DAQ-2025-001342

1

DAQC-246-25
Site IDs: 100462, 100463, 100973,
101039, 101695, 101990, 102052 (B4)

MEMORANDUM

TO: STACK TEST FILE – UINTA WAX OPERATING, LLC – Bastian West Pad,
Shelby Tribal 1.5-25-36-3-1WH1, Griswold Tribal 15-21-16-3-1W-H1 CTB, RD
Tribal 32N-31E-H7UB, H8UB CTB, RD West Pad, Sand View Pad, and Gray Pad –
Duchesne County and Uintah County

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: March 3, 2025

SUBJECT: Sources: Bastian West Pad, Caterpillar G3306 TA/LCR, SN: G6X02211, Shelby
Tribal 1.5-25-36-3-1WH1, Caterpillar G3306TA, SN: R6S04506,
Griswold Tribal 15-21-16-3-1W-H1 CTB, Cummins KTA19GC, SN:
37271181, RD Tribal 32N-31E-H7UB, Caterpillar G3306TA, SN:
R6S01808, RD West Pad, Caterpillar G3306B TA/LCR, SN: R6S02295,
Sand View Pad, Cummins KTA19GC, SN: 37276137, and Gray Pad,
Caterpillar G3508 ULB, SN: RBK00102
Location: Remote Locations in Duchesne County and Uintah County, Utah
Contact: Karen Pratt: [phone]
Tester: Alliance Technical Group
Site ID #: 100462, 100463, 100973, 101039, 101695, 101990, 102052
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocols dated February 28, 2025

On February 28, 2025, Utah Division of Air Quality (DAQ) received protocols for the testing of the
above listed units in Duchesne County and Uintah County, Utah. Testing will be performed March 31,
2025, through April 4, 2025, 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 effluent gas velocity: OK
3. Method 3A used to determine dry molecular weight of the gas stream: OK
4. Method 320 used to determine H2O & CO2 content and NOx, CO, & VOC emissions: OK
5. Method 19 used to determine exhaust effluent flows and mass emission rates: OK
6. ASTM D6522-00(2005) used to determine O2 percentage of the effluent gas: OK
4 ' - ) - "
2

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 and concentrations.

ATTACHMENTS: Uinta Wax Operating, LLC’s pretest protocols.

February 28, 2025

Utah Department Of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Test Notification & Protocol Submission For Uinta Wax Operating,
LLC’s RP Tribal 22N-31W-H2UB, 23N-31W-H8UB, 26S-31W-H8CP, H6UB2,
H7UB, H7WS, H6CP, H7CP in Uintah County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 203 horsepower (hp) Caterpillar G3306 TA/LCR engine (Site ID: 100462; Latitude:
40.202885, Longitude: -109.97232) located at Uinta Wax Operating, LLC’s RP Tribal 22N-
31W-H2UB, 23N-31W-H8UB, 26S-31W-H8CP, H6UB2, H7UB, H7WS, H6CP, H7CP in
Uintah County, Utah. The engine is being tested in accordance with the Utah Administrative
Code Rule R307-510-4. A summary of the unit and details of our testing procedures can be found
in the attached protocol.

The engine has been scheduled with the client to be tested during the Monday, March 31st, 2025
– Friday, April 4th, 2025 test campaign.

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) Caterpillar G3306 TA/LCR

Facility: RP Tribal 22N-31W-H2UB, 23N-31W-H8UB, 26S-31W-
H8CP, H6UB2, H7UB, H7WS, H6CP, H7CP
Pad: RP22N/23N (Bastian West)

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

February 28, 2025

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.
1.1 TEST PROGRAM ORGANIZATION
Facility: RP Tribal 22N-31W-H2UB, 23N-31W-H8UB, 26S-31W-H8CP,
H6UB2, H7UB, H7WS, H6CP, H7CP

Site ID: 100462

Client: Uinta Wax Operating, LLC
Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Contact: Josh Morgan, Operations Tech
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 22N-31W-H2UB, 23N-
31W-H8UB, 26S-31W-H8CP, H6UB2, H7UB, H7WS, H6CP, H7CP (Site ID: 100462) in
Uintah County, Utah. The engine is being tested in accordance with the Utah Administrative
Code Rule R307-510-4.

