DAQ-2024-004474

DAQE-AN154870003-24

{{$d1 }}

Russel Sorensen
Integrated Water Management
PO Box 430
Altamont, UT 84001
[e-mail]

Dear Mr. Sorensen:

Re: Approval Order: Modification to Approval Order DAQE-AN154870002-19 to Add Four (4)
500 bbl Storage Tanks
Project Number: N154870003

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on August
16, 2022. Integrated Water Management must comply with the requirements of this AO, all applicable
state requirements (R307), and Federal Standards.

The project engineer for this action is John Persons, 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:JP:jg

cc: TriCounty 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

January 10, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}}
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APPROVAL ORDER
DAQE-AN154870003-24
Modification to Approval Order DAQE-AN154870002-19
to Add Four (4) 500 bbl Storage Tanks

Prepared By
John Persons, Engineer
[phone]
[e-mail]

Issued to
Integrated Water Management - Produced Water Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

January 10, 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 ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-AN154870003-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Integrated Water Management Integrated Water Management - Produced Water
Facility

Mailing Address Physical Address
PO Box 430 SE-SE Sec 30 T2S R4W
Altamont, UT 84001 Duchesne, UT 84088

Source Contact UTM Coordinates
Name Russel Sorensen 553,295 m Easting
Phone [phone],458,127 m Northing
Email [e-mail] Datum NAD83
UTM Zone 12

SIC code 1389 (Oil & Gas Field Services, NEC)

SOURCE INFORMATION
General Description
Integrated Water Management (IWM) is a produced water and solids treatment facility for the oil and gas
production sector. Produced water is received by truck and pipeline from oil and gas operations. The
water then undergoes phase separation using tanks and centrifuges for the recovery of oil and condensate.
The remaining water is then injected into a well on-site or discharged into evaporation ponds when
necessary. Water entering the evaporation ponds remains until it has been evaporated into the atmosphere
or injected as necessary. Recovered oil and condensate are stored on-site in tanks before being trucked
off-site for sale. In addition to the produced water operations the facility will treat contaminated soils
received from spills and other oil and gas production operations. The contaminated soils will be land
applied, watered, and tilled regularly or permanently disposed of in the landfill to minimize emissions to
the atmosphere.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Uinta Basin O3 NAA
Duchesne County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
DAQE-AN154870003-24
Page 4

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
IWM has requested to add four (4) 500 bbl storage tanks to the water receiving side of its produced water
facility. No changes to IWM's oil cleaning process will happen as a result of this NOI.

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 6232.00
Carbon Monoxide 0 9.13
Nitrogen Oxides 0 4.69
Particulate Matter - PM10 0 1.54
Particulate Matter - PM2.5 0 0.14
Sulfur Dioxide 0 0.03
Volatile Organic Compounds 0.03 57.70

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 240
Ethyl Benzene (CAS #100414) 0 40
Generic HAPs (CAS #GHAPS) 0 260
Methanol (CAS #67561) 0 12440
Toluene (CAS #108883) 0 320
Xylenes (Isomers And Mixture) (CAS #1330207) 0 260
Change (TPY) Total (TPY)
Total HAPs 0 6.78

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-AN154870003-24
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 IWM - Produced Water Facility
Produced Water and Solids Treatment Facility

II.A.2 Emergency Storage Pond

II.A.3 Landfarm
Treatment of contaminated soil

II.A.4 Landfill
Treatment of solids from decanting tanks, centrifuges, and other processes

II.A.5 One (1) Filter Pot

II.A.6 Twenty-three (23) Storage Tanks (4 New)
Maximum capacity: 500 bbl (each)
Contents: Received Fluids
All controlled by a combustor

II.A.7 Nine (9) Injection Storage Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

DAQE-AN154870003-24
Page 6

II.A.8 Four (4) Centrifuge Feed Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

II.A.9 One (1) Oil Pump Tank
Maximum capacity: 500 gal
Controlled by a combustor

II.A.10 One (1) Water Pump Tank
Maximum capacity: 500 gal
Controlled by a combustor

II.A.11 One (1) Centrifuge Water Collection Tank
Maximum capacity: 500 bbl
Controlled by a combustor

II.A.12 Four (4) Oil Storage Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

II.A.13 One (1) Fresh Water Tank
Contents: Clean water used for boiler

II.A.14 Seven (7) Brine Water Storage Tanks
Contents: Clean Brine Water

II.A.15 Tank Heaters
Maximum rated capacity: less than 5.0 MMBtu/hr (each)
Fuel: Natural Gas

II.A.16 One (1) Boiler
Fuel: Propane
Rating: 1.4 MMBtu/hr

II.A.17 Two (2) Centrifuges

II.A.18 Solids Storage Container
Contents: Sludge from tanks, centrifuges, etc.
Capacity: 28 cubic feet
Controlled by combustor

II.A.19 Evaporation Ponds
Total combined pond throughput: 125,000 BBLS/yr

II.A.20 Two (2) Combustors

II.A.21 Generator Engine
Fuel: Diesel
Maximum engine rating: 70 hp
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.22 Miscellaneous Equipment
Small Engines listed under 25 hp

DAQE-AN154870003-24
Page 7

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Source-Wide Requirements.
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary point or fugitive source on site to exceed 20% opacity. [R307-401-8]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Produced Water Requirements
II.B.2.a The owner/operator shall not exceed the following emissions limits:

A. 9.35 tons of combined GRO + DRO emissions (where GRO shall be considered
the measurement of organics in the C6 - C10 range and DRO shall be considered
the measurement of organics in the C11 - C28 range) from water sent to the
evaporation ponds per rolling 12-month period

B. 6.22 tons of Methanol emissions from the evaporation ponds per rolling
12-month period

C. 0.31 tons of combined HAP emissions (excluding Methanol) from the
evaporation ponds per rolling 12-month period.

[R307-401-8]

II.B.2.a.1
NEW
To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the last day of each month using data from the previous 12 months. Combined
VOC (GRO + DRO), HAPs, and methanol emissions shall be calculated using the following
formulas:

VOC (tons) = (water volume) x (VOC (GRO + DRO) sampled concentrations)

HAPs (tons) = (water volume) x (BTEX sampled concentrations)

Methanol (tons) = (water volume) x (methanol sampled concentrations)

Records of the water received shall be kept for all periods when the plant is in operation. The
water volume received shall be determined on a daily basis using billable receipts. Sample
requirements are described in Condition II.B.2.a.2.

[R307-401-8]

DAQE-AN154870003-24
Page 8

II.B.2.a.2

A sampling of processed water shall be collected and analyzed, at a minimum, once monthly.
The sample shall be collected, handled, and analyzed as follows:

A. Sample shall be collected at the outfall of the treatment process prior to the water
being discharged into the evaporation ponds

B. Sample shall be no less than 8oz. in volume

C. The sample shall be analyzed no more than 7 days after collection. Samples
shall be stored at a temperature no less than 32°F and no more than 40°F prior
to analysis

D. Samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10), TPH-
DRO (C11 - C28), and using appropriate EPA methods such as Method 8260 or
8015, or another EPA approved method as acceptable to the Director.

[R307-401-8]

II.B.2.a.3 For every month of non-compliance with the requirement of monthly sampling of the effluent
discharged into the evaporation ponds, except for periods of shutdown, the source is required to
report 10 tons of methanol emissions. This will require the owner/operator to comply with the
requirements of the Title V program, which includes paying all Title V fees and obtaining an
Operating Permit. [R307-401-8]

II.B.2.a.4 The owner/operator has 12 months from the date the Title V applicability is triggered to submit a
complete Title V application. [R307-401-8]

II.B.2.a.5 The owner/operator shall keep records of the periods when no water was received due to
breakdown, shutdown, or bypass. The records shall include the date of breakdown, shutdown, or
bypass and date operations began again. [R307-401-8]

II.B.3 Landfarm Requirements
II.B.3.a

The owner/operator shall not exceed the following emissions limits:

A. 33.48 tons of VOC emissions from the processed soil per rolling 12-month
period

B. 6.78 tons of total combined HAP emissions from the processed soil per rolling
12-month period.

[R307-401-8]

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the last day of each month using data from the previous 12 months. Combined
VOC and HAPs emissions shall be calculated using the following formula:

tons VOC and HAPs/month = (soil volume) X (soil density [2,200 lbs/yrd^3]) X (GRO + DRO
sampled concentrations) X (0.6 atmospheric emission rate)

Records of the soil received shall be kept for all periods when the plant is in operation. The soil
volume received shall be determined on a daily basis using billable receipts. The records for
received soil shall be kept on a daily basis using billable receipts. Sample requirements are
described in Condition II.B.3.b.

[R307-401-8]

DAQE-AN154870003-24
Page 9

II.B.3.b The owner/operator shall conduct initial sampling for all received soils prior to any land
application. The sample shall be collected, handled, and analyzed as follows:

A. Sample shall be as representative of the load as possible and be taken after any
soil amendments and adjustments

B. Sample shall be no less than 8oz. in volume

C. The sample shall be sent off for analysis or frozen within 24 hours after
collection. Frozen samples shall be stored until 20 samples are collected, or 30
calendar days have expired whichever comes first, at which point the samples
can be combined to generate a single composite sample to be sent off for
analysis

D. Samples shall be analyzed for TPH-GRO (C6 - C10) and TPH-DRO (C11 - C28)
using appropriate EPA methods such as Method 8260 or 8015, or other EPA
approved testing methods approved by the Director.

[R307-401-8]

II.B.3.b.1 To determine compliance with soil sampling, the owner/operator shall keep a record of all soil
samples while the plant is in operation. [R307-401-8]

II.B.3.c The owner/operator shall store the waste soil in a sealed container and shall spread and disk/till
the waste soil within seven (7) days after receipt when conditions permit. [R307-401-8]

II.B.3.c.1 If conditions prohibit the application of waste soil within the allotted time frame, a record must
be kept for every occurrence when the time frame was exceeded and what conditions caused the
exceedance. [R307-401-8]

II.B.3.d Prior to land application of any soils, the owner/operator shall treat the soil as follows to
maximize biodegradation:

A. Amend the soil as needed by adding bacterial inoculate, nutrients, and/or soil
amendments

B. Adjust water content above 5%

C. Adjust pH to above 6 and below 8

D. Take two (2) representative 8 oz. soil samples from below the soil surface, and
freeze for sample analysis.

[R307-401-8]

DAQE-AN154870003-24
Page 10

II.B.3.d.1 To determine compliance with soil amendments, prior to land application the owner/operator
shall keep records of the following:

A. Dates soil received, treated, and applied

B. Plot where soil is applied

C. Water content of the soil, measured by handheld probe

D. pH of soil, measured by handheld probe

E. Quantity of nutrients and soil amendments added to the soil, if any

[R307-401-8]

II.B.3.e The owner/operator shall disk/till/turn the soil to a minimum of the following, when weather
conditions permit:

A. At least once per week for the first 30 days after application

B. At least once per month for the first 6 months.

[R307-401-8]

II.B.3.e.1 The owner/operator shall keep records of all disking/tilling operations to determine compliance
with disking/tilling operations. Records shall include the following:

A. Plot location

B. Date of all disking/tilling operations

C. If weather conditions prohibit disking/tilling operations a record of the specific
conditions shall be kept.

[R307-401-8]

II.B.3.f The owner/operator shall use water applications on all operational areas to reduce fugitive dust
emissions as well as maintain an adequate moisture content to facilitate biological degradation of
hydrocarbons. [R307-401-8]

II.B.3.f.1 The owner/operator shall keep records of water application for all periods when the plant is in
operation to determine compliance. The records shall include the following items:

A. Date treatments were made

B. Location of treatments and quantity of water applied

C. Rainfall amount received, if any.

[R307-401-8]

DAQE-AN154870003-24
Page 11

II.B.4 Tank Requirements
II.B.4.a The owner/operator shall not process more than the following:

A. 145,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period

B. 5,000 barrels (1 barrel = 42 gallons) of condensate per rolling 12-month period.

[R307-401-8]

II.B.4.a.1 The owner/operator shall:

A. Determine process data by examination of sales receipts

B. Record process data every month

C. Use the process data to calculate a new rolling 12-month total by the
20th day of each month using data from the previous 12 months

D. Keep the process data on site at all times the facility is in
operation.

[R307-401-8]

II.B.4.b The owner/operator shall store centrifuge solids and tank sludge in an enclosed storage vessel
prior to treatment on site. [R307-401-8]

II.B.4.b.1 The owner/operator shall contain all sludge and centrifuge waste in the enclosed storage vessel at
the end of each business day. [R307-401-8]

II.B.4.c Secondary containment located under and around the centrifuge shall have no standing crude oil
or solids present at any time. [R307-401-8]

II.B.4.d The owner/operator shall load and unload all tanker trucks on site by the use of submerged
loading. [R307-401-8]

II.B.4.e The owner/operator shall keep the storage tank thief hatches closed and latched except during
tank loading, unloading, or other maintenance activities. [R307-401-8]

II.B.4.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief
hatches are closed, latched, and the associated gaskets, if any, are in good working condition.
Records of thief hatch inspections shall include the date of the inspection and the status of the
thief hatches. [R307-401-8]

II.B.5 Combustor Requirements
II.B.5.a The owner/operator shall route all exhaust gas/vapors from all storage tanks and storage
containers to a vapor capture system that is controlled by a combustor. [R307-401-8]

II.B.5.b The owner/operator shall operate combustors that are equipped with a continuous pilot flame and
an operational auto-igniter. [R307-503-4]

II.B.5.c The owner/operator shall operate the combustor with no visible emissions. [R307-401-8]

II.B.5.c.1 Visual determination of smoke emissions from the combustor shall be conducted according to 40
CFR 60, Appendix A, Method 22. [R307-401-8]

DAQE-AN154870003-24
Page 12

II.B.6 Engine Requirements
II.B.6.a The owner/operator shall install and operate a non-resettable hour meter on the 70-hp generator
engine. [R307-401-8]

II.B.6.b The owner/operator shall operate the 70-hp generator engine for no more than 2080 hours per
rolling 12-month period. [R307-401-8]

II.B.6.b.1 The owner/operator shall:

A. Determine hours of operation through the use of an hour meter

B. Record hours of operation monthly

C. Use the hours of operation data to calculate a new rolling 12-month total
by the 20th day of each month using data from the previous 12 months.

[R307-401-8]

II.B.6.c The owner/operator shall not allow the sulfur content of any diesel fuel burned in the generator
engine to exceed 15 ppm by weight. [R307-401-8]

II.B.6.d The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent.
Certification of fuels shall be either by the owner/operator's own testing or test reports from the
fuel marketer. [R307-401-8]

II.B.7 Haul Road Requirements
II.B.7.a The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources on site. [R307-205]

II.B.7.b Visible emissions from haul roads and fugitive dust sources shall not exceed 20% opacity.
[R307-401-8]

II.B.7.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-401-8]

II.B.7.c All unpaved roads and other unpaved operational areas that are used by mobile equipment shall
be water sprayed to control fugitive dust. The application of water shall be used except when the
ambient temperature is below freezing. Treatment shall be of sufficient frequency and quantity
to meet the opacity limits listed in this AO, or as determined necessary by the Director.
[R307-401-8]

II.B.7.c.1 Records of water treatment shall be kept for all periods when the plant is in operation. The
records shall include the following items:

A. Date of treatment

B. Number of treatments made

C. Records of temperature if the temperature is below freezing.

[R307-401-8]

DAQE-AN154870003-24
Page 13

PERMIT HISTORY

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

Supersedes AO DAQE-AN154870002-19 dated November 22, 2019
Is Derived From NOI dated August 16, 2022
Incorporates Additional Information dated October 3, 2022
Incorporates Additional Information dated October 10, 2022
Incorporates Additional Information dated December 1, 2022
Incorporates Additional Information dated March 7, 2023

DAQE-AN154870003-24
Page 14

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-IN154870003-23

November 22, 2023

Russel Sorensen
Integrated Water Management
PO Box 430
Altamont, UT 84001
[e-mail]

Dear Mr. Sorensen:

Re: Intent to Approve: Modification to Approval Order DAQE-AN154870001-19 to Add Four (4)
500 bbl Storage Tanks
Project Number: N154870003

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Persons, as well as the
DAQE number as shown on the upper right-hand corner of this letter. John Persons, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:JP:jg

cc: TriCounty 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

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN154870003-23
Modification to Approval Order DAQE-AN154870001-19 to Add
Four (4) 500 bbl Storage Tanks

Prepared By
John Persons, Engineer
[phone]
[e-mail]

Issued to
Integrated Water Management - Produced Water Facility

Issued On
November 22, 2023

{{$s }}

New Source Review Section Manager
Alan D. Humpherys
{{#s=Sig_es_:signer1:signature}}

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 ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 7
PERMIT HISTORY ................................................................................................................... 13
ACRONYMS ............................................................................................................................... 14

DAQE-IN154870003-23
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Integrated Water Management Integrated Water Management - Produced Water
Facility

Mailing Address Physical Address
PO Box 430 SE-SE Sec 30 T2S R4W
Altamont, UT 84001 Duchesne, UT 84088

Source Contact UTM Coordinates
Name Russel Sorensen 553,295 m Easting
Phone [phone],458,127 m Northing
Email [e-mail] Datum NAD83
UTM Zone 12

SIC code 1389 (Oil & Gas Field Services, NEC)

SOURCE INFORMATION
General Description
Integrated Water Management (IWM) is a produced water and solids treatment facility for the oil and gas
production sector. Produced water is received by truck and pipeline from oil and gas operations. The
water then undergoes phase separation using tanks and centrifuges for the recovery of oil and condensate.
The remaining water is then injected into a well on site or discharged into evaporation ponds when
necessary. Water entering the evaporation ponds remains until it has been evaporated into the atmosphere
or injected as necessary. Recovered oil and condensate are stored on-site in tanks before being trucked
off-site for sale. In addition to the produced water operations the facility will treat contaminated soils
received from spills and other oil and gas production operations. The contaminated soils will be land
applied, watered, and tilled regularly or permanently disposed of in the landfill to minimize emissions to
the atmosphere.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Uinta Basin O3 NAA
Duchesne County
Airs Source Size: B

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-IN154870003-23
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MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
IWM has requested to add four (4) 500 bbl storage tanks to the water receiving side of its produced water
facility. No changes to IWM's oil cleaning process will happen as a result of this NOI.

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 6232.00
Carbon Monoxide 0 9.13
Nitrogen Oxides 0 4.69
Particulate Matter - PM10 0 1.54
Particulate Matter - PM2.5 0 0.14
Sulfur Dioxide 0 0.03
Volatile Organic Compounds 0.03 57.70

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 240
Ethyl Benzene (CAS #100414) 0 40
Generic HAPs (CAS #GHAPS) 0 260
Methanol (CAS #67561) 0 12440
Toluene (CAS #108883) 0 320
Xylenes (Isomers And Mixture) (CAS #1330207) 0 260
Change (TPY) Total (TPY)
Total HAPs 0 6.78

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Uintah Basin Standard on November 29, 2023. During the
public comment period the proposal and the evaluation of its impact on air quality will be available for
the public to review and provide comment. If anyone so requests a public hearing within 15 days of
publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as
practicable to the location of the source. Any comments received during the public comment period and
the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the
comments received.

DAQE-IN154870003-23
Page 5

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.

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]

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.

II.A THE APPROVED EQUIPMENT

II.A.1 IWM - Produced Water Facility
Produced Water and Solids Treatment Facility

DAQE-IN154870003-23
Page 6

II.A.2 Emergency Storage Pond

II.A.3 Landfarm
Treatment of contaminated soil

II.A.4 Landfill
Treatment of solids from decanting tanks, centrifuges, and other processes

II.A.5 One (1) Filter Pot

II.A.6 Twenty-three (23) Storage Tanks (4 New)
Maximum capacity: 500 bbl (each)
Contents: Received Fluids
All controlled by a combustor

II.A.7 Nine (9) Injection Storage Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

II.A.8 Four (4) Centrifuge Feed Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

II.A.9 One (1) Oil Pump Tank
Maximum capacity: 500 gal
Controlled by a combustor

II.A.10 One (1) Water Pump Tank
Maximum capacity: 500 gal
Controlled by a combustor

II.A.11 One (1) Centrifuge Water Collection Tank
Maximum capacity: 500 bbl
Controlled by a combustor

II.A.12 Four (4) Oil Storage Tanks
Maximum capacity: 500 bbl (each)
All controlled by a combustor

II.A.13 One (1) Fresh Water Tank
Contents: Clean water used for boiler

II.A.14 Seven (7) Brine Water Storage Tanks
Contents: Clean Brine Water

II.A.15 Tank Heaters
Maximum rated capacity: less than 5.0 MMBtu/hr (each)
Fuel: Natural Gas

II.A.16 One (1) Boiler
Fuel: Propane
Rating: 1.4 MMBtu/hr

II.A.17 Two (2) Centrifuges

DAQE-IN154870003-23
Page 7

II.A.18 Solids Storage Container
Contents: Sludge from tanks, centrifuges, etc.
Capacity: 28 cubic feet
Controlled by combustor

II.A.19 Evaporation Ponds
Total combined pond throughput: 125,000 BBLS/yr

II.A.20 Two (2) Combustors

II.A.21 Generator Engine
Fuel: Diesel
Maximum engine rating: 70 hp
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ

II.A.22 Miscellaneous Equipment
Small Engines listed under 25 hp

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.

