DAQ-2024-004513

DAQE-AN157310004-24

{{$d1 }}

Edward Higuera
Wolverine Gas and Oil Company of Utah, LLC
One Riverfront Plaza
55 Campau Ave NW, Suite 1
Grand Rapids, MI 49503
[e-mail]

Dear Mr. Higuera:

Re: Approval Order: Modification to Approval Order DAQE-AN157310003-23 to Add a Propane
Storage Tank
Project Number: N157310004

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
September 12, 2023. Wolverine Gas and Oil Company of Utah, LLC must comply with the requirements
of this AO, all applicable state requirements (R307), and Federal Standards.

The project engineer for this action is Mr. Enqiang He, 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:EH:jg

cc: Central Utah 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 18, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN157310004-24
Modification to Approval Order DAQE-AN157310003-23
to Add a Propane Storage Tank

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Wolverine Gas and Oil Company of Utah, LLC - Covenant Field Production
Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality
January 18, 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 ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-AN157310004-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wolverine Gas and Oil Company of Utah, LLC Wolverine Gas and Oil Company of Utah, LLC -
Covenant Field Production Facility

Mailing Address Physical Address
One Riverfront Plaza
55 Campau Ave NW, Suite 1
2080 South State Highway 24
Sigurd, UT 84657
Grand Rapids, MI 49503

Source Contact UTM Coordinates
Name: Edward Higuera 418,226 m Easting
Phone: [phone],296,256 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 1311 (Crude Petroleum & Natural Gas)

SOURCE INFORMATION
General Description
Wolverine Gas and Oil Company of Utah, LLC (Wolverine) operates a crude oil production gathering
facility, named Covenant Field Production Facility (Covenant), located in Sevier County. Multiple wells
bring produced fluids to the site via flowline where they are separated and stored in tanks prior to being
transported off site by trucks. The source also utilizes an evaporation pond for the disposal of produced
water from surrounding operations. The source operates on line power; an emergency generator engine is
on site for use during power disruption. The source processes up to 2,920,000 barrels
(1 barrel = 42 gallons) of crude oil per year.

NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Sevier County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984,
DAQE-AN157310004-24
Page 4

NSPS (Part 60), OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities
for which Construction, Modification or Reconstruction Commenced After September 18,
2015,
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Description
Wolverine has proposed to add a propane storage tank. The tank has a capacity of 30,000 gallons with a
proposed through-put of 46,000 gallons per year. There are also three (3) valves and three (3) flanges
associated with the tank.

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 5307.00
Carbon Monoxide 0 15.48
Nitrogen Oxides 0 3.11
Particulate Matter - PM10 0 0.00
Particulate Matter - PM2.5 0 0.00
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 107.57

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1580
Ethyl Benzene (CAS #100414) 0 180
Generic HAPs (CAS #GHAPS) 0 40
Methanol (CAS #67561) 0 19720
Toluene (CAS #108883) 0 2940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 0 12.32

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]

DAQE-AN157310004-24
Page 5

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

II.A THE APPROVED EQUIPMENT

II.A.1 Covenant Facility

II.A.2 Two (2) Oil Storage Tanks
Capacity: 10,000 barrels (each)
Control: Combustor
NSPS Applicability: Subpart Kb

II.A.3 Two (2) Bad Oil Storage Tanks
Capacity: 400 barrels (each)
Control: Combustor

II.A.4 One (1) Produced Water Storage Tank
Capacity: 2,500 barrels
Control: Combustor

II.A.5 One (1) Propane Storage Tank - new equipment
Pressurized propane storage tank and associated valves and flanges
Capacity: 30,000 gallons

DAQE-AN157310004-24
Page 6

II.A.6 One (1) Combustor
98% destruction efficiency

II.A.7 Truck Loading Operations
Control: Vapor Capture Line

II.A.8 One (1) Emergency Generator
Rating: 264 hp
Fuel: Propane
Manufacture Date: Pre-July 1, 2008
MACT Applicability: Subpart ZZZZ

II.A.9 Evaporation Pond

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 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 Oil Storage Tank (Storage Vessel) Requirements
II.B.2.a The owner/operator shall not receive more than 2,920,000 barrels (1 barrel = 42 gallons) of crude
oil per rolling 12-month period. [R307-401-8]

II.B.2.a.1 The owner/operator shall:

A. Determine crude oil production with process flow meters and/or sales records

B. Record crude oil production on a daily basis

C. Use the monthly production data reported to the Utah Division of Oil, Gas,
and Mining to calculate a new 12-month total by the 20th day of each month
using data from the previous 12 months

D. Keep the production records for all periods the plant is in operation.

[R307-401-8]

II.B.2.b At all times after startup of production, the owner/operator shall route all gases, vapors, and
fumes from the oil storage tanks and produced water storage tanks on site to the operating
combustor. [R307-401-8]

II.B.2.c The owner/operator shall keep the storage tank thief hatches and other tank openings closed and
sealed except during tank unloading or other maintenance activities. [R307-401-8]

II.B.2.d At least once each month, the owner/operator shall inspect each closed vent system (including
tank openings, thief hatches, and bypass devices) for defects that could result in air emissions
according to 40 CFR 60.5416a(c). Records of inspections shall include the date of the inspection
and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart OOOOa]

DAQE-AN157310004-24
Page 7

II.B.3 Truck Loading Requirements
II.B.3.a The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401-8, R307-504-4]

II.B.3.b The owner/operator shall connect a vapor capture line to the operating combustor for use during
on-site truck loading operations. The vapor capture line shall be used at all times during loading
operations. [R307-401-8]

II.B.4 Combustor Requirements
II.B.4.a The owner/operator shall operate the combustor on site with a continuous pilot flame equipped
with an auto-igniter. [R307-503-4]

II.B.4.b The owner/operator shall operate the combustor with no visible emissions. [R307-401-8]

II.B.4.b.1 Visual determination of emissions from each combustor shall be conducted according to 40 CFR
60, Appendix A, Method 22. [R307-401-8]

II.B.5 Produced Water Requirements
II.B.5.a The owner/operator shall not exceed 35.05 tons of combined VOC (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 pond per rolling 12-month period. [R307-401-8]

II.B.5.b The owner/operator shall not exceed 2.43 tons of combined HAP emissions (excluding
methanol) from evaporation pond per rolling 12-month period. [R307-401-8]

II.B.5.c The owner/operator shall not exceed 9.86 tons of methanol emissions from evaporation pond per
rolling 12-month period. [R307-401-8]

II.B.5.d 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 + BTEX) sampled concentrations]

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

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

[R307-401-8]

II.B.5.d.1 The owner/operator shall:

A. Determine water volume received with billable receipts

B. Record water volume received on a daily basis

C. Keep the records of water received for all periods the plant is in operation.

[R307-401-8]

DAQE-AN157310004-24
Page 8

II.B.6 The owner/operator shall collect and analyze samples as follows:
II.B.6.a Unless specified below, the owner/operator shall collect and analyze samples, at a minimum,
once monthly.

