DAQ-2024-004358

1

DAQC-1303-23
CAERS ID: 4579 (B4)

MEMORANDUM

TO: STACK TEST FILE – UINTA WAX OPERATING, LLC – RP27S Battery H6UB
and H8UB Tank Battery – Duchesne County

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: November 30, 2023

SUBJECT: Source: One (1) Ajax E-565 Engine; SN: 86705
Location: Remote Locations in Duchesne County, Utah
Contact: Karen Pratt: [phone]
Tester: Oasis Emissions Consultants, Inc.
Site ID #: 4579
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol dated November 28, 2023

On November 28, 2023, Utah Division of Air Quality (DAQ) received a protocol for the testing of one (1)
Ajax E-565 Engine at RP27S Battery H6UB and H8UB Tank Battery in Duchesne County, Utah. Testing
will be performed December 19–22, 2023, to determine compliance with the emission limits found in 40
CFR part 60 subpart JJJJ.

PROTOCOL CONDITIONS:

1. Method 1 used to determine sample traverses; OK
2. Method 3A used to determine dry molecular weight of the gas stream; OK
3. Method 4 used to determine the moisture content within the gas stream; OK
4. Method 7E used to determine NOx emissions; OK
5. Method 10 used to determine CO emissions; OK
6. Method 18 used to determine ethane and methane concentrations of the gas stream; OK
7. Method 19 used to determine exhaust effluent flows and mass emission rates; OK
8. Method 25A used to determine VOC emissions; OK

DEVIATIONS: None stated in the protocol.

CONCLUSION: The protocol appears to be acceptable.

2

RECOMMENDATION: The test methods stated in the protocol are sufficient to determine NOx,
CO, and VOC emission rates and concentrations.

ATTACHMENTS: Uinta Wax Operating, LLC’s notification letter and pretest protocol.
November 28, 2023

Utah Department Of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Test Notification / Protocol Submission & Waiver Request For Uinta
Wax Operating, LLC’s Skoufos Tribal 4-27-34-3-1W-H1, 13, 14-22-15-3-1W-H3, RP
Tribal 27-31W-H6UB, H8UB, RP 22N-31W-H7UB (Skoufos West) in Duchesne
County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 40 horsepower (hp) Ajax E-565 engine located at Uinta Wax Operating, LLC’s Skoufos
Tribal 4-27-34-3-1W-H1, 13, 14-22-15-3-1W-H3, RP Tribal 27-31W-H6UB, H8UB, RP 22N-
31W-H7UB (Skoufos West) (Well: Skoufos Tribal 14-22-15-3-1W-H3; CAERS ID # 4579) in
Duchesne County, Utah. The engine is being tested in accordance with the Utah Administrative
Code Rule R307-510-4 and EPA 40 CFR 60, Subpart JJJJ. A summary of the unit and details of
our testing procedures can be found in the attached protocol.

The engine was identified as needing to be tested during a recent audit. In order to test the engine
as soon as possible, testing has been scheduled with the client for the Tuesday, December 19th,
2023 – Friday, December 22nd, 2023 test campaign. Please waive the standard 30-day
notification period. If this is not possible, please advise and we will reschedule.

If you have any questions or concerns, please contact the undersigned at [phone].

Sincerely,
Oasis Emission Consultants, Inc.
__________________________
Christopher N. Knott, P.Eng
Director, Engineering & Operations

enc.

Utah Department of Environmental Quality
Division of Air Quality
Compliance Test Protocol

Engine: (1) Ajax E-565

Facility: Skoufos Tribal 4-27-34-3-1W-H1, 13, 14-22-15-3-1W-
H3, RP Tribal 27-31W-H6UB, H8UB, RP 22N-31W-H7UB (Skoufos
West)
Well: Skoufos Tribal 14-22-15-3-1W-H3

Uinta Wax Operating, LLC
25 HP – 100 HP Engine
In Duchesne County, Utah

November 28, 2023

Prepared By:

Oasis Emission Consultants, Inc.
2730 Commercial Way
Rock Springs, WY 82901

1.0 INTRODUCTION

The purpose of this document is to provide relevant information pertaining to proposed
compliance emission testing for Uinta Wax Operating, LLC by Oasis Emission Consultants, Inc.
The unit is classified as a non-emergency stationary engine rated below 100 horsepower (hp).
The engine is being tested in accordance with the Utah Administrative Code Rule R307-510-4
and EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ).
1.1 TEST PROGRAM ORGANIZATION

Facility: Skoufos Tribal 4-27-34-3-1W-H1, 13, 14-22-15-3-1W-H3, RP Tribal
27-31W-H6UB, H8UB, RP 22N-31W-H7UB (Skoufos West)

Well: Skoufos Tribal 14-22-15-3-1W-H3
Latitude: 40.20109 Longitude: -109.9833

CAERS ID: 4579

Client: Uinta Wax Operating, LLC
Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Test Company: Oasis Emission Consultants, Inc.
Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Christopher Knott, P.Eng., Director, Engineering & Operations
Phone: [phone] Fax: [phone]

State Authority: Utah Department Of Environmental Quality
Address: PO Box 144820
Salt Lake City, UT 84114-4820
Contact: Rik Ombach, Minor Source Compliance Manager
Email: [e-mail]
Phone: [phone]

Stack Test Report Submission:
https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh
1.2 Test Project Objective(s)

The engine is located at the Uinta Wax Operating, LLC’s Skoufos Tribal 4-27-34-3-1W-H1, 13,
14-22-15-3-1W-H3, RP Tribal 27-31W-H6UB, H8UB, RP 22N-31W-H7UB (Skoufos West)
(Well: Skoufos Tribal 14-22-15-3-1W-H3; CAERS ID # 4579) in Duchesne County, Utah. The
engine is being tested in accordance with the Utah Administrative Code Rule R307-510-4 and
EPA 40 CFR 60, Subpart JJJJ.

2.0 SOURCE TEST PROGRAM DESCRIPTION

2.1 Test Contractor

All source emission tests will be performed by Oasis Emission Consultants, Inc., based out of
Rock Springs and Sheridan, Wyoming. Processed test results and all raw data captured during the
tests are forwarded to Chris Knott, P.Eng., Director of Engineering and Operations and/or
Charles Chapman, Manager of Technical Services, for quality control and data checking. Once
approved, tests are forwarded to the client.

2.2 Test Date

The unit will be tested by Oasis Emission Consultants, Inc. during the December 19th, 2023 –
22nd, 2023 test campaign.

2.3 Report Date

The compliance test report will be submitted no later than 60 days following the compliance test.

2.4 Emission Source Description

A summary of the unit to be tested is provided in the table below:

*The serial number will be provided in the final report, if currently unavailable.

Facility CAERS ID Well Latitude /
Longitude
Engine Serial
Number*
HP
Skoufos Tribal 4-27-34-3-1W-H1,
13, 14-22-15-3-1W-H3, RP Tribal
27-31W-H6UB, H8UB, RP 22N-
31W-H7UB (Skoufos West)
4579 Skoufos Tribal 14-22-15-3-1W-H3 40.20109,
-109.9833
Ajax E-565 86705 40

2.4.1 Utah Administrative Code Rule R307-510-4 Standards

In accordance with the Utah Administrative Code Rule R307-510-4 from the Oil and Gas
Industry: Natural Gas Engine Requirements (510), testing will be conducted to show levels in
units of HC+NOx and CO (as g/BHp-hr).
2.4.2 EPA 40 CFR 60, Subpart JJJJ Standards

According to the requirements of EPA 40, CFR 60 Subpart JJJJ § 60.4233(d), non-emergency
stationary SI ICE manufactured after July 1st, 2008, and rated between 25 hp and 100 hp must
comply with the requirements of the standards for field testing listed in 40 CFR § 1048.101(c).
Under 40 CFR § 1048.101(c)(2) the HC + NOx standard is 3.8 g/KW-hr (2.8 g/BHp-hr) and the
CO standard is 6.5 g/kW-hr (4.8 g/BHp-hr). For natural gas-fueled engines, owners and operators
are not required to measure non-methane hydrocarbon emissions or total hydrocarbon emissions
to show that the engines meet the emission standards; that is, HC is assumed to equal zero.

