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Home My WebLink AboutDAQ-2025-0002161 DAQC-004-25 Site IDs: 100443, 6987, 8314, 101603, 101006, 4683, 100907, 101734, 101858, 101768, 101623, 101855, 101621, 101738, 8071, 14399, 101854, 102096 (B4) MEMORANDUM TO: STACK TEST FILE – JAVELIN ENERGY PARTNERS MANAGEMENT, LLC – 8-25-26-C5-3H MWF; Lake Fork Ranch 4-26-25-B4-4H MWF; Lake Fork Ranch 4-35-36-B4-1H MWF; Presbytery 1-15-16-C4-1H MWF; Remund 1-27-28-C4-1H MWF; 8-24-23-C5-2H MWF; Betts 1-34-33-C4-2H MWF; IWM 8/7-17/18-C4-1H; NORTH MOON 1; Park City 5-6-5-C4-3H MWF; Remund Ridge 16-22-21-C4-7H MWF; SOUTH MOON 05-31-32-C4-4H; Bluebell 16-24-23-C5-9H MWF; Ferrarini 12-26-25-B4-6H MWF; Goergen 9-13-14-C5-3H MWF; Hutchins-Chiodo 3-20C5; LFR SOUTH 27-28 B4; OLSEN 13-14-C5 MULTI-WELL FACILITY THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Paul Bushman, Environmental Scientist DATE: January 2, 2025 SUBJECT: Sources: Engines: (4) Caterpillar G3508, (4) Caterpillar G3516, (4) Waukesha 3524GSI, (2) Cummins KTA19GCE, (1) Caterpillar G3306B TA/LCR, (1) Waukesha 5794GSI, and (2) Cummins KTA19 Location: Remote location in Duchesne County, UT Contact: Jennifer McQueen: 720-705-8042 Tester: Oasis Emission Consultants, Inc. Site ID # 100443, 6987, 8314, 101603, 101006, 4683, 100907, 101734, 101858, 101768, 101623, 101855, 101621, 101738, 8071, 14399, 101854, 102096 Permit/AO #: PBR Subject: Review of Pretest Protocol dated December 22, 2024 On December 23, 2024, DAQ received a protocol for the testing of the above units at multiple locations in Duchesne County, UT. Testing will be performed during the January 27-29, 2025, February 3-7, 2025, and February 17-21, 2025, test campaigns, 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 used to determine the dry molecular weight of the gas stream: OK 4. RM 19 used to determine exhaust effluent flow: OK 2 5. RM 320 used to determine H2O, CO, NOx, and VOC emissions: OK 6. ASTM D6522-00 used to determine O2: 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: Javelin Energy Partners Management, LLC test notification letter and pretest protocol. December 22, 2025 Rik Ombach Minor Source Compliance Manager PO Box 144820 Salt Lake City, UT 84114-4820 RE: Compliance Test Notification and Protocol Submission For the Javelin Energy Partners Management, LLC’s Various Facilities in Duchesne County, Utah Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on four (4) 690 horsepower (hp) Caterpillar G3508, four (4) 1380 hp Caterpillar G3516, four (4) 840 hp Waukesha 3524GSI, two (2) 420 hp Cummins KTA19GCE, one (1) 203 hp Caterpillar G3306B TA/LCR, one (1) 1380 hp Waukesha 5794GSI and two (2) 380 hp Cummins KTA19 engines located at Javelin Energy Partners Management, LLC's Various Facilities in Duchesne County, Utah. The tests will be conducted in accordance with Utah Administrative Code Rule R307-510-4 and EPA 40 CFR 60, Subpart JJJJ (NSPS Subpart 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 the Monday, January 27th, 2025– Wednesday, January 29th, 2025; Monday, February 3rd, 2025 – Friday, February 7th, 2025; and Monday, February 17th – Friday, February 21st, 2025 test campaign. 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 Engines: (4) Caterpillar G3508, (4) Caterpillar G3516, (4) Waukesha 3524GSI, (2) Cummins KTA19GCE, (1) Caterpillar G3306B TA/LCR, (1) Waukesha 5794GSI & (2) Cummins KTA19 Javelin Energy Partners Management, LLC Various Facilities, In Duchesne County, Utah December 22, 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 Javelin Energy Partners Management, LLC by Oasis Emission Consultants, Inc. The engines are rated at ≥100 hp and are being tested according to the require- ments set out by the Utah Administrative Code Rule R307-510-4 and NSPS Subpart JJJJ. 1.1 TEST PROGRAM ORGANIZATION Facilities: 8-25-26-C5-3H MWF, Lake Fork Ranch 4-26-25-B4-4H MWF, Lake Fork Ranch 4-35-36-B4-1H MWF, Presbytery 1-15-16-C4-1H MWF, REMUND 26-25-C4 MULTI-WELL FACILITY, 8-24-23-C5-2H MWF, Betts 1-34-33-C4-2H MWF, IWM 8/7-17/18-C4-1H, NORTH MOON 1, Park City 5-6-5-C4-3H MWF, Remund Ridge 16-22-21-C4-7H MWF, SOUTH MOON 05-31-32-C4-4H, Bluebell 16-24-23-C5-9H MWF, Ferrarini 12-26-25-B4-6H MWF, Goergen 9-13-14-C5-3H MWF, Hutchins-Chiodo 3-20C5, LFR SOUTH 27-28 B4, & OLSEN 13-14-C5 