DAQ-2024-007956

DAQE-AN124140005-24

{{$d1 }}

James Weisman
Coastal Plains Energy, Incorporated
6303 North Portland Avenue, Suite 208
Oklahoma City, OK 73112
[e-mail]

Dear Mr. Weisman:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN0124140001-09 to
Replace Engines, Resulting in a Reduction in Air Pollutants under Rule R307-401-12
Project Number: N124140005

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on March 27,
2024. Coastal Plains Energy, Incorporated must comply with the requirements of this AO, all applicable
state requirements (R307), and Federal Standards.

The project engineer for this action is Christine Bodell, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received
on this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Southeastern Utah District Health Department

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

April 29, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
{{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}}

APPROVAL ORDER
DAQE-AN124140005-24
Administrative Amendment to Approval Order
DAQE-AN0124140001-09 to Replace Engines, Resulting in a
Reduction in Air Pollutants under Rule R307-401-12

Prepared By
Christine Bodell, Engineer
[phone]
[e-mail]

Issued to
Coastal Plains Energy, Incorporated - Drunkards Wash CBM Central
Processing Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
April 29, 2024

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9

DAQE-AN124140005-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Coastal Plains Energy, Incorporated Coastal Plains Energy, Incorporated - Drunkards
Wash CBM Central Processing Facility

Mailing Address Physical Address
6303 North Portland Avenue, Suite 208 8 Miles Southwest of Price
Oklahoma City, OK 73112 Carbon County, UT 84501

Source Contact UTM Coordinates
Name: James Weisman 509,638 m Easting
Phone: [phone],373,675 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 1311 (Crude Petroleum & Natural Gas)

SOURCE INFORMATION
General Description
Coastal Plains Energy, Incorporated owns and operates a natural gas compressor station approximately
seven (7) miles southwest of Price in the Drunkards Wash Field in Carbon County. Natural gas from
field wells is piped into this site. The gas goes through the compressor and then through a glycol
dehydration unit and CO2 membrane to remove water, CO2, and other impurities. The gas is then routed
back to a sales gas line. The compressors, glycol dehydration unit, and membrane heaters are natural
gas-fired. The compressors and heaters all vent into the air through separate stacks. The CO and other
gas impurities (non-sales gases) from the membrane separator are vented to a flare unit with a flame
burner and a backup solar-powered igniter system. The waste water from the glycol unit is routed to a
500-bbl storage tank. This water is later injected back into an on-site well using natural gas-fired
injection pumps. The site has two (2) 500-bbl storage tanks for the injection well. There is a small
natural gas line heater unit to keep the water lines thawed.

NSR Classification
Administrative Amendment

Source Classification
Located in Attainment Area
Carbon County
Airs Source Size: B

DAQE-AN124140005-24
Page 4

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
Coastal Plains Energy, Incorporated has requested a modification to AO DAQE-AN0124140001-09 to
replace two (2) 1,250 hp natural gas-fired compressor engines (Equipment ID II.A.2 in AO
DAQE-AN0124140001-09) with one (1) 608 hp natural gas-fired compressor engine. The changes will
result in a net decrease in all emissions. This project meets the requirements of UAC R307-401-12
Reduction in Air Pollutants and does not require a public comment period.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4,140.00
Carbon Monoxide -18.81 76.19
Nitrogen Oxides -15.02 40.68
Particulate Matter - PM10 0 0.29
Particulate Matter - PM2.5 0 0.29
Sulfur Dioxide 0 0.02
Volatile Organic Compounds -7.17 9.63

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) -4,760 40
Change (TPY) Total (TPY)
Total HAPs -2.38 0.02

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

DAQE-AN124140005-24
Page 5

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 Coalbed Methane Processing Facility

II.A.2 One (1) Compressor Engine
Manufacturer: Caterpillar
Model: G3412C
Rating: 608 hp
Fuel: Natural Gas
Manufacture Date: 2002

II.A.3 Two (2) Main Pump Engines
Manufacturer: Cummins
Model: GTA-P1
Rating: 135 hp
Fuel: Natural Gas

II.A.4 One (1) Glycol Dehydration Unit
Burner Capacity: 0.2 MMBtu/hr
Fuel: Natural Gas

DAQE-AN124140005-24
Page 6

II.A.5 Two (2) Water Injection Pumps
Manufacturer: Ford Industrial
Model: LRG425
Rating: 27 hp
Fuel: Natural Gas

II.A.6 Line Heater

II.A.7 Flare

II.A.8 Three (3) Small Storage Tanks
Capacity: 500 bbls, each
Contents: Wastewater

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Natural gas-fired equipment - 10% opacity.