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Source-Wide Requirements.
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary point or fugitive source on site to exceed 20% opacity. [R307-401-8]

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-201-3]

II.B.2 Produced Water Requirements
II.B.2.a The owner/operator shall not exceed the following emissions limits:

A. 9.35 tons of combined GRO + DRO emissions (where GRO shall be considered
the measurement of organics in the C6 - C10 range and DRO shall be considered
the measurement of organics in the C11 - C28 range) from water sent to the
evaporation ponds per rolling 12-month period

B. 6.22 tons of Methanol emissions from the evaporation ponds per rolling
12-month period

C. 0.31 tons of combined HAP emissions (excluding Methanol) from the
evaporation ponds per rolling 12-month period.

[R307-401-8]

DAQE-IN154870003-23
Page 8

II.B.2.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the last day of each month using data from the previous 12 months. Combined
VOC (GRO + DRO), HAPs, and methanol emissions shall be calculated using the following
formulas:

VOC (tons) = (water volume) x (VOC (GRO + DRO) sampled concentrations)

HAPs (tons) = (water volume) x (BTEX sampled concentrations)

Methanol (tons) = (water volume) x (methanol sampled concentrations)

Records of the water received shall be kept for all periods when the plant is in operation. The
water volume received shall be determined on a daily basis using billable receipts. Sample
requirements are described in Condition II.B.2.d.1.

[R307-401-8]

II.B.2.a.2 A sampling of processed water shall be collected and analyzed, at a minimum, once monthly.
The sample shall be collected, handled, and analyzed as follows:

A. Sample shall be collected at the outfall of the treatment process prior to the water
being discharged into the evaporation ponds

B. Sample shall be no less than 8oz. in volume

C. The sample shall be analyzed no more than 7 days after collection. Samples shall
be stored at a temperature no less than 32 °F and no more than 40 °F prior to
analysis

D. Samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10), TPH-
DRO (C11 - C28), and using appropriate EPA methods such as Method 8260 or
8015, or another EPA approved method as acceptable to the Director.

[R307-401-8]

II.B.2.a.3 For every month of non-compliance with the requirement of monthly sampling of the effluent
discharged into the evaporation ponds, except for periods of shutdown, the source is required to
report 10 tons of methanol emissions. This will require the owner/operator to comply with the
requirements of the Title V program, which includes paying all Title V fees and obtaining an
Operating Permit. [R307-401-8]

II.B.2.a.4 The owner/operator has 12 months from the date the Title V applicability is triggered to submit a
complete Title V application. [R307-401-8]

II.B.2.a.5 The owner/operator shall keep records of the periods when no water was received due to
breakdown, shutdown, or bypass. The records shall include the date of breakdown, shutdown, or
bypass and date operations began again. [R307-401-8]

II.B.3 Landfarm Requirements
DAQE-IN154870003-23
Page 9

II.B.3.a The owner/operator shall not exceed the following emissions limits:

A. 33.48 tons of VOC emissions from the processed soil per rolling 12-month
period

B. 6.78 tons of total combined HAP emissions from the processed soil per rolling
12-month period.

[R307-401-8]

II.B.3.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the last day of each month using data from the previous 12 months. Combined
VOC and HAPs emissions shall be calculated using the following formula:

tons VOC and HAPs/month = (soil volume) X (soil density [2,200 lbs/yrd^3]) X
(GRO + DRO sampled concentrations) X (0.6 atmospheric emission rate).

Records of the soil received shall be kept for all periods when the plant is in operation. The soil
volume received shall be determined on a daily basis using billable receipts. The records for
received soil shall be kept on a daily basis using billable receipts. Sample requirements are
described in Condition II.B.3.b.

[R307-401-8]

II.B.3.b The owner/operator shall conduct initial sampling for all received soils prior to any land
application. The sample shall be collected, handled, and analyzed as follows:

A. Sample shall be as representative of the load as possible and be taken after any
soil amendments and adjustments

B. Sample shall be no less than 8oz. in volume

C. The sample shall be sent off for analysis or frozen within 24 hours after
collection. Frozen samples shall be stored until 20 samples are collected, or 30
calendar days have expired whichever comes first, at which point the samples
can be combined to generate a single composite sample to be sent off for
analysis

D. Samples shall be analyzed for TPH-GRO (C6 - C10) and TPH-DRO (C11 - C28)
using appropriate EPA methods such as Method 8260 or 8015, or other EPA
approved testing methods approved by the Director.

[R307-401-8]

II.B.3.b.1 To determine compliance with soil sampling, the owner/operator shall keep a record of all soil
samples while the plant is in operation. [R307-401-8]

II.B.3.c The owner/operator shall store the waste soil in a sealed container and shall spread and disk/till
the waste soil within 7 days after receipt when conditions permit. [R307-401-8]

II.B.3.c.1 If conditions prohibit the application of waste soil within the allotted time frame, a record must
be kept for every occurrence when the time frame was exceeded and what conditions caused the
exceedance. [R307-401-8]

DAQE-IN154870003-23
Page 10

II.B.3.d Prior to land application of any soils, the owner/operator shall treat the soil as follows t o
maximize biodegradation:

A. Amend the soil as needed by adding bacterial inoculate, nutrients, and/or soil
amendments

B. Adjust water content above 5%

C. Adjust pH to above 6 and below 8

D. Take two (2) representative 8 oz. soil samples from below the soil surface, and
freeze for sample analysis.

[R307-401-8]

II.B.3.d.1 To determine compliance with soil amendments, prior to land application the owner/operator
shall keep records of the following:

A. Dates soil received, treated, and applied

B. Plot where soil is applied

C. Water content of the soil, measured by handheld probe

D. pH of soil, measured by handheld probe

E. Quantity of nutrients and soil amendments added to the soil, if any.

[R307-401-8]

II.B.3.e The owner/operator shall disk/till/turn the soil to a minimum of the following, when weather
conditions permit:

A. At least once per week for the first 30 days after application

B. At least once per month for the first 6 months.

[R307-401-8]

II.B.3.e.1 The owner/operator shall keep records of all disking/tilling operations to determine compliance
with disking/tilling operations. Records shall include the following:

A. Plot location

B. Date of all disking/tilling operations

C. If weather conditions prohibit disking/tilling operations a record of the specific
conditions shall be kept.

[R307-401-8]

II.B.3.f The owner/operator shall use water applications on all operational areas to reduce fugitive dust
emissions as well as maintain an adequate moisture content to facilitate biological degradation of
hydrocarbons. [R307-401-8]

DAQE-IN154870003-23
Page 11

II.B.3.f.1 The owner/operator shall keep records of water application for all periods when the plant is in
operation to determine compliance. The records shall include the following items:

A. Date treatments were made

B. Location of treatments and quantity of water applied

C. Rainfall amount received, if any.

[R307-401-8]

II.B.4 Tank Requirements
II.B.4.a The owner/operator shall not process more than the following:

A. 145,000 barrels (1 barrel = 42 gallons) of crude oil per rolling 12-month period

B. 5,000 barrels (1 barrel = 42 gallons) of condensate per rolling 12-month period.

[R307-401-8]

II.B.4.a.1 The owner/operator shall:

A. Determine process data by examination of sales receipts

B. Record process data every month

C. Use the process data to calculate a new rolling 12-month total by the
20th day of each month using data from the previous 12 months

D. Keep the process data on site at all times the facility is in
operation.

[R307-401-8]

II.B.4.b The owner/operator shall store centrifuge solids and tank sludge in an enclosed storage vessel
prior to treatment on site. [R307-401-8]

II.B.4.b.1 The owner/operator shall contain all sludge and centrifuge waste in the enclosed storage vessel at
the end of each business day. [R307-401-8]

II.B.4.c Secondary containment located under and around the centrifuge shall have no standing crude oil
or solids present at any time. [R307-401-8]

II.B.4.d The owner/operator shall load and unload all tanker trucks on site by the use of submerged
loading. [R307-401-8]

II.B.4.e The owner/operator shall keep the storage tank thief hatches closed and latched except during
tank loading, unloading, or other maintenance activities. [R307-401-8]

II.B.4.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief
hatches are closed, latched, and the associated gaskets, if any, are in good working condition.
Records of thief hatch inspections shall include the date of the inspection and the status of the
thief hatches. [R307-401-8]

II.B.5 Combustor Requirements
II.B.5.a The owner/operator shall route all exhaust gas/vapors from all storage tanks and storage
containers to a vapor capture system that is controlled by a combustor. [R307-401-8]

DAQE-IN154870003-23
Page 12

II.B.5.b The owner/operator shall operate combustors that are equipped with a continuous pilot flame and
an operational auto-igniter. [R307-503-4]

II.B.5.c The owner/operator shall operate the combustor with no visible emissions. [R307-401-8]

II.B.5.c.1 Visual determination of smoke emissions from the combustor shall be conducted according to 40
CFR 60, Appendix A, Method 22. [R307-401-8]

II.B.6 Engine Requirements
II.B.6.a The owner/operator shall install and operate a non-resettable hour meter on the 70-hp generator
engine. [R307-401-8]

II.B.6.b The owner/operator shall operate the 70-hp generator engine for no more than 2080 hours per
rolling 12-month period. [R307-401-8]

II.B.6.b.1 The owner/operator shall:

A. Determine hours of operation through the use of an hour meter

B. Record hours of operation monthly

C. Use the hours of operation data to calculate a new rolling 12-month total
by the 20th day of each month using data from the previous 12 months.

[R307-401-8]

II.B.6.c The owner/operator shall not allow the sulfur content of any diesel fuel burned in the generator
engine to exceed 15 ppm by weight. [R307-401-8]

II.B.6.d The sulfur content shall be determined by ASTM Method D-4294-89, or approved equivalent.
Certification of fuels shall be either by the owner/operator's own testing or test reports from the
fuel marketer. [R307-401-8]

II.B.7 Haul Road Requirements
II.B.7.a The owner/operator shall comply with all applicable requirements of R307-205 for Fugitive
Emission and Fugitive Dust sources on site. [R307-205]

II.B.7.b Visible emissions from haul roads and fugitive dust sources shall not exceed 20% opacity.
[R307-401-8]

II.B.7.b.1 Visible emission determinations for fugitive dust emissions from haul-road traffic and mobile
equipment in operational areas shall use procedures similar to Method 9. The normal
requirement for observations to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than 1/2 vehicle length behind the vehicle and not less than 1/2 the height
of the vehicle. [R307-401-8]

II.B.7.c All unpaved roads and other unpaved operational areas that are used by mobile equipment shall
be water sprayed to control fugitive dust. The application of water shall be used except when the
ambient temperature is below freezing. Treatment shall be of sufficient frequency and quantity
to meet the opacity limits listed in this AO, or as determined necessary by the Director.
[R307-401-8]

DAQE-IN154870003-23
Page 13

II.B.7.c.1 Records of water treatment shall be kept for all periods when the plant is in operation. The
records shall include the following items:

A. Date of treatment

B. Number of treatments made

C. Records of temperature if the temperature is below freezing.

[R307-401-8]

PERMIT HISTORY

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

Supersedes AO DAQE-AN154870002-19 dated November 22, 2019
Is Derived From NOI dated August 16, 2022
Incorporates Additional Information dated October 3, 2022
Incorporates Additional Information dated October 10, 2022
Incorporates Additional Information dated December 1, 2022
Incorporates Additional Information dated March 7, 2023

DAQE-IN154870003-23
Page 14

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-NN154870003-23

November 22, 2023

Uintah Basin Standard
Legal Advertising Department
268 South 200 East
Roosevelt, UT 84066

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Uintah Basin Standard
(Account Number: 3207) on November 29, 2023.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Duchesne County
cc: Uintah Basin Association of Governments

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

DAQE-NN154870003-23
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Integrated Water Management
Location: Integrated Water Management - Produced Water Facility – SE-SE Sec 30 T2S
R4W, Duchesne, UT
Project Description: Integrated Water Management (IWM) is a produced water and solids treatment
facility for the oil and gas production sector. IWM has requested to add four (4)
500 bbl storage tanks to the water receiving side of its produced water facility.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before December 29, 2023 will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: November 29, 2023

{{#s=Sig_es_:signer1:signature}}

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-1

Table B-1. Approximate Equipment Location and Stack Height Information.
Source Location (UTM Zone 12) Release Height (ft) Easting (m) Northing (m)
Tanks: Off Loading 553290.32 4458157.41
NA
Tanks.: Separation
Tanks: Centrifuge Feed 553391.74 4458088.00 Tanks: Centrifuge Misc
Tanks: Oil Sales 553391.74 4458088.00
Tanks: Pre Injection 553348.93 4458190.50
Injection Well 553344.72 4458150.71
Flare 553397.23 4458194.81 18
Engines 553315.18 4458095.68 2
Storage Pond 553435.63 4458369.61
0 Landfill 553333.10 4458339.85
Land Farm 553531.21 4458772.44

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-2

Table B-2a. Facility Uncontrolled Emissions (tons/yr).
Estimated Emissions in tons/yr (Uncontrolled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks 29.9 1.01 0.09 0.16 0.06 0.24 NA NA NA NA NA NA NA NA AP-42
Centrifuge Solids 248 7.3 0.17 1.82 0.18 5.12 NA NA NA NA NA NA NA NA Measured
Drilling Mud 13.0 0.10 0.001 0.01 0.004 0.04 NA NA NA NA NA NA NA NA Measured
Imported Solids 55.5 0.08 ND 0.002 0.001 0.013 NA NA NA NA NA NA NA NA Measured
Evaporation Pond 9.35 4.46 0.10 0.12 0.007 0.07 NA 4.15 NA NA NA NA NA NA Measured
Engines 0.18 2.34E-04 5.81E-05 2.55E-05 NA 1.78E-05 NA NA 9.7 0.06 0.01 NA 0.01 0.12 AP-42
Tank Heaters 0.24 NA NA NA NA NA 0.05 NA 3,104 1.89 0.14 NA 0.02 3.25 AP-42
Loading 19.8 0.38 0.04 0.06 0.02 0.09 NA NA NA NA NA NA NA NA AP-42
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 5.54 0.55 NA NA AP-42
Fugitive VOCs (Leaks) 0.04 0.0015 1.40E-04 0.0002 8.32E-05 0.0004 NA NA NA NA NA NA NA NA AP-42
Total Emissions 376 13.3 0.41 2.18 0.27 5.58 0.05 4.15 3,113 1.95 5.69 0.55 0.03 3.37
Notes: NA: Not Applicable

Table B-2b. Facility Controlled Emissions (tons/yr).
Estimated Emissions in tons/yr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks 0.60 0.02 0.002 0.003 0.001 0.005 NA NA NA NA NA NA NA NA Calc.
Centrifuge Solids 4.84 0.02 0.001 0.014 0.002 0.01 31.48 NA 86.38 NA NA NA NA NA EPA
LandGEM Drilling Mud
Imported Solids 33.4 0.08 ND 0.002 0.001 0.01 NA NA NA NA NA NA NA NA Calc.
Evaporation Ponds 9.35 4.46 0.10 0.12 0.007 0.07 NA 4.15 NA NA NA NA NA NA Measured
Engines 0.18 2.34E-04 5.81E-05 2.55E-05 NA 1.78E-05 NA NA 9.7 0.06 0.01 NA 0.01 0.12 Calc.
Tank Heaters 0.24 NA NA NA NA NA 0.05 NA 3,104 1.89 0.14 NA 0.02 3.25 Calc.
Flare (combustion) 2.72 NA NA NA NA NA 1.49 NA 3,032 7.18 NA NA NA 1.32 Calc.
Loading 6.3 0.12 0.011 0.020 0.007 0.029 NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 1.39 0.139 NA NA Calc.
Fugitive VOCs (Leaks) 0.04 1.51E-03 1.40E-04 2.43E-04 8.32E-05 3.63E-04 NA NA NA NA NA NA NA NA Calc.
Total Emissions 57.7 4.71 0.12 0.16 0.02 0.13 33.0 4.15 6,232 9.13 1.54 0.14 0.03 4.69
Notes: NA: Not Applicable

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-3

Table B-3. Facility Controlled Emissions (lbs/hr).
Estimated Emissions in lbs/hr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks1 0.14 4.61E-03 4.26E-04 7.40E-04 2.54E-04 0.001 NA NA NA NA NA NA NA NA Calc.
Centrifuge Solids1 1.10 0.005 1.3E-04 0.003 4.38E-04 0.001 7.19 NA 19.7 NA NA NA NA NA Calc.
Drilling Mud1 Calc.
Imported Solids Solids1 7.6 0.02 ND 3.53E-04 1.89E-04 0.003 NA NA NA NA NA NA NA NA Calc.
Engines2 0.30 3.98E-04 9.90E-05 4.34E-05 NA 3.03E-05 NA NA 16.5 0.11 0.01 NA 0.01 0.20 Calc.
Tank Heaters3 0.16 NA NA NA NA NA 0.03 NA 2,120 1.29 0.10 NA 0.01 2.22 Calc.
Flare (combustion)1 0.62 NA NA NA NA NA 0.34 NA 692 1.64 NA NA NA 0.30 Calc.
Loading4 22.8 0.44 0.04 0.07 0.02 0.11 NA NA NA NA NA NA NA NA Calc.
Unpaved Roads5 NA NA NA NA NA NA NA NA NA NA 0.26 0.03 NA NA Calc.
Fugitive VOCs (Leaks)1 0.01 3.45E-04 3.2E-05 5.5E-05 1.9E-05 8.3E-05 NA NA NA NA NA NA NA NA Calc.
Notes: 1: Assumes emissions occur 365 days per year and 24 hours per day
2: Assumes a running time of 3224 hrs/yr (total combined engine hours)
3: Assumes 2,928 hours of operation per year (1/3 of the year)
4: Assumes 1812 loads per year that take 0.5 hours each (906 hrs/yr)
5: Assumes 22,896 deliveries per year that take 15 minutes to drive through the facility

Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Process Benzene Toluene Ethyl Benzene Xylene Naphthalene Tetrachloroethylene Formaldehyde Methanol Acetaldehyde Acrolein Distance to
Boundary (m)
Vertically
Restricted?
TLV HAPS Analysis
Category
Landfarm ND 3.5E-04 1.9E-04 2.9E-03 6.0E-04 9.1E-05 NA NA NA NA 10 Yes <20 m (restricted) TLV Limit 0.082 3.84 4.43 44.29 2.67 8.65 0.01 14.20 1.71 0.01 -- --
Landfill 1.3E-04 3.2E-03 4.4E-04 1.1E-03 NA NA NA NA NA NA 34 Yes 20-50 m (restricted) TLV Limit 0.105 4.97 5.73 57.31 3.46 11.19 0.02 18.38 2.30 0.01 -- --
Leaks (Fugitive VOCs) 3.2E-05 5.5 E-05 1.9E-05 8.3E-05 NA NA NA NA NA NA 50 Yes
50-100 m (restricted) Loading 0.04 0.07 0.02 0.11 NA NA NA NA NA NA 80 Yes
TLV Limit 0.197 9.27 10.68 106.81 6.45 20.85 0.03 34.25 4.14 0.02 -- --
Engines 9.90E-05 4.34E-05 NA 3.03E-05 6.2E-05 NA 8.7E-04 NA 5.6E-04 6.8E-05 35 No 50-100 m (unrestricted) TLV Limit 0.358 16.88 19.45 194.52 11.74 37.97 0.08 62.37 10.09 0.05 -- --
Flare NA NA NA NA NA NA NA NA NA NA 108 No >100 m (unrestricted) TLV Limit 0.588 27.73 31.96 319.57 19.29 62.39 0.11 102.47 13.96 0.07 -- --
Notes: NA: Not Applicable
ND: Not Detected

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-4

Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Estimated Emissions in Tons/yr (Controlled)
Process CO Fugitive PM10 Nonfugitive PM10 SOX NOX
Total Emissions (Controlled) 9.13 1.15 0.38 0.03 4.69
Criteria Pollutants Mod. Threshold 100 15 5 40 40

Table B-6. Regulatory Review.
State Regulatory Determinations
State Requirements Requirement Applicability Determination
R307-401. Permit:
New and Modified
Sources
Obtain an Approval Order
prior to construction
Applicable - facility exceeds the small source
exemption threshold for VOC as outlined in
R307-401-9
R307-405. Permits:
Major Sources in
Attainment Areas
Federal PSD
implementation
Not Applicable - the facility is not located in
a nonattainment or maintenance area.
R3074-415. Permits:
Operating Permit
Requirements
Federal Title V
implementation
Not Applicable - facility emissions are below
the Title V threshold limits.
40 CFR Part 63
Subpart DD
National Emission
Standards for Hazardous
Air Pollutants from Off-
Site Waste and Recovery
Operations
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single HAP
or 25 tons/yr of any combination of HAPs)
40 CFR Part 63
Subpart ZZZZ
National Emissions
Standards for Hazardous
Air Pollutants for
Stationary Reciprocating
Internal Combustion
Engines
Not Applicable - Facility does not operate
engines that may be subject to standards
applicable to area or major sources of HAP
40 CFR Part 63
Subpart DDDDD
National Emissions
Standards for Hazardous
Air Pollutants for Major
Sources: Industrial,
Commercial, and
Institutional Boilers and
Process Heaters
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single HAP
or 25 tons/yr of any combination of HAPs)
40 CFR Part 60
Subpart Dc
Standards of Performance
for Small Industrial-
commercial-Institutional
Steam Generating units
Not Applicable - Facility does not operate
any steam generating units with maximum
heat input greater than 10 MMBtu/hr
40 CFR Part 60
Subpart Kb
Standards of Performance
for Volatile Organic Liquid
Storage Vessels
Not Applicable - Facility does not operate
storage vessels with a capacity greater than
75 cubic meters.
Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-5

Federal Regulatory Determinations
Federal
Requirements Requirement Applicability Determination
40 CFR Part 60
Subpart IIII
Standards of Performance
for Stationary
Compression Ignition
Internal Combustion
Engines
Not Applicable - Compression ignition
engine(s) located at the Facility commenced
construction, modification or reconstruction
prior to July 11, 2005
40 CFR Part 60
Subpart JJJJ
Standards of Performance
for Stationary Spark
Ignition Internal
Combustion Engines
Not Applicable - Spark ignition engine(s)
located at the Facility commenced
construction, modification or reconstruction
prior to June 12, 2006
40 CFR Part 60
Subpart OOOO
Standards of Performance
for Crude Oil and Natural
Gas Production,
Transmission and
Distribution
Not Applicable - The facility does not
operate at as a production, transmission or
distribution facility. Facility does not operate
other potentially-affected sources covered
by the rule.
Table B-6. Regulatory Review (continued).

