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Finley Resources, Inc. - Pumpjack Engine Emission Measurement Inspections - Uinta Basin, Utah Wellpads - On-Site Partial Compliance Evaluations (PCE) Inspection Dates: Inspection Report Date: Inspection Report Prepared By: Inspection Report Reviewed By: EPA Inspectors: Company Representatives: Tribal Representatives: State Representatives: Parent Company Address: Facilities County/State Location: EPA Region: Specific Facility Information: 9/15/21, 9/29/21 11/15/2021 Cindy Beeler Scott Patefield, Branch Chief SCOTT PATEFIELD PATEFIELD Digitally signed by SCOTT Date: 2021.11.15 09:27:40 -07'00' Cindy Beeler (9/15/21) Tracey Footer, ERG (9/29/21) Jason Lachance, Senior Facilities Engineer (9/15/21 and last site on 9/29/21) Brent Cook, Lead Mechanic (9/15/21) Rafael Vargas, R&R Oilfield Services (9/15/21) Nate Adamson, LDAR Technician (9/29/21) Mike Natchees, Director, Air Quality Program, Ute Indian Tribe (UITAQ) (9/15/21) Marie Kaufusi, UITAQ (9/15/21) Monaco Weidner, UITAQ (9/15/21) None PO Box 2200 Fort Worth, Texas 76113 Uintah/Utah Region 8 See Table 1 Inspection Information As part of a regional effort to better characterize emissions from pumpjack engines, United States Environmental Protection Agency (EPA) and Ute Tribal Air Program inspectors visited several Finley Resources wellpads in the Uinta Basin in Utah. The objective of the testing is to verify point source pollutant levels used for air quality modeling and emission inventories, assess the effectiveness of engine emission regulatory limits, and evaluate the emissions maintenance practices of individual operations. The engine emission tests were conducted by a third-party contractor, Alliance Source Testing (AST). In the aggregate over three weeks, the EPA and its contractor conducted testing at 61 engines with seven operators. The sample population was created to reflect the universe of almost 3,400 pumping spark-ignition engines as provided in the 2017 Uinta Basin Emission Inventory - by operator, by engine make and model, by age of engine, and by jurisdiction. The aggregate results are shown below: Page 1 of 10 Table 1 lists the Finley sites inspected, their location, the dates of inspection and the start time of each test run. Note that `facility names' with the same latitude and longitude reflect the well name and its associated pumpjack engine at a multi-well wellpad facility. For example, the facility name of the first four engines listed in Table 1 was "Fin Federal 4-5a-8-20, Fin Federal 4-5b-8-20, Fin Federal 4-6a-820, Fin Federal 4-6b-8-20." Table 1 - Sites Inspected The inspection team adhered to the following approach for the engine measurements: 1) At the beginning of each day, EPA met Finley, AST, and other agency personnel offsite and shared a list of geographically clustered Finley wellpads with engines. a) On 9/15/21, EPA inspectors Cindy Beeler, Sara Loiacono and Cindy Schafer met at Hwy 191 & 88 (16500E) and the Ute Tribe Air Program personnel accompanied the inspections. Sara Loiacono and Cindy Schafer did concurrent tanks inspections at the engine sites and other sites (a separate inspection report from Sara Loiacono covers those inspections). From Finley, Jason Lachance accompanied us throughout the day as did Brent Cook. Rafael Vargas, a Finley engine services contractor, was also present. b) On 9/29/21, EPA representative, Tracey Footer of Eastern Research Group (ERG), met at the corner of HWY 191 & 7500E (Ar88 Fort Duchesne). From Finley, Nate Adamson accompanied Tracey Footer throughout the day. Two site operators showed up at separate times (their names were not noted). Jason Lachance was present at the last site. With input from Finley, we proceeded to a subset of sites on the list where engines were gaspowered and operating, testing as many engines as possible in the day. 2) AST positioned their testing trailer to be a safe distance from the process equipment. 3) AST began set up and conducted the calibration of the analyzers at the first site each day. The analyzers were kept running between sites with (1) a generator in the bed of the truck; and (2) power conditioned/battery back-up - so they could hold a calibration for the remainder of the day. Following the calibration, and at succeeding sites, AST ran the pre-bias check, a 21-minute Page 2 of 10 measurement with pollutants recorded each minute, and the post-bias check. 