B. All other emission points - 20% opacity.

[R307-401-8]

II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall use only natural gas as a fuel in the engines, dehydration unit, and
heaters. [R307-401-8]

II.B.2 Compressor Engine Stack Testing Requirements
II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from natural
gas-fired 608 hp compressor engine:

Pollutant lb/hr
NOx 2.68
CO 3.12
VOC 1.02

[R307-401-8]

II.B.2.a.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]

II.B.2.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]

DAQE-AN124140005-24
Page 7

II.B.2.a.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within five (5) years after the
date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

II.B.2.b The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.2.b.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.2.b.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.2.b.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.2.b.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.2.b.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.2.c Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]

II.B.2.c.1 Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K).

B. Pressure - 29.92 in Hg (101.3 kPa).

C. Averaging Time - As specified in the applicable test method.

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.c.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.2.c.3 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]

DAQE-AN124140005-24
Page 8

II.B.2.c.4 CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:

Supersedes AO DAQE-AN0124140001-09 dated May 6, 2009
Is Derived From NOI dated March 27, 2024

DAQE-AN124140005-24
Page 9

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-

RN124140005
April 2, 2024

James Weisman
Coastal Plains Energy, Inc.
6303 N. Portland Ave., Suite 208
Oklahoma City, OK 73112
[e-mail]

Dear James Weisman,

Re: Engineer Review - Administrative Amendment:
Administrative Amendment to Approval Order DAQE-AN0124140001-09 to Replace Engines,
Resulting in a Reduction in Air Pollutants under Rule R307-401-12
Project Number: N124140005

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review (NSR) permitting program. Coastal
Plains Energy, Inc. should complete this review within 10 business days of receipt.

Coastal Plains Energy, Inc. should contact Christine Bodell at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director.

If Coastal Plains Energy, Inc. does not respond to this letter within 10 business days, the project will
move forward without source concurrence. If Coastal Plains Energy, Inc. has concerns that cannot be
resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.

Approval Signature _____________________________________________________________
(Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of
Environmental Quality

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N124140005
Owner Name Coastal Plains Energy, Inc.
Mailing Address 6303 N. Portland Ave., Suite 208
Oklahoma City, OK, 73112

Source Name Coastal Plains Energy, Inc.- Drunkards Wash CBM Central
Processing Facility
Source Location 8 Miles Southwest of Price
Carbon County, UT 84501

UTM Projection 509,638 m Easting, 4,373,675 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 1311 (Crude Petroleum & Natural Gas)

Source Contact James Weisman
Phone Number [phone]
Email [e-mail]

Billing Contact James Weisman
Phone Number [phone]
Email [e-mail]

Project Engineer Christine Bodell, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted March 27, 2024
Date of Accepted Application April 1, 2024

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 2
SOURCE DESCRIPTION

General Description
Coastal Plains Energy, Inc owns and operates a natural gas compressor station approximately
seven (7) miles southwest of Price in the Drunkards Wash Field, in Carbon County. Natural gas
from field wells is piped into this site. The gas goes through the compressor and then through a
glycol dehydration unit and CO2 membrane to remove water, CO2, and other impurities. The gas
is then routed back to a sales gas line. The compressors, glycol dehydration unit, and membrane
heaters are natural gas-fired. The compressors and heaters all vent to the air through separate
stacks. The CO and other gas impurities (non-sales gasses) from the membrane separator are
vented to a flare unit with flame burner and a backup solar powered igniter system. The waste
water from the glycol unit is routed to a 500-bbl storage tank. This water is later injected back to
an on-site well using natural gas-fired injection pumps. The site has two 500-bbl storage tanks for
the injection well. There is a small natural gas line heater unit to keep the water lines thawed.