If sampled emissions are below the following values for 12 consecutive sampling periods:

GRO + DRO = 0.70 tons/month,

Combined HAPs excluding methanol = 0.05 tons/month, and

Methanol = 0.20 tons/month,
the owner/operator may collect and analyze samples, at a minimum of once every 12 months.
The owner/operator shall use the concentration results of the most recently analyzed samples
when determining compliance with Conditions II.B.5.a, b, and c. [R307-401-8]

II.B.6.b The owner/operator shall collect, handle, and analyzed the samples as follows:

A. The samples shall be collected at the outfall of the treatment process prior to
water being discharged into the evaporation pond

B. The samples shall be no less than eight (8) oz. in volume

C. The sample shall be analyzed within seven (7) days after collection, and shall be
stored at a temperature no less than 32oF and no more than 40oF prior to analysis

D. The samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10),
TPH-DRO (C11 - C28), 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.6.b.1 The owner/operator shall keep records of the results of the analyzed samples. [R307-401-8]

II.B.7 Emergency Generator Requirements
II.B.7.a The owner/operator shall only use propane as a fuel source in the emergency generator.
[R307-401-8]

II.B.7.b The owner/operator shall not allow visible emissions from the emergency generator to exceed
10% opacity at any time. [R307-401-8]

II.B.7.c The owner/operator shall not operate the emergency generator engine for more than 100 hours
per rolling 12-month period for regular maintenance, testing, and other allowed non-emergency
uses listed in 40 CFR 63 Subpart ZZZZ. There is no restriction on use during emergency
situations. [R307-401-8]

II.B.7.c.1 Records documenting generator usage shall be kept in a log with the following information:

A. Date the generator was used

B. Duration in hours of the generator use

C. Reason for generator use.

[R307-401-8]

DAQE-AN157310004-24
Page 9

II.B.7.c.2 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months.
[R307-401-8]

II.B.8 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.8.a The owner/operator shall develop a fugitive emissions monitoring plan. At a minimum, the plan
shall include:

A. Monitoring frequency

B. Monitoring technique and equipment

C. Procedures and timeframes for identifying and repairing leaks

D. Recordkeeping practices

E. Calibration and maintenance procedures.

[R307-401-8]

II.B.8.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

II.B.8.b The owner/operator shall conduct monitoring surveys on site to observe each "fugitive emissions
component" for "fugitive emissions."

A. "Fugitive emissions component" means any component that has the potential to
emit fugitive emissions of VOC, including but not limited to valves, connectors,
pressure relief devices, open-ended lines, flanges, covers and closed vent
systems, thief hatches or other openings, compressors, instruments, and meters

B. "Fugitive emissions" are considered any visible emissions observed using optical
gas imaging or a Method 21 instrument reading of 500 ppm or greater.

[R307-401-8]

II.B.8.b.1 Monitoring surveys shall be conducted according to the following schedule:

A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a

B. Semi-annually after the initial monitoring survey. Consecutive semiannual
monitoring surveys shall be conducted at least four (4) months apart

C. Annually after the initial monitoring survey for "difficult-to-monitor"
components

D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor"
components.

[R307-401-8]

DAQE-AN157310004-24
Page 10

II.B.8.b.2 Monitoring surveys shall be conducted using one or both of the following to detect fugitive
emissions:

A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of
imaging gases in the spectral range for the compound of highest concentration in
the potential fugitive emissions

B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60,
Appendix A.

[R307-401-8]

II.B.8.c If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive
emissions component as soon as possible but no later than 15 calendar days after detection.

If the repair or replacement is technically infeasible, would require a vent blowdown, a well
shutdown or well shut-in, or would be unsafe to repair during operation of the unit, the repair or
replacement must be completed during the next well shutdown, well shut-in, after an
unscheduled, planned or emergency vent blowdown or within 24 months, whichever is earlier.
[R307-401-8]

II.B.8.c.1 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later
than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8]

II.B.8.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring
surveys, repairs, and resurveys. [R307-401-8]

PERMIT HISTORY

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

Supersedes AO DAQE-AN157310003-23 dated June 1, 2023
Incorporates NOI dated September 12, 2023
Incorporates additional information dated October 4, 2023
Incorporates additional information dated November 20, 2023

DAQE-AN157310004-24
Page 11

ACRONYMS

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

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by 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-IN157310004-23

December 11, 2023

Edward Higuera
Wolverine Gas and Oil Company of Utah, LLC
One Riverfront Plaza 55 Campau Avenue NW, Suite 1
Grand Rapids, MI 49503
[e-mail]

Dear Mr. Higuera:

Re: Intent to Approve: Modification to Approval Order DAQE-AN157310003-23 to Add a Propane
Storage Tank
Project Number: N157310004

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, Mr. Enqiang He, as well as the
DAQE number as shown on the upper right-hand corner of this letter. Mr. Enqiang He, can be reached at
[phone] or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:EH:jg

cc: Central Utah 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-IN157310004-23
Modification to Approval Order DAQE-AN157310003-23
to Add a Propane Storage Tank

Prepared By
Mr. Enqiang He, Engineer
[phone]
[e-mail]

Issued to
Wolverine Gas and Oil Company of Utah, LLC - Covenant Field Production
Facility

Issued On
December 11, 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 .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 11
ACRONYMS ............................................................................................................................... 12

DAQE-IN157310004-23
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wolverine Gas and Oil Company of Utah, LLC Wolverine Gas and Oil Company of Utah, LLC -
Covenant Field Production Facility

Mailing Address Physical Address
One Riverfront Plaza 55 Campau Avenue NW,
Suite 1
2080 South State Highway 24
Sigurd, UT 84657
Grand Rapids, MI 49503