4) EPA photographed the site sign. 5) EPA asked questions to describe the operating parameters of the engine, the associated equipment around each engine, and the maintenance schedules as well as taking numerous photographs. Table 3 summarizes the information collected. Testing Information Testing was conducted to determine the emission rates of nitrogen oxides (NOx), carbon monoxide (CO) and non-methane hydrocarbons (NMHC) from the engine exhausts. Emission rates were calculated using the Wyoming Analyzer Protocol, Page 25, Section 10.1.2. Where manufacturer-specified Brake Specific Fuel Consumption (BSFC) in BTU/HP-hr and nameplate horsepower were available, those were used in calculations for emission mass rates. For site-rated hp, nameplate was adjusted to 5,000 elevation. Where they were not available, the Wyoming Analyzer Protocol default value of 9,400 BTU/hp-hr was used. Where manufacture year or horsepower were not available on the engine nameplate, or there was no nameplate, the year and horsepower noted were identified by the EPA relying on emission inventory data submitted by Finley. The emission testing program was conducted in accordance with the test methods listed in Table 2. Method descriptions are provided in Attachment A - AST Test Report. Table 2 - Source Testing Methodology Other Field Notes Maintenance practices - Brent Cook described yearly oil, oil filter, grease and air filter changes and that Finley maintains a "service record." Jason Lachance described that oil and filters should be changed quarterly. Finley does not currently have a well-defined maintenance plan in place, but one is under development. The inspector could not observe the pressure of the fuel gas entering the engine because many sites did not have pressure gauges, or gauges in place were not operating. Some engines had a "tattle-tale" which the inspector understood to be a shutdown system if the engine goes down directing the fuel valve to close, so the engine does not bleed gas until the engine is restarted. The "tattle-tale" also aids the operator when they arrive on-site to troubleshoot why the engine shut down (e.g., a wellhead kick, too much vibration, temperature too high). Page 3 of 10 At wellpads inspected on 9/15/21, dry, processed gas came from Lake Pelican Compressor Station (CS). The source compressor station for dry fuel gas at wellpads inspected on 9/29/21 was not noted. The engines run continuously, even if the pumpjack is not pumping, when this can be referred to as "clutched" or idled" while the engine continues to run to power a heat trace circulation pump that provides a heated medium throughout the wellpad (tank heaters, heater treater, heat trace along piping, etc.). Seeking Finley Review and Input The EPA would like to better understand what could influence pumpjack engine emissions and so seeks Finley's review and input on the equipment associated with each engine. From observations and conversations with operators, engine manufacturers, and experienced engine stack testers, EPA offers descriptions and photos of our understanding of nomenclature around equipment associated with the engine. In addition to the following questions, the EPA requests Finley's confirmation of the engine parameters and configurations listed for each engine in Table 3, below. 1) Confirm the engine Make/Model, nameplate HP, serial #, and engine category (e.g., 2-Stroke Lean Burn [2SLB], 4SRB). 2) Confirm the manufacture year of each engine with particular attention to whether, and when, the engine may have been reconstructed, remanufactured, reconditioned, rebuilt, refurbished, or modified. Page 4 of 10 4) Knock-Out (KO) Scrubbers - Inspectors noted whether there was a single KO scrubber on the fuel gas entering the engine, or sequential dual KO scrubbers. 5) Fuel Gas Source - Casing free gas (gas from the annulus on the backside of the production tubing, direct from the well casing), separator gas (the associated gas with oil production that comes off the wellpad's separator or heater treater), or dry processed gas (piped in from a neighboring compressor station). Noted during inspection was EPA's understanding of the fuel gas source used by the engine during testing determined by walking the lines with the operator. On 9/29/21, we received conflicting responses and observations from walking the piping that routed the fuel gas to the engines. EPA understands that the fuel gas source can be changed at each site. For example, if dry processed gas is distributed to wellpads from a compressor station and the pipeline should