NSR Classification:
Administrative Amendment

Source Classification
Located in Attainment Area
Carbon County
Airs Source Size: B

Applicable Federal Standards
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Proposal
Administrative Amendment to Approval Order DAQE-AN0124140001-09 to Replace Engines,
Resulting in a Reduction in Air Pollutants under Rule R307-401-12

Project Description
Coastal Plains Energy, Inc. has requested a modification to AO DAQE-AN0124140001-09 to
replace two (2) 1,250 hp natural gas-fired compressor engines (Equipment ID II.A.2 in AO
DAQE-AN0124140001-09) with one (1) 608 hp natural gas-fired compressor engine. The
changes will result in a net decrease in all emissions. This project meets the requirements of UAC
R307-401-12 Reduction in Air Pollutants and does not require a public comment period.

EMISSION IMPACT ANALYSIS
No criteria air pollutants and/or HAPs emissions are increasing. Therefore, no modeling is required. [Last
updated March 27, 2024]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 3
SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 4140.00
Carbon Monoxide -18.81 76.19
Nitrogen Oxides -15.02 40.68
Particulate Matter - PM10 0 0.29
Particulate Matter - PM2.5 0 0.29
Sulfur Dioxide 0 0.02
Volatile Organic Compounds -7.17 9.63

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 40
Change (TPY) Total (TPY)
Total HAPs -2.38 0.02

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding New Engine
This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-
401-12). Under UAC R307-401-12(1), Costal Plains Energy is not required to submit a notice of
intent. Therefore, no BACT analysis is required. [Last updated March 28, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 5
I.8 The owner/operator shall submit documentation of the status of construction or modification
to the Director within 18 months from the date of this AO. This AO may become invalid if
construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director,
send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Coalbed Methane Processing Facility

II.A.2 One (1) Compressor Engine
Manufacturer: Caterpillar
Model: G3412C
Rating: 608 hp
Fuel: Natural Gas
Manufacture Date: 2002

II.A.3 Two (2) Main Pump Engines
Manufacturer: Cummins
Model: GTA-P1
Rating: 135 hp
Fuel: Natural Gas

II.A.4 One (1) Glycol Dehydration Unit
Burner Capacity: 0.2 MMBtu/hr
Fuel: Natural Gas

II.A.5 Two (2) Water Injection Pumps
Manufacturer: Ford Industrial
Model: LRG425
Rating: 27 hp
Fuel: Natural Gas

II.A.6 Line Heater

II.A.7 Flare

II.A.8 Three (3) Small Storage Tanks
Capacity: 500 bbls, each
Contents: Wastewater

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 6
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
Site-Wide Requirements
II.B.1.a
NEW
The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:

A. Natural gas-fired equipment - 10% opacity

B. All other emission points - 20% opacity

[R307-401-8]

II.B.1.a.1
NEW
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b
NEW
The owner/operator shall use only natural gas as a fuel in the engines, dehydration unit, and
heaters. [R307-401-8]

II.B.2
NEW
Compressor Engine Stack Testing Requirements
II.B.2.a
NEW
The owner/operator shall not emit more than the following rates and concentrations from
natural gas-fired 608 hp compressor engine:

Pollutant lb/hr
NOx 2.68
CO 3.12
VOC 1.02

[R307-401-8]

II.B.2.a.1
NEW
Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained
in this AO. [R307-165-2, R307-401-8]

II.B.2.a.2
NEW
Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days
after startup of the emission unit. [R307-165-2]

II.B.2.a.3
NEW
Test Frequency
The owner/operator shall conduct a stack test on the emission unit within five (5) years after
the date of the most recent stack test of the emission unit. The Director may require the
owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 7
II.B.2.b
NEW
The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]

II.B.2.b.1
NEW
Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.2.b.2
NEW
Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]

II.B.2.b.3
NEW
Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]

II.B.2.b.4
NEW
Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]

II.B.2.b.5
NEW
Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

II.B.2.c
NEW
Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved
test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8]

II.B.2.c.1
NEW
Standard Conditions

A. Temperature - 68 degrees Fahrenheit (293 K)

B. Pressure - 29.92 in Hg (101.3 kPa)

C. Averaging Time - As specified in the applicable test method

[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.c.2
NEW
NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]

II.B.2.c.3
NEW
VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 8
II.B.2.c.4
NEW
CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to
the Director. [R307-401-8]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 9
PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes AO DAQE-AN0124140001-09 dated May 6, 2009
Is Derived From NOI dated March 27, 2024

REVIEWER COMMENTS

1. Comment regarding Name Change:
Approval Order DAQE-AN0124140001-09, dated May 6, 2009, was issued to Marathon Oil
Company. In 2018, the Utah Division of Air Quality (DAQ) received a request for a name and
ownership change from Marathon Oil Company to Coastal Plains Energy, Inc. This change has been
reflected in the new AO. [Last updated March 27, 2024]

2. Comment regarding Federal Standard Applicability:
CFR 60 NSPS Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines) applies to engines that were ordered after June 12, 2006 and manufactured on
or after July 1, 2008, for engines with a maximum engine power less than 500 HP. This subpart also
applies to engines that were ordered after June 12, 2006 and manufactured on or after July 1, 2007
for engines with maximum power greater than or equal to 500 hp.

