DAQ-2024-004381

1

DAQC-1370-23
Site IDs: 8057, 8059, 100386 (B4)

MEMORANDUM

TO: STACK TEST FILE – FINLEY RESOURCES INC. – Deep Creek 12-26-4-2E, Deep
Creek 2-27-4-2E, and Deep Creek 9-26-4-2E, and Deep Creek 16-26-4-2E Tank
Batteries – Uintah County

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: December 27, 2023

SUBJECT: Source: Three (3) Ajax E-565 pumpjack engines.
Location: Deep Creek 12-26-4-2E, Deep Creek 2-27-4-2E, and Deep Creek
9-26-4-2E, and Deep Creek 16-26-4-2E Tank Batteries, Uintah County,
Utah
Contact: Karen Pratt: 720-990-9927
Tester: Oasis Emissions Consultants, Inc.
Site ID #: 8057, 8059, 100386
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol dated December 19, 2023

On December 19, 2023, Utah Division of Air Quality (DAQ) received a protocol for the testing of three
(3) Ajax E-565 Engines at Deep Creek 12-26-4-2E, Deep Creek 2-27-4-2E, and Deep Creek 9-26-4-2E,
and Deep Creek 16-26-4-2E Tank Batteries in Uintah County, Utah. Testing will be performed January
29, 2024, through February 2, 2024, to determine compliance with the emission limits found in 40 CFR
part 60 subpart JJJJ.

PROTOCOL CONDITIONS:

1. Method 1 used to determine sample traverses; OK
2. Method 3A used to determine dry molecular weight of the gas stream; OK
3. Method 4 used to determine the moisture content within the gas stream; OK
4. Method 7E used to determine NOx emissions; OK
5. Method 10 used to determine CO emissions; OK
6. Method 18 used to determine ethane and methane concentrations of the gas stream; OK
7. Method 19 used to determine exhaust effluent flows and mass emission rates; OK
8. Method 25A used to determine VOC emissions; OK

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: Finley Resources Inc. notification letter, Finley Resources Inc. pretest
protocol.
December 19, 2023

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

RE: Compliance Test Notification and Protocol Submission For Finley Resources, Inc.’s
Various Facilities in Uintah County, Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
three (3) 40 horsepower (hp) Ajax E-565 engines located at Finley Resources, Inc.’s Deep Creek
2-27-4-2E (Well: Deep Creek 2-27-4-2E; CAERS ID # 8538), Deep Creek 12-26-4-2E and Deep
Creek Tribal 27-09-4-2E (Well: Deep Creek 12-26-4-2E; CAERS ID # 8057), and Deep Creek 9,
16-26-4-2E (Well: Deep Creek 9-26-4-2E; CAERS ID # 100386) in Uintah County, Utah. The
engines are being tested in accordance with Utah Administrative Code Rule R307-510-4 and
EPA 40 CFR 60, 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 29th, 2024 – Friday,
February 2nd, 2024 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: (3) Ajax E-565

Facilities: Deep Creek 2-27-4-2E,
Deep Creek 12-26-4-2E and Deep Creek Tribal 27-09-4-2E,
& Deep Creek 9, 16-26-4-2E
Wells: Deep Creek 2-27-4-2E,
Deep Creek 12-26-4-2E,
& Deep Creek 9-26-4-2E

Finley Resources, Inc.
25 HP – 100 HP Engines
In Uintah County, Utah

December 19, 2023

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 Finley Resources, Inc. by Oasis Emission Consultants, Inc. The
units are classified as non-emergency stationary engines rated below 100 horsepower (hp). The
engines are being tested in accordance with the Utah Administrative Code Rule R307-510-4 and
EPA 40 CFR 60, Subpart JJJJ.

1.1 TEST PROGRAM ORGANIZATION

Facilities: Deep Creek 2-27-4-2E,
Deep Creek 12-26-4-2E and Deep Creek Tribal 27-09-4-2E,
& Deep Creek 9, 16-26-4-2E

Wells: Deep Creek 2-27-4-2E,
Deep Creek 12-26-4-2E,
& Deep Creek 9-26-4-2E

CAERS IDs: 8538,
8057,
& 100386

Client: Finley Resources, Inc.
Contact: Karen Pratt, Regulatory Manager
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 Finley Resources, Inc.’s engines in Uintah County, Utah are being tested in accordance with
the Utah Administrative Code Rule R307-510-4 and EPA 40 CFR 60, Subpart JJJJ.

2.0 SOURCE TEST PROGRAM DESCRIPTION

2.1 Test Contractor

All source emission tests will be performed by Oasis Emission Consultants, Inc., based out of
Rock Springs and Sheridan, Wyoming. Processed test results and all raw data captured during the
tests are forwarded to Chris Knott, P.Eng., Director of Engineering and Operations and/or
Charles Chapman, Manager of Technical Services, for quality control and data checking. Once
approved, tests are forwarded to the client.

2.2 Test Dates

The units will be tested by Oasis Emission Consultants, Inc. during the January 29th – February
2nd, 2024 test campaign.

2.3 Report Date

The compliance test reports will be submitted no later than 60 days following the compliance
tests.

2.4 Emission Source Description

A summary of the units to be tested is provided in the table below:

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

Facility Well CAERS ID # Latitude /
Longitude
Engine Serial
Number*
HP
Deep Creek 2-27-4-2E Deep Creek 2-27-4-2E 8538 40.113616,
-109.750816
Ajax E-565 86572 40
Deep Creek 12-26-4-2E and Deep Creek Tribal 27-09-4-2E Deep Creek 12-26-4-2E 8057 40.105511,
-109.742915
Ajax E-565 86225 40
Deep Creek 9, 16-26-4-2E Deep Creek 9-26-4-2E 100386 40.102389,
-109.726166
Ajax E-565 86533 40

2.4.1 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 will be conducted to show levels in
units of HC+NOx and CO (as g/BHp-hr).
2.4.2 EPA 40 CFR 60, Subpart JJJJ Standards

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.

Emission Measurement Methodologies:

The units will be tested 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). Three, one hour tests will be conducted on each 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.
Maximum Engine hp HC+NOX CO
Equal to or greater than 25 hp
and < 100 hp
2.83 g/BHp-hr 4.85 g/BHp-hr
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)
It is expected that the performance tests will be conducted within ±10% of 100% peak, or the
highest achievable load.

Test Methods:

All EPA 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 3A: O2 measurements will be conducted using an
instrumental analyzer according to Method 3A. The O2 levels will 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.
 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 employs an integrated grab bag
sampling system. Method 18 will be utilized to account for Ethane and Methane
concentrations to determine NMNEHC.
 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: Total Hydrocarbons will be measured on a hot-
wet basis by using a Flame Ionization Analyzer. This analyzer will be calibrated using EPA
Protocol G1 Propane (C3) gas before and after each one hour test run.