DAQ-2024-008273

DAQE-AN161620001-24

{{$d1 }}

Tom Kirkwood
Wesco Operating, Incorporated
120 South Durbin Street
PO Box 1650
Casper, WY 82602
[e-mail]

Dear Mr. Kirkwood:

Re: Approval Order: New Helium Recovery Plant
Project Number: N161620001

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on July 12,
2023. Wesco Operating, Incorporated must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

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

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:CB:jg

cc: Southeastern Utah District Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

June 4, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

{{#s=Sig_es_:signer1:signature}}
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APPROVAL ORDER
DAQE-AN161620001-24
New Helium Recovery Plant

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

Issued to
Wesco Operating, Incorporated - Long Canyon Helium Recovery Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

June 4, 2024
TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 10

DAQE-AN161620001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wesco Operating, Incorporated Wesco Operating, Incorporated - Long Canyon
Helium Recovery Plant

Mailing Address Physical Address
120 South Durbin Street
PO Box 1650
Remote Approximately 10 Miles East of Moab
Grand County, UT
Casper, WY 82602

Source Contact UTM Coordinates
Name: Tom Kirkwood 609,001 m Easting
Phone: [phone],268,772 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2813 (Industrial Gases)

SOURCE INFORMATION
General Description
Wesco Operating, Incorporated (Wesco) has requested to operate the Long Canyon Helium Recovery
Plant in Grand County. The facility will process helium-rich gas from the Long Canyon #1 well, located
approximately three (3) miles to the east. Natural gas will be sent via a flowline to the facility and first
sent through an amine contactor. The gas will then be processed by a glycol dehydrator and a helium
recovery unit (HRU). The extracted helium will be compressed and held in a trailer-based tank to be
hauled off-site by trucks for sale. Waste streams will be controlled through the use of a thermal oxidizer
(TO). The facility will not process more than 4.83 million standard cubic feet per day (MMscf/day) of
waste gas.

NSR Classification
New Minor Source

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

DAQE-AN161620001-24
Page 4

Applicable Federal Standards
None
Project Description
Wesco has requested a new minor source to produce helium through the processing of natural gas.

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 26390.00
Carbon Monoxide 9.46
Nitrogen Oxides 15.55
Particulate Matter - PM10 1.68
Particulate Matter - PM2.5 1.68
Sulfur Dioxide 94.90
Volatile Organic Compounds 17.90

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hexane (CAS #110543) 7640
Change (TPY) Total (TPY)
Total HAPs 3.82

SECTION I: GENERAL PROVISIONS

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

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

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

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]

DAQE-AN161620001-24
Page 5

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 Long Canyon Recovery Helium Plant

II.A.2 One (1) HRU
Control: TO and Iron Sponge Media

II.A.3 One (1) Glycol Dehydrator
Control: TO and Iron Sponge Media

II.A.4 One (1) Amine Membrane Skid
Control: TO and Iron Sponge Media

II.A.5 One (1) TO
Burner Rating: 4.0 MMBtu/hr
Maximum Inlet Heat Rating: 47.44 MMBtu/hr
Burner Fuel: Natural Gas
Minimum VOC Destruction Efficiency: 99%

II.A.6 Single-Vessel Iron Sponge Media
Minimum H2S Control Efficiency: 99%

DAQE-AN161620001-24
Page 6

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Site-Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 10% opacity. [R307-401-8]

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

II.B.1.b The owner/operator shall not produce more than 1,763 million standard cubic feet (MMscf) of
waste gas per rolling 12-month period. [R307-401-8]

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

A. Determine the production with flow meters.

B. Record production on a daily basis.

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

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

[R307-401-8]

II.B.2 TO Requirements
II.B.2.a The owner/operator shall route all emissions from the glycol dehydrator, membrane skid, and
HRU through the TO before being vented to the atmosphere. [R307-401-8]

II.B.2.b The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no less
than 99%. [R307-401-8]

II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed TO. [R307-401-8]

II.B.2.c The owner/operator shall operate the TO according to the manufacturer's recommendations.
[R307-401-8]