Source Contact UTM Coordinates
Name Edward Higuera 418,226 m Easting
Phone [phone],296,256 m Northing
Email [e-mail] Datum NAD83
UTM Zone 12
SIC code 1311 (Crude Petroleum & Natural Gas)

SOURCE INFORMATION
General Description
Wolverine Gas and Oil Company of Utah, LLC (Wolverine) operates a crude oil production gathering
facility, named Covenant Field Production Facility (Covenant), located in Sevier County. Multiple wells
bring produced fluids to the site via flowline where they are separated and stored in tanks prior to being
transported off site by trucks. The source also utilizes an evaporation pond for the disposal of produced
water from surrounding operations. The source operates on line power; an emergency generator engine is
on site for use during power disruption. The source processes up to 2,920,000 barrels (1 barrel = 42
gallons) of crude oil per year.
NSR Classification
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Sevier County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984
NSPS (Part 60), OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities
for which Construction, Modification or Reconstruction Commenced After September 18,
2015
DAQE-IN157310004-23
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
Title V (Part 70) Area Source

Project Description
Wolverine has proposed to add a propane storage tank. The tank has a capacity of 30,000 gallons with a
proposed through-put of 46,000 gallons per year. There are also three (3) valves and three (3) flanges
associated with the tank.

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 5307.00
Carbon Monoxide 0 15.48
Nitrogen Oxides 0 3.11
Particulate Matter - PM10 0 0.00
Particulate Matter - PM2.5 0 0.00
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 107.57

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1580
Ethyl Benzene (CAS #100414) 0 180
Generic HAPs (CAS #GHAPS) 0 40
Methanol (CAS #67561) 0 19720
Toluene (CAS #108883) 0 2940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 0 12.32

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 Sanpete Messenger on December 14, 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-IN157310004-23
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]

DAQE-IN157310004-23
Page 6

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 Covenant Facility

II.A.2 Two (2) Oil Storage Tanks
Capacity: 10,000 barrels (each)
Control: Combustor
NSPS Applicability: Subpart Kb

II.A.3 Two (2) Bad Oil Storage Tanks
Capacity: 400 barrels (each)
Control: Combustor

II.A.4 One (1) Produced Water Storage Tank
Capacity: 2,500 barrels
Control: Combustor

II.A.5 One (1) Propane Storage Tank - new equipment
Pressurized propane storage tank and associated valves and flanges
Capacity: 30,000 gallons

II.A.6 One (1) Combustor
98% destruction efficiency

II.A.7 Truck Loading Operations
Control: Vapor Capture Line

II.A.8 One (1) Emergency Generator
Rating: 264 hp
Fuel: Propane
Manufacture Date: Pre-July 1, 2008
MACT Applicability: Subpart ZZZZ

II.A.9 Evaporation Pond

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]

DAQE-IN157310004-23
Page 7

II.B.1.a.1 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 Oil Storage Tank (Storage Vessel) Requirements
II.B.2.a The owner/operator shall not receive more than 2,920,000 barrels (1 barrel = 42 gallons) of crude
oil per rolling 12-month period. [R307-401-8]

II.B.2.a.1 The owner/operator shall:

A. Determine crude oil production with process flow meters and/or sales records

B. Record crude oil production on a daily basis

C. Use the monthly production data reported to the Utah Division of Oil, Gas,
and Mining to calculate a new 12-month total by the 20th day of each month
using data from the previous 12 months

D. Keep the production records for all periods the plant is in operation.

[R307-401-8]

II.B.2.b At all times after startup of production, the owner/operator shall route all gases, vapors, and
fumes from the oil storage tanks and produced water storage tanks on site to the operating
combustor. [R307-401-8]

II.B.2.c The owner/operator shall keep the storage tank thief hatches and other tank openings closed and
sealed except during tank unloading or other maintenance activities. [R307-401-8]

II.B.2.d At least once each month, the owner/operator shall inspect each closed vent system (including
tank openings, thief hatches, and bypass devices) for defects that could result in air emissions
according to 40 CFR 60.5416a(c). Records of inspections shall include the date of the inspection
and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart OOOOa]

II.B.3 Truck Loading Requirements
II.B.3.a The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401-8, R307-504-4]

II.B.3.b The owner/operator shall connect a vapor capture line to the operating combustor for use during
on-site truck loading operations. The vapor capture line shall be used at all times during loading
operations. [R307-401-8]

II.B.4 Combustor Requirements
II.B.4.a The owner/operator shall operate the combustor on site with a continuous pilot flame equipped
with an auto-igniter. [R307-503-4]

II.B.4.b The owner/operator shall operate the combustor with no visible emissions. [R307-401-8]

II.B.4.b.1 Visual determination of emissions from each combustor shall be conducted according to 40 CFR
60, Appendix A, Method 22. [R307-401-8]

II.B.5 Produced Water Requirements
II.B.5.a The owner/operator shall not exceed 35.05 tons of combined VOC (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 pond per rolling 12-month period. [R307-401-8]

DAQE-IN157310004-23
Page 8

II.B.5.b The owner/operator shall not exceed 2.43 tons of combined HAP emissions (excluding
methanol) from evaporation pond per rolling 12-month period. [R307-401-8]

II.B.5.c The owner/operator shall not exceed 9.86 tons of methanol emissions from evaporation pond per
rolling 12-month period. [R307-401-8]

II.B.5.d 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 + BTEX) sampled concentrations]

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

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

[R307-401-8]

II.B.5.d.1 The owner/operator shall:

A. Determine water volume received with billable receipts

B. Record water volume received on a daily basis

C. Keep the records of water received for all periods the plant is in operation.

[R307-401-8]

II.B.6 The owner/operator shall collect and analyze samples as follows:
II.B.6.a Unless specified below, the owner/operator shall collect and analyze samples, at a minimum,
once monthly.