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-6

Table B-7a. BACT Controls Analysis of VOC Reductions and Emissions.
Control Source Control Capital
Cost
Annual
Cost
Life
Span
(yrs)
Interest
Rate
Annualized
Cost
VOC
Reduction
(tons)
Methanol
Reduction
(tons)
HAPs
Reduction
(tons)
VOC
Reduction
Costs ($/ton)
Methanol
Reduction Costs
($/ton)
HAPs
Reduction
Costs ($/ton)
Cost per barrel
of water1
Air Stripper + Thermal
Oxidizer + GAC
Storage Pond Water
$435,960 $2,951 20
3%
$32,254 8.85 0.41 0.46 $3,645 $78,668 $70,118 $0.26
Steam Stripper + Thermal
Oxidizer $2,788,890 $18,474 20 $205,931 9.30 3.94 4.24 $22,136 $52,267 $48,569 $1.65
Flare System Tank vapors $261,860 $36,565 20 $54,166 414 NA 14.0 $131 NA $3,866.25 $0.01
Notes: 1: Assumes 125,000 bbls of produced water processed annually for Evaporation pond and 7.3 million bbls for the Flare system.

Table B-7b. BACT Controls Analysis of PM Reductions and Emissions

Approval Order Modification Submittal

Integrated Water Management
Produced Water Disposal Facility

Notice of Intent (NOI)

August 16, 2022

Prepared by:

14425 S. Center Point Way, Bluffdale, Utah 84065
T: [phone] F: [phone]
IWM – August 2022 NOI

Copyright © 2022 GeoStrata Notice of Intent
Page | i
Table of Contents
INTRODUCTION ................................................................................................................... 1
1.1 Process Flow: ................................................................................................................... 1
1.1.1 Water ......................................................................................................................... 1
1.1.2 Oil ............................................................................................................................. 2
1.1.3 Solids......................................................................................................................... 2
EQUIPMENT DETAILS ........................................................................................................ 2
2.1 Storage Tanks ................................................................................................................... 3
2.1.1 Emissions Controls ................................................................................................... 3
FACILITY THROUGHPUT ................................................................................................... 3
EMISSIONS INFORMATION ............................................................................................... 4
4.1 Storage Tanks ................................................................................................................... 4
EMISSIONS IMPACT ASSESSMENT (EIA) ....................................................................... 4
REGULATORY REVIEW...................................................................................................... 4
BACT ANALYSIS .................................................................................................................. 4
7.1 Storage Tanks ................................................................................................................... 5
REFERENCES ........................................................................................................................ 7

IWM – August 2022 NOI

Copyright © 2022 GeoStrata Notice of Intent
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List of Figures
Figure A-1. Facility Location.
Figure A-2. Proposed Water Cleaning Facility Site Layout.
Figure A-3 Proposed Water Cleaning Facility Process Flow Diagram

List of Tables
Table B-1. Equipment Location and Stack Height Information.
Table B-2. Facility Controlled and Uncontrolled Emissions (tons/yr).
Table B-3. Facility Controlled Emissions (lbs/hr).
Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Table B-6. Regulatory Review.
Table B-7. BACT Controls Analysis Reductions and Emissions.

List of Appendices
Appendix A. Figures
Appendix B. Tables
Appendix C. Emissions Estimates
Appendix D. Equipment Specification Sheets
Appendix E. Utah DAQ Forms
Appendix F. EPA Tanks 4.09D Results
IWM – August 2022 NOI
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INTRODUCTION
The Integrated Water Management (IWM) operates a water disposal facility under the existing
Utah Division of Air Quality (UDAQ) Approval Order Number DAQE-AN154870001-19. It is
intent that IWM will adjust the existing equipment at this facility and will incorporate additional
tank storage capacity and remove and replace several tanks at the water receiving portion of the
facility. The changes to the tank storage will not affect the throughputs permit at the facility and
there are no proposed changes to the equipment or throughputs at the oil cleaning portion of the
facility.

This change to the storage tank equipment is an alteration to the layout of the facility and based
on conversations with representatives at UDAQ will require a new Notice of Intent (NOI) and
update to the Approval Order (AO). This NOI is submitted to the New Minor Source Review
group for review and modification of the existing AO. This submittal includes new updated
information reflecting how the IWM facility will operate going forward including new off-
loading tank emissions, updated facility wide emissions and an updated Best Available Control
Technology analysis. This introduction will review the key components of the facility and the
process flow of the facility with the proposed changes.

The IWM facility is located at UTM coordinates 553295.16 meters (m) East 4458126.96 m
North (zone 12 NAD 1983). The facility is located approximately 7.8 miles north of Duchesne,
Utah. Figure A-1 illustrates the location of the IWM facility. The existing facility layout is
illustrated in Figure A-2 and includes the following emissions sources:

1. Storage tanks for produced water, crude oil, and condensate,
2. Evaporation Ponds for treated water,
3. Mechanical oil, water, and solids separation equipment, (i.e., equipment leaks)
4. Centrifuge solids and other imported solids,
5. Tank heaters,
6. Truck loading, and
7. Unpaved roads.

IWM will be adding storage tanks to the water receiving storage tanks. These tanks are listed as
item II.A.6 under the approved equipment in the AO. The proposed layout with the new tank
configuration is shown on Figure A-3. The facility oil cleaning process will not be altered as part
of this NOI however it is proved in this introduction as a review of the process that is part of the
existing AO. The diagram in Figure A-4 show the existing process flow at the facility.
1.1 Process Flow:
1.1.1 Water
Produced water from oil production wells is delivered to the facility and pumped into a tank
battery consisting of twenty-three (23) off-loading tanks for initial gravity separation of water
IWM – August 2022 NOI
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and oil. Water separated in this process is then ran through a filter pot and routed to a set of nine
(9) pre-injection tanks. The water will then be routed and pumped into the deep injection well on
site. Water collected from the oil cleaning facility will be stored in a 500-bbl tank and piped back
to the decanting tanks at the head of the process. Figure A-4 and A-5 are process flow diagrams
that show the flow of water through the facility

1.1.2 Oil
The oil separated in any of the tanks as part of the water cleaning process will be loaded into a
tanker truck and moved to the proposed on-site oil cleaning facility where water and solids will
be removed from the oil. The trucks will unload the oil/water mixture to a filter pot and then into
one of four (4) tanks that will feed the oil/water mixture to the centrifuges for cleaning. As the
water/oil mixture is piped to the centrifuges it will be heated in a heat exchanger and then piped
to one of the two centrifuges located in the proposed oil cleaning building. Oil that is processed
through the centrifuge will be collected in a 500-gallon tank that feeds oil to a pump. Oil is
pumped and routed to one of four (4) oil storage tanks. Oil will remain in these tanks until it is
sold and transported off-site. See Figure A-4 and A-5 for further details.

1.1.3 Solids
The solids are separated from the oil and water primarily in the centrifuge and filter pots located
at the oil cleaning portion of the facility. Solids will also be separated from the water and oil in
the gravity separation tanks. The solids separated in the gravity separation will be routinely
cleaned out of the tanks and disposed in the onsite landfill. The solids removed during the
centrifuge process will be moved by an enclosed screw conveyor to a covered solids hopper. As
the hopper is filled with solids it will periodically be emptied into a haul truck and disposed in
the on-site landfill.

Drilling mud delivered to the site will be disposed directly into the landfill. All solids placed in
the landfill will have daily cover applied to control VOC off-gassing.

The IWM facility accepts off site sources of contaminated soils from oil and gas exploration and
production operations for treatment in its landfarm. These soils have typically been contaminated
by offsite sources, such as spills from oil production facilities, and the material typically has
fewer hydrocarbons than drilling mud and centrifuged solids. The imported solids will be mixed
into the landfarm at the northwest corner of the facility. The solids will be turned/aerated to
enhance biodegradation of the hydrocarbon content and to prevent stagnation of the oil and soil
substrate.
EQUIPMENT DETAILS
A list of equipment that will be modified as part of this NOI and associated emission controls are
provided below. The only section that has updated equipment is the Storage Tanks that are
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
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identified in the AO under Section II, II.A.6. All other equipment is unchanged from the AO. A
list of all of the emission sources, approximate coordinates and the stack heights are presented in
Table B-1 of Appendix B. For a complete list of the equipment please refer to the 2019 NOI and
the current AO.
2.1 Storage Tanks
Based on the updated configuration of the tanks at the facility, there will be a total of 44 tanks at
the facility that will be used as part of the water and oil cleaning processes each with various
capacities and contents. All tanks at the site have fixed roofs equipped with a thief hatch.
Twenty-three (23) vertical tanks are used as produced water decanting tanks where oil and water
are gravity separated. And additional nine (9) will be used to store water prior to injection into
the on-site deep well. These tanks will have a capacity of up to 500-bbl each. All of these tanks
are not heated.

There are twelve (12) tanks for the new oil cleaning portion of the facility. Of the twelve tanks
four (4) are used as the Centrifuge feed tanks, one (1) oil pump tank, one (1) water pump tank,
one (1) centrifuged water tank, four (4) oil storage tanks and (1) freshwater tank (no production
water) that will is associated with the boiler. All of these tanks are heated.

In addition to the water and oil cleaning tanks, there are seven (7) tanks on site that are used for
storing brine water and do not contain materials that would have air pollutants. There are also
several other tanks on site that have been put out-of-service and/or will be phased out-of-service
and IWM will clearly mark tanks as out-of-service and dispose these tanks as part of the
construction process of the new portions of the facility.

2.1.1 Emissions Controls
All tank emissions will be controlled by a vapor collection system that will discharge the
collected vapors to a combustor. The destruction efficiency of the combustor is estimated to be
98% (Appendix D, TCI Specification Sheet).
FACILITY THROUGHPUT
The annual throughput of material at the facility is summarized below. The throughputs provided
here are unchanged from the 2019 NOI.

1. Produced Water (oil/water mix): 7,300,000 bbl;
2. Oil (separated and delivered): 145,000 bbl;
3. Condensate: 5,000 bbl
4. Centrifuged Solids (wet): 1,880 cubic yards (yds3) (1,185 tons dry)
5. Drilling Mud (wet): 360,000 bbl (52,400 tons dry)
6. Imported Solids (wet): 6,000 yds3 (5,525 tons dry);
7. Propane use for the tank heaters: 256,000 gallons per year.
IWM – August 2022 NOI
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EMISSIONS INFORMATION
This section lists the estimated controlled and uncontrolled emissions from the facility and a
description of the methods used to estimate the emissions for the modified equipment in this
NOI. All other equipment emissions information can be found in the 2019 NOI. The facility
wide emissions have been estimated based on the additional tanks added as part of this NOI and
are found in Appendix B.
4.1 Storage Tanks
The emissions from the storage tanks were estimated using the “EPA Tanks” program. The
assumptions, calculations, and results from the AP-42 emissions estimates are included in
Appendix C. The uncontrolled and controlled annual emissions from the tanks are listed in Table
B-2 and the hourly controlled emissions are included in Table B-3. EPA Tanks output results are
provided in Appendix F.
EMISSIONS IMPACT ASSESSMENT (EIA)
Following the Utah DAQ Guidelines (UDAQ, 2012) an Emissions Impact Assessment (EIA)
was performed for all the sources at the IWM facility to determine if any of the emission rates
were above the Emission Threshold Value (ETV) and if the emission levels exceed the modeling
requirement. The ETVs for each pollutant were determined using the American Conference of
Governmental Industrial Hygienists (ACGIH) spreadsheet (UDAQ, 2013).

The emissions from each source at the facility were compared to the regulatory limits. The
distance from the source to the property boundary, the type of emissions discharge (restricted or
non-restricted), the ETV category, and the ETVs are listed in Table B-4. None of the constituents
emitted from the facility exceed the ETVs.

The total facility criteria pollutant emissions from the facility are compared to the Utah DAQ
dispersion modeling threshold values in Table B-5 (UDAQ, 2012). None of the annual facility
emissions exceed the modeling threshold values.
REGULATORY REVIEW
Relevant state and federal regulations are identified in Table B-6 with a description of the
applicability to the facility. Forms for this modification to the AO are found in Appendix E.
BACT ANALYSIS
The state of Utah requires a “top-down” approach for the Best Available Control Technology
(BACT) analysis which determines the most stringent control technology and emissions
limitation combination available for a similar source of emission units.

At the top of the “top-down” analysis are the control technologies and emissions limits that
represent the Lowest Achievable Emission Rate (LAER). As defined by NSR/PSD regulations,
IWM – August 2022 NOI
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LAER is the most effective control alternative and must be considered under the BACT analysis
process. The USEPA’s RACT/BACT/LAER Clearinghouse (RBLC) was used to identify recent
control technologies for similar units for this BACT analysis.

If the top level of control has adverse environmental, energy, or economic impacts, the
technology is rejected, and the next highest control is analyzed for impacts. This process is
continued until the BACT level under consideration cannot be eliminated by technical,
economic, energy, or environmental consideration. BACT cannot be determined to be less
stringent than the emissions limits established by an applicable New Source Performance
Standard (NSPS) for the affected air emissions source.

The economic impact of the control technologies is evaluated by determining the cost per ton of
pollutant removed. The annual cost per ton of constituent removed was determined using the
following equations (UDAQ BACT Guide).

𝐴=(𝐴+𝐴)/𝐴 Eq-1

&

𝐴=𝑃𝑉(𝑖
1−(1+𝑖)−𝑛) Eq-2

Where A is the annualized cost ($/ton), B is the annualized equipment cost, C is the annual
operation and maintenance cost, D is the annual emissions reduction (tons), PV is the present
value of the equipment, i is the interest rate (assumed to be 3%), and n is the life span of the
equipment. A description of the assumptions and calculations for estimating the controlled and
uncontrolled emissions are included in Appendix C. The results of the economic analysis are
included in Table B-7.
7.1 Storage Tanks
The constituents emitted from the storage tanks are VOCs and HAPs. The control of these
emissions includes the use of two technologies which are 1) Vapor Recovery and 2) destruction
(i.e., combustors). Vapor recovery systems for fixed roof tanks include a condenser that is
installed at the tank thief hatch (i.e., pressure valve). The vapors are condensed into a liquid state
and drip back down into the tank. The efficiency of a vapor recovery system ranges from 90% to
98% (AP-42 Section 7.2.1).

Control efficiency of combustors range from 95% to 99% destruction of VOC and HAP
emissions. The combustor produces combustion by products such as hydrocarbons, particulate
matter (PM), nitrogen oxides (NOX), carbon monoxide (CO), carbon dioxide (CO2), and odors.

IWM has constructed two combustors to control the VOC and HAP emissions from tanks and
other containments. One combustor is used on the water cleaning facility and the other
combustor is used on the oil cleaning facility. In comparison with the vapor recovery unit, the
control efficiencies are similar, but the combustor is mechanically easier to operate. Therefore,
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
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the use of a combustor is considered BACT. The additional tanks incorporated into the facility
will have the vapor emissions controlled by use of the combustor. The annualized cost of a
combustor is included in Table B-7.

REFERENCES

Environmental Protection Agency (EPA) Air Emissions Models For Waste and Wastewater.
Document Number EPA-453/R-94-080A. November 1994.

Environmental Protection Agency (EPA) Protocol for Equipment Leak Emission Estimates.
Document Number EPA-453/R-95-017. November 1995.

Sonoma Technology, Inc. (STi) Technical Memorandum: Control Strategies for Reducing
Evaporation Pond Emissions (Final Report, EPA AIRNow Operations and AQI Support,
Contract #EP-D-09-097) September 15, 2011.

Utah Department of Air Quality (UDAQ), 2012. Air Quality Emissions Assessment Guideline;
Website: http://www.airquality.utah.gov/Planning/Modeling/NSR_Permit_Modeling
/Modguint.htm. Accessed on December 20, 2014.

Utah Department of Air Quality (UDAQ), 2013. 2014 ACGIH—TLVs and UDAQ—TSLs and
ETVs; Website: http://www.airquality.utah.gov/Planning/Modeling/NSR_Permit
_Modeling/docs/2014/08Aug/2014ACGIH_TLVs.xls Accessed on December 20, 2014.