II.B.2.d At all times while operating the TO, the owner/operator shall maintain a temperature at or above
1,400oF in the TO. [R307-401-8]

II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TO each operating
day while the TO is operating. [R307-401-8]

II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an
inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.d.3 The owner/operator shall calibrate all temperature monitoring equipment according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.2.e The owner/operator shall install a low-NOx burner on the TO that is certified to meet an emission
concentration of no more than 30 ppm of NOx and 30 ppm of CO. [R307-401-8]

DAQE-AN161620001-24
Page 7

II.B.2.e.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed low-NOx burner on the TO.
[R307-401-8]

II.B.2.f The owner/operator shall not exceed an H2S concentration of 1,850 ppmv at the inlet of the TO at
all times. [R307-401-8]

II.B.2.f.1 The owner/operator shall monitor and record the waste gas H2S concentration once a week while
the TO is operating. [R307-401-8]

II.B.2.f.2 The owner/operator shall monitor the H2S concentration at the inlet of the TO with equipment
located such that an inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.f.3 The owner/operator shall calibrate all H2S-monitoring instruments according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.3 Iron Sponge Requirements
II.B.3.a The owner/operator shall route all acid gas streams from the amine membrane skid through an
iron sponge prior to entering the TO. [R307-401-8]

II.B.3.b The owner/operator shall install an iron sponge that is certified to meet a hydrogen sulfide (H2S)
control efficiency of no less than 99% and a H2S capture efficiency of no less than 61%. [R307-
401-8]

II.B.3.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed iron sponge. [R307-401-8]

II.B.4 Haul Road and Fugitive Dust Emissions Requirements
II.B.4.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20% opacity. [R307-401-8]

II.B.4.a.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to
40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at 15-
second intervals over a six-minute period shall not apply. The number of observations and the
time period shall be determined by the length of the intermittent source. For fugitive dust
generated by mobile sources, visible emissions shall be measured at the densest point of the
plume but at a point not less than one-half vehicle length behind the vehicle and not less than
one-half the height of the vehicle. [R307-401-8]

II.B.4.b The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas
with road base material. The owner/operator shall use chemical suppressants and water
applications to maintain the opacity limits listed in this AO. If the temperature is below freezing,
the owner/operator may stop applying chemical suppressant and water to the unpaved haul roads
and wheeled-vehicle operational areas. The owner/operator shall resume applying chemical
suppressant and water to the unpaved haul roads and wheeled-vehicle operational areas when the
temperature is above freezing. [R307-401-8]

DAQE-AN161620001-24
Page 8

II.B.4.b.1 Records of chemical suppressant and water application shall be kept for all periods when the
plant is in operation. The records shall include the following items:

A. Date and time treatments were made.

B. Number of treatments made, quantity of water applied, and chemical dilution
ratio used.

C. Rainfall amount received, if any.

D. Records of temperature, if the temperature is below freezing.

[R307-401-8]

II.B.4.c The owner/operator shall not allow the unpaved haul roads on site to exceed 700 feet in length.
[R307-401-8]

II.B.4.c.1 Compliance shall be determined through Global Positioning System (GPS) measurements or
aerial photographs. [R307-401-8]

II.B.5 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.5.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.5.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

II.B.5.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]

DAQE-AN161620001-24
Page 9

II.B.5.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. Semiannually 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]

II.B.5.b.2 Monitoring surveys shall be conducted using one (1) 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.5.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.5.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.5.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:

Is Derived From NOI dated July 12, 2023
Incorporates Additional Information dated August 7, 2023
Incorporates Additional Information dated December 28, 2023
Incorporates Additional Information dated January 15, 2024

DAQE-AN161620001-24
Page 10

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-IN161620001-24

April 30, 2024

Tom Kirkwood
Wesco Operating, Incorporated
120 South Durbin Street
PO Box 1650
Casper, WY 82602
[e-mail]

Dear Mr. Kirkwood:

Re: Intent to Approve: New Helium Recovery Plant
Project Number: N161620001

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

Sincerely,

{{$s }}

Alan D. Humpherys, Manager
New Source Review Section

ADH:CB:jg

cc: Southeastern Utah District Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN161620001-24
New Helium Recovery Plant

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

Issued to
Wesco Operating, Incorporated - Long Canyon Helium Recovery Plant

Issued On
April 30, 2024

{{$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 .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ................................................................................................................... 10
ACRONYMS ............................................................................................................................... 11

DAQE-IN161620001-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Wesco Operating, Incorporated Wesco Operating, Incorporated - Long Canyon
Helium Recovery Plant

Mailing Address Physical Address
120 South Durbin Street
PO Box 1650
Remote Approximately 10 Miles East of Moab
Grand County, UT
Casper, WY 82602

Source Contact UTM Coordinates
Name: Tom Kirkwood 609,001 m Easting
Phone: [phone],268,772 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

SIC code 2813 (Industrial Gases)

SOURCE INFORMATION
General Description
Wesco Operating, Incorporated (Wesco) has requested to operate the Long Canyon Helium Recovery
Plant in Grand County. The facility will process helium-rich gas from Long Canyon # 1 well, located
approximately 3 miles to the east. Natural gas will be sent via a flowline to the facility and first sent
through an amine contactor. The gas will then be processed by a glycol dehydrator and a helium recovery
unit (HRU). The extracted helium will be compressed and held in a trailer-based tank to be hauled
off- site by trucks for sale. Waste streams will be controlled through the use of a thermal oxidizer (TO).
The facility will not process more than 4.83 million standard cubic feet per day (MMscf/day) of waste
gas.
NSR Classification
New Minor Source

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

Applicable Federal Standards
None

DAQE-IN161620001-24
Page 4

Project Description
Wesco has requested a new minor source to produce helium through the processing of natural gas.

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 26390.00
Carbon Monoxide 9.46
Nitrogen Oxides 15.55
Particulate Matter - PM10 1.68
Particulate Matter - PM2.5 1.68
Sulfur Dioxide 94.90
Volatile Organic Compounds 17.90

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hexane (CAS #110543) 7640
Change (TPY) Total (TPY)
Total HAPs 3.82

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 Times Independent Printing on May 2, 2024. 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.

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]

DAQE-IN161620001-24
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

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 Long Canyon Recovery Helium Plant

II.A.2 One (1) Helium Recovery Unit
Control: Thermal Oxidizer and Iron Sponge Media

II.A.3 One (1) Glycol Dehydrator
Control: Thermal Oxidizer and Iron Sponge Media

II.A.4 One (1) Amine Membrane Skid
Control: Thermal Oxidizer and Iron Sponge Media

DAQE-IN161620001-24
Page 6

II.A.5 One (1) Thermal Oxidizer (TO)
Burner Rating: 4.0 MMBtu/hr
Maximum Inlet Heat Rating: 47.44 MMBtu/hr
Burner Fuel: Natural Gas
Minimum VOC Destruction Efficiency: 99%

II.A.6 Single-Vessel Iron Sponge Media
Minimum H2S Control Efficiency: 99%

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 Site-Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any source on site to exceed 10% opacity. [R307-401-8]

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

II.B.1.b The owner/operator shall not produce more than 1,763 million standard cubic feet (MMscf) of
waste gas per rolling 12-month period. [R307-401-8]

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

A. Determine the production with flow meters.

B. Record production on a daily basis.

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

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

[R307-401-8]

II.B.2 Thermal Oxidizer (TO) Requirements
II.B.2.a The owner/operator shall route all emissions from the glycol dehydrator, membrane skid, and
helium recovery unit through the TO before being vented to the atmosphere. [R307-401-8]

II.B.2.b The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no less
than 99%. [R307-401-8]

II.B.2.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed TO. [R307-401-8]

II.B.2.c The owner/operator shall operate the TO according to the manufacturer's recommendations.
[R307-401-8]

DAQE-IN161620001-24
Page 7

II.B.2.d At all times while operating the TO, the owner/operator shall maintain a temperature at or above
1,400oF in the TO. [R307-401-8]

