DAQ-2024-010888

1

DAQC-1040-24
Site ID 15513 (B4)

MEMORANDUM

TO: STACK TEST FILE – CITATION OIL & GAS CORPORATION – Pineview Tank
Battery and Gas Plant

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

FROM: Paul Bushman, Environmental Scientist

DATE: October 9, 2024

SUBJECT: Source: One (1) 800 hp White Superior 8G825 (ENG 1 – North)
Location: 3604 East Chalk Creek Road, Coalville, Utah
Contact: Ron Schultz: 281-891-1559
Tester: Oasis Emissions Consultants, Inc.
Site ID #: 15513
Permit/AO #: Approval Order (AO) DAQE-AN155130002-22 dated August 15, 2022
Subject: Review of Pretest Protocol dated October 7, 2024

On October 9, 2024, Utah Division of Air Quality (DAQ) received a test notification for the testing of one
(1) 800 hp White Superior 8G825 (ENG 1 – North) located at Pineview Tank Battery and Gas Plant,
Summit County, Utah. Testing will be performed December 12, 2024, to determine compliance with the
emission limits found in condition II.B.6.c of AO DAQE-AN155130002-22, and 40 CFR 63, Subpart
ZZZZ.

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 used to determine dry molecular weight of the gas stream: OK
4. RM 320 used to determine NOx, CO, and VOC emissions: OK

DEVIATIONS: No deviations stated in the protocol.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice.

ATTACHMENTS: Citation Oil & Gas Corporation pretest protocol and test notification.

14077 Cutten Road ꞏ Houston, TX 77069-2212 ꞏ 281.891.1000

October 08, 2024

Ms. Alexis North Via E-mail: [e-mail]
Office of Enforcement
US EPA Region 8
8ENF-AT
1595 Wynkoop Street
Denver, CO 80202-1129

Mr. Rik Ombach Via Website: https://utahgov.co1.qualtrics.com/jfe/form/SV_3dSxf7JSzy4jwGh
Minor Source Compliance Manager
Permitting and Compliance Division
P.O. Box 144820
Salt Lake City, UT 84114-4820

Dear Mr. Ombach and Ms. North:

SUBJECT: SOURCE TEST NOTIFICATION AND PROTOCOL SUBMISSION
CITATION OIL & GAS CORP.
PINEVIEW TANK BATTERY AND GAS PLANT
PERMIT #DAQE-AN155130002-22
SUMMIT COUNTY, UTAH

In order to demonstrate compliance with UDAQ Permit # DAQE-AN155130002-22 and EPA 40
CFR 63, Subpart ZZZZ, Citation Oil & Gas Corp. (Citation) has requested Oasis Emission
Consultants, Inc. (Oasis) to perform source emission testing on one (1) 800 hp White Superior
8G825 engine (ENG 1 – North) located at Citation’s Pineview Tank Battery and Gas Plant near
Coalville in Summit County, Utah.

The White Superior 8G825 engine is designated as existing, non-emergency, 4SRB stationary
RICE > 500 HP located at an area source of HAP that is not remote and operates more than 24
hours per calendar year. As such, the engine is being tested to demonstrate compliance with the
nitrogen (NOx) and carbon monoxide (CO) performance testing requirements of the UDEA
approval order (DAQE-AN155130002-22). In addition, the engine is being tested in accordance
with the provisions of RICE MACT EPA 40 CFR 63, Subpart ZZZZ (NESHAP ZZZZ). Testing
will be conducted to demonstrate compliance with the EPA CO standard of 270 ppmvd @ 15%
O2.

Page 2 of 2
Source Test Notification & Protocol Submission
Pineview Tank Battery & Gas Plant
October 08, 2024
14077 Cutten Road ꞏ Houston, TX 77069-2212 ꞏ 281.891.1000

Oasis is scheduled to conduct the performance testing on the White Superior 8G825 engine on
Thursday, December 12, 2024. We expect to complete all testing within one (1) day.

