DAQ-2024-004380

1

DAQC-020-24
Site IDs: 4683, 100441, 101768 (B4)

MEMORANDUM

TO: STACK TEST FILE – JAVELIN ENERGY MANAGEMENT PARTNERS, LLC –
EP Energy 8-24-23-C5-2H MWF, Flying Dutchman 1-13C5 MWF, and Park City
5-6-5-C4-3H MWF – Duchesne County

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

FROM: Kyle Greenberg, Environmental Scientist

DATE: January 5, 2024

SUBJECT: Source: EP Energy 8-24-23-C5-2H MWF: Caterpillar G3516; SN: N6E00129
Flying Dutchman 1-13C5 MWF: Cummins KTA19GC; SN: 37254961
Park City 5-6-5-C4-3H MWF: Caterpillar G3516J; SN: N6W/4EK00736
Location: Duchesne County, Utah
Contact: Brian Shpakoff: 682-209-2074
Tester: Oasis Emissions Consultants, Inc.
CAERS IDs #: 4683, 100441, 101768
Permit/AO #: Permit by Rule
Subject: Review of Pretest Protocol dated January 3, 2024

On January 3, 2024, Utah Division of Air Quality (DAQ) received protocols for the above listed units in
Duchesne County, Utah. Testing will be performed February 5-9, 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. Method 1 used to determine sample traverses; OK
2. Method 2 used to determine velocity of the effluent gas stream; OK
3. Method 3 used to determine dry molecular weight of the effluent gas stream; OK
4. Method 320 used to determine NOx, CO, VOC, and H2O of the effluent gas stream; OK
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.

ATTACHMENTS: Javelin Energy notification letter and pretest protocol.

January 3, 2024

Rik Ombach
Minor Source Compliance Manager
PO Box 144820
Salt Lake City, UT 84114-4820

RE: NSPS JJJJ Compliance Test Notification and Protocol Submission For the Javelin
Energy Partners’ Flying Dutchman 18-17-C4 & Moose Hollow 24-23-C5 in Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 380 hp Cummins KTA19GC and one (1) 1380 hp Caterpillar G3516 ULB located at
Javelin Energy Partners’ Flying Dutchman 18-17-C4 (CAERS ID: 100441; Latitude: 40.217278,
Longitude: -110.393122) and Moose Hollow 24-23-C5 (CAERS ID: 4683; Latitude: 40.205614,
Longitude: -110.387667) in Utah. The tests will be conducted in accordance with EPA 40 CFR
60, Subpart JJJJ (NSPS 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, February 5th, 2024 – Friday,
February 9th, 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

Federal Regulation: EPA 40 CFR 60, Subpart JJJJ
Engines: (1) Cummins KTA19GC & (1) Caterpillar G3516 ULB

Javelin Energy Partners
Flying Dutchman 18-17-C4
& Moose Hollow 24-23-C5,
In Utah

January 3, 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 by Oasis Emission Consultants, Inc. The
engines are greater than or equal to 100 hp and less than 500 hp, or greater than or equal to 500
hp and are being tested according to the requirements set out by EPA 40 CFR 60, Subpart JJJJ
(NSPS JJJJ).
1.1 TEST PROGRAM ORGANIZATION

Federal Regulation: EPA 40 CFR 60, Subpart JJJJ

Facilities: Flying Dutchman 18-17-C4
& Moose Hollow 24-23-C5

CAERS IDs: 100441 & 4683

Client: Javelin Energy Partners
Contact: Greg Simms
Email: [e-mail]
Cell.: [phone]

Contact: Julie Spear, P.E., Principal Engineer
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)

Javelin Energy Partners’ facility engines are being tested to demonstrate compliance with the
standards and test requirements listed by 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 February 5th – 9th, 2024
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 test reports will show results in accordance with NSPS Subpart 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). NOx, CO
and VOC results from the compliance tests will be reported in g/Bhp-hr.
Facility Latitude /
Longitude
CAERS
Source ID
Unit
Number
Engine Serial
Number
HP RICE
Configuration
Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
Flying Dutchman
18-17-C4
40.217278,
-110.393122
100441 6318 Cummins
KTA19GC
37254961 380 4SRB 6/1/2012 1.0 g/BHp-hr 2.0 g/BHp-hr 0.7 g/BHp-hr
Moose Hollow
24-23-C5
40.205614,
-110.387667
4683 6995 Caterpillar
G3516 ULB
N6E00129 1380 4SLB 2/16/2015 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 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.

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.
 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.

January 3, 2024

Rik Ombach
Minor Source Compliance Manager
PO Box 144820
Salt Lake City, UT 84114-4820

RE: Compliance Test Notification and Protocol Submission For Javelin Energy
Partners’ Park City 6-5-C4 MWF in Utah

Oasis Emission Consultants, Inc. has been requested to conduct compliance emission testing on
one (1) 1380 hp Caterpillar G3516J engine located at Javelin Energy Partners’ Park City 6-5-C4
MWF (CAERS ID: 101768; Latitude: 40.24938, Longitude: -110.39121) in Utah. The test will
be conducted 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.

Testing has been scheduled with the client for the Monday, February 5th, 2024 – Friday,
February 9th, 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

Engine: (1) Caterpillar G3516J

Javelin Energy Partners
Park City 6-5-C4 MWF,
In Utah

January 3, 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 by Oasis Emission Consultants, Inc. The
engine is rated at ≥100 hp and is being tested according to the requirements set out by the Utah
Administrative Code Rule R307-510-4.
1.1 TEST PROGRAM ORGANIZATION

Facility: Park City 6-5-C4 MWF

CAERS ID: 101768

Client: Javelin Energy Partners
Contact: Greg Simms
Email: [e-mail]
Cell.: [phone]

Contact: Julie Spear, P.E., Principal Engineer
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)

Javelin Energy Partners’ Park City 6-5-C4 MWF engine is being tested to demonstrate
compliance with the standards and test requirements listed by 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 Date

The unit will be tested by Oasis Emission Consultants, Inc. during the February 5th – 9th, 2024
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:

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 compliance with NOx, CO and VOC standards on a grams per brake-horsepower hour (g/Bhp-
hr) basis.
Facility Latitude /
Longitude
CAERS
Source ID
Unit
Number
Engine Serial Number HP Mfg. Date NOX
STANDARD
CO
STANDARD
VOC
STANDARD
Park City 6-5-C4
MWF
40.24938,
-110.391205
101768 806932 Caterpillar
G3516J
N6W/4EK00736 1380 11/27/1995 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 this 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 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.
 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.