DAQ-2024-010846

1

DAQC-964-24
Site IDs 101842, 101843 (B4)

MEMORANDUM

TO: STACK TEST FILE – OVINTIV USA, INC. – Colorow East 15-8-4-2 and
Knoll 15-9-4-2

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

FROM: Paul Bushman, Environmental Scientist

DATE: September 24, 2024

SUBJECT: Sources: Colorow East 15-8-4-2: Two (2) Doosan 21.9L; SN’s: EZYOF903692,
EEYOF400694; Knoll 15-9-4-2: Two (2) Doosan 21.9L; SN’s:
EZYOF802467, EZYOF904249
Location: Duchesne County, UT
Contact: Ryan Zillner: 720-876-3144
Tester: Oasis Emission Consultants, Inc.
Site ID #: 101842, 101843
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol dated September 24, 2024

On September 24, 2024, DAQ received the protocol for the testing of four (4) Doosan 21.9L engines at
Colorow East 15-8-4-2 and Knoll 15-9-4-2 in Duchesne County, UT. Testing will be performed during
the week of October 28, 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. 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 the dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content within the gas stream: OK
5. RM 7E used to determine NOx emissions: OK
6. RM 10 used to determine CO emissions: OK
7. RM 19 used to determine exhaust effluent flows and mass emission rates: OK
8. RM 25A used to determine VOC emissions: OK
9. RM 320 used to determine H2O, NOx, CO, and VOC emissions: OK

2

DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Ovintiv pretest protocol and notice of testing date.

09/24/2024

VIA Stack Test Report Submission:
https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh

Rik Ombach
Manager, Minor Source Compliance
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

RE: Notification of Performance Testing
Ovintiv USA Inc.
Duchesne County

Dear Mr. Ombach:

Ovintiv USA Inc. is providing notification of performance testing for the spark ignition internal combustion
engines that satisfy the following requirements for which the engines are subject:
• 40 CFR Part 60 Subpart JJJJ: 40 CFR §60.8 and §60.4243(b)(2)(i) initial test or
§60.4243(b)(2)(ii) initial test or subsequent test every 8,760 hours or 3 years, whichever
comes first; and
• Permit by Rule

Facility Latitude/
Longitude
CAERS
Source
ID
Unit ID Manufacturer
& Model
Serial
Number
Performance
Test Scheduled
Date
Knoll 15-9
4-2
40.143107,
-110.112885 101843
22-17-058 Doosan
21.9L EZYOF802467 Week of
10/28/2024
22-18-167 Doosan
21.9L EZYOF904249 Week of
10/28/2024
Colorow UT
15-8 4-2
40.143102,
-110.131823 101842
22-19-175 Doosan
21.9L EZYOF903692 Week of
10/28/2024
22-18-280 Doosan
21.9L EEYOF400694 Week of
10/28/2024

The performance testing protocol is attached. If you have any questions, please contact me at 720-876-
3144 or [e-mail].

Sincerely,
Ryan Zillner
Senior Air Quality Engineer

Attachment

Utah Department of Environmental Quality
Division of Air Quality / US EPA

EPA 40 CFR 60, Subpart JJJJ
& Applicable State / Permit Requirements
Compliance Test Protocol

Ovintiv USA Inc.
Facilities Located In
Utah

September 9, 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 source
emission testing for Ovintiv USA Inc. by Oasis Emission Consultants, Inc.

1.1 TEST PROGRAM ORGANIZATION

Client: Ovintiv USA Inc.

Contact: Ryan Zillner, Senior Air Quality Engineer
Email: [e-mail]
Phone: [phone]

Test Company: Oasis Emission Consultants, Inc.

Address: 2730 Commercial Way
Rock Springs, WY 82901
Contact: Chris 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

EPA Authority: Office of Enforcement, EPA Region VIII
Address: 8ENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129
Contact: Alexis North, Environmental Scientist
Email: [e-mail]
Phone: [phone]

Contact: Michael Stovern
Email: [e-mail]
Phone: [phone]

R8AirReportEnforcement Region Email:
[e-mail]

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 Report Date(s)

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

2.3 Emission Source Limitations:

The source(s) will be tested according to methodologies described in this protocol. Any emission
levels which, based on averaged levels, exceed the applicable State / permitted limitations and/
or EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ) standards will be flagged in the test report(s).
Relevant information is provided in the tables below.