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 unit will be tested by Oasis Emission Consultants, Inc. during the March 31st – April 4th,
2025 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 test report, if currently unavailable.

.
Facility Pad Latitude /
Longitude
Site ID Engine Serial
Number
HP Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
RP Tribal 22N-31W-H2UB,
23N-31W-H8UB, 26S-31W-
H8CP, H6UB2, H7UB,
H7WS, H6CP, H7CP
RP22N/23N
(Bastian
West)
40.202885,
-109.97232
100462 Caterpillar
G3306 TA/LCR
G6X02211 203 2/2/2006 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

Emission Measurement Methodologies:

The Caterpillar G3306 TA/LCR engine will be tested for three, one hour test runs according to
EPA 40 CFR 60 (A), Methods 1, 19 and EPA 40 CFR 63 (A), Method 320 for NOx, CO, VOC
(as NMNEHC C3) & H2O. Oxygen will be measured using ASTM D6522-00(2005). In order to
demonstrate compliance with NOx, CO and VOC emission standards in units of g/BHp-hr, ppm
levels will be converted to g/BHp-hr levels using the formulae from the Wyoming/Colorado
portable analyzer protocol and a BSFC factor (BTU/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 report.

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.

Operating Parameters:

Engine operating parameters, where applicable, will be recorded for each 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; the engine load; or,
the engine load obtained from the engine control panel.

Test Methods:

Oasis Emission Consultants, Inc. will EPA Method 320 for NOx, CO, VOC & H2O
concentration measurement. Oxygen levels in the exhaust stream will be monitored through the
use of a portable analyzer, concurrently with the FTIR test. 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. 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 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.
 ASTM D6522-00(2005): ASTM D6522-00(2005) will be used to measure the exhaust gas
Oxygen content. The O2 levels will be used in conjunction with Method 19 to determine the
overall exhaust effluent flow.

February 28, 2025

Utah Department Of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Test Notification & Protocol Submission For Uinta Wax Operating,
LLC’s Various Facilities in Uintah County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
two (2) 380 horsepower (hp) Cummins KTA19GC, one (1) 203 hp Caterpillar G3306B TA/LCR
and two (2) 203 hp Caterpillar G3306TA engines located at Uinta Wax Operating, LLC’s
Various Facilities in Uintah County, Utah. The engines are being tested in accordance with the
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 to be tested during the Monday, March 31st,
2025 – Friday, April 4th, 2025 test campaign.

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

Engines: (2) Cummins KTA19GC,
(1) Caterpillar G3306B TA/LCR,
& (2) Caterpillar G3306TA

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

February 28, 2025

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 units are classified as stationary engines rated ≥100 horsepower (hp). The engines are being
tested in accordance with the Utah Administrative Code Rule R307-510-4 and NSPS Subpart
JJJJ.
1.1 TEST PROGRAM ORGANIZATION

Facilities: RD Tribal 8N, 17S, 7N Production Facility;
RP Tribal 21N-31W-H3UB, H5UB, H7CP, H4WS, H4CP, H2CP,
H4LP, H8LB;
MB Tribal 5S-41E-H7UB, 6S-41E-H1UB,H2CP,H3UB & RD Tribal
32N-31E-H7UB, H8UB, 31N-31E-H2UB;
Shelby Tribal 2.5-25-36-3-1W-H1, RP Tribal 25S-31W-H1UB, H3UB;
& RD Tribal 17S-31E-H4UB, H2UB, H1CP, H3LP, H1WS, H2WS

Site IDs: 101695,
100973,
101039,
100463,
& 101990

Client: Uinta Wax Operating, LLC
Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Contact: Josh Morgan, Operations Tech
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)

Uinta Wax Operating, 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 March 31st – April 4th,
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:

*The serial numbers will be provided in the final test reports, if currently unavailable.

