DAQ-2024-007962

1

DAQC-417-24
Site ID 15971 (B4)

MEMORANDUM

TO: STACK TEST FILE – RAMSEY HILL EXPLORATION, LLC – RHEx Vernal
Sand Mine – Uintah County

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: May 2, 2024

SUBJECT: Source: Sand Dryer #3 and Crusher #2
Location: 1015 East 12600 North, Cove, UT 84320
Contact: Mike Cina: 715-821-1866 Ext. 6
Tester: Western Environmental Services and Testing, Inc.
Site ID #: 15971
Permit/AO #: DAQE-AN159710004-23, dated July 31, 2023
Subject: Review of Pretest Protocol dated April 17, 2024

On April 26, 2024, Utah Division of Air Quality (DAQ) received a protocol for the Sand Dryer #3 and
Crusher #2 at the RHEx Vernal Sand Mine in Uintah County, Utah. Testing will be performed on May
29-31, 2024, to determine compliance with the emission limits found in Conditions II.B.2.a and II.B.4.e
of Approval Order DAQE-AN159710004-23, 40 CFR Part 60 Subpart OOO, and 40 CFR Part 60 Subpart
UUU.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3/3A used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 5 used to determine filterable particulate matter emissions: OK
6. RM 7E used to determine NOx emissions: OK
7. RM 9 used to determine visible emission: OK

DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: The methods proposed in the pretest protocol are sufficient to determine
particulate matter, NOx emissions, and VEOs from Sand Dryer #3 and
VEOs from Crusher #2. Ramsey Hill Exploration confirmed via email
that a stratification test will also be conducted on Sand Dryer #3. It is
recommended that the pretest protocol be determined as acceptable.

2

ATTACHMENTS: Ramsey Hill Exploration’s test notification letter and pretest protocol and
email correspondence with Ramsey Hill Exploration addressing a
stratification test and emission limits in the permit.

WESTERN
ENVIRONMENTAL
SERVICES AND
TESTING, INC.
Employee Owned and Operated
email: [e-mail]
Fax: [phone]
Toll-Free: [phone]
Phone: [phone]
913 Foster Road
Casper, Wyoming 82601
Ramsey Hill
Exploration, LLC
Vernal, Utah

RHEx Vernal Sand Mine

Sand Drying and Processing Source

State of Utah Department of Environmental Quality Division of Air
Quality Approval Order DAQE-AN159710004-23

Compliance Source Emissions Test Protocol
Filterable Particulate, Opacity, Oxides of
Nitrogen

Project Number: 24-1043
Prepared For:
Mr. Eric Sturm
ARC Owner, Lead Consultant

&

Ramsey Hill Exploration, LLC
RHEx Vernal Sand Mine
8.5 Miles North on US-191 from Vernal Main St.
Vernal, Utah

April 17, 2024

Ramsey Hill Exploration, LLC
Vernal, Utah
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Western Environmental Services and Testing, Inc. 24-1043
EXECUTIVE SUMMARY:
Air Regulations Consulting, LLC (ARC) and Ramsey Hill Exploration, LLC (RHEx) have
retained Western Environmental Services and Testing, Inc. (Western Environmental) to provide
point source emissions surveys, analysis, and reporting. The sources to be tested are at the RHEx
Vernal Sand Mine located 8.5 miles north on US-191 from Vernal Main Street, Vernal, Utah.
The purpose of the testing is to demonstrate the relationship between measured emissions and the
provisions and conditions outlined in the State of Utah Department of Environmental Quality
(UDEQ), Division of Air Quality, Approval Order DAQE-AN159710004-23. This testing will
also demonstrate compliance with the requirements of Code of Federal Regulations Title 40 Part
60 Subpart UUU (NSPS Subpart UUU) and Subpart OOO (NSPS Subpart OOO).
The sources to be tested is listed below:
Compliance Test Sources
Source Emission
Point ID
Source
Description
Test
Duration Analyte EPA
Methods Emission Limits
Vernal
Sand Mine
II.A.5 Sand Dryer
#3
3 2-hour runs
Filterable
PM/PM10/
PM2.5
1-5 0.01 gr/dscf
0.61 lb/hr
3 1-hour
observations Opacity 9 < 10%
3 1-hour runs NOX 7E 4.35 lb/hr
200 ppm
II.A.3 Crusher #2 1 1-hour
observation Opacity 9 < 12%