If sampled emissions are below the following values for 12 consecutive sampling periods:

GRO + DRO = 0.70 tons/month,

Combined HAPs excluding methanol = 0.05 tons/month, and

Methanol = 0.20 tons/month,

the owner/operator may collect and analyze samples, at a minimum of once every 12 months.
The owner/operator shall use the concentration results of the most recently analyzed samples
when determining compliance with Conditions II.B.5.a, b, and c. [R307-401-8]

DAQE-IN157310004-23
Page 9

II.B.6.b The owner/operator shall collect, handle, and analyzed the samples as follows:

A. The samples shall be collected at the outfall of the treatment process prior to
water being discharged into the evaporation pond

B. The samples shall be no less than eight (8) oz. in volume

C. The sample shall be analyzed within seven (7) days after collection, and shall be
stored at a temperature no less than 32oF and no more than 40oF prior to analysis

D. The samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10),
TPH-DRO (C11 - C28), 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.6.b.1 The owner/operator shall keep records of the results of the analyzed samples. [R307-401-8]

II.B.7 Emergency Generator Requirements
II.B.7.a The owner/operator shall only use propane as a fuel source in the emergency generator.
[R307-401-8]

II.B.7.b The owner/operator shall not allow visible emissions from the emergency generator to exceed
10% opacity at any time. [R307-401-8]

II.B.7.c The owner/operator shall not operate the emergency generator engine for more than 100 hours
per rolling 12-month period for regular maintenance, testing, and other allowed non-emergency
uses listed in 40 CFR 63 Subpart ZZZZ. There is no restriction on use during emergency
situations. [R307-401-8]

II.B.7.c.1 Records documenting generator usage shall be kept in a log with the following information:

A. Date the generator was used

B. Duration in hours of the generator use

C. Reason for generator use.

[R307-401-8]

II.B.7.c.2 To determine compliance with a rolling 12-month total the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months.
[R307-401-8]

DAQE-IN157310004-23
Page 10

II.B.8 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.8.a The owner/operator shall develop a fugitive emissions monitoring plan. At a minimum, the plan
shall include:

A. Monitoring frequency

B. Monitoring technique and equipment

C. Procedures and timeframes for identifying and repairing leaks

D. Recordkeeping practices

E. Calibration and maintenance procedures.

[R307-401-8]

II.B.8.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

II.B.8.b The owner/operator shall conduct monitoring surveys on site to observe each "fugitive emissions
component" for "fugitive emissions."

A. "Fugitive emissions component" means any component that has the potential to
emit fugitive emissions of VOC, including but not limited to valves, connectors,
pressure relief devices, open-ended lines, flanges, covers and closed vent
systems, thief hatches or other openings, compressors, instruments, and meters

B. "Fugitive emissions" are considered any visible emissions observed using optical
gas imaging or a Method 21 instrument reading of 500 ppm or greater.

[R307-401-8]

II.B.8.b.1 Monitoring surveys shall be conducted according to the following schedule:

A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a

B. Semi-annually after the initial monitoring survey. Consecutive semiannual
monitoring surveys shall be conducted at least 4 months apart

C. Annually after the initial monitoring survey for "difficult-to-monitor"
components

D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor"
components.

[R307-401-8]

DAQE-IN157310004-23
Page 11

II.B.8.b.2 Monitoring surveys shall be conducted using one or both of the following to detect fugitive
emissions:

A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of
imaging gases in the spectral range for the compound of highest concentration in
the potential fugitive emissions.

B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60,
Appendix A.

[R307-401-8]

II.B.8.c If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive
emissions component as soon as possible but no later than 15 calendar days after detection.

If the repair or replacement is technically infeasible, would require a vent blowdown, a well
shutdown or well shut-in, or would be unsafe to repair during operation of the unit, the repair or
replacement must be completed during the next well shutdown, well shut-in, after an
unscheduled, planned or emergency vent blowdown or within 24 months, whichever is earlier.

[R307-401-8]

II.B.8.c.1 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no later
than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8]

II.B.8.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring
surveys, repairs, and resurveys. [R307-401-8]

PERMIT HISTORY

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

Supersedes AO DAQE-AN157310003-23 dated June 1, 2023
Incorporates NOI dated September 12, 2023
Incorporates additional information dated October 4, 2023
Incorporates additional information dated November 20, 2023

DAQE-IN157310004-23
Page 12

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

12/11/23, 2:44 PM State of Utah Mail - Legal Notice to be published December 14, 2023
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permthid=thread-a:r6056556988720951861&simpl=msg-a:r350057068926330…1/1
Jeree Greenwood <[e-mail]>
Legal Notice to be published December 14, 2023
2 messages
Jeree Greenwood <[e-mail]>Mon, Dec 11, 2023 at 9:42 AM
To: Sanpete Messenger loyd <[e-mail]>
Please publish the following notice on December 14, 2023. Also, submit to Utahlegals.com.
If you can, please reply to this email for my confirmation records.
Jeree
--
Jeree Greenwood
Office Technician II | Minor NSR Section
M: [phone]
airquality.utah.gov
DAQE-NN157310004-23.pdf
332K
Ad Manager <[e-mail]>Mon, Dec 11, 2023 at 2:34 PM
To: Jeree Greenwood <[e-mail]>
Hi Jeree: 
The notice has been received, thank you. It will be published in the Dec. 14 edition of the Sanpete Messenger and on
the Utah Legals website as well. 
Best regards,
Jackson Lambie, Ad Manager
[phone]
[Quoted text hidden]

DAQE-NN157310004-23

December 11, 2023

Sanpete Messenger
Legal Advertising Department
35 South Main Street
Manti, UT 84646

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Sanpete Messenger on
December 14, 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: Sevier County
cc: Six County 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-NN157310004-23
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: Wolverine Gas and Oil Company of Utah, LLC
Location: Wolverine Gas and Oil Company of Utah, LLC - Covenant Field Production
Facility – 2080 South State Highway 24, Sigurd, UT
Project Description: Wolverine Gas and Oil Company of Utah, LLC (Wolverine) operates a crude oil
production gathering facility, named Covenant Field Production Facility
(Covenant), located in Sevier County. Wolverine has requested a modification to
add a propane storage tank with associated valves and flanges. Wolverine has not
proposed any other changes to the facility. Production limit will remain
unchanged at 2,920,000 barrels (1 barrel = 42 gallons) of crude oil per year.

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 January 13, 2024 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: December 14, 2023

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

DAQE-

RN157310004
November 20, 2023

Edward Higuera
Wolverine Gas and Oil Company of Utah, LLC
One Riverfront Plaza 55 Campau Ave NW, Suite 1
Grand Rapids, MI 49503
[e-mail]

Dear Edward Higuera,

Re: Engineer Review:
Modification to AO DAQE-AN157310003-23 to Add a Propane Storage Tank
Project Number: N157310004

The DAQ requests a company representative review and sign the attached Engineer Review (ER). This
ER identifies all applicable elements of the New Source Review permitting program. Wolverine Gas and
Oil Company of Utah, LLC should complete this review within 10 business days of receipt.