The two (2) main pump engines, rated at 135 hp each, and two (2) water injection pumps, rated at 27
hp each, were manufactured before July 1, 2008. The one (1) compressor engine, rated at 608 hp,
was manufactured before July 1, 2007. Therefore, NSPS Subpart JJJJ is not applicable to these
engines.

40 CFR 63 Subpart ZZZZ (National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines) is applicable to owners/operators of
stationary RICE at a major or area sources of HAP emissions. MACT Subpart ZZZZ applies to the
Facility as the compressor, main pump engines, and water injection pump engines are RICE. The
engines will meet Subpart ZZZZ by meeting 40 CFR Part 60, Subpart JJJJ as the Facility is an area
source of HAP emissions. Therefore, MACT Subpart ZZZZ applies to engine on site.
[Last updated March 28, 2024]

3. Comment regarding Title V Applicability:
Title V of the 1990 Clean Air Act (Title V) applies to the following:

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is not subject to
regulations under 40 CFR 60 (NSPS) or 40 CFR 61 (NESHAP). The facility is subject to 40 CFR 63
(MACT) Subparts A and ZZZZ. Unless otherwise required by law, the owner or operator of an area
source subject to the provisions of MACT Subpart ZZZZ is exempt the obligation to obtain a Title V

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 10
permit. No such reasons exist for this source. Therefore, Title V does not apply to the Drunkard
Wash facility. [Last updated March 28, 2024]

4. Comment regarding Source Emission Estimates:
Emissions from the new 608 hp natural gas-fired compressor engine were made with manufacturer
provided information:
2.0 g/hp-hr of NOx, 2.33 g/hp-hr of CO, and 0.80 g/hp-hr of VOCs. All other emission factors are
from AP-42 Table 3.2-3. 8760 hours of operation annually is assumed.

The 2009 AO does not specify a PTE for PM10, PM2.5, SO2, or CO2e emissions. These values have
been estimated and added to the current AO. PM10, PM2.5, SO2, or CO2e emissions are not
increasing. They were not accounted for in the 2009 AO. This project is still a true reduction in air
pollutants under R307-401-12.

Emissions from the main pump engines and water injection pumps were estimated using AP-42
Section 3.2 - Natural Gas-fired Reciprocating Engines. Emissions from the 0.2 MMBtu/hr burner in
the dehydration unit were calculated using emission factors from AP-42 Section 1.4 - Natural Gas
Combustion.

These values should be verified for accuracy and updated in the future, when the source undergoes a
modification.

[Last updated March 28, 2024]