TEST PROGRAM:
The following protocol is structured in such a manner as to be acceptable to the UDEQ, ARC,
and RHEx. All proposed sampling procedures and techniques are subject to change following
further discussions and meetings with the UDEQ, ARC, and RHEx.
Company and individual contact information associated with the testing program are provided
Ramsey Hill Exploration, LLC
Vernal, Utah
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Western Environmental Services and Testing, Inc. 24-1043
below.
Company Air Regulations Consulting, LLC
(ARC)
Western Environmental
Services and Testing, Inc.
Contact Mr. Eric Sturm Mr. Terry May
Address 5455 Red Rock Lane, Suite 13
Lincoln, Nebraska 68516
913 Foster Road
Casper, Wyoming 82601
Phone [phone] [phone]
E-mail [e-mail] [e-mail]
SCHEDULE:
Testing is tenatively scheduled for the week of May 26, 2024. A detailed testing schedule is
outlined in the table below.

Date Activity Notes/Methodology
May 28, 2024 Mobilize to Vernal, Utah
May 29, 2024
Set up on Sand Dryer #3. Collect
preliminary measurement data, Perform
3 two-hour test runs for particulate on
the Sand Dryer #3. Perform 3 1-hour
opacity observations on the Sand Dryer
#3 (one 1-hour opacity observation will
be performed during each 2-hour
particulate test run). Perform 3 1-hour
runs for O2, CO2, and NOX (one 1-hour
run will be performed during each 2-
hour particulate test run). Perform
opacity observations on Crusher #2
(one 1-hour observation period per
location).
EPA Methods 1-5, 9, and
7E
May 30-31, 2024 Optional reseverve days to test either
Sand Dryer or Crusher; demobilize.
EPA Methods 1-5, 9, and
7E
Ramsey Hill Exploration, LLC
Vernal, Utah
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Western Environmental Services and Testing, Inc. 24-1043
TEST PARAMETERS:
Emissions testing will be performed on the source identified above. Test parameters for the
source are described below.

Sand Dryer #3 II.A.5
TEST PARAMETERS
Parameter /
Constituent
EPA Test
Method(s)
Sampling
Configuration
Sampling
Time per
Run
Notes:
Gas Stream
Characteristics
(flow rates)
1 – 4 Impinger Train 120 minutes
Performed in
conjunction with
Method 5
Filterable
PM/PM10/PM2.5 5 Impinger Train 120 minutes Isokinetic Test Method
Opacity 9 Certified
Observer 60 minutes
Performed
simultaneously with
Method 5
NOX 7E CEMS 60 minutes
Performed
simultaneously with
Method 5

Crusher #2 II.A.2
TEST PARAMETERS
Parameter /
Constituent
EPA Test
Method(s)
Sampling
Configuration
Sampling
Time per
Run
Notes:
Opacity 9 Certified
Observer 60 minutes
The crusher has two
points which require
opacity observations

METHODOLOGY:
The point source characterizations include the above listed sources and the associated test
parameters. A summary of the source test methods follows. Because standard EPA methodology
will be followed, only a brief description of each method is provided. Detailed US
Environmental Protection Agency (EPA) Methods are available in Title 40 of the CFR (40CFR).
Ramsey Hill Exploration, LLC
Vernal, Utah
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Western Environmental Services and Testing, Inc. 24-1043
40CFR, Part 60, Appendix A
Method 1 “Sample and Velocity Traverses for Stationary Sources”
Method 2 “Determination of Stack Gas Velocity and Volumetric Flow Rate”
Method 3 “Gas Analysis for the Determination of Dry Molecular Weight”
Method 3A “Determination of Oxygen and Carbon Dioxide Concentrations in
Emissions from Stationary Sources”
Method 4 “Determination of Moisture Content in Stack Gas”
Method 5 “Determination of Particulate Emissions from the Stationary Sources”
Method 7E “Determination of Nitrogen Oxides Emissions from Stationary Sources”
Method 9 “Visible Emissions Observations from Stationary Sources”