Wolverine Gas and Oil Company of Utah, LLC should contact Mr. Enqiang He at [phone] if
there are questions or concerns with the review of the draft permit conditions. Upon resolution of your
concerns, please email Mr. Enqiang He at [e-mail] the signed cover letter. Upon receipt of the
signed cover letter, the DAQ will prepare an ITA for a 30-day public comment period. At the completion
of the comment period, the DAQ will address any comments and will prepare an Approval Order (AO)
for signature by the DAQ Director.

If Wolverine Gas and Oil Company of Utah, LLC does not respond to this letter within 10 business days,
the project will move forward without source concurrence. If Wolverine Gas and Oil Company of Utah,
LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

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

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N157310004
Owner Name Wolverine Gas and Oil Company of Utah, LLC
Mailing Address One Riverfront Plaza 55 Campau Ave NW, Suite 1
Grand Rapids, MI 49503

Source Name Wolverine Gas and Oil Company of Utah, LLC - Covenant Field
Production Facility
Source Location 2080 South State Highway 24
Sigurd, UT 84657

UTM Projection 418,226 m Easting, 4,296,256 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 1311 (Crude Petroleum & Natural Gas)

Source Contact Edward Higuera
Phone Number [phone]
Email [e-mail]

Billing Contact Edward Higuera
Phone Number [phone]
Email [e-mail]

Project Engineer Mr. Enqiang He, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted September 12, 2023
Date of Accepted Application November 20, 2023

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 2
SOURCE DESCRIPTION

General Description
Wolverine Gas and Oil Company of Utah, LLC (Wolverine) operates a crude oil production
gathering facility, named Covenant Field Production Facility (Covenant), located in Sevier
County. Multiple wells bring produced fluids to the site via flowline where they are separated and
stored in tanks prior to being transported off site by trucks. The source also utilizes an
evaporation pond for the disposal of produced water from surrounding operations. The source
operates on line power; an emergency generator engine is on site for use during power disruption.
The source will process up to 2,920,000 barrels (1 barrel = 42 gallons) of crude oil per year.

NSR Classification:
Minor Modification at Minor Source

Source Classification
Located in Attainment Area
Sevier County
Airs Source Size: SM

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels
(Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or
Modification Commenced After July 23, 1984
NSPS (Part 60), OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities
for which Construction, Modification or Reconstruction Commenced After September 18,
2015
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Area Source

Project Proposal
Modification to AO DAQE-AN157310003-23 to Add a Propane Storage Tank

Project Description
Wolverine has proposed to add a propane storage tank. The tank has a capacity of 30,000 gallons
with proposed through-put of 46,000 gallons per year. There are also three (3) valves and three
(3) flanges associated with the tank.

EMISSION IMPACT ANALYSIS
The VOC emission increases from this modification are less than 0.01 tpy. There are no emission increases for
all other pollutants. Therefore, modeling is not required at this time. [Last updated November 8, 2023]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 3
SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 5307.00
Carbon Monoxide 0 15.48
Nitrogen Oxides 0 3.11
Particulate Matter - PM10 0 0.00
Particulate Matter - PM2.5 0 0.00
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 0 107.57

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1580
Ethyl Benzene (CAS #100414) 0 180
Generic HAPs (CAS #GHAPS) 0 40
Methanol (CAS #67561) 0 19720
Toluene (CAS #108883) 0 2940
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 0 12.32

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

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding addition of a propane storage tank
The source has proposed a modification to add a pressurized propane storage tank. There are no
emissions from the tank. Fugitive VOC emissions from the valves and flanges are less than 0.01
tpy. Therefore, it is economically infeasible to install and operate any control technology to
control such small amount of VOC emissions. The source shall follow the manufacturer's
recommendations for maintenance of the tank, and shall conduct the monitoring program including
leak detection and repair for the valves and flanges. The Minor NSR Section considers the good
maintenance practices and monitoring program as BACT for the propane tank and the associated
components. [Last updated November 20, 2023]

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

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

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

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 5
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. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Covenant Facility

II.A.2 Two (2) Oil Storage Tanks
Capacity: 10,000 barrels (each)
Control: Combustor
NSPS Applicability: Subpart Kb

II.A.3 Two (2) Bad Oil Storage Tanks
Capacity: 400 barrels (each)
Control: Combustor

II.A.4 One (1) Produced Water Storage Tank
Capacity: 2,500 barrels
Control: Combustor

II.A.5
NEW
One (1) Propane Storage Tank - new equipment
Pressurized propane storage tank and associated valves and flanges
Capacity: 30,000 gallons

II.A.6 One (1) Combustor
98% destruction efficiency

II.A.7 Truck Loading Operations
Control: Vapor Capture Line

II.A.8 One (1) Emergency Generator
Rating: 264 hp
Fuel: Propane
Manufacture Date: Pre-July 1, 2008
MACT Applicability: Subpart ZZZZ

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 6
II.A.9 Evaporation Pond

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 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 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 Oil Storage Tank (Storage Vessel) Requirements
II.B.2.a The owner/operator shall not receive more than 2,920,000 barrels (1 barrel = 42 gallons) of
crude oil per rolling 12-month period. [R307-401-8]

II.B.2.a.1 The owner/operator shall:

A. Determine crude oil production with process flow meters and/or sales records.

B. Record crude oil production on a daily basis.

C. Use the monthly production data reported to the Utah Division of Oil, Gas,
and Mining to calculate a new 12-month total by the 20th day of each month
using data from the previous 12 months.