Appendix A

1:80,000 ±
Integrated Water ManagementOil Cleaning PlantDuchesne, UTProject Number: 751-061 Facility Location
0 5,000 10,000 15,000 20,0002,500 Feet
FigureA-1
Copyright GeoStrata, 2018
Legend
Site Bound ary
Facility Location
PRE-INJECTION
TANKS
SEPARATION
TANKS
BRINE
TANKS
OFF-LOADING
TANKS
IMW Facility, Duchesne, UtahSCALE: 1" = ADD SCALE
751-074 Air Permit Modification 2019
NOA
REV DATE BY DESCRIPTION
BER Proposed Facility Layout07-12-19
A-2
X:\Projects\751-Integrated Water Management\060-Tabby Junction Landfill Permit\Design\Integrated Internet Symbol 2.png
LEGEND
Removed Tank
New Tanks
NEW TANK
IN-SERVICE TANK
REMOVED TANK
0'25'50'100'
Storage Tanks
Centrifuge Bldg.
Ramp
Access Rd.
Section Line
Detention Basin
30
31170'
SECT 30
SECT 31
T 2S, R 4W, UINTAH BASIN
SPECIAL MERIDIAN
IMW Facility, Duchesne, UtahSCALE:1" = ADD SCALE
751-074 Air Permit Modification 2019
NOA
REV DATE BY DESCRIPTION
BER Proposed Water Cleaning Facility07-12-19
A-3
X:\Projects\751-Integrated Water Management\060-Tabby Junction Landfill Permit\Design\Integrated Internet Symbol 2.png
Production water
delivered to Site
Copyright GeoStrata, 2022
Proposed Water Cleaning Flow Diagram
Figure
A3
IWM Site
Produced Water Facility
Project Number: 751-074
Legend
Water
Oil/Condensate
Solids
Produced Water
Injection
Well/Injection
Tank
Off-loading
Tanks
Landfill
Oil Trucked to
on-site Oil
Cleaning Facility
(see Figure A-5)
Gravity
Separation
Tanks
Pre-
Injection
Tanks
Evaporation
Pond (as
needed)
Recovered Oil
from Initial
Separation
process (trucked
to Oil Cleaning)
Copyright GeoStrata, 2022
Proposed Oil Cleaning Flow Diagram
Figure
A-5
IWM Site
Produced Water Facility
Project Number: 751-074
Legend
Water
Oil/Condensate
Solids
Produced Water
Injection
Well/Injection
tank
Mechanical
Separation
Equipment (2
Centrifuges)
Centrifuge
Water
Pump Tank
LandfillSolids
Hopper
Oil Sales
Tanks
(x4)
Oil Trucked off
site
Centrifuge
Water Tank
Cone
Bottom
Centrifuge
Oil Pump
Tank
Centrifuge
Receiving
Tanks
(Cone B. x4)
Heat
Exchanger
(x2)
Copyright GeoStrata, 2015
Proposed Oil Cleaning Flow Diagram
Figure
A-6
IWM Site
Produced Water Facility
Project Number: 751-074
Legend
Water
Oil/Condensate
Solids
Produced Water
Cent. receiving tanks (4)
Cent. Water (2)Solids Hopper
Cent. Oil (4)

Appendix B

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-1

Table B-1. Approximate Equipment Location and Stack Height Information.
Source Location (UTM Zone 12) Release Height (ft) Easting (m) Northing (m)
Tanks: Off Loading 553290.32 4458157.41
NA
Tanks.: Separation
Tanks: Centrifuge Feed 553391.74 4458088.00 Tanks: Centrifuge Misc
Tanks: Oil Sales 553391.74 4458088.00
Tanks: Pre Injection 553348.93 4458190.50
Injection Well 553344.72 4458150.71
Flare 553397.23 4458194.81 18
Engines 553315.18 4458095.68 2
Storage Pond 553435.63 4458369.61
0 Landfill 553333.10 4458339.85
Land Farm 553531.21 4458772.44

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-2

Table B-2a. Facility Uncontrolled Emissions (tons/yr).
Estimated Emissions in tons/yr (Uncontrolled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks 29.9 1.01 0.09 0.16 0.06 0.24 NA NA NA NA NA NA NA NA AP-42
Centrifuge Solids 248 7.3 0.17 1.82 0.18 5.12 NA NA NA NA NA NA NA NA Measured
Drilling Mud 13.0 0.10 0.001 0.01 0.004 0.04 NA NA NA NA NA NA NA NA Measured
Imported Solids 55.5 0.08 ND 0.002 0.001 0.013 NA NA NA NA NA NA NA NA Measured
Evaporation Pond 9.35 4.46 0.10 0.12 0.007 0.07 NA 4.15 NA NA NA NA NA NA Measured
Engines 0.18 2.34E-04 5.81E-05 2.55E-05 NA 1.78E-05 NA NA 9.7 0.06 0.01 NA 0.01 0.12 AP-42
Tank Heaters 0.24 NA NA NA NA NA 0.05 NA 3,104 1.89 0.14 NA 0.02 3.25 AP-42
Loading 19.8 0.38 0.04 0.06 0.02 0.09 NA NA NA NA NA NA NA NA AP-42
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 5.54 0.55 NA NA AP-42
Fugitive VOCs (Leaks) 0.04 0.0015 1.40E-04 0.0002 8.32E-05 0.0004 NA NA NA NA NA NA NA NA AP-42
Total Emissions 376 13.3 0.41 2.18 0.27 5.58 0.05 4.15 3,113 1.95 5.69 0.55 0.03 3.37
Notes: NA: Not Applicable

Table B-2b. Facility Controlled Emissions (tons/yr).
Estimated Emissions in tons/yr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks 0.60 0.02 0.002 0.003 0.001 0.005 NA NA NA NA NA NA NA NA Calc.
Centrifuge Solids 4.84 0.02 0.001 0.014 0.002 0.01 31.48 NA 86.38 NA NA NA NA NA EPA
LandGEM Drilling Mud
Imported Solids 33.4 0.08 ND 0.002 0.001 0.01 NA NA NA NA NA NA NA NA Calc.
Evaporation Ponds 9.35 4.46 0.10 0.12 0.007 0.07 NA 4.15 NA NA NA NA NA NA Measured
Engines 0.18 2.34E-04 5.81E-05 2.55E-05 NA 1.78E-05 NA NA 9.7 0.06 0.01 NA 0.01 0.12 Calc.
Tank Heaters 0.24 NA NA NA NA NA 0.05 NA 3,104 1.89 0.14 NA 0.02 3.25 Calc.
Flare (combustion) 2.48 NA NA NA NA NA 1.36 NA 2,763 6.54 NA NA NA 1.20 Calc.
Loading 6.3 0.12 0.011 0.020 0.007 0.029 NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 1.39 0.139 NA NA Calc.
Fugitive VOCs (Leaks) 0.04 1.51E-03 1.40E-04 2.43E-04 8.32E-05 3.63E-04 NA NA NA NA NA NA NA NA Calc.
Total Emissions 57.5 4.71 0.12 0.16 0.02 0.13 32.9 4.15 5,963 8.50 1.54 0.14 0.03 4.57
Notes: NA: Not Applicable

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-3

Table B-3. Facility Controlled Emissions (lbs/hr).
Estimated Emissions in lbs/hr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Source
All Tanks1 0.14 4.61E-03 4.26E-04 7.40E-04 2.54E-04 0.001 NA NA NA NA NA NA NA NA Calc.
Centrifuge Solids1 1.10 0.005 1.3E-04 0.003 4.38E-04 0.001 7.19 NA 19.7 NA NA NA NA NA Calc.
Drilling Mud1 Calc.
Imported Solids Solids1 7.6 0.02 ND 3.53E-04 1.89E-04 0.003 NA NA NA NA NA NA NA NA Calc.
Engines2 0.30 3.98E-04 9.90E-05 4.34E-05 NA 3.03E-05 NA NA 16.5 0.11 0.01 NA 0.01 0.20 Calc.
Tank Heaters3 0.16 NA NA NA NA NA 0.03 NA 2,120 1.29 0.10 NA 0.01 2.22 Calc.
Flare (combustion)1 0.57 NA NA NA NA NA 0.31 NA 631 1.49 NA NA NA 0.27 Calc.
Loading4 22.8 0.44 0.04 0.07 0.02 0.11 NA NA NA NA NA NA NA NA Calc.
Unpaved Roads5 NA NA NA NA NA NA NA NA NA NA 0.26 0.03 NA NA Calc.
Fugitive VOCs (Leaks)1 0.01 3.45E-04 3.2E-05 5.5E-05 1.9E-05 8.3E-05 NA NA NA NA NA NA NA NA Calc.
Notes: 1: Assumes emissions occur 365 days per year and 24 hours per day
2: Assumes a running time of 3224 hrs/yr (total combined engine hours)
3: Assumes 2,928 hours of operation per year (1/3 of the year)
4: Assumes 1812 loads per year that take 0.5 hours each (906 hrs/yr)
5: Assumes 22,896 deliveries per year that take 15 minutes to drive through the facility

Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Process Benzene Toluene Ethyl Benzene Xylene Naphthalene Tetrachloroethylene Formaldehyde Methanol Acetaldehyde Acrolein Distance to
Boundary (m)
Vertically
Restricted?
TLV HAPS Analysis
Category
Landfarm ND 3.5E-04 1.9E-04 2.9E-03 6.0E-04 9.1E-05 NA NA NA NA 10 Yes <20 m (restricted) TLV Limit 0.082 3.84 4.43 44.29 2.67 8.65 0.01 14.20 1.71 0.01 -- --
Landfill 1.3E-04 3.2E-03 4.4E-04 1.1E-03 NA NA NA NA NA NA 34 Yes 20-50 m (restricted) TLV Limit 0.105 4.97 5.73 57.31 3.46 11.19 0.02 18.38 2.30 0.01 -- --
Leaks (Fugitive VOCs) 3.2E-05 5.5 E-05 1.9E-05 8.3E-05 NA NA NA NA NA NA 50 Yes
50-100 m (restricted) Loading 0.04 0.07 0.02 0.11 NA NA NA NA NA NA 80 Yes
TLV Limit 0.197 9.27 10.68 106.81 6.45 20.85 0.03 34.25 4.14 0.02 -- --
Engines 9.90E-05 4.34E-05 NA 3.03E-05 6.2E-05 NA 8.7E-04 NA 5.6E-04 6.8E-05 35 No 50-100 m (unrestricted) TLV Limit 0.358 16.88 19.45 194.52 11.74 37.97 0.08 62.37 10.09 0.05 -- --
Flare NA NA NA NA NA NA NA NA NA NA 108 No >100 m (unrestricted) TLV Limit 0.588 27.73 31.96 319.57 19.29 62.39 0.11 102.47 13.96 0.07 -- --
Notes: NA: Not Applicable
ND: Not Detected

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-4

Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Estimated Emissions in Tons/yr (Controlled)
Process CO Fugitive PM10 Nonfugitive PM10 SOX NOX
Total Emissions (Controlled) 9.13 1.15 0.38 0.03 4.69
Criteria Pollutants Mod. Threshold 100 15 5 40 40

Table B-6. Regulatory Review.
State Regulatory Determinations
State Requirements Requirement Applicability Determination
R307-401. Permit:
New and Modified
Sources
Obtain an Approval Order
prior to construction
Applicable - facility exceeds the small source
exemption threshold for VOC as outlined in
R307-401-9
R307-405. Permits:
Major Sources in
Attainment Areas
Federal PSD
implementation
Not Applicable - the facility is not located in
a nonattainment or maintenance area.
R3074-415. Permits:
Operating Permit
Requirements
Federal Title V
implementation
Not Applicable - facility emissions are below
the Title V threshold limits.
40 CFR Part 63
Subpart DD
National Emission
Standards for Hazardous
Air Pollutants from Off-
Site Waste and Recovery
Operations
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single HAP
or 25 tons/yr of any combination of HAPs)
40 CFR Part 63
Subpart ZZZZ
National Emissions
Standards for Hazardous
Air Pollutants for
Stationary Reciprocating
Internal Combustion
Engines
Not Applicable - Facility does not operate
engines that may be subject to standards
applicable to area or major sources of HAP
40 CFR Part 63
Subpart DDDDD
National Emissions
Standards for Hazardous
Air Pollutants for Major
Sources: Industrial,
Commercial, and
Institutional Boilers and
Process Heaters
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single HAP
or 25 tons/yr of any combination of HAPs)
40 CFR Part 60
Subpart Dc
Standards of Performance
for Small Industrial-
commercial-Institutional
Steam Generating units
Not Applicable - Facility does not operate
any steam generating units with maximum
heat input greater than 10 MMBtu/hr
40 CFR Part 60
Subpart Kb
Standards of Performance
for Volatile Organic Liquid
Storage Vessels
Not Applicable - Facility does not operate
storage vessels with a capacity greater than
75 cubic meters.
Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-5

Federal Regulatory Determinations
Federal
Requirements Requirement Applicability Determination
40 CFR Part 60
Subpart IIII
Standards of Performance
for Stationary
Compression Ignition
Internal Combustion
Engines
Not Applicable - Compression ignition
engine(s) located at the Facility commenced
construction, modification or reconstruction
prior to July 11, 2005
40 CFR Part 60
Subpart JJJJ
Standards of Performance
for Stationary Spark
Ignition Internal
Combustion Engines
Not Applicable - Spark ignition engine(s)
located at the Facility commenced
construction, modification or reconstruction
prior to June 12, 2006
40 CFR Part 60
Subpart OOOO
Standards of Performance
for Crude Oil and Natural
Gas Production,
Transmission and
Distribution
Not Applicable - The facility does not
operate at as a production, transmission or
distribution facility. Facility does not operate
other potentially-affected sources covered
by the rule.
Table B-6. Regulatory Review (continued).

Integrated Water Management - NOI
Appendix B
Copyright © 2022 GeoStrata Page | B-6

Table B-7a. BACT Controls Analysis of VOC Reductions and Emissions.
Control Source Control Capital
Cost
Annual
Cost
Life
Span
(yrs)
Interest
Rate
Annualized
Cost
VOC
Reduction
(tons)
Methanol
Reduction
(tons)
HAPs
Reduction
(tons)
VOC
Reduction
Costs ($/ton)
Methanol
Reduction Costs
($/ton)
HAPs
Reduction
Costs ($/ton)
Cost per barrel
of water1
Air Stripper + Thermal
Oxidizer + GAC
Storage Pond Water
$435,960 $2,951 20
3%
$32,254 8.85 0.41 0.46 $3,645 $78,668 $70,118 $0.26
Steam Stripper + Thermal
Oxidizer $2,788,890 $18,474 20 $205,931 9.30 3.94 4.24 $22,136 $52,267 $48,569 $1.65
Flare System Tank vapors $261,860 $36,565 20 $54,166 414 NA 14.0 $131 NA $3,866.25 $0.01
Notes: 1: Assumes 125,000 bbls of produced water processed annually for Evaporation pond and 7.3 million bbls for the Flare system.

Table B-7b. BACT Controls Analysis of PM Reductions and Emissions

Appendix C

Integrated Water Management NOI
Appendix C
Copyright © 2022 GeoStrata Page | C-1

C-1.0 Storage Tanks
The emissions of VOCs from the 44 storage tanks were estimated using the EPA Tanks program
(EPA, 2012). The tanks at this facility have cone shaped fixed roofs that are equipped with pressure
relief valves. Ten of the tanks are heated to approximately 120°F to 180°F. The unheated tanks
remain at ambient temperatures. The following lists the method used to estimate the VOC
emissions from the storage tanks.
C-1.1 Methods
The total emissions from a fixed roof tank are estimated using the EPA Tanks program to obtain
the total losses of each tank. This program estimates the emissions of organic chemicals from
storage tanks based on AP-42 methods. An inventory of all the tanks at the facility is listed in
Table C-1.
C-1.1.1 HAPs Emissions Correlations
The Hazardous Air Pollutants (HAPs) emissions were estimated using VOC emissions to specific
HAP emission ratios as reported in the report “Emission Estimate Protocol for petroleum
Refineries” written by TRI International (RTI, 2011). The ratios are listed in Table C-2.
C-1.1 Assumptions and Results
C-1.1.1 Assumptions for All Facility Tanks
The process tanks at the facility have various capacities ranging from 400 bbl to 500 bbl with two
smaller 500 Gallon containers that are part of the oil cleaning process. The total throughput of each
tank, tank contents and throughput per tank is provided in Table C-3. The uncontrolled VOCs and
HAPs emissions from the tanks are listed in Table C-4. The results from the EPA Tanks analysis
are included in Appendix G.

Integrated Water Management NOI
Appendix C
Copyright © 2022 GeoStrata Page | C-2

Table C-1. Tank Inventory and specifications
Tank ID # of
Tanks Contents Type Shell
Diameter
Shell
Height
Volume
(bbls
Ave. Liquid
Height Heated
Tank
Temp.
(F)
Water Off-Load Tanks 9 Water Vertical 12 24 480 10 No Ambient
Separation Tanks
Produced Water 14 Water Vertical 12 20 400 10 No Ambient
Pre injection Tank 9 Water Vertical 12 25 500 10 No Ambient
Centrifuge Feed Tank 4 Crude Oil Vertical 12 25 500 10 Yes 120
Centrifuge Water Pump
Tank 1 Crude Oil Vertical 12 25 12 22 No Ambient
Centrifuge Oil Pump Tank 1 Crude Oil Horizontal 4 5 12 4 No Ambient
Centrifuge Water
Collection Tank 1 Crude Oil Horizontal 4 5 500 4 Yes 120
Oil Sales tanks 4 Crude Oil Vertical 12 28 500 22 Yes 120
Condensate Tank 1 Injection Vertical 12 25 500 10 No Ambient
Water Tank 1 Hot Water Vertical 12 25 500 10 Yes 120

Table C-2. VOCs and HAPS Ratios
HAPs Estimates per Tank: VOC HAPs Benzene Toluene Ethyl Benzene Xylene
Ratio of HAPS to VOCs 100% 3.38% 0.31% 0.54% 0.19% 0.81%

Integrated Water Management NOI
Appendix C
Copyright © 2022 GeoStrata Page | C-3

Table C-3. Tank Flow Rates
Tank ID Contents Throughput
(bbls)
VOC Emissions
per tank (tons/yr)
Water Off-Load Tanks Produced Water 811,111 0.031
New Separation Tanks Produced Water Produced Water 510,072 0.028
Pre injection Tank Produced Water 793,452 0.000
Centrifuge Feed Tank Produced Water 121,499 0.521
Centrifuge Water Pump Tank Produced Water 337,100 0.038
Centrifuge Oil Pump Tank Oil 36,029 3.948
Centrifuge Water Collection Tank Produced Water 337,035 0.051
Oil Sales tanks Oil 36,029 5.789
Condensate Tank Distillate fuel oil #2 5,000 0.002
Water Tank Brine/ fresh water 0.000

Table C-4. EPA Tanks Results and Uncontrolled Emissions Estimates
Tank ID #
Tanks
Uncontrolled Emissions (tons/yr)
VOC HAPs Benzene Toluene
Ethyl
Benzene Xylene Methanol
Water Off-
Load Tanks 9 0.28 0.01 0.001 0.002 0.001 0.002 0.04
Separation
Tanks
Produced
Water 14 0.31 0.01 0.001 0.002 0.001 0.003
0.02
Pre injection
Tank 9 0.001
4.56E-
05
4.21E-
06
7.32E-
06
2.51E-
06 1.09E-05 0.03
Centrifuge
Feed Tank 4 2.08 0.07 0.01 0.01 0.004 0.02 0.03
Centrifuge
Water Pump
Tank
1
0.04 0.001
1.18E-
04
2.06E-
04
7.06E-
05 3.08E-04
0.009
Centrifuge
Oil Pump
Tank
1
3.95 0.13 0.01 0.02 0.01 0.03
0
Centrifuge
Water
Collection
Tank
1
0.05 0.002
1.59E-
04
2.76E-
04
9.47E-
05 4.13E-04
0.01
Oil Sales
tanks 4 23.2 0.78 0.07 0.13 0.04 0.19 0
Condensate
Tank 1 0.011
3.73E-
04
3.45E-
05
5.99E-
05
2.05E-
05 8.96E-05 0
Water Tank 1 0 0 0 0 0 0 0
Integrated Water Management NOI
Appendix C
Copyright © 2022 GeoStrata Page | C-4

Total Ucontrolled
Emissions (tons/yr) 29.9 1.01 0.09 0.16 0.06 0.24 0.14
Total Controlled
Emissions (tons/yr) 0.60 0.02 0.002 0.003 0.001 0.005 0.003

C-2.0 Flare
The emissions from the proposed flares are estimated using the methods listed in AP-42 Section
3.15 and 1.5 (Industrial Flares & Liquefied Petroleum Gas Combustion). The emission factors
and assumptions are included below.
C-2.1 Method and Results
The flow and total energy content (MMBtu/yr) of the tanks at the site are listed in Table C-5. The
emission factors for the flare are listed in Table C-16. The emissions of the total hydrocarbons
(including ethane and other organics), CO, NOX, and Soot were estimated using emission factors
from AP-42 Tables 3.15-1 and 3.15-2. The emission factor for CO2 was assumed to be equivalent
to the combustion of propane as defined in AP-42 Section 1.5. It is assumed that the flare
combustion gas contains 300 Btu/ft3 of heat value (AP-42 Section 3.15). The flare controls vapors
from 40 tanks with throughputs (i.e. vapor flow rates) listed in Table C-15.

Integrated Water Management NOI
Appendix C
Copyright © 2022 GeoStrata Page | C-5

Table C-5. Vapor Flow Rates.
Tank Contents &
Capacity (bbls)
Quantity of
Tanks
Throughput
(bbls/yr)
Energy
Content
(Btu/ft3)
Annual Energy
Throughput
(MMBtu/yr)
Water Off-Load Tanks 9 7,300,000
300
12296
Separation Tanks
Produced Water 14 7,141,066 12028
Pre injection Tank 9 7,141,066 12028
Centrifuge Feed Tank 4 485,997 819
Centrifuge Water Pump
Tank 1 337,100 568
Centrifuge Oil Pump
Tank 1 144,117 243
Centrifuge Water
Collection Tank 1 337,035 568
Oil Sales tanks 4 144,117 243
Condensate Tank 1 5,000 8

Total 44 23,035,500 38,800

Table C-6. Flare Emission Factors and Estimated Emissions.
Analyte
Emission
Factor
(lb/MMBtu)
Annual
Combustion
(MMBtu/yr)
Annual
Emissions
(tons/yr) Source
Total Hydrocarbons 0.14
38,800
2.72 AP-42, 3.5
Methane 0.077 1.49 AP-42, 3.5
Ethane/Ethylene 0.0112 0.22 AP-42, 3.5
Acetylene 0.007 0.14 AP-42, 3.5
Propane 0.0098 0.19 AP-42, 3.5
Propylene 0.035 0.68 AP-42, 3.5
CO 0.37 7.18 AP-42, 3.5
CO21 156 3032 AP-42, 1.5-1
NOX 0.068 1.32 AP-42, 3.5
Soot 177 3434 AP-42, 3.5
Notes: 1. Assumes equivalent CO2 emission factor as combustion of propane

Appendix D

Appendix D
Equipment Specifications Sheets

Customer: Geostrata, Bluffdale, Utah
Site: Produced Water, LaPoint, Utah
Date: 11/13/14

Design Basis: Flow rate: 100 gpm
Water temperature: 55 oF (assumed)

Contaminant Influent Effluent
Conc. Criteria
(ug/L) (ug/L)
TPH-DRO (as naphthalene) 65,000 -
TPH-GRO (as benzene) 35,000 -
TPH (DRO & GRO) 100,000 5,000*

* Based on a removal efficiency of 95%.