Stack Gas Sampling Procedures
The stack gas sampling procedures will be EPA Methods 1, 2, 3, 4, 5, 7E, and 9, published in
Title 40 CFR, Part 60. Pre-test and post-test leak checks will be performed for each sampling
train as required in the respective test methods. Leak checks may also be performed at port
changes, if circumstances warrant, such as glassware movement or bumping of the stack
sampling train.
Sampling Point Determination - EPA Method 1
The number and location of sampling points will be determined in accordance with the
procedures outlined in EPA Method 1. The sampling locations will meet the criteria specified in
Method 1.
Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2
Flue gas velocity and volumetric flow rate will be determined in accordance with the procedures
outlined in EPA Method 2. Velocity measurements will be made using type S Pitot tubes
conforming to the geometric specifications outlined in EPA Method 2. Each Pitot tube is wind
tunnel calibrated for accuracy. Differential pressures will be measured with fluid manometers.
Effluent gas temperatures will be measured with type K thermocouples equipped with digital
readouts.
Flue Gas Composition and Molecular Weight - EPA Method 3
Oxygen (O2) concentration, carbon dioxide (CO2) concentration, and flue gas dry molecular
weight will be determined in accordance with the procedures outlined in EPA Method 3. O2 and
CO2 concentrations will be measured using an Orsat Gas Analyzer. Nitrogen (N2) concentrations
will be determined by difference. An integrated multi-point sampling system will provide a
Ramsey Hill Exploration, LLC
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Western Environmental Services and Testing, Inc. 24-1043
sample for analysis. Flue gas dry molecular weight will be determined from the O2, CO2, and N2
concentrations.
Flue Gas Moisture Content - EPA Method 4
The flue gas moisture content will be determined in accordance with the procedures outlined in
EPA Method 4. The impingers will be connected in series and will contain reagents as described
in the following section. The impingers will be contained in an ice bath to ensure condensation
of the moisture from the stack gas stream. Any moisture that is not condensed in the impingers is
captured in the silica gel. The mass of the collected moisture will be entered into moisture
content calculations.
Determination of Particulate - EPA Methods 5
Particulate emissions will be determined in accordance with the procedures outlined in EPA
Method 5. Sampling nozzles will be constructed of stainless steel. All other sampling train
components (probe liner, filter holders, impingers, etc.) will be constructed of borosilicate glass.
All glassware will be thoroughly decontaminated prior to testing in accordance with Method 5
requirements. The impingers used in the train are as follows:

* Impinger 1: Modified Greenburg-Smith impinger containing 100 ml of DI H2O
* Impinger 2: Greenburg-Smith impinger containing 100 ml of DI H2O
* Impinger 3: Modified Greenburg-Smith impinger, dry
* Impinger 4: Modified Greenburg-Smith impinger containing silica gel

Samples will be collected isokinetically for a minimum of 120 minutes with a minimum sample
volume of 1.70 dry standard cubic meters (60 dry standard cubic feet). The sampling runs will be
performed to meet the conditions specified in EPA Method 5. A schematic of the Method 5
sampling train is shown in Figure 1.
Ramsey Hill Exploration, LLC
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Western Environmental Services and Testing, Inc. 24-1043
Figure 1
Method 5 Sampling Train Schematic
Upon successful completion of a test run, all exposed front-half sampling surfaces; nozzle,
probe, connecting glassware, and front half of the filter holder will be rinsed and brushed a
minimum of three times with acetone for particulate recovery and collected in polyethylene
sample containers. The front half filter will be carefully recovered and transferred to a container
for transport. The front half samples will be analyzed gravimetrically for particulate matter.
After the mass of the impingers has been recorded for moisture content determination, any liquid
collected in the impingers will be discarded. Blanks of all reagents used will also be collected
and analyzed with the samples.