D. Keep the production records for all periods the plant is in operation

[R307-401-8]

II.B.2.b At all times after startup of production, the owner/operator shall route all gases, vapors, and
fumes from the oil storage tanks and produced water storage tanks on site to the operating
combustor. [R307-401-8]

II.B.2.c The owner/operator shall keep the storage tank thief hatches and other tank openings closed
and sealed except during tank unloading or other maintenance activities. [R307-401-8]

II.B.2.d At least once each month, the owner/operator shall inspect each closed vent system (including
tank openings, thief hatches, and bypass devices) for defects that could result in air emissions
according to 40 CFR 60.5416a(c). Records of inspections shall include the date of the
inspection and the results of the inspection. [R307-401-8, 40 CFR 60 Subpart OOOOa]

II.B.3 Truck Loading Requirements

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 7
II.B.3.a The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401-8, R307-504-4]

II.B.3.b The owner/operator shall connect a vapor capture line to the operating combustor for use
during on-site truck loading operations. The vapor capture line shall be used at all times
during loading operations. [R307-401-8]

II.B.4 Combustor Requirements
II.B.4.a
NEW
The owner/operator shall operate the combustor on site with a continuous pilot flame
equipped with an auto-igniter. [R307-503-4]

II.B.4.b
NEW
The owner/operator shall operate the combustor with no visible emissions. [R307-401-8]

II.B.4.b.1 Visual determination of emissions from each combustor shall be conducted according to 40
CFR 60, Appendix A, Method 22. [R307-401-8]

II.B.5 Produced Water Requirements
II.B.5.a The owner/operator shall not exceed 35.05 tons of combined VOC (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 pond per rolling 12-month period. [R307-401-8]

II.B.5.b The owner/operator shall not exceed 2.43 tons of combined HAP emissions (excluding
methanol) from evaporation pond per rolling 12-month period. [R307-401-8]

II.B.5.c The owner/operator shall not exceed 9.86 tons of methanol emissions from evaporation pond
per rolling 12-month period. [R307-401-8]

II.B.5.d 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 + BTEX) sampled concentrations]

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

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

[R307-401-8]

II.B.5.d.1 The owner/operator shall:

A. Determine water volume received with billable receipts

B. Record water volume received on a daily basis

C. Keep the records of water received for all periods the plant is in operation

[R307-401-8]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 8
II.B.6 The owner/operator shall collect and analyze samples as follows:
II.B.6.a Unless specified below, the owner/operator shall collect and analyze samples, at a minimum,
once monthly.

If sampled emissions are below the following values for 12 consecutive sampling periods:

GRO + DRO = 0.70 tons/month,

Combined HAPs excluding methanol = 0.05 tons/month, and

Methanol = 0.20 tons/month,

the owner/operator may collect and analyze samples, at a minimum of once every 12 months.
The owner/operator shall use the concentration results of the most recently analyzed samples
when determining compliance with Conditions II.B.5.a, b, and c. [R307-401-8]

II.B.6.b The owner/operator shall collect, handle, and analyzed the samples as follows:

A. The samples shall be collected at the outfall of the treatment process prior to water
being discharged into the evaporation pond

B. The samples shall be no less than eight (8) oz. in volume

C. The sample shall be analyzed within seven (7) days after collection, and shall be
stored at a temperature no less than 32oF and no more than 40oF prior to analysis
D. The samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10), TPH-
DRO (C11 - C28), 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.6.b.1 The owner/operator shall keep records of the results of the analyzed samples. [R307-401-8]

II.B.7 Emergency Generator Requirements
II.B.7.a The owner/operator shall only use propane as a fuel source in the emergency generator.
[R307-401-8]

II.B.7.b
NEW
The owner/operator shall not allow visible emissions from the emergency generator to exceed
10% opacity at any time. [R307-401-8]

II.B.7.c
NEW
The owner/operator shall not operate the emergency generator engine for more than 100 hours
per rolling 12-month period for regular maintenance, testing, and other allowed non-
emergency uses listed in 40 CFR 63 Subpart ZZZZ. There is no restriction on use during
emergency situations. [R307-401-8]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 9
II.B.7.c.1 Records documenting generator usage shall be kept in a log with the following information:

A. Date the generator was used

B. Duration in hours of the generator use

C. Reason for generator use

[R307-401-8]

II.B.7.c.2 To determine compliance with a rolling 12-month total the owner/operator shall calculate a
new 12-month total by the 20th day of each month using data from the previous 12 months.
[R307-401-8]

II.B.8 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.8.a The owner/operator shall develop a fugitive emissions monitoring plan. At a minimum, the
plan shall include:

A. Monitoring frequency

B. Monitoring technique and equipment

C. Procedures and timeframes for identifying and repairing leaks

D. Recordkeeping practices

E. Calibration and maintenance procedures

[R307-401-8]

II.B.8.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

II.B.8.b The owner/operator shall conduct monitoring surveys on site to observe each "fugitive
emissions component" for "fugitive emissions."

A. "Fugitive emissions component" means any component that has the potential to emit
fugitive emissions of VOC, including but not limited to valves, connectors, pressure
relief devices, open-ended lines, flanges, covers and closed vent systems, thief
hatches or other openings, compressors, instruments, and meters.

B. "Fugitive emissions" are considered any visible emissions observed using optical gas
imaging or a Method 21 instrument reading of 500 ppm or greater.

[R307-401-8]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 10
II.B.8.b.1 Monitoring surveys shall be conducted according to the following schedule:

A. No later than 60 days after startup of production, as defined in 40 CFR 60.5430a

B. Semi-annually after the initial monitoring survey. Consecutive semiannual monitoring
surveys shall be conducted at least 4 months apart

C. Annually after the initial monitoring survey for "difficult-to-monitor" components

D. As required by the owner/operator's monitoring plan for "unsafe-to-monitor"
components

[R307-401-8]

II.B.8.b.2 Monitoring surveys shall be conducted using one or both of the following to detect fugitive
emissions:

A. Optical gas imaging (OGI) equipment. OGI equipment shall be capable of imaging
gases in the spectral range for the compound of highest concentration in the potential
fugitive emissions.

B. Monitoring equipment that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A.

[R307-401-8]

II.B.8.c If fugitive emissions are detected at any time, the owner/operator shall repair the fugitive
emissions component as soon as possible but no later than 15 calendar days after detection.

If the repair or replacement is technically infeasible, would require a vent blowdown, a well
shutdown or well shut-in, or would be unsafe to repair during operation of the unit, the repair
or replacement must be completed during the next well shutdown, well shut-in, after an
unscheduled, planned or emergency vent blowdown or within 24 months, whichever is earlier.