Recommendations: Pre-Filters (to remove suspended solids)

Two Krystil Klear L8830 bag filters in parallel

Low Profile Air Strippers (to remove hydrocarbons from water)

STAT 180 with 6 trays, operated at 900 cfm
 The effluent DRO and GRO concentrations are predicted to be 25,643 and 122 ppb, respectively
(see the modeling output below).

Liquid Phase Carbon Adsorbers (to remove residual hydrocarbons)

Two PC28’s in series, each with 5,000 lbs of granular activated carbon
 TPH-DRO is the critical contaminant. TPH-GRO which is less adsorbable to carbon, will be
allowed to pass through the carbon adsorbers at an effluent concentration of 122 ppb. The
effluent TPH-DRO concentration must be kept below 4,878 ppb in order for the TPH discharge
limit of 5,000 ppb to be met.
 Both adsorbers are predicted to require carbon change-out every 80 days (see the modeling
output below).

NOTICE

THIS DOCUMENT AND ITS CONTENTS ARE PROPRIETARY TO CARBONAIR ENVIRONMENTAL SYSTEMS, AND MAY NOT
BE COPIED, DISTRIBUTED OR USED BY ANYONE, IN WHOLE OR IN PART, WITHOUT THE EXPRESS AUTHORIZATION OF
CARBONAIR.

THE CONTENT OF THIS DOCUMENT HAS BEEN DEVELOPED BY CARBONAIR TO ADDRESS SPECIFIC FACTUAL
INFORMATION. IT MAY BE BASED ON INFORMATION AND ASSUMPTIONS THAT ARE NOT DISCLOSED WITHIN THIS
DOCUMENT, BUT REFLECT CARBONAIR'S KNOWLEDGE AND EXPERIENCE. THE INFORMATION IN THIS DOCUMENT
SHOULD NOT BE USED OR RELIED UPON BY ANYONE WITHOUT THE COOPERATION OR ASSISTANCE OF CARBONAIR
TO FULLY UNDERSTAND ITS INTENDED APPLICATION AND USE.

CARBONAIR ENVIRONMENTAL SYSTEMS
1480 County Road C West, Roseville, MN 55113
PHONE: [phone] FAX: [phone]

STAT MODEL CALCULATIONS
Thu Nov 13 10:46:19 CST 2014

UNIT MODEL: STAT 180
WATER FLOW RATE (GPM): 100.00
AIR FLOW RATE (ACFM): 900.00
AIR-TO-WATER RATIO: 67:1
WATER TEMPERATURE (F): 55.00
AIR TEMPERATURE (F): 55.00
OPERATING PRESS (ATM): 1.00
SAFETY FACTOR (%): 30.00

Influent Conc. for TPH AS DIESEL(AS NAPHTHALENE) 65000.00000 ppb

NO OF REMOVAL EFF EFF CONC OFF-GAS CONC AIR EMISSION
TRAY % ppb ug/l lb/d
1 19.57605 52275.57036 189.91686 15.27604
2 32.95996 43576.02398 319.76084 25.72010
3 42.68689 37253.51913 414.12658 33.31044
4 50.07427 32451.72635 485.79513 39.07513
5 55.87455 28681.54155 542.06654 43.60135
6 60.54877 25643.29695 587.41348 47.24885

Influent Conc. for TPH AS GAS(ASSUME BENZENE) 35000.00000 ppb

NO OF REMOVAL EFF EFF CONC OFF-GAS CONC AIR EMISSION
TRAY % ppb ug/l lb/d
1 62.71656 13049.20460 327.62381 26.35256
2 85.58373 5045.69564 447.07917 35.96100
3 94.34926 1977.75749 492.86929 39.64415
4 97.77338 779.31657 510.75647 41.08291
5 99.12081 307.71749 517.79526 41.64908
6 99.65256 121.60295 520.57309 41.87251

Influent Conc. for TOTAL VOCs 100000.00000 ppb

NO OF REMOVAL EFF EFF CONC OFF-GAS CONC AIR EMISSION
TRAY % ppb ug/l lb/d
1 34.67523 65324.77496 517.54067 41.62860
2 51.37828 48621.71962 766.84001 61.68110
3 60.76872 39231.27661 906.99587 72.95459
4 66.76896 33231.04292 996.55160 80.15804
5 71.01074 28989.25904 1059.86181 85.25043
6 74.23510 25764.89990 1107.98657 89.12136

STAT Modeler Disclaimer

Carbonair's STAT Modeler is accurate only when contaminants are completely
dissolved in water in the absence of substances, which may significantly
affect the stripper capabilities of contaminants, such as oil & grease,
surface active and foaming agents, alcohols, ketones, and other potential
Henry's constant altering contaminants. Although the effluent concentration
predictions made by the STAT Modeler are accurate predictions of field
performance, they do not constitute a guarantee that these concentrations
will be met in the field. Please contact your Carbonair representative for a
design review and confirmation.

LIQUID-PHASE CARBON ADSORPTION MODEL CALCULATIONS

CARBONAIR ENVIRONMENTAL SYSTEMS
1480 COUNTY ROAD C WEST
ROSEVILLE, MN 55113
PHONE: [phone]
FAX: [phone]

CARBON ADSORBERS: PC28
NO OF ADSORBERS IN SERIES: 2
TOTAL MASS OF CARBON (LBS): 10000.
FLOW RATE (GPM): 100.00
HYDRAULIC LOADING (GPM/SQ.FT): 3.5318
EMPTY BED CONTACT TIME (MIN.): 27.261

DESIGN COMPOUND: NAPHTHALENE
EXPECTED INFLUENT CONCENTRATION (PPB): 25643.  STAT 180
MODEL INFLUENT CONCENTRATION (PPB): 25643.
EFFLUENT CRITERIA (PPB): 4878.0
EFFECTIVE K-VALUE (%): 30.000

TIME(DAYS) VOLUME TREATED(GAL) EFF. CONC.(PPB)
5.0 720000. 0.0000
10.0 1440000. 0.0000
15.0 2160000. 0.0000
20.0 2880000. 0.0000
25.0 3600000. 0.0000
30.0 4320000. 0.0000
35.0 5040000. 0.0000
40.0 5760000. 0.0000
45.0 6480000. 0.0000
50.0 7200000. 0.0000
55.0 7920000. 0.0000
60.0 8640000. 0.0000
65.0 9360000. 0.0000
70.0 10080000. 0.0000
75.0 10800000. 115.8100
80.0 11520000. 2345.7857  BREAKTHROUGH
85.0 12240000. 8500.6779
90.0 12960000. 13388.7453
95.0 13680000. 16906.7932
100.0 14400000. 19437.6322

Note: The model influent concentration results from the
impact of the other background compounds, which is
determined by using a competitive adsorption model

DISCLAIMER: ACTUAL RESULTS MAY VARY SIGNIFICANTLY FROM
THE MODEL. THE MODEL IS BASED ON THE ASSUMPTIONS THAT
THE FLOW RATE AND INFLUENT CONCENTRATION ARE CONSTANT,
AND ONLY THE CONTAMINANTS PROVIDED TO CARBONAIR ARE
PRESENT IN THE WATER. VARYING OPERATING CONDITIONS CAN
HAVE ADVERSE EFFECTS ON CARBON ADSORPTIVE CAPACITY.
THE PREDICTED BED LIFE IS NOT GUARANTEED.

November 14, 2014

Mark Greenwood
Geostrata
14425 S. Center Point Way
Bluffdale, UT 84065

Phone: [phone]
Fax: Email:

Re: Proposal Number: 24729
Project Name: Produced Water Treatment – Airstripping and Carbon Adsorption
Project Location: LaPoint, UT

Dear Mark:

Carbonair is pleased to quote products and services for the referenced project. The proposal is based on the information
provided.

Summary

It is our understanding that Carbonair is to provide the following equipment for the reference site. The proposal is based
on the understanding that there are NO Chlorides in the incoming water stream.

We also understand there may be surfactants in the water stream which will have a detrimental effect on the Airstripping
process. We believe a pilot study should be performed and the client should have an anti-foam chemical available with a
chemical feed pump to pump in to eliminate any foaming during the Airstripping process.

(1) Carbonair Model STAT 180 low profile air stripper
- 316 SST pump out sump with high level alarm and pump operation switches
- 6 trays with demister and fasteners
- 10 hp, 230 V, 3 phase, TEFC blower (900 cfm @ 43” wc)
- Blower low pressure alarm switch
- Blower pressure gauge
- Blower inlet silencer
- Air flow meter kit
- 7.5 hp, 230/460 V, 3 phase, TEFC transfer pump
- Minimum flow of 20 gpm @ 137’ TDH
- Maximum flow of 200 gpm @ 100’ TDH
- Mounted on a common skid

(1) Control panel
- NEMA 4 enclosure
- Inner door with disconnect switch
- H.O.A. switches w/ lights
- IEC Motor starters w/overloads
- Alarm interlocks w/ red lights
- Alarm reset button
- Intrinsic safety barriers
- UL Listing
- GFI receptacle
- System interlocks and automatic control logic

- System interface contacts

Budgetary Pricing
*plus sales tax if applicable

Supply of the equipment and carbon described above $82,984.00

Estimated freight to site via step deck truck and trailer $4,063.00

Summary – Epoxy Coated Carbon Steel Option

If there is no chance of chlorides in the water stream and your customer would prefer to install epoxy coated carbon steel
tanks here is a description of the equipment to be provided.

(2) Carbonair Model PC 28 Epoxy Coated Carbon Steel Vessels
Each Including:
- ASME Label for 90 PSI
- 304 stainless steel internal header with (16) PVC laterals for underdrain
- 1” drain valve on bottom of tank
- 1” air relief valve piping piped to side of tank with valve on side
- ¾” full coupling on side sheet of vessel for sample port location
- 4” flanged water inlet and outlet connections
- 2” flanged connection for customer supplied pressure relief valve
- (2) 24” flanged manholes with davit arms
- Interior lined with Sherwin Williams 646 coating
- Exterior commercial blast followed by epoxy primer and polyurethane finish
- 5,000 pounds of reactivated 8x30 mesh carbon supplied in supersacks

Budgetary Pricing
*plus sales tax if applicable

Supply of the equipment and carbon described above $91,891.00

Estimated freight to site via step deck truck and trailer $4,063.00

Summary – Fiberglass Reinforced Plastic Tank Option

If you have a chance of having chlorides in your water stream here is a description and price for (2) Fiberglass Reinforced
Plastic tanks. Here is a description of the equipment to be provided.

Design Code: D3299 (No Stamps or Certifications)
Seismic Zone: 0
Chemicals: Potable Water
Temperature: Ambient
Specific Gravity: 1.0
Pressure: 90 PSI
Size: 6’-0” Diameter x 5’-0” Straight Sidewall
Resin Liner: Dion 9102-70 NSF-61 Approved
Resin Structural: Dion 9102-70 NSF-61 Approved
Cure System: MEKP
Liner: 100 Mil Single C-Veil Corrosion Barrier
Structural: Filament Wound
Top Head: Elliptical
Bottom Head: Inverted Elliptical
Exterior: Wax Coat with UV Inhibitor
Color: Natural

Lift Lugs: Fiberglass

MATERIAL LISTING

Each Including:
- 4” FRP pipe and elbow for upper distributor
- 304 stainless steel internal header with (16) PVC laterals for underdrain
- 1” drain piping with brass ball valve on bottom of tank
- 1” galvanized air relief piping piped to side of tank with brass ball valve on side
- ¾” full coupling on side sheet of vessel for sample port location with galvanized pipe and brass ball valve
- 4” flanged water inlet and outlet connections
- 2” flanged connection for customer supplied pressure relief valve
- (2) 14” x 18” FRP Manways w/Covers
- (2) 4” Diameter FRP 150# Single Pad Flange
- (2) 2” Diameter FRP 150# Flange w/Gussets
- (1) 1” Diameter FRP FNPT Coupling
- (1) ¾” Diameter FRP FNPT Coupling
- 5,000 pounds of 8x30 mesh reactivated liquid phase carbon

Budgetary Pricing
*plus sales tax if applicable

Supply of the equipment and carbon described above $135,467.00

Estimated freight to site via step deck truck and trailer $4,063.00

NOTICE

THIS DOCUMENT AND ITS CONTENTS ARE PROPRIETARY TO CARBONAIR ENVIRONMENTAL SYSTEMS, AND MAY NOT BE COPIED,
DISTRIBUTED OR USED BY ANYONE, IN WHOLE OR IN PART, WITHOUT THE EXPRESS AUTHORIZATION OF CARBONAIR.

THE CONTENT OF THIS DOCUMENT HAS BEEN DEVELOPED BY CARBONAIR TO ADDRESS SPECIFIC FACTUAL INFORMATION. IT MAY BE
BASED ON INFORMATION AND ASSUMPTIONS THAT ARE NOT DISCLOSED WITHIN THIS DOCUMENT, BUT REFLECT CARBONAIR'S
KNOWLEDGE AND EXPERIENCE. THE INFORMATION IN THIS DOCUMENT SHOULD NOT BE USED OR RELIED UPON BY ANYONE
WITHOUT THE COOPERATION OR ASSISTANCE OF CARBONAIR TO FULLY UNDERSTAND ITS INTENDED APPLICATION AND USE.

IMPORTANT NOTICE: PH INCREASES AND METALS SPIKES WITH COAL BASED CARBONS

ALL NON-ACID/WATER WASHED REACTIVATED AND VIRGIN, COAL BASED GRANULAR ACTIVATED CARBONS USED IN WATER
TREATMENT APPLICATIONS, CAN CAUSE AN INCREASE IN THE PH OF THE WATER BEING TREATED AT SYSTEM STARTUP. IN ADDITION,
THERE IS A POTENTIAL FOR THESE CARBONS TO LEACH HEAVY METALS LIKE ARSENIC AND LEAD. IF YOU ARE USING GRANULAR
ACTIVATED CARBON TO TREAT WATER ON YOUR PROJECT AND YOUR DISCHARGE PERMIT REQUIRES YOU TO MEET STANDARDS FOR
PH AND/OR HEAVY METALS, YOU MAY NEED TO USE SPECIAL CARBON TO AVOID PROBLEMS WITH PH RISE AND METALS SPIKES. IT IS
CRITICAL THAT YOU PROVIDE CARBONAIR WITH ALL DISCHARGE CRITERIA AND LIMITS WHEN REQUESTING A QUOTE FOR A CARBON
SYSTEM. CARBONAIR ASSUMES NO RESPONSIBILITY FOR THESE PROBLEMS IF WE ARE NOT INFORMED OF ALL DISCHARGE
REQUIREMENTS AND LIMITS AT THE TIME WE PROVIDE A PROPOSAL.

Carbon Exchange Service
Carbonair has the capability to provide on-site exchange and disposal of liquid and vapor phase carbon for this project or
any other sites that may require this service. Carbonair would be happy to provide a proposal for this or any others
project that you are working on. Please call me or your local Carbonair Service office (see our website at
www.carbonair.com for the nearest office) if we can be of any assistance.

General Conditions
• Pricing based upon current market price for carbon and steel. Due to the volatility of these markets, pricing
is only valid for 15 days. All pricing subject to change without notice.
• Terms of payment are 30% invoiced with order due upon receipt, 30% after submittal, 30% due prior to shipment of
equipment and balance due Net 30 days after shipment of equipment to site with approved credit.
• Proposal is subject to the attached terms and conditions.
• Proposal is based on electrical service as stated above. Different electrical service may affect costing.

• This proposal and pricing is based on our interpretation of the sections of the RFP or specification that have been
made available to us. Exceptions have been noted wherever possible. In the event of a conflict between the language
in the specification and the proposal, the language in the proposal takes precedence and is the basis of the proposed
pricing. Carbonair reserves the right to reject any order based on differences in pricing. Carbonair reserves the right to
reject any order based on differences in interpretation of the specification, or for any reason, at the time the order is
tendered.
• Carbonair will not initiate work without a fully executed contract or purchase order.
• Submittal package can be provided within 3-5 weeks of receipt of order.
• The proposed equipment can generally be shipped within 10-16 weeks after receipt of approved submittal. Actual
shipment timeframe will be updated at the time of order execution.
• Shipping charges are not included in the prices quoted. Actual freight costs will be pre-paid and added to the invoice.
• Sales tax is not included in the prices quoted. The customer must pay all applicable Federal, State and Local sales or
use taxes.

For shipments to the states of California, Colorado, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas,
Kentucky, Louisiana, Michigan, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, Nebraska, New
Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, Pennsylvania, South Carolina, South Dakota,
Tennessee, Texas, Virginia, Washington, West Virginia, Wisconsin and the District of Columbia: State and local
sales and use tax will be added to the invoice, unless a valid sales/use tax exemption certificate is
supplied with the contract or purchase order for this project. Exemption certificates must be supplied at
the time of order.

For shipments to any other states: The prices quoted do not include any state or local sales/use taxes.
Customer is responsible for paying any applicable state and local taxes. An affidavit certifying payment
of sales/use tax (attached) or a valid exemption certificate will be required at time of order.

If you have any questions or comments concerning this information, please feel free to call me at 651-202-2952. Thank
you for the opportunity to bid on this project.

Sincerely,

Bob Bergsgaard
National Accounts Manager/Equipment Manufacturing

Accepted by:

The proposal and terms & conditions herein are acknowledged and accepted:

____________________________________________ _____________________________
Name/Title Date

____________________________________________
Authorized Signature Purchase Order Number

Terms and Conditions

ACCEPTANCE: This proposal is an invitation for an offer and will become a binding contract when accepted.
LIMITATION OF PROPOSAL: The prices and terms quoted in this proposal are subject to acceptance by the Purchaser within a period of (30)
calendar days from the date hereon.
EXCLUSIONS: This proposal is based solely and completely on specifications submitted to Carbonair Environmental Systems, Inc. (Carbonair)
at the time of the writing of the proposal. General plans and specification not actually submitted shall not apply. This proposal, together with all
annexed specifications, when accepted, shall be the complete agreement between the parties; and any alternations or unusual and undisclosed
conditions or deviations from the above specifications involving extra costs shall be agreed upon in writing by both parties and shall become an
additional charge over and above the proposal price set forth herein. Delays or impossibility of performance by Carbonair because of strikes,
accidents, or other reasons beyond the control of Carbonair shall relieve us from all liability herein.
SHIPMENT: Time of shipment shall be no longer than ten to sixteen (10-16) weeks after receipt of order and acceptance and final approval of
all drawings and submittal.
TERMS OF PAYMENT: Subject to the payment terms described in the General Conditions section in the proposal. We reserve the right to
cancel the contract or cease work if payments thereon are not received when due. 1.5% per month shall be charged on all unpaid balances.
TAXES: The Purchaser shall pay any local, state or federal sales, excise or use tax imposed on the equipment in addition to the prices quoted.
WARRANTY LIMITATION: There are no warranties that extend beyond the warranties herein after expressed.
WARRANTIES: All work shall be done in a workmanlike manner according to standard practices. We warrant performance against defects in
workmanship for a period of twelve (12) months from date of shipment. We agree to pass on to the Purchaser such warranties, if any, as may
be extended by the manufacturer for material supplied. Labor for replacing defective materials shall not be provided by us unless it is
specifically spelled out in the proposal. We shall not be responsible for materials damaged, lost or stolen after delivery, through no fault of ours,
or for failure to deliver and perform because of reasons beyond our control.
EXCLUSIVE REMEDIES: Remedies are limited to the repair or replacement at FOB point of delivery. Consequential damages are excluded. In
no event shall Carbonair be responsible for consequential damages of any such defective material or workmanship including, but not limited to,
the Purchaser's loss of material or profits, increased expenses of operation, downtime or reconstruction of the work, and in no event shall
Carbonair's obligation under this warranty exceed the original contract price of the defective item. It is agreed that any action for breach of
express or implied warranty shall be initiated within fifteen (15) months of the date of shipment by Carbonair and only those defects that are
documented to have occurred within twelve (12) months of shipment will be covered by the warranty.
DISCLAIMER: Carbonair will not be responsible for damage to equipment or materials through improper installation, storage, improper
services, or through attempts to operate it in excess of its rated capacity or recommended use, intentional or otherwise, by parties other than
Carbonair or its authorized representatives.
CONDITIONS OF SALE: Prices quoted are those now in effect. Seller reserves the right to bill at the prices in effect at the time of shipment if
the proposal is not accepted in writing within thirty (30) days, unless a longer term of validity is in writing on the proposal.
LIMITATIONS OF LIABILITY
A. Neither Seller nor its suppliers of any tier will be liable to Purchaser, whether in contract, in tort (including negligence and strict
liability), under any warranty or otherwise, for any special, indirect, incidental, or consequential loss or damage whatsoever, or for loss of or to
the plant, loss of use of equipment or power system, cost of capital, loss of profits or revenue or the loss of use thereof, cost of environmental
damage or clean-up, or claims of customers of Purchaser. The remedies set forth herein are exclusive, and the total cumulative liability of seller
and it suppliers under any purchase order or any act or omission in connection therewith or related thereto, whether in contract, in tort
(including negligence and strict liability), under any warranty, or otherwise, will be limited to the price of the contract.
B. The provisions of this Article shall survive termination, cancellation or expiration of the purchase order and shall apply,
notwithstanding any other provisions of this Agreement or any related document thereto, to the fullest extent permitted by law. Prior to the
transfer of any equipment or material furnished or for which work is furnished hereunder from the project site (except temporarily for repair work
or permanently for disposal), or the transfer of any interest therein or in the plant, Purchaser shall obtain for Seller written assurances from the
transferee of limitation of and protection against liability following the proposed transfer at least equivalent to that afforded seller and its
suppliers under the purchase order.
Pressure Drop for PC28
0.0
0.5
1.0
1.5
2.0
2.5
3.0
0 25 50 75 100 125 150 175 200 225 250
Flow Rate (gpm)
Pr
e
s
s
u
r
e

D
r
o
p

(
p
s
i
)

“Engineered Solutions For Combusting Waste Gas”
TCI USA, INC.TCI USA, INC.TCI USA, INC.
“Engineered Solutions for Combusting Waste Gas”
www.tciusainc.com ● [phone]

Topics Page No.
General Product Information ···························· 1
Pictures ····························································· 3
Engineering ······················································ 4
Standard Equipment ········································· 5
Unit Sizes ························································· 6
Equipment Options ··········································· 7
Operation ························································ 10
Installation······················································· 11
Service····························································· 12

Appendices
Data Enquiry Form ········································· 13
Typical P&ID ·················································· 15
Disclaimer ······················································ 16
Contact Information········································· 16
Glossary··························································· 17

* Please note: words in bold italics are defined in the
Glossary
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
TABLE OF CONTENTS

“

GENERAL PRODUCT INFORMATION
APPLICATIONS

• VOC & Methane emission control
• Flash tanks
• TEG / EG reboiler still vapors
• Amine flash tanks
• Vapor recovery unit back up...