2.3.1 EPA 40 CFR 60, Subpart JJJJ Standards

Engine Type &
Fuel
Maximum Engine
Power
Manufacture
Date
Emission Standard
g/BHp-hr ppmvd @ 15% O2
NOx CO VOC NOx CO VOC
Non-Emergency SI
Natural Gas and
Non-Emergency SI
Lean Burn LPG
100 ≤ HP < 500
July 1, 2008 2.0 4.0 1.0 160 540 86
January 1,
2011 1.0 2.0 0.7 82 270 60
Non-Emergency SI
Lean Burn Natural
Gas and LPG
500 ≤ HP < 1,350
January 1,
2008 2.0 4.0 1.0 160 540 86
July 1, 2010 1.0 2.0 0.7 82 270 60
Non-Emergency SI
Natural Gas and
Non-Emergency SI
Lean Burn LPG
(Except Lean Burn
500 ≤ HP < 1,350)
HP ≥ 500
July 1, 2007 2.0 4.0 1.0 160 540 86
July 1, 2010 1.0 2.0 0.7 82 270 60
Emergency 25 < HP < 130 January 1,
2009
10 (NOx +HC) 387 N/A N/A N/A N/A
HP ≥ 130 2.0 4.0 1.0 160 540 86

The stationary non-certified SI engines will be tested according to EPA 40 CFR 60, Subpart JJJJ
§60.4244 for nitrogen oxides (NOx), carbon monoxide (CO) and Volatile Organic Compounds
(VOC). The test reports will show results in accordance with NSPS 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).

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.

2.3.1 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 on engines equal to or greater than 25
hp and less than 100 hp will be conducted to show levels in units of HC+NOx and CO (as
g/BHp-hr).

2.3.3 UDEQ Permitted Limits

The source(s) will be tested to show compliance with applicable UDEQ permitted limits.

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)
Maximum Engine hp NOX CO VOC HC+NOX
≥ 25 hp and < 100 hp --- 4.85 g/BHp-hr --- 2.83 g/BHp-hr
≥ 100 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
2.4 Testing Methodology and Procedures

Emission Test Procedures:

NOx, CO & VOC (NCV)-

FTIR:

Methods 1-3:

Three, one hour tests will be conducted 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.

Method 19:

Three, one hour tests will be conducted according to EPA 40 CFR 60 (A), Methods 1, 19 and
EPA 40 CFR 63 (A), Method 320 for NOx, CO, VOC (as NMNE HC C3) & H2O. Oxygen will
be measured using ASTM Method D6522-00(2005). 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).

CEMS:

Methods 1-4:

Three, one hour tests will be conducted according to EPA 40 CFR 60 (A), Methods 1-4, 7E, 10
& 25A with a Hydrocarbon Cutter. Additionally, Method 18 may also be employed to account
for Ethane levels.

Method 19:

Three, one hour tests will be conducted according to EPA 40 CFR 60 (A), Methods 1, 3A, 4, 7E,
10, 19 & 25A with a Hydrocarbon Cutter. 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). Additionally, Method 18 may also be employed to account for
Ethane levels.

Utah Administrative Code Rule R307-510-4 for Engines Greater Than or Equal to 25 hp and
Less Than 100 hp:

Three, one hour tests will be conducted 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).

FTIR Emission Measurement Methodologies:

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 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 Dr. Spartz and 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:

Engine operating parameters, where applicable, will be recorded for each test.

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; the engine load; or the
reading obtained from the engine panel.

Test Methods:

All test methods are described below and will be utilized as applicable.

FTIR:

 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 or equal to 6 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.
 ASTM D6522-00(2005): ASTM D6522-00(2005) will be used to measure the exhaust gas
Oxygen content. The O2 levels may be used in conjunction with Method 19 to determine the
overall exhaust effluent flow.
 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 63 (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.

CEMS:

 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 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 a stack
diameter less than or equal to 6 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 3A: Method 3A provides the means to calculate the
dry molecular weight of the effluent gas. After passing through a gas condenser, Oxygen &
CO2 gas concentrations from the effluent stream are measured by an instrumental analyzer.
Measurements may be taken in conjunction with those from Method 2. The dry molecular
weight will be calculated for each of the test runs. The O2 levels may 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.
Moisture content will be calculated for each of the runs.
 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 may be used to determine the Ethane
concentration. Method 18 will be utilized to account for Ethane and Methane concentrations
to determine NMNEHC for engines that are subject to Utah Administrative Code Rule R307-
510-4 and that are greater than or equal to 25 hp and less than 100 hp. Method 18 employs an
integrated grab bag sampling system.
 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.
 ASTM D6522-00(2005): ASTM D6522-00(2005) will be used to measure the exhaust gas
Oxygen content. The O2 levels may be used in conjunction with Method 19 to determine the
overall exhaust effluent flow.