[R307-401-8]

II.B.8.c.1 The owner/operator shall resurvey the repaired or replaced fugitive emissions component no
later than 30 calendar days after the fugitive emissions component was repaired. [R307-401-8]

II.B.8.d The owner/operator shall maintain records of the fugitive emissions monitoring plan,
monitoring surveys, repairs, and resurveys. [R307-401-8]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 11
PERMIT HISTORY

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

Supersedes DAQE-AN157310003-23 dated June 1, 2023
Incorporates NOI dated September 12, 2023
Incorporates additional information dated October 4, 2023
Incorporates additional information dated November 20, 2023

REVIEWER COMMENTS

1. Comment regarding emission estimates:
Because the propane storage tank is pressurized, it is not expected to emit any VOCs from the tank.
Emissions from the valves and flanges are calculated based on the emission factors in "1995 EPA
Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017, November 1995)". [Last
updated November 8, 2023]

2. Comment regarding Oil and Gas NSPS & MACT Applicability:
40 CFR 60 NSPS Subpart Kb applies to each storage vessel with a capacity greater than or equal to
75 cubic meters (19,813 gallons) that is used to store volatile organic liquids. Storage tanks on site
will have a capacity of more than 75 cubic meters, and store volatile organic liquids; therefore,
NSPS Subpart Kb will apply to this facility.

40 CFR 60 NSPS Subpart KKK applies to onshore natural gas processing plants that commence
construction, reconstruction, or modification after January 20, 1984, and on or before August 23,
2011. This facility will not extract natural gas liquids from field gas and will commence
construction after August 23, 2011; therefore, NSPS Subpart KKK will not apply to this facility.

40 CFR 60 NSPS Subpart LLL applies to sweetening units and sweetening units followed by sulfur
recovery units that process natural gas and commenced construction or modification after January
20, 1984, and on or before August 23, 2011. This facility will not have a sweetening unit and will
commence construction after August 23, 2011; therefore, NSPS Subpart LLL will not apply to this
facility.

40 CFR 60 NSPS Subpart OOOO applies to the following onshore affected facilities that commence
construction, modification, or reconstruction after August 23, 2011, and on or before September 18,
2015: gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage
vessels, sweetening units, and hydraulically refractured wells. This source will commence
construction after September 18, 2015; therefore, NSPS Subpart OOOO will not apply to this
facility.

40 CFR 60 NSPS Subpart OOOOa applies to the following onshore affected facilities that
commence construction, modification, or reconstruction after September 18, 2015: wells, centrifugal
compressors, reciprocating compressors, pneumatic controllers, storage vessels, sweetening units,
pneumatic pumps, and collections of fugitive emissions components at a well site or compressor
station. This source will have a well and collections of fugitive emissions components at a well site,
and will be constructed after September 18, 2015; therefore, NSPS Subpart OOOOa will apply to
this facility.
[Last updated November 8, 2023]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 12

3. Comment regarding Engine NSPS & MACT Applicability:
40 CFR 60 NSPS Subpart JJJJ applies to owners and operators of stationary SI ICE that commence
construction after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1,
2008, for engines with a maximum engine power less than 500 hp. Because engines at this facility
are manufactured before July 1, 2008, NSPS Subpart JJJJ will not apply to this facility.

40 CFR 63 MACT Subpart ZZZZ applies to owners and operators of stationary RICE at a major or
area source of HAP emissions. Because this source will have stationary RICE at an area source of
HAP emissions, MACT Subpart ZZZZ will apply to this facility.

[Last updated November 8, 2023]

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

1. Any major source;

2. Any source subject to a standard, limitation, or other requirement under Section 111 of the
Act, Standards of Performance for New Stationary Sources;

3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants; or

4. Any Title IV affected source.

This facility is not a major source and is not a Title IV source. The facility is subject to 40 CFR 60
NSPS Subparts A, Kb, and OOOOa, and 40 CFR 63 MACT Subparts A and ZZZZ regulations.
NSPS Subparts OOOOa and MACT Subpart ZZZZ exempt sources from the obligation to obtain a
permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain
a permit. The source is subject to NSPS Subpart Kb; therefore, Title V applies to this facility as an
area source.

[Last updated September 18, 2023]

Engineer Review N157310004: Wolverine Gas and Oil Company of Utah, LLC- Covenant Field Production Facility
November 20, 2023
Page 13
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

11/20/23, 4:41 PM State of Utah Mail - New Permit Modification N157310004
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1783115307127167673&simpl=msg-f:1783115307127167673 1/4
Enqiang He <[e-mail]>
New Permit Modification N157310004
Tony Cook <[e-mail]>Mon, Nov 20, 2023 at 1:14 PM
To: Enqiang He <[e-mail]>
See my comments in blue below.

Tony E. Cook

From: Enqiang He <[e-mail]>
Sent: Monday, November 20, 2023 1:03 PM
To: Tony Cook <[e-mail]>
Subject: Re: New Permit Modification N157310004

CAUTION: This email DID NOT come from a Wolverine employee or department. Do not respond, click links or open
attachments unless you recognize the sender and know the content is safe.

Hello Tony,

I have finished my technical review on the project. The next step
will be a peer review. Before I can move it forward, I'd like to
have your confirmation regarding the following questions:

1. Conditions in II.B.4 sound like there are more than 1
combustors operating on site. But according to the equipment
list, it seems there is only one combustor operating on site.
Please confirm there is only one combustor on site. There is only
one combustor.

11/20/23, 4:41 PM State of Utah Mail - New Permit Modification N157310004
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1783115307127167673&simpl=msg-f:1783115307127167673 2/4
2. As part of the BACT analysis, the valves and flanges
associated with the new propane tank would be subject to the
same monitoring requirements in II.B.8. Please confirm this. Yes,
I can put together a monitoring plan for the propane tank.

Let me know if you have any questions. Please reply ASAP.
Thanks,

EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]

On Thu, Sep 28, 2023 at 10:16 AM Tony Cook <[e-mail]> wrote:
Good morning,

We use Stantec for our air emissions consulng services. I just received these documents back from them this morning.

This email with (3) aachments is to address your request below. Please let me know if you have anything else that you need.

Thank you,

Tony E. Cook

11/20/23, 4:41 PM State of Utah Mail - New Permit Modification N157310004
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1783115307127167673&simpl=msg-f:1783115307127167673 3/4
From: Enqiang He <[e-mail]>
Sent: Monday, September 18, 2023 11:02 AM
To: Tony Cook <[e-mail]>
Subject: New Permit Modification N157310004

CAUTION: This email DID NOT come from a Wolverine employee or department. Do not respond, click links or
open attachments unless you recognize the sender and know the content is safe.