Engineer Review N124140005: Coastal Plains Energy, Inc.- Drunkards Wash CBM Central Processing Facility
April 2, 2024
Page 11
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Christine Bodell <[e-mail]>
DAQ Drunkard Wash AO DAQE-AN0124140001-09
9 messages
Christine Bodell <[e-mail]>Mon, Mar 18, 2024 at 9:43 AM
To: [e-mail]
Good Morning James,
Thank you for your emails.
I was able to pull up the current Approval Order for the Drunkard Wash Station (see attached).
According to the AO, there are two Caterpillar G3516LE (2) Compressor engines, each with a rating of 1250 hp.
Are you waiting to replace both engines with a new 3412 engine? I see you send an attachment of the old G3516 engines, but I need a
manufacturer specification sheet for the 3412 model before I can proceed with determining if this is a true reduction in air
pollutants under R307-401-12.
Thank you,
Christine
--
Christine Bodell
Environmental Engineer
Email | [e-mail]
Phone| [phone]
Emails to and from this email address may be considered public records and
thus subject to Utah GRAMA requirements
DAQE-AN0124140001-09 (1).pdf
63K
James Weisman <[e-mail]>Mon, Mar 18, 2024 at 10:32 AM
To: Christine Bodell <[e-mail]>
please find attached cat 3412 data- thanks Jim Weisman
[Quoted text hidden]
3 attachments
Scan_3412 data.pdf
143K
Scan_3412 emiss 1.pdf
58K
Scan_3412 emiss 2).pdf
57K
Christine Bodell <[e-mail]>Mon, Mar 18, 2024 at 12:06 PM
To: James Weisman <[e-mail]>
James,
Just to confirm - are you removing two(2) G3516 engines and replacing them with one (1) 3412 engine?
[Quoted text hidden]
James Weisman <[e-mail]>Tue, Mar 19, 2024 at 9:24 AM
To: Christine Bodell <[e-mail]>
There was only one 3516 at Drunkard Wash before we removed it and replaced it with the 3512, the permit, as you know, was for 2-
3516 engines.- Jim Weisman
[Quoted text hidden]
Christine Bodell <[e-mail]>Tue, Mar 19, 2024 at 10:33 AM
To: James Weisman <[e-mail]>
Hello James,
Thank you for confirming. I have verified the values and can see that this project qualifies as a Reduction in Air Pollutants under R307-
401-12.
For the DAQ to proceed, the following tasks need to be completed.
1. Please complete Form 2 (attached) and send it back to me.
2. Please pay the applicable fee. The DAQ fee webpage can be found at https://deq.utah.gov/air-quality/fees-air-quality-permitting.
There is a filing fee cost of $500. To pay this fee, go to the page > make a payment (green button) > scroll to the bottom where it says
"Approval Order Notice Of Intent".
In the additional information box, write the following:
"Administrative Amendment application for a reduction in air pollutants for Approval Order DAQE-AN0124140001-09".
Please let me know if you have any questions.
Thank you,
Christine
[Quoted text hidden]
Form2.pdf
96K
James Weisman <[e-mail]>Wed, Mar 20, 2024 at 12:11 PM
To: Christine Bodell <[e-mail]>
Please find Form 2. I will have check sent as soon as you OK this form- thanks Jim Weisman
[Quoted text hidden]
Form2 (5).pdf
139K
Christine Bodell <[e-mail]>Thu, Mar 21, 2024 at 1:17 PM
To: James Weisman <[e-mail]>
James,
The form looks good. Please send the check at your earliest convenience. Once it is received, the DAQ will start processing the
application.
Thank you,
Christine
[Quoted text hidden]
Christine Bodell <[e-mail]>Wed, Mar 27, 2024 at 1:49 PM
To: James Weisman <[e-mail]>
Hi James,
Do you know the manufacturer date of the new engine?
Thanks,
Christine
[Quoted text hidden]
James Weisman <[e-mail]>Thu, Mar 28, 2024 at 4:38 AM
To: Christine Bodell <[e-mail]>
Cat 3412C, built 01-02-2002- Jim Weisman
[Quoted text hidden]
1 of 1
Form 2 Date ____________
Company Information/Notice of Intent (NOI)
Utah Division of Air Quality
New Source Review Section
Application for: □ Initial Approval Order □Approval Order Modification
General Owner and Source Information
1.Company name and mailing address:
____________________________
____________________________
____________________________
Phone No.: ( )
Fax No.: ( )
2.Company** contact for environmental matters:
____________________________
Phone no.: ( )
Email: _______________________
** Company contact only; consultant or independent contractor contact
information can be provided in a cover letter
3.Source name and physical address (if different from
above):____________________________
____________________________
____________________________
Phone no.: ( )
Fax no.: ( )
4.Source Property Universal Transverse Mercator
coordinates (UTM), including System and Datum:
UTM:_________________________
X:____________________________
Y:____________________________
5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC)
__ __ __ __
7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____
8.Brief (50 words or less) description of process.
Electronic NOI
9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black ([e-mail]) or Alan
Humpherys ([e-mail]) can expedite review process. Please mark application type.
Hard Copy Submittal Electronic Copy Submittal □ Both
Authorization/Signature
I hereby certify that the information and data submitted in and with this application is completely true, accurate and
complete, based on reasonable inquiry made by me and to the best of my knowledge and belief.
Signature: Title:
_______________________________________
Name (Type or print)
Telephone Number:
( )
Email:
Date:
DAO 2018 002272