MULTI-WELL FACILITY Site IDs: 100443, 6987, 8314, 101603, 4683, 100907, 101734, 101858, 101768, 101623, 101855, 101621, 101738, 8071, 14399, & 101854 Client: Javelin Energy Partners Management, LLC Contact: Jennifer McQueen, Principal Consultant – Air Quality Email: jmcqueen@slrconsulting.com Cell.: (720) 705-8042 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) Javelin Energy Partners Management, LLC’s facility engines are being tested to demonstrate compliance with the standards and test requirements listed by the Utah Administrative Code Rule R307-510-4 and NSPS 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 Dates The units will be tested by Oasis Emission Consultants, Inc. during the January 27th – 29th, 2025; February 3rd – 7th, 2025; and February 17th – 21st, 2025 test campaign. 2.3 Report Date The compliance test reports will be submitted no later than 60 days following the compliance tests. Emission Source Description A summary of the units to be tested is provided in the table below: Site ID Site Coordinates Unit Number Engine Serial Number HP RICE Configuration Mfg Date 100443 8-25-26-C5-3H MWF 40.19049, -110.3907 7471 Caterpillar G3508J ULB N8W00133 690 4SLB 12/20/2018 6987 Lake Fork Ranch 4-26-25- B4-4H MWF 40.27925, -110.31406 7224 Caterpillar G3508 ULB RBK01626 690 4SLB 10/21/2015 8314 Lake Fork Ranch 4-35-36- B4-1H MWF 40.26991, -110.31366 6532 Caterpillar G3508B RBK01279 690 4SLB 4/10/2013 101603 Presbytery 1-15-16-C4-1H MWF 40.22425, -110.311676 6978 Caterpillar G3516B N6W01508 1380 4SLB 9/27/2019 REMUND 26-25-C4 MULTI-WELL FACILITY 40.19539, -110.31202 7756 Caterpillar G3516J ULB N6W01573 1380 4SLB 11/3/2021 4683 8-24-23-C5-2H MWF 40.20622, -110.387634 6995 Caterpillar G3516B ULB N6E00129 1380 4SLB 2/16/2015 100907 Betts 1-34-33-C4-2H MWF 40.18052, -110.31182 4354 Caterpillar G3508 TA/LE 9TG00082 690 4SLB 11/15/1995 101734 IWM 8/7-17/18-C4-1H 40.22548, -110.349236 76716 Waukesha 3524GSI WAU-1681921 840 4SRB 4/11/2023 101858 NORTH MOON 1 40.25548, -110.39102 76775 Waukesha 3524GSI 5283705602 840 4SRB 3/6/2018 101768 Park City 5-6-5-C4-3H MWF 40.24938, -110.391205 806932 Caterpillar 3516J N6W/4EK00736 1380 4SLB 11/27/1995 101006 101623 Remund Ridge 16-22-21- C4-7H MWF 40.20591, -110.308975 74347 Waukesha 3524GSI C-13890/1 840 4SRB 8/20/2001 101855 SOUTH MOON 05-31-32- C4-4H 40.17886, -110.38487 MC2087 Waukesha 5794GSI 5283700013 1380 4SRB 3/23/2009 101621 Bluebell 16-24-23-C5-9H MWF 40.19806, -110.39149 7926 Cummins KTA19GCE 37288722 420 4SRB 9/30/2022 101738 Ferrarini 12-26-25-B4-6H MWF 40.27488, -110.314316 5913 Caterpillar G3306B TA/LCR R6S00415 203 4SRB 12/5/2012 8071 Goergen 9-13-14-C5-3H MWF 40.21952, -110.387535 6317 Cummins KTA19GC 37237077 380 4SRB 8/19/2008 14399 Hutchins-Chiodo 3-20C5 40.2009, -110.46794 806994 Cummins KTA19 37276899 380 4SRB 11/5/2018 101854 LFR SOUTH 27-28 B4 40.27523, -110.309204 77023 Waukesha 3524GSI WAU-1681926 840 4SRB 5/22/2023 - OLSEN 13-14-C5 MULTI- WELL FACILITY 40.21534, -110.3832 7748 Cummins KTA19GCE 37285242 420 4SRB 8/23/2021 *The serial numbers will be provided in the final test reports, if currently unavailable. In accordance with the Utah Administrative Code Rule R307-510-4 from the Oil and Gas Industry: Natural Gas Engine Requirements (510) and EPA 40 CFR 60, Subpart JJJJ (NSPS JJJJ), testing will be conducted to show compliance with (NOx), carbon monoxide (CO) and Volatile Organic Compounds (VOC) standards on a grams per brake-horsepower hour (g/Bhp-hr) basis. NSPS JJJJ 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 g/Bhp-hr or units of parts per million volume dry standardized to 15% oxygen (ppmvd @ 15% O2). 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 standards will be flagged in the test report(s). Relevant information is provided in the tables below. 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 Utah Administrative Code Rule R307-510-4 Standards 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. If the engine stack does not meet the requirements of Method 2/2C, 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). 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 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.  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 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.