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Home My WebLink AboutDAQ-2024-0074641 DAQC-115-24 Site ID: 101763 (B4) MEMORANDUM TO: STACK TEST FILE – XCL RESOURCES – Denning #29-4A-23 – Protocol Review and Test Date Confirmation – Duchesne County THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: February 7, 2024 SUBJECT: Source: One (1) Caterpillar G3508; SN: RBK01585 and One (1) Waukesha 5794GSI; SN: C-17709/1 Location: Duchesne County, Utah Contact: Lauren Brown: 713-808-9406 Tester: Oasis Emissions Consultants, Inc. Site ID: 101763 Permit/AO #: Permit by Rule Subject: Review of Pretest Protocol dated June 27, 2023 On February 7, 2024, Utah Division of Air Quality (DAQ) received a protocol for one (1) Caterpillar G3508 and one (1) Waukesha 5794GSI at the Denning #29-4A-23 production facility in Duchesne County, Utah. Testing will be performed on March 11, 2024, 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 2 used to determine exhaust flows of the effluent gas stream; OK 3. Method 3 used to determine O2 and CO2 concentrations of the effluent gas stream; OK 4. Method 320 used to determine NOx, CO, VOC, and H2O of the effluent gas stream; OK DEVIATIONS: None stated in the protocol. CONCLUSION: The protocol appears to be acceptable. RECOMMENDATION: The test methods stated in the protocol are sufficient to determine NOx, CO, and VOC emission rates. ATTACHMENTS: XCL Resources notification letter and pretest protocol. February 7, 2024 Rik Ombach Minor Source Compliance Manager PO Box 144820 Salt Lake City, UT 84114-4820 RE: NSPS JJJJ Compliance Test Notification and Protocol Submission For the XCL Resources’ Denning #29-4A-23 (No. 1 & No. 2) in Duchesne County, Utah Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on one (1) 690 horsepower (hp) Caterpillar G3508 lean burn engine and one (1) 1,380 hp Waukesha 5794GSI rich burn engine located at XCL Resources’ Denning #29-4A-23 (CAERS Source ID: 101763) in Duchesne County, Utah (Latitude: 40.27717975, Longitude: -110.2431165). The tests will be conducted in accordance with EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ). A summary of the units and details of our testing procedures can be found in the attached protocol. The engines have been scheduled with the client for Monday, March 11th, 2024. If you have any questions or concerns, please contact the undersigned at (307) 382-3297. 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 Federal Regulation: EPA 40 CFR 60, Subpart JJJJ Engines: (1) Caterpillar G3508 & (1) Waukesha 5794GSI XCL Resources Pad: Denning #29-4A-23, In Duchesne County, Utah February 7, 2024 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 XCL Resources by Oasis Emission Consultants, Inc. The engines are greater than or equal to 500 hp and are being tested according to the requirements set out by EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ). 1.1 TEST PROGRAM ORGANIZATION Federal Regulation: EPA 40 CFR 60, Subpart JJJJ Pad: Denning #29-4A-23 CAERS ID: 101763 Client: XCL Resources (c/o Peakview Environmental LLC) Contact: Julie Spear , P.E., Principal Engineer Email: julie@juliespear.com Cell.: (720) 334-3001 Test Company: Oasis Emission Consultants, Inc. Address: 2730 Commercial Way Rock Springs, WY 82901 Contact: Christopher Knott, P.Eng., Director, Engineering & Operations Phone: (307) 382-3297 Fax: (307) 382-3327 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: rombach@utah.gov Phone: (801) 536-4164 Stack Test Report Submission: https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh 1.2 Test Project Objective(s) The engines at XCL Resources’ Denning #29-4A-23 (No. 1 & No. 2) are being tested to demonstrate compliance with the standards and test requirements listed by 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 units will be tested by Oasis Emission Consultants, Inc. on March 11th, 2024. 2.3 Report Date The compliance test reports will be submitted no later than 60 days following the compliance tests. 2.4 Emission Source Description A summary of the units to be tested is provided in the table below: 2.5 Standards and Limits The test reports will show results in accordance with NSPS Subpart JJJJ Table 1 and Table 1 Footnote a. Footnote a allows owners and operators of stationary non-certified SI engines to choose to comply with the NSPS JJJJ standards in units of either grams per brake-horsepower hour (g/BHp-hr) or units of parts per million volume dry standardized to 15% oxygen (ppmvd @ 15% O2). NOx, CO and VOC results from the compliance tests will be reported in g/Bhp-hr. Pad Latitude / Longitude CAERS Source ID Unit Number Engine Serial Number HP RICE Configuration Mfg. Date Denning #29-4A-23 (No. 1) 40.27717975, -110.2431165 101763 806743 Caterpillar G3508 RBK01585 690 4SLB 3/15/2015 Denning #29-4A-23 (No. 2) MC3000 Waukesha 5794GSI C-17709/1 1,380 4SRB 2/11/2008 Pad CAERS Source ID Unit Number Engine Serial Number HP NOX Standard CO Standard VOC Standard Denning #29-4A-23 (No. 1) 101763 806743 Caterpillar G3508 RBK01585 690 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr Denning #29-4A-23 (No. 2) MC3000 Waukesha 5794GSI C-17709/1 1,380 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr 2.6 Emission Measurement Methodologies: Three, one hour tests will be conducted on each engine according to EPA 40 CFR 60 (A) Methods 1-3 & EPA 40 CFR 63 (A) Method 320 for NOx, CO, VOC (as NMNEHC C3) and H2O. Each of the test runs will consist of readings taken at one (1) minute intervals. Oxygen & CO2 will be measured using a Fyrite analyzer. The MKS 2030 analyzer will be operated using a 0.5 cm-1, Medium Norton Beer Apodization and 60 second averaging. Based on the compounds that will be measured, the MKS 