DAQ-2024-004353

1

DAQC-1292-23
CAERS ID: 101697 (B4)

MEMORANDUM

TO: STACK TEST FILE – UINTA WAX OPERATING, LLC – RP Tribal 23N-31W-
H2UB, 24N-31W-H6UB, H8UB Tank Battery – Uintah County

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: November 28, 2023

SUBJECT: Source: One (1) Cummins KTA19GC Engine; SN: 37264705
Location: Remote Locations in Uintah County, Utah
Contact: Karen Pratt: [phone]
Tester: Oasis Emissions Consultants, Inc.
Site ID #: 101697
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol dated November 27, 2023

On November 28, 2023, Utah Division of Air Quality (DAQ) received a protocol for the testing of one (1)
Cummins KTA19GC Engine at RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB Tank Battery in
Uintah County, Utah. Testing will be performed December 19–22, 2023, to determine compliance with
the emission limits found in Utah Administrative Code R307-510 and 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 27, 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 RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB (Buster
Pad) / Buster Pad in Uintah County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 380 horsepower (hp) Cummins KTA19GC engine located at Uinta Wax Operating,
LLC’s RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB (Buster Pad) / Buster Pad (CAERS
ID # 101697) in Uintah 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) Cummins KTA19GC

Facility: RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB
(Buster Pad) / Buster Pad

Uinta Wax Operating, LLC
≥ 100 HP Engine
In Uintah County, Utah

November 27, 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 stationary engine rated ≥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: RP Tribal 23N-31W-H2UB, 24N-31W-H6UB, H8UB (Buster Pad) /
Buster Pad
Latitude: 40.2001 Longitude: -109.954

CAERS ID: 101697

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 RP Tribal 23N-31W-H2UB, 24N-
31W-H6UB, H8UB (Buster Pad) / Buster Pad (CAERS ID # 101697) in Uintah 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.

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 Name Facility
Name 2
Engine Serial
Number
HP RICE
Configuration
Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
RP Tribal 23N-31W-H2UB,
24N-31W-H6UB, H8UB
(Buster Pad)
Buster Pad Cummins
KTA19GC
37264705 380 4SRB 3/5/2015 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

Emission Measurement Methodologies:

The unit will be tested for three, one hour test runs according to EPA 40 CFR 60 (A), Methods 1,
3A, 4, 7E, 10, 18, 19 and 25A with a Hydrocarbon Cutter. Method 18 may also be employed to
account for Ethane levels. 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).

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.

It is expected that the performance tests 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 (Optional): Method 18 employs an integrated
grab bag sampling system. Method 18 may be utilized to account for the Ethane
concentration 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: Non – Methane Hydrocarbons will be
measured on a hot-wet basis by using a Flame Ionization Analyzer equipped with a
Hydrocarbon Cutter. The FID analyzer will measure levels of both THC and Methane. The
NMHC levels are automatically measured and output by the analyzer by subtracting the
measured Methane levels from the Total Hydrocarbon levels. This analyzer will be calibrated
using EPA Protocol G1 Propane (C3) gas before and after each one hour test run.