TCI USA, INC. products are an
environmentally friendly alternative to
flaring. Combustion efficiency is
99.9% resulting in no smoke, no odor
and no visible flame during normal
operations. This is a preferred method
when operating in sensitive areas such
as near residents or when conducting
confidential well testing in
competitive markets.

• Robust Oil Field Design
• Natural Draft
• Simple to use
• Require very little
maintenance

TCI USA, INC. units are designed for
a product life of 15 years and are used
to combust waste gas from on-shore
oil and gas operations. They are
installed on piles or on platforms for
long term service or on trailers or
skids for temporary waste gas
applications such as well testing.
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]

TCI USA, INC. units may be
categorized by one or more of
the following names:

• Incinerator
• Enclosed Burner
• Thermal Oxidizer

MAIN COMPONENTS

• 304 Stainless Steel Stack
• Carbon Steel Body
• Piping
• Valves
• Regulators
• Tubing
• Venturi Burners

Rental Trailer, capacity 400 mscf/d
1

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]

GENERAL PRODUCT INFORMATION
OPERATION

Waste gas enters an inlet manifold at the base of
the unit and is then diverted to flow controlled
burner trains. Specially designed burners premix
waste gas, controlled naturally aspirated air and
make-up gas when required. Additional air enters
through the segregated stack. Air not used to
complete combustion throughout the stack travels
upwards along the wall maintaining a cool stack
wall temperature.

TYPICAL APPLICATIONS

Installed units mounted on a post, pier or platform
are used to combust waste gas from:

• coal bed methane,
• casing head gas,
• separators,
• treaters,
• high / low pressure tanks, and
• dehydrators at batteries or plants.

Rental trailer or skid mounted units are used to
combust waste gas from:

• pigging,
• pipeline blow-downs,
• completions, and
• well testing, including:
• coal bed methane, and
• under-balanced drilling.
BENEFITS

• Natural Draft,
• enclosed combustion,
• 99.9% VOC destruction
efficiency,
• no high temperature limit,
• low pressure and variable
flow rates our specialty,
• overpressure bypass to
route excess waste gas into
the stack for combustion.
TCI 4800 dual stream, capacity HP 2 mmscf/d, LP 427 mscf/d
2

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
Back Pressure Relief Valve
Stack Thermocouple
Ignitor System
Relief Line
Burner Ball Valves
Waste Gas Inlet
PICTURES
3
Main Burners
Fuel Gas Make-Up
Main Waste Gas Inlet Lines

“

ENGINEERING
Components Standard construction Sour construction
option
Pipe flanges SA-105N SA-350 LF2
Inlet piping and main header piping SA-106B SA-333 Gr6
Welded pipe fittings SA-234 WPB SA-420 WPL6
Threaded pipe fittings SA-105N SA350LF2
Ring burner manifold SA-312 304/304L
Stack walls SA-312 304/304L
Stack base mounting ring SA-36
Incinerator base SA-36
Companion flange SA-36
Ball valves SA-351 CF8M 316/316L
Back pressure regulator SA-126B Gray cast iron
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
TCI provides flow curves, certified drawings, operation
manuals, data books, heat calculations and make up gas
requirements for new and existing projects. Preliminary
dispersion modeling for SO2 is supplied at the quote stage to
determine approximate platform height for sour gas
applications.

TCI is committed to continuous product improvement and to
finding solutions for unique applications. All products are
designed and manufactured in compliance with the following
industry standards:

• ANSI (American National Standards Institute),
• ASME (American Society of Mechanical Engineers),
• CE (Conformité Européenne. The CE mark on
goods indicates a conformance to European
Union regulations)
• UL (Underwriters Laboratories Inc.), and
• CSA (Canadian Standards Association). TCI 6000, capacity 6 mmscf/d
4

“

“Engineered Solutions For Combusting Waste Gas”
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STANDARD EQUIPMENT
• Manual ball valves open or close
one or more burner trains and
maintain a suitable back pressure to
the venturi burners.

• High pressure bypass provides a
bypass to route excess waste gas into
the stack for combustion prior to
venting waste gas at the source (these
are installed on all waste gas lines to
relieve unwanted pressure due to
temporary system upsets and to
ensure waste gas is combusted and
not vented upstream.

• TCI USA, INC. uses English thread
oilfield equipment.
TCI 4000, capacity 400 mcf/d
TCI USA, INC. also
supplies guy wires to
protect each unit’s stack
from excessive wind
loads. Units working at
ground level have 3 wires
attached near the top of
the stack at equal spacing
of 60, 180 and 300 degrees
from the waste inlet line,
and 60 to 45 degrees from
the vertical stack.
Alternative spacing is
available provided the
customer notifies TCI
USA, INC. prior to
fabrication.

Units on the ground or on
a platform that have stack
extensions may have
additional guy wires if
required. Guy wires must
be installed as per
instructions provided in
TCI USA, INC.’s
Operation Manual to allow
for stack expansion.
5

UNIT SIZES
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
NOTES:

1. Capacities in this table are given as a
sizing guideline only, the waste gas
capacity of each unit will depend on the
pressure, temperature, and composition of
the gas as well as the burner configuration.
Waste gas backpressure will be a function
of the burner configuration and flow rate.
Waste gas pressure should be maintained
between 0.5 oz/in2 and 14.9 psig. Burner
configurations and unit size are determined
by TCI based on specific conditions and
requirements of each application.

2. Inlet flanges and manifolds of different
sizes can be custom configured.

3. Stack top ID, length, overall unit height
and weight will increase when optional
stack extensions are used.
Unit Size
Nominal
Waste
Gas
Capacity1
Stack
Top ID3
Stack
Length
3
Unit
Height
3
Approximate
Net Weight
Approximate
Shipping
Weight
Standard
Inlet
Flange
and
Manifold2
Standard
Base
Plate
Size
(Square)
(MSCFD) (in) (in) (in) (lb) (lb) NPS (in)
TCI 60 5 13.50 268 292 600 800 2 12.0
TCI 500 20 24.25 161 197 800 1000 3 20.0
TCI 1200 50 28.25 169 205 1100 1300 3 20.0
TCI 1200P 80 40.50 172 208 1400 1600 3 20.0
TCI 2000 200 48.00 175 211 2500 2700 3 24.0
TCI 3000 300 58.00 175 212 4500 4700 3 28.5
TCI 4000 500 79.50 181 220 6800 7200 3 48.0
TCI 4800 2000 113.50 310 349 11000 11400 3 48.0
Standard
Inlet
Flange
Height
(in)
12.625
24.500
24.500
24.500
30.000
31.500
33.000
33.000
TCI 2000, capacity 200 mcf/d
6

“

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
EQUIPMENT OPTIONS
Options listed below with the word (web) written beside them are included on the TCI web site at
www.tciburners.com on the Suppliers link page. Equipment options may vary depending on the application.
Thermocouple (web): Used
to determine and relay
information about the internal
stack top temperature. It may
be connected to a TCI
supplied temperature display
or customer supplied SCADA
or PLC in the field. Operating
range is typically 0-1600
degrees Celsius.
Temperature Read Out Display (web): Receives a 4-20mA sig-
nal from the thermocouple and provides a temperature reading inside the top
of the stack.

Optional Manifold Size: TCI units can be fitted with larger inlet
flanges and manifolds to match existing piping. This has no effect on the
stated capacity of the unit.

Semi-Automated Control for Widely Varying Waste Gas Streams:
Waste gas is controlled manually with ball valves in
conjunction with one or more back pressure regulators connected between
the main waste gas line and TCI ring burners, for example, multiple lines
from different storage tanks.

Dual Inlet: Separates high pressure and low pressure waste gas streams.
TCI 1200+, capacity 80 mcf/d
7

EQUIPMENT OPTIONS
Manual or Electronic
Pilot Ignition (web):
Manual push button piezo igniters (spark
igniters which require no source of
electric power; the spark is generated via
a piezoelectric effect when an ignite
button is pushed manually) are typically
used for temporary applications at
manned sites. A spark ignites a fuel
source (usually propane) which provides
a flame across the burners in the unit.
Electronic pilot ignition systems (with
provisions for detecting loss of a pilot
flame that include a control panel with
alarm capabilities) come with control
panels that provide alarm capabilities and
continuous relight features. They are
typically used on installed units when
field personnel are not always present at
site and/or with sour gas applications.
Each TCI supplied electronic pilot
ignition systems require 1.6 watts of
power with the display on or 0.9 watts
with the display off.
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
Flame Arrester (web): TCI can supply a full range of deflagration or
detonation flame arresters. Flow curve tables are used to determine the
correct size based on the line pressure and expected gas volume. The flame
arresters are also tapped on both ends of the body so that customers can install
pressure gauges. The gauges provide a means for a field operator to check the
pressure differential across the flame arrester element. If the differential is
greater than that recommended by the manufacturer, the arrester requires
servicing.
Thermocouple: Used to determine stack temperature.
TCI 4000, capacity 500 mscf/d
TCI 4800 x2, capacity 5 mmscf/d
8

“

EQUIPMENT OPTIONS
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
Platform TCI supplies elevated
platforms to comply with regulations
for dispersion of sulfur dioxide (SO2)
in sour gas applications. These are
built to industry standards and come
with certified drawings.

View Port / Sample Port
Installed in the TCI stack; allows an
operator to look inside the burn
chamber and provides access for
testing equipment.
Wind Shroud Typically a metal enclosure that is mounted around
the base of a TCI unit to protect the ignition from extreme cross
winds. Strongly recommended for units mounted on platforms.

Stack Extension Sizes Stack extensions are available for most
nominal TCI unit sizes. These may be installed at the time of
manufacture to increase the stack top height so that a unit can
comply with industry codes for proper dispersion of SO2 in sour
waste gas applications.

Solar UPS Power Required when there is insufficient or no
uninterruptible power supply available for an electronic pilot ignition
system. TCI can provide third party supplied solar power systems
approved by CSA, CE and UL with up to 14 days autonomy for 12 to
24 VDC.
TCI 4800 dual inlet, capacity HP .5—1.5 mmscf/d, LP .5—200 mscf/d
9

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
OPERATION
QUOTE INFORMATION

Key information required for a quote:
• Gas analysis,
• flow volume,
• temperature, and
• waste gas pressure.

For installed units, please complete as much information as available on the
data sheet that is included in the appendix of this publication.
TCI can also supply preliminary dispersion modeling to help
determine make-up gas requirements and/or height of a platform in sour gas
applications. Final dispersion modeling must be supplied by the customer.
The gas analysis and properties should be taken from a source as close as
possible to where the TCI unit will be installed.
A site plan may also be submitted along with site pictures to help
clarify any questions about installation or the application. TCI terms and
conditions apply to all sales unless stated otherwise at the time of quotation.
TCI equipment can handle intermittent or continuous flows and
multiple waste gas inlet lines at different pressures. It is recommended that
customers supply and install a knock-out tank between the waste gas source and
the TCI unit to remove liquids from the waste gas stream. Piping should slope
downwards from the source to the knock out tank and upwards to the TCI unit.

Fuel gas
• is required for flame failure ignition systems and/or,
• to operate one or more back pressure regulators;
• may also be added to the waste gas stream to either increase its heating value
or to help reduce the required stack height for
dispersion of S02 in sour gas
10

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
INSTALLATION
Set-up and Commissioning
should be done under the supervision of a
qualified TCI representative or equivalent.

For mobile units the trailer or skid is
leveled, the stack or stacks are erected then
guyed and connections are made for the waste
gas. This typically takes 2 to 4 hours.

For installed units a crane or picker truck
is required to lift a unit onto a pile or platform
where it is bolted down. Guy wires are then
attached and the waste gas lines connected.
This typically takes between 4 to 8 hours. All
logistics are EX Works, Incoterms 2000
unless stated otherwise and manufacturing is
usually completed within 4-8 weeks.
During installation the customer is responsible for:
• ensuring the inlet waste gas pressure does not exceed 14.9 psig;
• final dispersion modeling;
• installing a flame arrester;
• all electrical work at site;
• installing and maintaining a knock out tank and all associated piping;
• supplying a picker truck or crane at site;
• installing a pile, spool piece, base plate and anchors for the guy wires;
• transportation and installation of a platform if purchased;
• supplying not less than 30 psig clean dry instrument air or clean dry fuel gas;
• providing uninterrupted power and not less than 10 psig clean dry fuel gas for the
ignition;
• operating the unit safely as instructed by the TCI technician.

TCI is responsible for:
• overseeing the installation, providing a base plate and guy wires, final
inspection, fine tuning controls, on site training and making arrangements for on going
scheduled service.
TCI 1200, capacity 50 mscf/d
11

SERVICE

All TCI products carry a warranty for
any defective materials and
workmanship as stated in the sales
contract. The use of OEM parts is
required for the warranty to be in effect
unless stated otherwise. TCI recommends
that customers have their equipment
inspected every 6 months by a qualified
TCI employee or equivalent. TCI will
provide a written report for each service
visit. To help facilitate this, recommended
spare parts should be purchased and kept in
stock at all remote locations. Any repairs
or maintenance should be noted and
corrected immediately to ensure the
product works to its designed
specifications, to prevent unnecessary
damage to the equipment and to maximize
product life. Safety: TCI recommends that
all installations be done by
qualified personnel. Safety
signs are placed on all
equipment to warn workers of
hot surfaces and a removable
safety cage is available for less
secure areas. Correct operation
and safety training is provided
with each new application and
written instructions are left with
operators for future reference.
Compliance: Third party testing has
been completed to ensure compliance
with radiant heat, noise and
combustion efficiencies for installed
units. Please contact your TCI
representative if you require access to
this information.

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
TCI 6000, capacity 6 mmscf/d
12

“

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
TCI - DATA INQUIRY FORM

SECTION 1 CONTACT INFORMATION

Company name:
Company address:
Location of job is:
Contact name:
Title:
Contact phone number:
Contact facsimile number:
Contact e-mail:
End user name:
Project name or inquiry reference number:
Requested delivery date:
Is a budget or firm price required?
______________________________________________________________________________________

SECTION 2 WASTE GAS INFORMATION

Main Waste Gas Line
If you have more than one inlet line please complete SECTION 3
Source of waste gas is:
Normal flow volume (mscf/d) is:
Maximum flow volume (mscf/d) is:
Gas Temperature (C or F) is:
Net lower heating value (MJ/m3) is:
Gas molecular weight is:
Maximum allowable back pressure (psig or kPag) is:
Back pressure setting for the waste gas relief valve is (oz/in2 or psig):
Pipe size and pipe schedule are:
Height of pipe at inlet of incinerator is:
Note: If the net lower heating value of your waste gas is less than 20MJ/m3 please complete
SECTION 4

Ignition - Please Circle Either A or B.
(A) Manual piezo spark ignition:
(B) Flame failure ignition with auto-relight, control panel and alarms-requires uninterrupted power
supply:
What voltage do you require (IE: 12 or 24 VDC or 120VAC, etc.):
Enclosure type required for control panel is:

If you do not have uninterrupted power supply at site for (B) above please compete SECTION 5
Each TCI supplied Profire flame failure ignition system requires 1.6 watts with display on and 0.9 watts
with display off.

TCI requires a gas analysis
If the waste gas stream is sour (IE: Contains hydrogen sulfide or H2S) please complete
SECTION 6
13

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
Logistics
Do you require a price for crating? (Not required for orders in western Canada):
______________________________________________________________________________________

SECTION 3 OPTIONAL LINES

Additional Waste Gas Inlet Lines
Optional second waste gas line
Source of waste gas is:
Normal flow volume (mscf/d) is:
Maximum flow volume (mscf/d) is:
Gas temperature (C or F) is:
Net lower heating value (MJ/m3) is:
Gas molecular weight is:
Maximum allowable back pressure (psig or kPag) is:
Back pressure setting for the waste gas relief valve is (oz/in2 or psig):
Pipe size and pipe schedule are:
Height of pipe at inlet of incinerator is:
______________________________________________________________________________________

SECTION 4 MAKE-UP GAS

Make-up gas available at site is (IE: Methane, Propane, etc.):
Amount of make-up gas available at site is:
Pressure of make-up gas at Site (psig or kPag) is:
______________________________________________________________________________________

SECTION 5 UNINTERUPTED POWER SUPPLY

Voltage requirement for solar system with 14 day autonomy is (12VDC to 600VDC):
______________________________________________________________________________________
SECTION 6 SOUR GAS

Sour gas information – please supply a site plan
Stack top height required for dispersion of sulfur dioxide (SO2) is:
Maximum allowable level of ground level SO2:
Seismic zone is:
Design wind speed is:
Site elevation:
Note: TCI can do preliminary dispersion modeling to provide approximate make up gas requirements
and/or approximate height of a TCI supplied platform to meet regulations.
______________________________________________________________________________________

Notes on Gas Analysis Submitted to TCI:
When replacing existing combustion equipment a waste gas sample and properties should be taken at the
flange that will connect to the TCI unit.

When constructing a new facility, a computer simulation may be used taking into account all equipment,
piping and changes to gas composition and properties between the waste gas source and the inlet of the
TCI unit.
14

“

TYPICAL P&ID
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
15

“

“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
DISCLAIMER
The marketing literature in this product
catalog was written based on the most
up-to-date information available at the
time of publishing. If any errors or
omissions are found, please contact TCI
w i t h c o r r e c t i o n s a t
www.tciburners.com. This catalog is
intended to serve as an overview of
products and services available at TCI.
In different parts of the world products
and services may vary. Therefore, we
recommend that you contact your local
agent or representative to confirm any
information you require.
Contact Information:

Thomas P. Mark, LLC
Enclosed Burner / Incinerator
Sales and Service
8026 S. Quince Way
Centennial, CO, USA 80112-3214
Phone: [phone]
Fax: [phone]
www.tciusainc.com
Last revision date: July 15. 2009
TCI 500, capacity 20 mscf/d
16
Head Office:
TCI USA, INC.
6725D Golden West Avenue
Red Deer, Alberta T4P 1A7
Canada
Ph: [phone]
Fax: [phone]
Web: www.tciburners.com

GLOSSARY
“Engineered Solutions For Combusting Waste Gas”
www.tciusainc.com ● [phone]
Deflagration flame arrester (p.8) A device designed
to stop the propagation of flames. Typically,
deflagration flame arresters must only be used at
or close to the open end of a system. Deflagration
is a subsonic combustion process in which the
flame heats the next layer of fuel to ignite it.