As indicated in the permit (DAQE-AN155130002-22), two additional 800 hp White Superior
compressor engines (ENG 2 and Recip (South)) are located at this site and are subject to the same
State and Federal performance testing requirements. However, both of these engines are currently
out of service or are inoperable at this time. Therefore, emission testing for these two engines is
not scheduled at this time. If Citation decides to bring these engines back into service, performance
testing will be conducted prior to operation.

Attached is a Source Test protocol for your review.

If you have any questions or require further information, please contact me at [phone] or
via e-mail at [e-mail]

Very truly yours,
R J Redweik
Robert J. Redweik
VP – EHS and Regulatory

Attachment: Source Test Protocol

UDEQ/EPA
Source Test Protocol

Approval Order: DAQE-AN155130002-22

Unit ID: ENG1 (North)

Citation Oil & Gas Corporation
Pineview Tank Battery and Gas Plant,
Summit County, Utah

October 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 periodic source
emission testing at Citation Oil & Gas Corporation’s Pineview Tank Battery and Gas Plant (Unit ID: ENG1
(North)), in Summit County, Utah. Emissions testing will be conducted in accordance with the UDEQ DAQ
Approval Order # DAQE-AN155130002-22 (Issuance Date: August 15, 2022) and EPA 40 CFR 63, Subpart
ZZZZ (NESHAP ZZZZ). Testing will be conducted by Oasis Emission Consultants, Inc.

1.1 Test Program Organization

Approval Order: DAQE-AN155130002-22

Federal Regulations: EPA 40 CFR 63, Subpart ZZZZ
Pineview Tank Battery and Gas Plant Unit ENG1 (North) is located at an area
source of HAP emissions. The engine is being tested according to the requirements of the National Emission Standards for Hazardous Air Pollutants
for Reciprocating Internal Combustion Engines (NESHAP) – 40 CFR Part 63, Subpart ZZZZ.

Facility / Location: Pineview Tank Battery and Gas Plant (Site ID: 15513)
The facility is located at 3604 East Chalk Creek Road in Coalville,
in Summit County, Utah.
UTM Coordinates: 487,342 m Easting, 4,531,757 m Northing,
UTM Zone 12

Emission Source(s): Unit ID: ENG1 (North) – White Superior 8G825
One (1) natural gas fired, non-emergency, 4-stroke rich burn (4SRB) White
Superior 8G825 stationary reciprocating internal combustion engine (RICE) rated at 800 horsepower (hp).
Client Owner / Operator: Citation Oil & Gas Corporation

Address: 14077 Cutten Road Houston, TX 77069-2212
Contact: Ron Schultz, Manager Regulatory Compliance
Email: [e-mail]
Office: [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]

1.2 TEST PROJECT OBJECTIVE(S)

The purpose of the emission compliance demonstration is to satisfy the requirements of UDEQ
DAQ Approval Order # DAQE-AN155130002-22 (Issuance Date: August 15, 2022) and EPA
40 CFR 63, Subpart ZZZZ. Testing on the engine to show compliance with the UDEQ DAQ
Approval Order # DAQE-AN155130002-22 and EPA 40 CFR 63, Subpart ZZZZ will be
conducted concurrently.

As required by UDEQ DAQ Approval Order # DAQE-AN155130002-22 Conditions II.B.6.c
through II.B.6.c.2, three (3) separate one (1) hour test runs will be conducted on the 4SRB 800
hp White Superior 8G825 engine (Unit ID: ENG1 (North)) to demonstrate compliance with nitrogen oxides (NOx) and carbon monoxide (CO) limitations. The test for NOx and CO will be
performed using EPA Reference Methods 1-3 and EPA 40 CFR 63 (A), Method 320. Results
from the UDEQ DAQ Approval Order # DAQE-AN155130002-22 compliance test will be reported in units of pounds per hour (lb/hr).