freeze, or the compressor station is down, the wellpad could switch to either casing free gas or gas from the separator on-site. What records does Finley keep regarding the source of fuel gas being used on-site? 6) Air Fuel Control - carburetor, fuel injection, mixer manifold, or Air Fuel Ratio Control (AFRC). From conversations with operators, engine manufacturers and experienced engine stack testers, EPA's understanding of various air fuel control systems present in the field are described with photos as the examples shown below: The fuel gas is routed to the carburetor where the air intake is also routed. The governor controls the engine speed and is linked to the carburetor. Page 5 of 10 The "AJAX" control box + the red Murphy fuel control valve to the right of the AJAX box = fuel injection system. The fuel gas is routed to the mixer manifold where the air intake is also routed. The governor controls the engine speed and is linked to the mixer manifold. Dual catalyst chamber on the engine exhaust. The Stepper control valve is to the right of carburetor (visible in the background) and shown zoomed in from another perspective. On the bottom is an Altronic EPC-50 control panel (CD1 digital ignition, electronic governor, O2 sensors, voltage signal to Stepper valve to control fuel flow, cam/crank sensors). EPA's understanding is the combination of this equipment is an Air Fuel Ratio Control (AFRC) system. Page 6 of 10 7) Fuel Gas Volume Capacity - Yes or No. A gas volume tank provides a reservoir of pressurized fuel gas to meet engine demand. Without a gas volume vessel, the available reservoir capacity is in the piping conveying the fuel gas to the engine. If the Ounce regulator is BEFORE the last KO scrubber and the engine, then fuel gas volume capacity IS available to the engine, equal to the volume of the 2nd KO scrubber (Y). The pressure of the fuel gas is adjusted by springs within the regulator - if spring is all the way out GLVFKDUJH pressure is the minimum pressure of range of the regulator. If spring is all the way in discharge pressure is the maximum pressure of range of the regulator. If the Ounce regulator is between the KO scrubber and the engine, then there is NO fuel gas volume capacity available for the engine (N), besides within the fuel gas line running to the engine. The pressure of the fuel gas is adjusted by springs within the regulator - if spring is all the way out GLVFKDUJHSUHVVXUHLVWKH minimum pressure of range of the regulator. If spring is all the way in GLVFKDUJHSUHVVXUHLVWKHPD[LPXPSressure of range of the regulator. 8) EPA requests the most recent fuel gas analyses available for each fuel gas source available for use on each site - casing gas, separator gas and dry processed gas. 9) Maintenance Practices - EPA requests a summary of the manufacturer recommended maintenance and servicing for each engine make/model listed in Table 3 and a table showing the maintenance performed by Finley on each engine from 1/1/2019 to now. Page 7 of 10 Table 3 - Provides parameters describing each engine tested, the emission rate results from AST, the manufacturer-provided brakespecific fuel consumption (BSFC), and characteristics of the equipment associated with the engine and fuel gas source observed during testing. Page 8 of 10 Areas of Concern Test data has identified certain engine emissions in exceedance of the limitations found in the New Source Performance Standards, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines: 60.4233(d) Owners and operators of stationary SI ICE with a maximum engine power greater than 19 KW [25 HP] and less than 75 KW [100 HP] . . . must comply with the emission standards for field testing in 40 CFR 1048.101(c) 1048.101(c) Standards for field testing. Starting in 2007, exhaust emissions may not exceed field-testing standards, as follows: (2) The HC + NOX standard is 3.8 g/kW-hr [2.83 g/hp-hr] . . . For natural gas-fueled engines, you are not required to measure nonmethane hydrocarbon emissions or total hydrocarbon emissions for testing to show that the engine meets the emission standards of this paragraph (c); that is, you may assume HC emissions are equal to zero 1048.101(c)(2) . . . and the CO standard is 6.5 g/kW-hr [4.85 g/hp-hr]. 60.4230(a)(4)(iii) . . . the requirements of subpart JJJJ apply to engines manufactured on or after July 1, 2008, if they are <500 HP. Page 9 of 10 Attachment A - AST Test Report File: 21-2251-002 ERG Finley Resources PJ Engine Testing_DraftR1.pdf Page 10 of 10