Emission Measurement Methodologies:

The unit will be tested according to EPA 40 CFR 60 (A), Methods 1, 3A, 4, 7E, 10, 18, 19 and
25A. Method 18 grab bags will be utilized to account for Methane and Ethane contents for the
determination of NMNEHC. Emissions in terms of g/BHp-hr will be converted from ppm levels
using the formulae from the Wyoming/Colorado portable analyzer protocol and a BSFC factor
(BTU/BHp-hr). Three, one hour tests will be conducted on this engine.

Operating Parameters:

Operating parameters, where applicable, will be recorded for each 1 hour test which may include
engine rpm, air/fuel ratio setting(s), suction/discharge pressures, ect.

Engine Load Approximation:

Oasis Emission Consultants, Inc. will approximate the engine load using the measured process
parameters, such as gas throughput, suction/discharge pressure/temperature; by correlating the
intake manifold conditions with the engine manufacture heat balance data; or, the engine load.
Maximum Engine hp HC+NOX CO
Equal to or greater than 25 hp
and < 100 hp
2.83 g/BHp-hr 4.85 g/BHp-hr
Maximum Engine Power NOX CO
Greater than 19 KW (25 hp)
and less than 75 KW (100)
(except gasoline and rich burn
engines that use LPG)
2.8 g/BHp-hr
(3.8 g/kW-hr)
4.8 g/BHp-hr
(6.5 g/kW-hr)
It is expected that the performance test will be conducted within ±10% of 100% peak, or the
highest achievable load.

Test Methods:

All EPA test methods that we intend to utilize are listed below.

 EPA 40 CFR 60 Appendix A, Method 1: Method 1 requires measurement of the various
physical attributes of a stack to establish appropriate sampling locations. An O2 stratification
check will be performed according to 8.1.2 of Method 7E prior to testing to determine
sampling location for engines with stack diameters greater than 6 inches, but less than 12
inches. For stacks equal to or greater than 12 inches in diameter, if the sampling port
locations meet the minimum Method 1 criterion for distance from disturbances, sampling
may be conducted at three points. If sampling ports do not meet Method 1 criterion for
distance from disturbances, stacks equal to or greater than 12 inches in diameter will have an
O2 stratification check performed to determine sampling locations. An O2 stratification is not
required for engines with a stack diameter less than 4 inches.
 EPA 40 CFR 60 Appendix A, Method 3A: O2 measurements will be conducted using an
instrumental analyzer according to Method 3A. The O2 levels will be used in conjunction
with Method 19 to determine the overall exhaust effluent flow.
 EPA 40 CFR 60 Appendix A, Method 4: Method 4 allows for the evaluation of the
moisture content within the effluent stream. A sample of the effluent stream is extracted at a
constant rate. The water is condensed from the stream through a series of impingers
surrounded by an ice bath. The total mass of the water condensed and the total volume of gas
measured are used to calculate the moisture content within the exhaust effluent stream.
 EPA 40 CFR 60 Appendix A, Method 7E: Method 7E is the instrumental method for
measuring the NOx concentration in the effluent stream. After passing through a sample
conditioning system, NOx concentration is measured by a chemiluminescent gas analyzer.
The analyzer is calibrated using EPA Protocol G1 gas before and after each one hour test
run.
 EPA 40 CFR 60 Appendix A, Method 10: Method 10 is the instrumental method for
measuring the CO concentration in the effluent stream. After passing through a sample
conditioning system, CO concentration is measured by a NDIR gas analyzer. The analyzer is
calibrated using EPA Protocol G1 gas before and after each one hour test run.
 EPA 40 CFR 60 Appendix A, Method 18: Method 18 employs an integrated grab bag
sampling system. Method 18 will be utilized to account for Ethane and Methane
concentrations to determine NMNEHC.
 EPA 40 CFR 60 Appendix A, Method 19: The BSFC factor and the measured Oxygen
content will be used to arrive at the overall exhaust effluent flow.
 EPA 40 CFR 60 Appendix A, Method 25A: Total Hydrocarbons will be measured on a hot-
wet basis by using a Flame Ionization Analyzer. This analyzer will be calibrated using EPA
Protocol G1 Propane (C3) gas before and after each one hour test run.