Detonation flame arrester (p.8) A device designed
to stop the propagation of flames. Typically,
detonation flame arresters are used in systems
where both ends of the flame arrester are
connected to confined spaces. Detonation is a
supersonic combustion process in which a shock
wave compresses the fuel in front of the wave and
ignites it. Detonation flame prorogation can
generate extremely high pressures.

Dispersion modeling (p.4) A set of mathematical
relationships based on scientific principles that
relate emission rates of an air contaminant to the
expected ambient concentrations of the
contaminant.

Make-up gas (fuel) (p.2) Gas added to waste gas to
improve the combustion characteristics of the
waste-gas. In some cases make-up gas is added in
order to avoid the dispersion of gas emissions by
increasing the energy density of the flue gases.

OEM part (p.12) Original Equipment Manufacturer
Part. A part that is approved for use by the
manufacturer.

TCI ring burners (p.7) A set of burners equally
spaced around the circumference of one or more
sections on a TCI stack. These burners have
independent lines and controls to allow additional
waste gas to be introduced to the unit above the
main burners.

Venturi burner (p.1) A type of naturally aspirated
gas burner in which a combustible gas flows
through an orifice into a venturi throat in order to
induce and pre-mix air prior to ignition. TCI 4000, capacity 400 mscf/d
TCI 10,000, capacity 9 mmscf/d
TCI 7500, capacity 6 mmscf/d
17
Page 1 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

Date: November 19, 2014

PURCHASE AGREEMENT

BUYER: Hiram Alba
d/b/a/ GeoStrata
14425 S. Center Point Way
Bluffdale, UT 84065

SELLER: WORLDWIDE RECYCLING EQUIMENT SALES, LLC
P.O. BOX 1027
MOBERLY, MO 65270

WHEREBY, Buyer agrees to buy and Seller agrees to sell:

DESCRIPTION: Indirect Fired Rotary Kiln Thermal Desorption System with Vapor
Recovery System Including one (1) used/reconditioned primary thermal desorption
system consisting of ≈2.5’ diameter x 16’ long stainless steel rotary drum with one (1)
used/reconditioned vapor recovery system including all controls.

As outlined in the attached Exhibit “A”

PROCESS CONDITIONS:
Material: Hydrocarbon Contaminated Waste
Feed Rate: 1 t/h
Feed Temperature: 70° F
Feed Moisture (diesel range): 20% - 15%
Product Temperature: 750° F
Heat Requirement: 1.74 MMBtu
Vapor & air flow: 400 ACFM
Elevation: ≈ 5500 ft. above sea level

1414 Riley Industrial Dr, P.O. Box 1027, Moberly, Missouri 65270 USA
Telephone: [phone] International: +1.660.263-7575
Fax: [phone] E-mail:[e-mail]
www.wwrequip.com

Page 2 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

SUPPORT SERVICES TO THE BUYER:
Erection, Installation of Equipment, Commissioning, and Training of Personnel
Also OFFERED is the OPTION for 1 technician for up to twenty eight (28) days of field
engineering services for supervising the erection of equipment, installation of equipment,
commissioning and training of operating personnel as, at a cost of $1500.00 USD a day
(includes travel time at same daily rate) to be paid prior to departure.

NOTE: Buyer will provide airfare; lodging and travel arrangements to and from the work site and
to and from any sites needed for materials needed to be purchased on site. Buyer will provide
translator for proper communication between Seller’s technicians and Buyer’s laborers. Buyer
will also provide tools necessary for erection the equipment herein, including but not limited to
arc or mig welder and rods/wire, oxygen/acetylene torch with gases, pipe cutter and pipe
threaded, pipe wrenches, hand tools, wrenches, ratchets, sockets and hammers customarily
used with the erection of such equipment. Buyer will upload, load and transport all equipment
from the port to the installation site.

Buyer will also provide on-site a crane and operator and riggers or combination of cranes, crane
operators and riggers capable of safely lifting 100,000 pounds, at the distance and height
necessary to install the above items in Buyers existing facilities as needed but not less than two
days. Buyer will also provide local labor necessary to erect the system under the supervision of
Seller’s technician.
Any services to be provided to Buyer under this section must be scheduled and received within
6 months from the shipping date of the equipment sold hereunder or the Sellers obligation to
provide such services is waived and the payments for such services are forfeited by Buyer.
Seller shall also be excused for delays in performance which result, in whole or in part, from
strikes, lockouts or other differences with employees or any cause beyond the control of the
Seller including, but not limited to, fire, earthquake, tornado/cyclone, hurricane/typhoon, flood or
windstorm, acts of God, disease outbreak, war, terrorism, riot, or embargoes.

PURCHASE PRICE

Eight Hundred Eight Five Thousand US Dollars $885,000.00 USD

Freight: Ex Works Moberly, MO

TERMS AND CONDITIONS

1. PAYMENT TERMS
50% of total purchase price due upon execution of this purchase agreement to be paid to
Seller via Bank Wire Transfer pursuant to instructions contained herein.

50% of total price to be paid to Seller prior to shipment of equipment to be paid to Seller via
Bank Wire Transfer pursuant to instructions contained herein.

100% of any option price above must be paid at execution of this agreement via Bank Wire
Transfer pursuant to instructions contained herein.
Page 3 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

SELLER’S BANK INFORMATION
BANK OF AMERICA
800 East Cherry Street
Columbia, MO
ABA Routing #026009593
SWITFT CODE BOFAUS6S
Account#3480634802
To the Account of
Worldwide Recycling Equipment Sales, LLC

2. Variation in Price and Availability
Prices quoted herein are valid for 60 days and all used equipment or used components
quoted in this agreement are subject to prior sale. Seller reserves the right to amend pricing
at any time prior to “Acceptance” as defined below due to fluctuations in commodity pricing
for components or raw materials used in the manufacture of any components of any
equipment sold under this agreement.

3. Condition Precedent to Effectiveness of this Agreement. As a condition precedent to
the effectiveness of this Agreement, this Agreement shall not be binding on either Buyer or
Seller until such time as Seller has received the first payment from Buyer.

4. Representations and Warranties. Each of Buyer and Seller represent and warrant that
(a) it has full power and authority to undertake the obligations set forth in this Agreement
and that it has not entered into any other agreement nor will it enter into any other
agreement that would render it incapable of satisfactorily performing its obligations
hereunder; (b) it has taken all action necessary to authorize the execution, delivery and
performance of this Agreement and when executed and delivered it will be the legal, valid
and binding obligation of such Party, enforceable against such Party in accordance with its
terms subject to applicable bankruptcy, moratorium and other similar laws affecting
creditors’ rights, and to general equity principles, and (c) the officer of such Party that is
executing this Agreement has been so authorized

5. Taxes
The amount of any present or future tax based on the sale, use, or contract price of the
equipment covered hereunder shall be paid by Buyer unless otherwise included in the sale
price. Buyer shall indemnify and hold Seller harmless from any such tax, and any interest
and penalties thereon, and hold Seller harmless from any such tax, and any interest and
penalties thereon, and any claims, demands or legal proceedings (including the costs,
expenses and reasonable attorney’s fees incurred in connection with the defense of any
such matter). Seller shall also receive interest on the amount of taxes paid at the rate of
1.833% per month if permitted by law, otherwise, at the highest lawful rate from the date of
payment of the taxes by Seller to the date of Buyer’s reimbursement to Seller of these taxes.

6. Tender of Delivery and Shipment
The equipment is sold “Ex Works” Moberly, MO. Tender of delivery by Seller to Buyer shall
occur at the place of shipment when Seller gives Buyer notice that the equipment is stowed
for delivery. Seller is authorized to make the necessary arrangements with a carrier for both
Page 4 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

the delivery of the equipment from the carrier and the transportation by the carrier to Buyer.
Buyer shall furnish notification reasonably necessary to enable the carrier to make proper
delivery at the destination, and Buyer must furnish facilities reasonably suited for the receipt
of the equipment. Risk of loss and title to the equipment shall pass to Buyer upon tender of
delivery to vessel for delivery at the port for shipping. Buyer shall bear the cost of shipment,
unless otherwise agreed to in writing by Seller. Claims on account of error or shortage will
not be considered unless made immediately on receipt of shipment. The items of material
as shown on the invoice, packing list, and bill of lading shall govern settlements in all cases
unless such notice of shortage is immediately reported to both the agent of the delivering
carrier and to Seller so that the alleged shortage can be verified.

7. Delays in Performance and Shipment
In addition to delays agreed to or caused by Buyer, Seller shall also be excused for delays
in performance which result, in whole or in part, from strikes, lockouts or other differences
with employees or any cause beyond the control of the Seller including, but not limited to,
fire, earthquake, flood or windstorm, war, terrorism, riot, or embargoes, delays, losses or
damages in transportation, or shortage or delay in receipt of cars, fuel, labor or material. If
any such event occurs, the time of completion shall be extended accordingly. Buyer may, at
its option, request a delay in the scheduled shipment date at no penalty provided the
request is made ten (10) days prior to the scheduled shipment date. Should such a delay
occurs, Buyer shall pay for the balance of the sales price when completed, irrespective of
the shipment date. At Seller’s sole option, the equipment may be stored at Buyer’s risk and
expense.

8. Security Interest and Default
Buyer hereby grants Seller a security interest in the equipment purchased and the proceeds
thereof, which shall continue until payment is full of the purchase price for such equipment.
If Buyer wrongfully rejects or revokes acceptance or fails to make a required payment on or
before delivery, repudiates or otherwise breaches the Agreement, then Seller shall have all
the remedies available herein and under the Uniform Commercial Code, including the right
to resell the equipment involved and recover damages from Buyer. If resale is at a private
sale, Seller shall give Buyer reasonable notification of its intention to resell. If the resale
does not result in satisfying all of Seller’s loss, then Buyer is obligated to pay to Seller such
additional amounts as will make Seller whole under the Agreement. Buyer shall pay Seller,
in addition to the interest on overdue payments specified in Paragraph 1 herein and all
damages as allowed by law, reasonable attorney’s fees and other costs of Seller incurred in
enforcing any of Seller’s rights or remedies under the Agreement and the Uniform
Commercial Code. The equipment purchased shall remain personal property and shall not
be considered a fixture or a part of any real estate on which it may be located.

9. Transportation of Equipment
Seller is responsible for delivery at Moberly, MO. Buyer is therein responsible for
transportation to Buyer’s site. Buyer shall be responsible for compliance with all applicable
transportation, motor vehicle and safety laws. Buyer shall obtain any necessary licenses
and/or permits and meet all federal, state, and local requirements from point of delivery.
Except for Seller’s negligence, the use of portable equipment is at Buyer’s risk and Seller
shall in no way be held responsible for damage, injury or expense incurred by Buyer or any
other party as a result of Buyer transporting equipment from Port of Discharge and transfer
of title. Buyer shall indemnify and hold Seller harmless from all claims, demands or legal
Page 5 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

proceedings (including the expenses and reasonable attorney’s fees incurred in connection
therewith) which may be made or brought against Seller in connection with Buyer’s failure to
comply with all applicable laws and regulations or arising out of Buyer’s transporting of said
equipment.

10. Used Equipment
If the equipment sold by Seller to Buyer is used, such equipment (even if refurbished) is sold
“as is where is” without representation or warranty of any kind.

11. Installation
Buyer shall be solely responsible, at its expense, for the proper installation and erection of
the equipment purchased, unless otherwise stated in Seller’s proposal or quotation.
Although Seller may in some cases provide a serviceman and or technician, instructions or
drawings to aid Buyer with installation or support of the equipment, Seller expressly
disclaims any warranties with respect to such installation and support. Buyer shall indemnify
defend and hold Seller harmless from all claims, demands or legal proceedings (including
the expenses and reasonable attorney’s fees incurred in connection therewith) which may
be made or brought against Seller in connection with damage or personal injury arising out
of improper installation, erection, start-up, or operation of the equipment.

12. Integration and Assignment
The final written proposal or bid of Seller and these Terms and Conditions, are intended by
the parties as the sole, final and collective expression of their bargain. These collectively
constitute and are referred to herein as the “Agreement”. Any representation made in or by
Seller’s advertising or samples, any prior dealings between the parties or any representation
by any agent, employee or representative of Seller which is not contained in any of the
above-referenced documents shall not supplement or explain, nor shall it be considered a
part of the Agreement. The Buyer may not assign any of its rights or obligations under the
Agreement without the prior written consent of Seller.

13. Acceptance
Applicable Law and Modification. Seller’s final written proposal or bid and these Terms and
Conditions are deemed accepted by Buyer and shall be the Agreement between the parties
upon receipt by Seller of the first payment. Any term or condition submitted by Buyer to
Seller (whether in a solicitation for bids, acceptance or in a purchase order) which is in
addition to or inconsistent with Seller’s final proposal or these Terms and Conditions shall be
deemed rejected by Seller and shall not become a part of the Agreement. Any reference
herein to the “Uniform Commercial Code” or the “Code” is to said “Code” as adopted by
Missouri. The Agreement can be modified only by a writing signed by Buyer and Seller.

14. Proprietary Information
Seller’s proposal or bid, any financial or business information about Seller, and all technical
information, data, specifications, plans, designs, drawings, know-how and ideas produced
by Seller to or for Buyer’s benefit are deemed confidential, proprietary information belonging
solely to Seller (collectively the “Information”). Buyer agrees to treat all said information
confidentially and to take reasonable precautions against disclosure of said information to
third parties. Buyer further agrees that the information shall be used by Buyer, and no one
else, for the limited purpose of evaluating Seller’s proposal or bid and, if accepted by Buyer,
for performance of the Agreement. Any other use of the information is prohibited.
Page 6 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

15. Governing Authority
The Laws of the State of Missouri, United States of America shall govern this Agreement.
The parties hereto agree to the exclusive jurisdiction and venue of the Circuit Court of St.
Louis County, Missouri, in reference to any dispute or litigation regarding this agreement.
Unless otherwise stated above Buyer is purchasing equipment “as is” “where is” with no
representations or warranties expressed or implied.

15. Signature by Facsimile
This Agreement may be executed by facsimile and in counterparts, each of which shall be
deemed an original, but which, when taken together, shall constitute one and the same
Agreement.

16. Additional Requirements to be provided by the Buyer
1. All state and local engineering approvals, soil analysis and footing design, risk
analysis, and certificates
2. Taxes and duties
3. Freight costs from point of discharge at Moberly, MO
4. Permits for air, construction, and others for operation of the plant.
5. Site preparation, including support (compacted soil) for equipment frames.
6. Electrical power supply as required.
7. Local to the equipment electrical disconnects (stop controls at individual pieces of
equipment) if required
8. Lubricating grease and oil
9. Equipment to equipment interconnecting fuel piping, fuel pumps, fuel valves, fuel
storage, propane low flame fuel and piping. Compressed air piping.
10. Water pressure and variable supply as needed
11. Start-up/calibration service for: dryer burner, compressor, unless purchased
12. Equipment, cranes, man lifts, and general tools for installation of equipment
13. Properly sized transformer from main power
14. Continuous Emission Monitoring Equipment on the stack.
15. Fuel oil supply sufficient psi and volume for pilot and for burner
16. Any service or item not part of this contract.

Agreed upon on the 19th day of November, 2014.

WORLDWIDE RECYCLING EQUIPMENT Hirma Alba d/b/a/ GEOSTRATA
SALES, LLC BUYER
SELLER

By:_________________________ By:________________________

Page 7 of 9
Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

EXHIBIT A

GENERAL:
Used one ton per hour indirect heated rotary thermal desorption unit designed to remediate soils
and drilling muds contaminated with petroleum hydrocarbons with a used vapor recovery unit to
capture vapors from primary desorption unit. This unit consists of the following components.
1. Used Feed System: Hopper, Airlock and Feed Auger
2. Used Primary Treatment Unit: Indirect fired, rotary kiln, with combustion chamber,
burners and seals
3. Used Dry material discharge: discharge auger, cooling, quench and stack
4. Used Vapor Recovery Unit: Quench Scrubber, Cooling Units, oil water separators and
Knock Out Pot

Process Description:
Oil contaminated waste from centrifuge supplied by client will be transferred to the feed hopper
of the Primary Thermal Desorption Unit with client’s backhoe or skid loader. The material will be
fed to a feed hopper, which is equipped with a weight controlled feed valve as well as a double
dump airlock. From the double dump airlock, the material will be augured in to the rotary kiln.
The indirect fired rotary kiln will have two heat zones; the operating temperature of the drum will
be up to 750⁰F. The rotary kiln is housed in a combustion chamber which has burners mounted
to the side delivering a total of 2 MMBtu heat which is transferred to the dryer shell. The kiln will
operate under a slight negative atmosphere and the vapors from the contaminated soil are
pulled out of the system in a counter current direction to the material flow. The clean dried
material is discharged to a water cooled discharge auger which will re-hydrate the material and
cool it down, and the steam is extracted through a quench stack which will remove any
particulate from the vapor stream before discharging it into the atmosphere.
The vapor from the primary unit is pulled in to a high efficiency quench scrubber which will use
oil as the quench liquid. The quench will operate at approximately 200⁰F and remove dust
particulate, as well as condense the heavier hydrocarbons in the vapor stream. The condensed
oil and sludge is pumped through a set of filters to an oil water separator where after it is
pumped to an onsite storage tank (to be supplied by client)
The vapor not condensed in the Quench Scrubber is pulled through a shell and tube heat
exchanger reducing the temperature to 70⁰F and then pulled into a knock out pot. The knock out
pot has a demister pad to remove any particulate greater than 10 Microns. The fluid from the
knock out pot, condensed water and oil, is pumped to an oil water separator, then to a water
and oil holding tank (to be supplied by client).
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Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

The non-condensable gasses are pulled from the knock put pot and circulated back to the
combustion chamber on the thermal desorption unit where it is being used as a fuel source to
supplement burners as well as reduce overall operating cost.
Main Process Components

MATERIAL FEED SYSTEM
Martial stockpile: Client to provide feed system.
PRIMARY THERMAL DESORPTION UNIT
Indirect thermal desorption unit consisting of rotary kiln, combustion area, seals, tires, trunions
and burners.
Used Rotary Kiln: The rotary drum is a ≈2.5’ diameter x 16’ long stainless steel rotary drum
processing 1 T/hr. Flights are spiral flights , mounted at the feed side followed by radial bar
flights for the remaining length of the drum. The tires are solid, rectangular section rolled forged
rings. Tires are mounted with spoke type mounting pads located under the tire. The dryer drive
is a electrical motor, 480 V, 3 Phase, with gear reducer. The gap between the rotating shell and
the stationary housing will be sealed with Flex-Steel overlapping type seals.
Used Combustion Chamber and Burners: The rotary drum is housed in a combustion
chamber (Firing Hood) which is a carbon steel, ceramic wool lined hood. The combustion
chamber has burners mounted to the side delivering a total of 2 MMBtu heat which is
transferred to the dryer shell. The hood will also be sealed with Flex-Steel type seals.

USED MATERIAL DISCHARGE SYSTEM
 Used Auger: Material is discharged in to water cooled screw auger were the material is
sprayed with water through a series of spray nozzles. The auger has a double dump
valve at discharge to prevent oxygen from entering system.
 Used Discharge Quench: The stack on the discharge auger will be fitted with water
spray nozzles alongside the length of the stack. The purpose of the quench spray is to
remove any excess particles from the gas stream before discharging stream into the
atmosphere.
USED VAPOR RECOVERY SYSTEM
One used vapor recovery unit (VRU) to recover vaporized hydrocarbons from Primary Thermal
Desorption Unit consisting of following type of components:

 Used Quench Scrubber: Quench scrubber with mist eliminator removing particulate
from vapor stream;
 Used Air Cooled Hear Exchanger: The air cooled heat exchanger will be used to cool
the scrubber fluid for the Quench Scrubber;
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Hiram Alba d/b/a/ - GeoStrata
November 19, 2014

 Used Spiral Heat Exchanger: to reduce vapor temperature, condensing water and
condensable hydrocarbons in knock-out pot;
 Used Refrigeration plant: The refrigeration plant cools the coolant used in the shell
and tube heat exchanger;
 Used Knock Out Pot: The knock out pot will be used to separate the fluids and non-
condensable gasses from the process vapor stream.
 Used Oil Water Separator: Fluid from Knock Out Pot is pumped here to remove oil
from water.
 Used Thermal Oxidizer: to oxidize all non-condensable VOC’s at high temperature to
form CO2 and H20.

Appendix E

Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2)
4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD)
9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced
3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]
A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________

Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________

End product of this process:

_______________________________

3. Permit Change Type: New Increase*

Equipment

Process

Condition Change ____________________

Other ______________________________

Other ______________________________

Other ______________________________

4. Does new emission unit affect existing
permitted process limits?

Yes No
5. Condition(s) Changing:

6. Description of Permit/Process Change**

7. New or modified materials and quantities used in process. **
Material Quantity Annually

8. New or modified process emitting units **

Emitting Unit(s)

Capacity(s)

Manufacture Date(s)

*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.