Hello Tony,

The Division of Air Quality has received your NOI to add a
propane tank. I have been assigned to review this project. After
initial review, I found the following information was missing:

1. The emission calculations for the new propane tank, and
2. BACT analysis. Wolverine needs to go through the BACT to
determine the BACT to control emissions from the tank.

Let me know if you have any questions. Please provide the
above information ASAP, preferably within 2 weeks from today.
Thank you!

EQ He, CPM
Permitting Engineer, Minor NSR Section, Permitting Branch |
Division of Air Quality
1950 West 195 North, Salt Lake City, UT 84116
Phone: [phone]
[e-mail]
11/20/23, 4:41 PM State of Utah Mail - New Permit Modification N157310004
https://mail.google.com/mail/u/0/?ik=20ff41d2e4&view=pt&search=all&permmsgid=msg-f:1783115307127167673&simpl=msg-f:1783115307127167673 4/4

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
Wolverine Covenant Facility Propane
Tank BACT Analysis

Best Available Control Technology Analysis for Wolverine Gas
and Oil Company of Utah, LLC - Covenant Facility
30,000 Gallon Propane Tank

Introduction

As stated in UACR R307-401-2, “Best available control technology (BACT)” means an emissions
limitation based on the maximum degree of reduction for each air contaminant which would be
emitted from any proposed stationary source or modification which the executive secretary, on a case-
by-case basis, determines is achievable for such source or modification. Wolverine Gas and Oil
Company of Utah, LLC (Wolverine) is required to perform a Best Available Control Technology
(BACT) analysis for control of emissions from its existing propane tank to be installed at Wolverine’s
Covenant Facility located near Sigurd, Utah.

This BACT analysis is being performed for criteria pollutant emissions and will follow EPA’s Top-
Down approach and Utah Division of Air Quality BACT analysis guidelines. This will consist of the
following steps:

• Step 1 – Identify Control Technologies
• Step 2 – Eliminate Technically Infeasible Options
• Step 3 – Rank Remaining Control Technologies by Control Effectiveness
• Step 4 – Evaluate Most Effective Controls
• Step 5 – Select BACT.

Several sources of information were examined for this BACT analysis, including the Environmental
Protection Agency’s (EPA) RACT/BACT/LAER Clearinghouse (RBLC), state agency databases, and
published literature. The EPA RBLC clearinghouse database was queried for process code 42.009 and
volatile organic compounds (VOC). Numerous results were found for various types of storage tanks.
Control Technology

• Vapor Recovery
• Submerged Fill Systems
• General Maintenance and management
Infeasible Options

The vapor recovery is infeasible for the single tank. A search of the RBLC failed to find BACT limits for
propane tanks. Additionally, the vast majority of tanks provided a value of zero for VOC. Stantec also
reviewed the California Air Resources Board (CARB) AB 617 Technology Clearinghouse BACT
Determinations. One determination from the South Coast Air Quality Management District identifies a
thermal oxidizer to limit VOC emissions by 95%.

The CARB example is not representative of Wolverine’s propane tank. The determination is based on 18
3,000 gallon tanks or a total of 54,000 gallon capacity all tied to a regenerative thermal oxidizer.
Additionally, the annual usage is expected to be 6.3 million gallons while the Covenant site will not
exceed 46,000 gallons. Also, the CARB tanks contained styrene and mineral spirits. All other BACT
determinations reviewed were specific to gasoline and diesel tanks.

Wolverine Covenant Facility Propane
Tank BACT Analysis

Submerged fill systems are used at the Covenant site for tanker truck loading. However, it is not feasible
to install on the propane tank. It is a pressurized tank used to operate other process equipment. This is
unlike the other production tanks that are not pressurized and routed to the flare control system.
Remaining Control Options

Proper management and maintenance practices is the only remaining control that is feasible. Good
management and maintenance practices that include monitoring leaks through vapor flanges/valves,
regular maintenance schedules, proper signage, fire prevention practices etc. are performed by
Wolverine. The tank is maintained by complying to vendor recommended procedures. Maintenance
records comply with National Fire Protection Association Code 58, which includes storage records and
accessibility. All maintenance personnel are provided appropriate training. All signage includes
appropriate warnings and pertinent information.
Most Effective Control

For the propane tank, proper maintenance is the best option. The expected VOC emissions from the
propane tank are essentially negligible as there are only three valves and three flanges associated with the
process. Consistent with past NOI emission calculations for this facility, potential fugitive VOC
emissions from the propane tank were estimated using the CAPCOA Oil and Gas Production screening
emission factors 1. The tank system contains piping that is mostly welded together to avoid potential
leaks. The remaining possible leak locations are the six locations referenced above. The CAPCOA
factors are pounds per hour per number of source (lb/hr-source). Table 1 below provides the total
expected tank emissions. Additionally, these emissions will be minimized where practicable through
monitoring, maintenance, and recordkeeping.

Table 1 – Propane Tank Leak Emissions

Component
Component
Count
Emission
Factor
(lbs/hr-
SRC) VOC %
VOC
Emissions
(lb/hr)
VOC
Emissions
(tpy)
Valves 3 0.000077 100.00% 2.31E-04 1.01E-03
Flanges 3 0.000062 100.00% 1.86E-04 8.15E-04
Connections 0 0.000026 100.00% 0.00E+00 0.00E+00
Open-ended lines 0 0.000053 100.00% 0.00E+00 0.00E+00
Pump Seals 0 0.002200 100.00% 0.00E+00 0.00E+00
Other 0 0.000320 100.00% 0.00E+00 0.00E+00
Totals 4.17E-04 1.83E-03

1 Table IV-2c of the South Coast Air Quality Management District Guidelines for Fugitive Emissions Calculations
June 2003. http://www.aqmd.gov/docs/default-source/planning/annual-emission-reporting/guidelines-for-
fugitive-emissions-calculations.pdf
Wolverine Covenant Facility Propane
Tank BACT Analysis

Selection of BACT

Based on a review of the available control technologies, it has been determined that BACT is use of good
maintenance practices in accordance with the most recent manufacturer’s specifications for the propane
storage tank. This will limit tank leakage and excessive VOC emissions. Wolverine will maintain records
of the tank identification, volume, and fuel type stored. The tank is also only filled to a maximum of 80%
of capacity to ensure expansion under higher temperatures.

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.
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:
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.

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
Docuinonl Ddlo: 02/28/2018
DAQ-2018-00226 ~7\