,
1


, J QA Manager j
~~| Leslie School! I
1
[QA Staff
1 Scott Bell
\
]

CEW GHG Technical Staff | | ETV GHG QA Coordinator]
z. Ringler, T. Eggleston I 1 Brian Phillips J


  t
  (i
Howard Johnson
President
I Fred Traekwell - Director
Product Development
A&ASeals
                                         Enron
                                  Rich Jolly
                                  Jim Petersen
                                  David Roenseh
                                  Jonny Hendricks
                                                             Transwestern
                                                               Howard Begay
                                                               Calvin Largo
                            Host Site Personnel (Enron and Transwestern)
                                           50

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                    10.0  TEST PROGRAM HEALTH AND SAFETY

This Section applies to Center personnel only.  Other organizations involved in the project have
their own health and safety plans - specific to their roles in the project.

Since the site is part of a pipeline facility, Enron Corporation's safety policies  are regulated, in
part by the US Department of Transportation.   The Center provided a scope of work to  the
National Compliance Management Service Company,  which is the managing company  for
Enron's compliance and safety program. Their assessment is that the Center's on-site job function
is  not covered by the  Research  and Special  Programs Administration,  DOT pipeline safety
regulations covered by  49  CFR Parts 192, 193, and  195. If the scope of work changes, this
determination would be re-evaluated.

Southern staff will comply with all Enron, state/local and Federal regulations relating to safety at
Transwestern's  compressor Station 4.   This includes use of personal protective gear  (flame
resistant clothing, safety glasses, hearing protection, safety toe shoes) as required and completion
of site safety orientation (site hazard awareness, alarms and signals, etc.).

Other than normal industrial hazards, the most significant hazard at Station 4 is the potential for
explosive concentrations of natural gas.  During FfVS testing, there is the potential to produce
hazardous gas concentrations. FfVS operational procedures (see Section 5.1) explicitly address
this issue.
                                  11.0  REFERENCES

Southern Research Institute (SRI),  Evaluation of the High Volume Collection System (HVCS)
for Quantifying Fugitive Organic Vapor Leaks, US EPA, EPA/600/SR-95/167, 1995.

Lott, Robert A., Touche Howard,  and Michael Webb. "New Technology for Measuring Leak
Rates." American Gas Association Operating Proceedings, 1995.

Lott, Robert A. "A Profitable Approach to Dealing with Fugitive Methane Emissions." Presented
at IGT's  Environmental Management  in the Natural Gas Industry. January 27,  1998.  Orlando,
Florida.

Taylor, John R., An Introduction to Error Analysis, second Edition.  University Science Books,
Sausalito, California, 1997.
                                           51

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