2030 analyzer has been configured in the following manner, which is intended to cover all types of natural gas fired engines. The MKS 2030 software provides a Natural Gas Method that is designed to minimize all expected interferences by removing the regions in the quant region where they are most absorbed (i.e. picket fence approach). So, for example, all the water peaks that are greater than about 0.1 abs are removed from the quant region. Since the spectral noise measured (sample spectrum) is in the range of 0.001 absorbance, it is desirable to have any error within this range. The MKS software will match the water calibration spectrum to the sample spectrum at any 1 point in the spectrum to about 1% precision. So, 1% of 0.1 absorbance is 0.001 abs. This is why any peaks greater than this for interfering compounds are usually excluded so they do not interfere. To summarize, the MKS software and the method are designed to minimize any interferences by removing their largest interfering absorptions. QA spiking procedures will be followed for pre and/or post testing. Various factors often make determining the exact concentrations for spiking procedures indiscernible prior to testing, even if the engine has been previously tested. Furthermore, it is infeasible to obtain and transport a multitude of gas concentrations for varying analytes. Therefore, a mixed gas bottle with a high enough concentration for multiple engines may be utilized during the spiking procedures. A summary of all spiking procedures/results will be provided in the final test reports. The CO2 present in the native sample will be used as the tracer. There are two components that make up the spike: 90% native and 10% spike. Both the native and spike are being added to the gas cell and measured simultaneously. Since the CO2 concentration for most engines is very stable during testing, the reduction in its concentration when a spike is applied can provide very accurate prediction on the ratio of spike gas to engine emission. The schematic for our sampling system, which is the same as the system provided in Method 320, is shown below. The sampling system is used to draw the sample from the stack at an elevated temperature, remove particulates and push the gas through a secondary heated line into the MKS 2030 analyzer to maintain correct pressure and temperature. There is no reduction in water concentration or any other component. Figure 1: Schematic of FTIR Sampling System. The MKS Multigas 2030 FTIR system inherently converts the wet levels of NOx, CO & VOC to dry levels and displays the dry levels to the Compliance Specialist(s) via a computer display. The system is able to perform this conversion due to the FTIR also measuring the moisture content of the effluent stream. Therefore, it is the dry levels that are typically logged. Measurement of VOC (NMNEHC C3): The algorithm currently used for NMNEHC C3 and developed for natural gas fired applications by MKS instruments in accordance with EPA standards, is the following: (2.4*c8/(1+exp((2-c8)/0.2))+1.9*c11/(1+exp((2-c11)/0.2))+6*c12/(1+exp((0.5-c12) /0.2))+2.85*c13/(1+exp((2-c13)/0.2))+3*c14/(1+exp((1-c14)/0.2)))/3 c8= acetylene c11= ethylene c12= hexane c13= propylene c14= propane Note: The constants in front of each of the compounds listed represents the FID response factor when calibrated with Propane. As with any CEMS analyzer, the FTIR may demonstrate a negative zero bias. The “exp” functions listed in the algorithm above are intended to mathematically filter out any negative biases and set them to approach zero. 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. It is expected that the performance tests will be conducted within ±10% of 100% peak, or the highest achievable load. Test Methods: Oasis Emission Consultants, Inc. will employ EPA Method 320 for NOx, CO, VOC & H2O. Oxygen and CO2 levels in the exhaust stream will be monitored through the use of a Fyrite analyzer, concurrently with each FTIR test. All test methods that we intend to utilize are listed on the following page.  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 2: Method 2 provides the means to calculate the average wet velocity for the exhaust effluent gas. This method employs the use of a standard or S-type pitot tube, a thermometer and an inclined manometer. The temperature, static & differential pressures are all used to calculate the average wet velocity. This value may be used in conjunction with the known stack diameter, and measured moisture content, to approximate the average dry volumetric flow rate.  EPA 40 CFR 60 Appendix A, Method 3: Method 3 provides the means to calculate the dry molecular weight of the effluent gas. After passing through a gas condenser, O2 & CO2 gas concentrations from the effluent stream are measured by a Fyrite analyzer. Measurements will be taken in conjunction with those from Method 2. The dry molecular weight will be calculated for each of the test runs.  EPA 40 CFR 63 Appendix A, Method 320: NOx, CO, VOC & H2O concentrations are obtained by running the engine exhaust through a heated sample line (191 deg C) to an MKS 2030 FTIR analyzer. When a gas sample is introduced in the gas cell, the infrared beam is partially absorbed by the gas species present. The spectral frequencies absorbed and their intensity are due to the atoms associated with the chemical bond and the strength of that bond. The absorption spectrum is unique for each infrared-active gas. The MKS FTIR analyzer measures the absorption spectrum, and its analysis algorithm measures the concentration of each gas using pre-loaded calibrations. The MG2000 software allows for the continuous measurement, display and recording of the sample stream.