.
Facility Pad Latitude /
Longitude
Site ID Engine Serial
Number
HP Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
RD Tribal 8N, 17S, 7N
Production Facility
RD West 40.22971,
-109.916
101695 Caterpillar
G3306B TA/LCR
R6S02295 203 2/1/2014 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
RP Tribal 21N-31W-H3UB,
H5UB, H7CP, H4WS, H4CP,
H2CP, H4LP, H8LB
Griswold 40.20142,
-109.999
100973 Cummins
KTA19GC
37271181 380 4/11/2017 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
MB Tribal 5S-41E-H7UB, 6S-
41E-H1UB,H2CP,H3UB &
RD Tribal 32N-31E-H7UB,
H8UB, 31N-31E-H2UB
COX
East
40.17257,
-109.919
101039 Caterpillar
G3306TA
R6S01808 203 9/13/2013 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
Shelby Tribal 2.5-25-36-3-
1W-H1, RP Tribal 25S-31W-
H1UB, H3UB
Shelby 40.20024,
-109.942
100463 Caterpillar
G3306TA
R6S04506 203 12/3/2014 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
RD Tribal 17S-31E-H4UB,
H2UB, H1CP, H3LP, H1WS,
H2WS
Sand
View
40.2310602,
-109.90391
101990 Cummins
KTA19GC
37276137 380 8/28/2018 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

Emission Measurement Methodologies:

Each engine will be tested for three, one hour test runs per the requirements of 40 CFR 60.4244.
Testing 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 NMNEHC C3) & H2O. Oxygen will be measured using
ASTM D6522-00(2005). In order to demonstrate compliance with NOx, CO and VOC emission
standards in units of g/BHp-hr, ppm levels will be converted to g/BHp-hr levels using the
formulae from the Wyoming/Colorado portable analyzer protocol and a BSFC factor (BTU/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 report.

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.

Operating Parameters:

Engine operating parameters, where applicable, will be recorded for each 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 performance tests will be conducted within ±10% of 100% peak, or the
highest achievable load.

Test Methods:

Oasis Emission Consultants, Inc. will EPA Method 320 for NOx, CO, VOC & H2O
concentration measurement. Oxygen levels in the exhaust stream will be monitored through the
use of a portable analyzer, concurrently with the 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 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.
 ASTM D6522-00(2005): ASTM D6522-00(2005) will be used to measure the exhaust gas
Oxygen content. The O2 levels will be used in conjunction with Method 19 to determine the
overall exhaust effluent flow.

February 28, 2025

Utah Department Of Environmental Quality
Division of Air Quality
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Test Notification & Protocol Submission For Uinta Wax Operating,
LLC’s RD Tribal 8N-31E-H3UB, H4CP, H4LP, H5UB in Uintah County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 690 horsepower (hp) Caterpillar G3508 ULB engine (Site ID: 102052; Latitude:
40.228622, Longitude: -109.90371) located at Uinta Wax Operating, LLC’s RD Tribal 8N-31E-
H3UB, H4CP, H4LP, H5UB 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 (NSPS
Subpart JJJJ). A summary of the unit and details of our testing procedures can be found in the
attached protocol.

The engine has been scheduled with the client to be tested during the Monday, March 31st, 2025
– Friday, April 4th, 2025 test campaign.

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) Caterpillar G3508 ULB

Facility: RD Tribal 8N-31E-H3UB, H4CP, H4LP, H5UB
Pad: Gray

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

February 28, 2025

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 NSPS Subpart
JJJJ.
1.1 TEST PROGRAM ORGANIZATION
Facility: RD Tribal 8N-31E-H3UB, H4CP, H4LP, H5UB

Site ID: 102052

Client: Uinta Wax Operating, LLC
Contact: Karen Pratt, Regulatory Manager
Email: [e-mail]
Cell.: [phone]

Contact: Josh Morgan, Operations Tech
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 RD Tribal 8N-31E-H3UB, H4CP,
H4LP, H5UB (Site ID: 102052) in Uintah County, Utah. The engine is being tested in
accordance with 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 Date

The unit will be tested by Oasis Emission Consultants, Inc. during the March 31st – April 4th,
2025 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 test report, if currently unavailable.

.
Facility Pad Latitude /
Longitude
Site ID Engine Serial
Number
HP Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
RD Tribal 8N-31E-H3UB,
H4CP, H4LP, H5UB
Gray 40.228622,
-109.90371
102052 Caterpillar
G3508 ULB
RBK00102 690 6/25/2009 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr

Emission Measurement Methodologies:

Three, one hour tests will be conducted on the Caterpillar G3508 ULB 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 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.

Operating Parameters:

Engine operating parameters, where applicable, will be recorded for each 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; the engine load; or,
the engine load obtained from the engine control panel.

It is expected that the performance test 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.