The White Superior 8G825 stationary RICE is an affected source equipped with a non-selective
catalytic reduction (NSCR) convertor located at an area source of HAP emissions. The engine is
being tested according to EPA 40 CFR 63, Subpart ZZZZ requirements for engines at an area
source that are considered not remote. As stipulated by Table 6 Condition 15 to Subpart ZZZZ
of Part 63, testing will be conducted to demonstrate that the average CO concentration for the
White Superior 8G825 engine is less than or equal to 270 ppmvd @ 15% O2. The engine will be
tested with the FTIR (EPA 40 CFR 63 (A), Method 320) at the outlet for the measurement of
CO.
1.3 Facility Description

Citation Oil & Gas Corporation (Citation) operates a crude oil and natural gas tank battery and
gas plant at the Pineview Facility. At the tank battery, crude oil, natural gas and produced water
are processed from an emulsion stream extracted from wells using electric submersible pumps
and pumping units. Fluid from the wellheads enters a separator where the oil and water are
separated from gas. The separated gas is sent to the adjoining gas plant. The liquids from the
separators are routed to crude oil and produced water storage tanks at the lower portion of the
tank battery. Emissions from the crude oil storage tanks are controlled by a flare. The crude oil
is sent off site via truck loading while the produced water is piped for off-site injection within
the field. Gas is routed to the gas plant. This facility will process up to 146,000 barrels (1 barrel
= 42 gallons) of crude oil per year.

Produced water from the separator is stored on-site at the upper portion of the tank battery
before being shipped off-site through a flowline for injection.

The gas plant processes up to 532.2 million standard cubic feet of natural gas per year. The gas
plant treats the field gas using glycol and a separator to remove any left-over liquids. The gas is
then cooled and compressed for storage in bullet tanks before being piped to the sales point for
truck loading.

The compliance test will be conducted on the 800 hp White Superior 8G825 natural gas fired,
rich-burn engine (Unit ID: ENG1 (North)) that drives a compressor.

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. on December 12th, 2024. We expect
to complete all testing within a one (1) day time frame.

2.3 Report Date

The test report will be submitted to Citation Oil & Gas Corporation no later than 60 days
following the test.

2.4 Testing Methodology And Procedures

A summary of the unit to be tested is provided below.

Approval Order # Unit ID Make &
Manufacturer
Serial
Number
Engine
HP
Max
Allowable
Nitrogen
Oxide (NOx)
lb/hr
Max Allowable
Carbon
Monoxide (CO)
lb/hr
DAQE-AN155130002-22 ENG1 (North) White Superior
8G825
270349 800 0.661 1.022

2.4.1 EPA 40 CFR 63, Subpart ZZZZ

Unit ID Make &
Manufacturer
Serial
Number
Engine
HP
EPA CO Standard
ENG1 (North) White Superior
8G825
270349 800 270 ppmvd @ 15% O2

The White Superior 8G825 engine is an existing non-emergency 4SRB RICE > 500 HP located
at an area source of HAP and is operated more than 24 hours per calendar year. Testing will be
conducted to demonstrate that the average CO concentration for the White Superior 8G825
engine is less than or equal to 270 ppmvd @ 15% O2.

Emission Measurement Methodologies:

Testing on the White Superior 8G825 compressor engine (Unit ID: ENG1 (North)) will consist
of three one hour tests post catalyst according to EPA 40 CFR 60 (A), Methods 1-3 and EPA 40
CFR 63 (A), Method 320 for NOx and CO. Oxygen levels will be measured to allow for the
correction of CO to 15% O2.

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 (ie. 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 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.

Stack Sampling Location

The inner exhaust stack diameter for the White Superior 8G825 engine will be measured by the
Oasis Emission Consultants, Inc. Compliance Specialist during the compliance test and will be
verified to meet the minimum specifications of a sampling location as defined by EPA Method
1. An aerial lift will be utilized, if needed, to conduct sampling.

Figure 2: Sample Location Diagram.

Engine Operating Parameters:

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

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 engine will be tested at 90%-110% of the site rated load.

Catalyst Parameters:

Oasis will record the catalyst parameters (i.e. catalyst inlet temperature and the pressure drop
across the catalyst) during each test.

Test Methods:

All 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.
 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 (Method 4), 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. The O2 levels will also be
used for the correction to 15% O2.
 EPA 40 CFR 63 (A), Method 320: NOx, CO and 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.