Ramsey Hill Exploration, LLC
Vernal, Utah
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Western Environmental Services and Testing, Inc. 24-1043
O2, CO2, and NOX Determination (EPA Methods 3A and 7E)
O2, CO2, and NOX concentrations will be measured in accordance with the procedures outlined
in EPA Methods 3A, and 7E, using extractive continuous emission monitors (CEMS). This
package is comprised of four basic subsystems:
• Sample acquisition and conditioning system
• Calibration gas system
• Analyzers
• Data acquisition system
The sample acquisition and conditioning system components transports the sample to the
analyzers and removes moisture from the sample. The sample is extracted continuously from one
point near the center of the stack through a probe and heated sample line. Moisture will be
removed with a gas conditioner and a portion of the gas will be delivered to each analyzer.
The calibration system includes protocol gases and a gas dilution system, which is calibrated
annually by the manufacturer. The gas dilution system introduces the desired calibration gas
concentrations into the sample acquisition and conditioning system as close to the probe as
possible. Each analyzer will be calibrated with high and mid-range gas concentrations and a zero
gas. The gas concentrations will also be used to determine calibration error and analyzer drift.
Analyzer ranges and the corresponding calibration gas concentrations will be chosen based on
permit limits and expected concentrations.
The data acquisition system operates on a computer platform. Instrument outputs follow a 16-bit
ADC and are polled once every second to compile minute averages. All instrumentation will be
rack mounted in a temperature controlled mobile laboratory. Examples of the analyzers to be
utilized are listed in the following table. A schematic of the CEMS calibration and sampling
system is shown in Figure 2.
CEMS Analyzers
Species Test Method Analyzer Principle of Operation
Oxygen 3A CAI ZRE Electrochemical Cell
Carbon Dioxide 3A CAI ZRE NDIR
Nitrogen Oxides 7E API 200AH Chemiluminescence

Ramsey Hill Exploration, LLC
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Western Environmental Services and Testing, Inc. 24-1043
Figure 2
CEMS Sampling Schematic
Visual Determination of the Opacity of Emissions - EPA Method 9
Sixty-minute opacity observations will be performed in accordance with the procedures outlined
in EPA Method 9. Opacity observations will be performed by a certified observer. Opacity
observations will be made at the point of greatest opacity and will be recorded to the nearest 5
percent at 15-second intervals on an observational record sheet. The observer will stand at a
distance sufficient to provide a clear view of the emissions with the sun oriented in the 140o
sector to his back.
The observer will record the name of the plant, emission location, type of facility, observer’s
name, and affiliation, a sketch of the observer’s position in relation to the source, and the date on
a field data sheet. The time, estimated distance to the emission location, approximate wind
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direction, estimated wind speed, description of the sky conditions (presence and color of clouds),
and plume background will be recorded on the data sheet at the time opacity readings are
initiated and completed. The opacity will be determined as an average of the observations
recorded at 15-second intervals during each run.
Deviations from the Methods
There are no anticipated deviations from the EPA test methodologies, except that particulate
matter test run duration will be at least 120 minutes and will have at least 1.70 dry standard cubic
meters (60 dry standard cubic feet) sampling volume. This is in accordance with the
requirements of NSPS Subpart UUU §60.736(b)(1).
Kyle Greenberg <[e-mail]>
Stack Test On Line Submittal For Ramsey Hill Exploration, LLC
Eric Sturm <[e-mail]>Thu, May 2, 2024 at 6:19 AM
To: Kyle Greenberg <[e-mail]>
Cc: [e-mail], Mike Cina <[e-mail]>
Kyle
My apologies. On travel this week. Yes, we will be testing Dryer #3 for NOx at 96 ppm and 2.9 lbs/hr. That is the limit in
the most recent AO with Dryer #3.
We confirmed with Western that a stratification check will be done beforehand.
Can we provide anything else? Or, if you would like to have a call, please let me know.
Best.
Eric Sturm, ARC
m. 402.310.4211
[Quoted text hidden]
5/2/24, 12:52 PM State of Utah Mail - Stack Test On Line Submittal For Ramsey Hill Exploration, LLC
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