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:

Appendix F

Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Jccumonl Dcjlc: 02/28/2018
TANKS 4.0.9d
Emissions Report - Detail Format
Tank Indentification and Physical Characteristics
Identification
User Identification: IWM New 500 Stroage Tank
City:
State:
Company:
Type of Tank: Vertical Fixed Roof Tank
Description: Permit Mod 2022
Tank Dimensions
Shell Height (ft): 25.00
Diameter (ft): 12.00
Liquid Height (ft) : 22.00
Avg. Liquid Height (ft): 20.00
Volume (gallons): 18,612.65
Turnovers: 1,267.13
Net Throughput(gal/yr): 23,584,615.00
Is Tank Heated (y/n): N
Paint Characteristics
Shell Color/Shade: White/White
Shell Condition Good
Roof Color/Shade: White/White
Roof Condition: Good
Roof Characteristics
Type: Cone
Height (ft) 1.00
Slope (ft/ft) (Cone Roof) 0.17
Breather Vent Settings
Vacuum Settings (psig): -0.03
Pressure Settings (psig) 0.03
Meterological Data used in Emissions Calculations: Salt Lake City, Utah (Avg Atmospheric Pressure = 12.64 psia)
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TANKS 4.0.9d
Emissions Report - Detail Format
Liquid Contents of Storage Tank
IWM New 500 Stroage Tank - Vertical Fixed Roof Tank
Daily Liquid Surf.
Temperature (deg F)
Liquid
Bulk
Temp Vapor Pressure (psia)
Vapor
Mol.
Liquid
Mass
Vapor
Mass Mol. Basis for Vapor Pressure
Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations
Water All 53.92 47.99 59.86 51.98 0.2326 0.1885 0.2855 18.6765 18.35 Option 2: A=8.14, B=1810.94, C=244
Crude oil (RVP 5)2.5505 2.2605 2.8697 50.0000 0.0200 0.0520 207.00 Option 4: RVP=5
Methanol 1.2146 1.0026 1.4641 32.0000 0.0013 0.0067 32.00 Option 2: A=8.08, B=1582.3, C=239.7
Water 0.2277 0.1842 0.2800 18.0000 0.9787 0.9413 18.00 Option 2: A=8.14, B=1810.94, C=244
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TANKS 4.0.9d
Emissions Report - Detail Format
Detail Calculations (AP-42)
IWM New 500 Stroage Tank - Vertical Fixed Roof Tank
Annual Emission Calcaulations
Standing Losses (lb): 8.0075
Vapor Space Volume (cu ft): 603.1858
Vapor Density (lb/cu ft): 0.0008
Vapor Space Expansion Factor: 0.0492
Vented Vapor Saturation Factor: 0.9383
Tank Vapor Space Volume:
Vapor Space Volume (cu ft): 603.1858
Tank Diameter (ft): 12.0000
Vapor Space Outage (ft): 5.3333
Tank Shell Height (ft): 25.0000
Average Liquid Height (ft): 20.0000
Roof Outage (ft): 0.3333
Roof Outage (Cone Roof)
Roof Outage (ft): 0.3333
Roof Height (ft): 1.0000
Roof Slope (ft/ft): 0.1700
Shell Radius (ft): 6.0000
Vapor Density
Vapor Density (lb/cu ft): 0.0008
Vapor Molecular Weight (lb/lb-mole): 18.6765
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 0.2326
Daily Avg. Liquid Surface Temp. (deg. R): 513.5939
Daily Average Ambient Temp. (deg. F): 51.9625
Ideal Gas Constant R
(psia cuft / (lb-mol-deg R)): 10.731
Liquid Bulk Temperature (deg. R): 511.6525
Tank Paint Solar Absorptance (Shell): 0.1700
Tank Paint Solar Absorptance (Roof): 0.1700
Daily Total Solar Insulation
Factor (Btu/sqft day): 1,452.1184
Vapor Space Expansion Factor
Vapor Space Expansion Factor: 0.0492
Daily Vapor Temperature Range (deg. R): 23.7301
Daily Vapor Pressure Range (psia): 0.0970
Breather Vent Press. Setting Range(psia): 0.0600
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 0.2326
Vapor Pressure at Daily Minimum Liquid
Surface Temperature (psia): 0.1885
Vapor Pressure at Daily Maximum Liquid
Surface Temperature (psia): 0.2855
Daily Avg. Liquid Surface Temp. (deg R): 513.5939
Daily Min. Liquid Surface Temp. (deg R): 507.6614
Daily Max. Liquid Surface Temp. (deg R): 519.5264
Daily Ambient Temp. Range (deg. R): 23.3583
Vented Vapor Saturation Factor
Vented Vapor Saturation Factor: 0.9383
Vapor Pressure at Daily Average Liquid:
Surface Temperature (psia): 0.2326
Vapor Space Outage (ft): 5.3333
Working Losses (lb): 464.2365
Vapor Molecular Weight (lb/lb-mole): 18.6765
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 0.2326
Annual Net Throughput (gal/yr.): 23,584,615.0000
Annual Turnovers: 1,267.1282
Turnover Factor: 0.1903
Maximum Liquid Volume (gal): 18,612.6517
Maximum Liquid Height (ft): 22.0000
Tank Diameter (ft): 12.0000
Working Loss Product Factor: 1.0000
Total Losses (lb): 472.2440
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TANKS 4.0.9d
Emissions Report - Detail Format
Individual Tank Emission Totals
Emissions Report for: Annual
IWM New 500 Stroage Tank - Vertical Fixed Roof Tank
Losses(lbs)
Components Working Loss Breathing Loss Total Emissions
Water 464.24 8.01 472.24
Water 436.98 7.54 444.52
Methanol 3.10 0.05 3.15
Crude oil (RVP 5) 24.16 0.42 24.58
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IWM – August 2022 NOI

Copyright © 2022 GeoStrata Notice of Intent
Page | i
Table of Contents
INTRODUCTION ................................................................................................................... 1
1.1 Process Flow: ................................................................................................................... 1
1.1.1 Water ......................................................................................................................... 1
1.1.2 Oil ............................................................................................................................. 2
1.1.3 Solids......................................................................................................................... 2
EQUIPMENT DETAILS ........................................................................................................ 2
2.1 Storage Tanks ................................................................................................................... 3
2.1.1 Emissions Controls ................................................................................................... 3
FACILITY THROUGHPUT ................................................................................................... 3
EMISSIONS INFORMATION ............................................................................................... 4
4.1 Storage Tanks ................................................................................................................... 4
EMISSIONS IMPACT ASSESSMENT (EIA) ....................................................................... 4
REGULATORY REVIEW...................................................................................................... 4
BACT ANALYSIS .................................................................................................................. 5
7.1 Storage Tanks ................................................................................................................... 5
REFERENCES ........................................................................................................................ 7

IWM – August 2022 NOI

Copyright © 2022 GeoStrata Notice of Intent
Page | ii
List of Figures
Figure A-1. Facility Location.
Figure A-2. Proposed Water Cleaning Facility Site Layout.
Figure A-3 Proposed Water Cleaning Facility Process Flow Diagram

List of Tables
Table B-1. Equipment Location and Stack Height Information.
Table B-2. Facility Controlled and Uncontrolled Emissions (tons/yr).
Table B-3. Facility Controlled Emissions (lbs/hr).
Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Table B-6. Regulatory Review.
Table B-7. BACT Controls Analysis Reductions and Emissions.

List of Appendices
Appendix A. Figures
Appendix B. Tables
Appendix C. Emissions Estimates
Appendix D. Equipment Specification Sheets
Appendix E. Utah DAQ Forms
Appendix F. EPA Tanks 4.09D Results
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
Page | 1
INTRODUCTION
The Integrated Water Management (IWM) operates a water disposal facility under the existing
Utah Division of Air Quality (UDAQ) Approval Order Number DAQE-AN154870001-19. It is
intent that IWM will adjust the existing equipment at this facility and will incorporate additional
tank storage capacity and remove and replace several tanks at the water receiving portion of the
facility. The changes to the tank storage will not affect the throughputs permit at the facility and
there are no proposed changes to the equipment or throughputs at the oil cleaning portion of the
facility.

This change to the storage tank equipment is an alteration to the layout of the facility and based
on conversations with representatives at UDAQ will require a new Notice of Intent (NOI) and
update to the Approval Order (AO). This NOI is submitted to the New Minor Source Review
group for review and modification of the existing AO. This submittal includes new updated
information reflecting how the IWM facility will operate going forward including new off-
loading tank emissions, updated facility wide emissions and an updated Best Available Control
Technology analysis. This introduction will review the key components of the facility and the
process flow of the facility with the proposed changes.

The IWM facility is located at UTM coordinates 553295.16 meters (m) East 4458126.96 m
North (zone 12 NAD 1983). The facility is located approximately 7.8 miles north of Duchesne,
Utah. Figure A-1 illustrates the location of the IWM facility. The existing facility layout is
illustrated in Figure A-2 and includes the following emissions sources:

1. Storage tanks for produced water, crude oil, and condensate,
2. Evaporation Ponds for treated water,
3. Mechanical oil, water, and solids separation equipment, (i.e., equipment leaks)
4. Centrifuge solids and other imported solids,
5. Tank heaters,
6. Truck loading, and
7. Unpaved roads.

IWM will be adding storage tanks to the water receiving storage tanks. These tanks are listed as
item II.A.6 under the approved equipment in the AO. The proposed layout with the new tank
configuration is shown on Figure A-3. The facility oil cleaning process will not be altered as part
of this NOI however it is proved in this introduction as a review of the process that is part of the
existing AO. The diagram in Figure A-4 show the existing process flow at the facility.
1.1 Process Flow:
1.1.1 Water
Produced water from oil production wells is delivered to the facility and pumped into a tank
battery consisting of twenty-three (23) off-loading tanks for initial gravity separation of water
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
Page | 2
and oil. Water separated in this process is then ran through a filter pot and routed to a set of nine
(9) pre-injection tanks. The water will then be routed and pumped into the deep injection well on
site. Water collected from the oil cleaning facility will be stored in a 500-bbl tank and piped back
to the decanting tanks at the head of the process. Figure A-4 and A-5 are process flow diagrams
that show the flow of water through the facility

1.1.2 Oil
The oil separated in any of the tanks as part of the water cleaning process will be loaded into a
tanker truck and moved to the proposed on-site oil cleaning facility where water and solids will
be removed from the oil. The trucks will unload the oil/water mixture to a filter pot and then into
one of four (4) tanks that will feed the oil/water mixture to the centrifuges for cleaning. As the
water/oil mixture is piped to the centrifuges it will be heated in a heat exchanger and then piped
to one of the two centrifuges located in the proposed oil cleaning building. Oil that is processed
through the centrifuge will be collected in a 500-gallon tank that feeds oil to a pump. Oil is
pumped and routed to one of four (4) oil storage tanks. Oil will remain in these tanks until it is
sold and transported off-site. See Figure A-4 and A-5 for further details.

1.1.3 Solids
The solids are separated from the oil and water primarily in the centrifuge and filter pots located
at the oil cleaning portion of the facility. Solids will also be separated from the water and oil in
the gravity separation tanks. The solids separated in the gravity separation will be routinely
cleaned out of the tanks and disposed in the onsite landfill. The solids removed during the
centrifuge process will be moved by an enclosed screw conveyor to a covered solids hopper. As
the hopper is filled with solids it will periodically be emptied into a haul truck and disposed in
the on-site landfill.

Drilling mud delivered to the site will be disposed directly into the landfill. All solids placed in
the landfill will have daily cover applied to control VOC off-gassing.

The IWM facility accepts off site sources of contaminated soils from oil and gas exploration and
production operations for treatment in its landfarm. These soils have typically been contaminated
by offsite sources, such as spills from oil production facilities, and the material typically has
fewer hydrocarbons than drilling mud and centrifuged solids. The imported solids will be mixed
into the landfarm at the northwest corner of the facility. The solids will be turned/aerated to
enhance biodegradation of the hydrocarbon content and to prevent stagnation of the oil and soil
substrate.
EQUIPMENT DETAILS
A list of equipment that will be modified as part of this NOI and associated emission controls are
provided below. The only section that has updated equipment is the Storage Tanks that are
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
Page | 3
identified in the AO under Section II, II.A.6. All other equipment is unchanged from the AO. A
list of all of the emission sources, approximate coordinates and the stack heights are presented in
Table B-1 of Appendix B. For a complete list of the equipment please refer to the 2019 NOI and
the current AO.
2.1 Storage Tanks
Based on the updated configuration of the tanks at the facility, there will be a total of 44 tanks at
the facility that will be used as part of the water and oil cleaning processes each with various
capacities and contents. All tanks at the site have fixed roofs equipped with a thief hatch.
Twenty-three (23) vertical tanks are used as produced water decanting tanks where oil and water
are gravity separated. And additional nine (9) will be used to store water prior to injection into
the on-site deep well. These tanks will have a capacity of up to 500-bbl each. All of these tanks
are not heated.

There are twelve (12) tanks for the new oil cleaning portion of the facility. Of the twelve tanks
four (4) are used as the Centrifuge feed tanks, one (1) oil pump tank, one (1) water pump tank,
one (1) centrifuged water tank, four (4) oil storage tanks and (1) freshwater tank (no production
water) that will is associated with the boiler. All of these tanks are heated.

In addition to the water and oil cleaning tanks, there are seven (7) tanks on site that are used for
storing brine water and do not contain materials that would have air pollutants. There are also
several other tanks on site that have been put out-of-service and/or will be phased out-of-service
and IWM will clearly mark tanks as out-of-service and dispose these tanks as part of the
construction process of the new portions of the facility.

2.1.1 Emissions Controls
All tank emissions will be controlled by a vapor collection system that will discharge the
collected vapors to a combustor. The destruction efficiency of the combustor is estimated to be
98% (Appendix D, TCI Specification Sheet).
FACILITY THROUGHPUT
The annual throughput of material at the facility is summarized below. The throughputs provided
here are unchanged from the 2019 NOI.

1. Produced Water (oil/water mix): 7,300,000 bbl;
2. Oil (separated and delivered): 145,000 bbl;
3. Condensate: 5,000 bbl
4. Centrifuged Solids (wet): 1,880 cubic yards (yds3) (1,185 tons dry)
5. Drilling Mud (wet): 360,000 bbl (52,400 tons dry)
6. Imported Solids (wet): 6,000 yds3 (5,525 tons dry);
7. Propane use for the tank heaters: 256,000 gallons per year.
IWM – August 2022 NOI
Copyright © 2022 GeoStrata Notice of Intent
Page | 4
EMISSIONS INFORMATION
This section lists the estimated controlled and uncontrolled emissions from the facility and a
description of the methods used to estimate the emissions for the modified equipment in this
NOI. All other equipment emissions information can be found in the 2019 NOI. The facility
wide emissions have been estimated based on the additional tanks added as part of this NOI and
are found in Appendix B.
4.1 Storage Tanks
The emissions from the storage tanks were estimated using the “EPA Tanks” program. The
assumptions, calculations, and results from the AP-42 emissions estimates are included in
Appendix C. The uncontrolled and controlled annual emissions from the tanks are listed in Table
B-2 and the hourly controlled emissions are included in Table B-3. EPA Tanks output results are
provided in Appendix F.

The estimated emissions from the tank breathing losses and working losses are reduced as a
result of the added tanks according to the estimates in EPA Tanks. The increased volume
available for storing liquids has reduced the emissions from the working losses of the tanks since
the volume available to store incoming water is increased. The throughput volume is unchanged
with this permit modification although the number of tanks available to store liquids is increased.
EMISSIONS IMPACT ASSESSMENT (EIA)
Following the Utah DAQ Guidelines (UDAQ, 2012) an Emissions Impact Assessment (EIA)
was performed for all the sources at the IWM facility to determine if any of the emission rates
were above the Emission Threshold Value (ETV) and if the emission levels exceed the modeling
requirement. The ETVs for each pollutant were determined using the American Conference of
Governmental Industrial Hygienists (ACGIH) spreadsheet (UDAQ, 2013).

The emissions from each source at the facility were compared to the regulatory limits. The
distance from the source to the property boundary, the type of emissions discharge (restricted or
non-restricted), the ETV category, and the ETVs are listed in Table B-4. None of the constituents
emitted from the facility exceed the ETVs.

The total facility criteria pollutant emissions from the facility are compared to the Utah DAQ
dispersion modeling threshold values in Table B-5 (UDAQ, 2012). None of the annual facility
emissions exceed the modeling threshold values.
REGULATORY REVIEW
Relevant state and federal regulations are identified in Table B-6 with a description of the
applicability to the facility. Forms for this modification to the AO are found in Appendix E.
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BACT ANALYSIS
The state of Utah requires a “top-down” approach for the Best Available Control Technology
(BACT) analysis which determines the most stringent control technology and emissions
limitation combination available for a similar source of emission units.

At the top of the “top-down” analysis are the control technologies and emissions limits that
represent the Lowest Achievable Emission Rate (LAER). As defined by NSR/PSD regulations,
LAER is the most effective control alternative and must be considered under the BACT analysis
process. The USEPA’s RACT/BACT/LAER Clearinghouse (RBLC) was used to identify recent
control technologies for similar units for this BACT analysis.

If the top level of control has adverse environmental, energy, or economic impacts, the
technology is rejected, and the next highest control is analyzed for impacts. This process is
continued until the BACT level under consideration cannot be eliminated by technical,
economic, energy, or environmental consideration. BACT cannot be determined to be less
stringent than the emissions limits established by an applicable New Source Performance
Standard (NSPS) for the affected air emissions source.

The economic impact of the control technologies is evaluated by determining the cost per ton of
pollutant removed. The annual cost per ton of constituent removed was determined using the
following equations (UDAQ BACT Guide).

𝐴=(𝐴+𝐴)/𝐴 Eq-1

&

𝐴=𝑃𝑉(𝑖
1−(1+𝑖)−𝑛) Eq-2

Where A is the annualized cost ($/ton), B is the annualized equipment cost, C is the annual
operation and maintenance cost, D is the annual emissions reduction (tons), PV is the present
value of the equipment, i is the interest rate (assumed to be 3%), and n is the life span of the
equipment. A description of the assumptions and calculations for estimating the controlled and
uncontrolled emissions are included in Appendix C. The results of the economic analysis are
included in Table B-7.
7.1 Storage Tanks
The constituents emitted from the storage tanks are VOCs and HAPs. The control of these
emissions includes the use of two technologies which are 1) Vapor Recovery and 2) destruction
(i.e., combustors). Vapor recovery systems for fixed roof tanks include a condenser that is
installed at the tank thief hatch (i.e., pressure valve). The vapors are condensed into a liquid state
and drip back down into the tank. The efficiency of a vapor recovery system ranges from 90% to
98% (AP-42 Section 7.2.1).

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Control efficiency of combustors range from 95% to 99% destruction of VOC and HAP
emissions. The combustor produces combustion by products such as hydrocarbons, particulate
matter (PM), nitrogen oxides (NOX), carbon monoxide (CO), carbon dioxide (CO2), and odors.

IWM has constructed two combustors to control the VOC and HAP emissions from tanks and
other containments. One combustor is used on the water cleaning facility and the other
combustor is used on the oil cleaning facility. In comparison with the vapor recovery unit, the
control efficiencies are similar, but the combustor is mechanically easier to operate. Therefore,
the use of a combustor is considered BACT. The additional tanks incorporated into the facility
will have the vapor emissions controlled by use of the combustor. The annualized cost of a
combustor is included in Table B-7.

REFERENCES

Environmental Protection Agency (EPA) Air Emissions Models For Waste and Wastewater.
Document Number EPA-453/R-94-080A. November 1994.

Environmental Protection Agency (EPA) Protocol for Equipment Leak Emission Estimates.
Document Number EPA-453/R-95-017. November 1995.

Sonoma Technology, Inc. (STi) Technical Memorandum: Control Strategies for Reducing
Evaporation Pond Emissions (Final Report, EPA AIRNow Operations and AQI Support,
Contract #EP-D-09-097) September 15, 2011.

Utah Department of Air Quality (UDAQ), 2012. Air Quality Emissions Assessment Guideline;
Website: http://www.airquality.utah.gov/Planning/Modeling/NSR_Permit_Modeling
/Modguint.htm. Accessed on December 20, 2014.

Utah Department of Air Quality (UDAQ), 2013. 2014 ACGIH—TLVs and UDAQ—TSLs and
ETVs; Website: http://www.airquality.utah.gov/Planning/Modeling/NSR_Permit
_Modeling/docs/2014/08Aug/2014ACGIH_TLVs.xls Accessed on December 20, 2014.

Appendix A

Appendix B

Appendix C

Appendix D

Appendix E

Appendix F

Appendix G

Appendix H

Appendix I