II.B.2.d.1 The owner/operator shall monitor and record the operating temperature of the TO each operating
day, while the TO is operating. [R307-401-8]

II.B.2.d.2 The owner/operator shall monitor the operating temperature with equipment located such that an
inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.d.3 The owner/operator shall calibrate all temperature monitoring equipment according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.2.e The owner/operator shall install a low-NOx burner on the TO that is certified to meet an emission
concentration of no more than 30 ppm of NOx and 30 ppm of CO. [R307-401-8]

II.B.2.e.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed low-NOx burner on the TO.
[R307-401-8]

II.B.2.f The owner/operator shall not exceed an H2S concentration of 1,850 ppmv at the inlet of the TO at
all times. [R307-401-8]

II.B.2.f.1 The owner/operator shall monitor and record the waste gas H2S concentration once weekly,
while the TO is operating. [R307-401-8]

II.B.2.f.2 The owner/operator shall monitor the H2S concentration at the inlet of the TO with equipment
located such that an inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.f.3 The owner/operator shall calibrate all H2S-monitoring instruments according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.3 Iron Sponge Requirements
II.B.3.a The owner/operator shall route all acid gas streams from the amine membrane skid through an
iron sponge prior to entering the TO. [R307-401-8]

II.B.3.b The owner/operator shall install an iron sponge that is certified to meet a hydrogen sulfide (H2S)
control efficiency of no less than 99% and a H2S capture efficiency of no less than 61%.
[R307-401-8]

II.B.3.b.1 To demonstrate compliance with the above condition, the owner/operator shall maintain records
of the manufacturer's emissions guarantee for the installed iron sponge. [R307-401-8]

II.B.4 Haul Road and Fugitive Dust Emissions Requirements
II.B.4.a The owner/operator shall not allow visible emissions from haul roads and fugitive dust sources
on site to exceed 20% opacity. [R307-401-8]

II.B.4.a.1 Opacity observations of fugitive dust from intermittent sources shall be conducted according to
40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made at
15-second intervals over a six-minute period shall not apply. The number of observations and
the time period shall be determined by the length of the intermittent source. For fugitive dust
generated by mobile sources, visible emissions shall be measured at the densest point of the
plume but at a point not less than one-half vehicle length behind the vehicle and not less than
one-half the height of the vehicle. [R307-401-8]

DAQE-IN161620001-24
Page 8

II.B.4.b The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas
with road base material. The owner/operator shall use chemical suppressant and water
application to maintain opacity limits listed in this AO. If the temperature is below freezing, the
owner/operator may stop applying chemical suppressant and water to the unpaved haul roads and
wheeled-vehicle operational areas. The owner/operator shall resume applying chemical
suppressant and water to the unpaved haul roads and wheeled-vehicle operational areas when the
temperature is above freezing. [R307-401-8]

II.B.4.b.1 Records of chemical suppressant and water application shall be kept for all periods when the
plant is in operation. The records shall include the following items:

A. Date and time treatments were made.

B. Number of treatments made, quantity of water applied, and chemical dilution
ratio used.

C. Rainfall amount received, if any.

D. Records of temperature, if the temperature is below freezing.

[R307-401-8]

II.B.4.c The owner/operator shall not allow the unpaved haul roads on site to exceed 700 feet in length.
[R307-401-8]

II.B.4.c.1 Compliance shall be determined through Global Positioning System (GPS) measurements or
aerial photographs. [R307-401-8]

II.B.5 Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.5.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.5.a.1 The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

DAQE-IN161620001-24
Page 9

II.B.5.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.5.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. Semiannually 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.5.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.5.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.5.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.5.d The owner/operator shall maintain records of the fugitive emissions monitoring plan, monitoring
surveys, repairs, and resurveys. [R307-401-8]

DAQE-IN161620001-24
Page 10

PERMIT HISTORY

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

Is Derived From NOI dated July 12, 2023
Incorporates Additional Information dated August 7, 2023
Incorporates Additional Information dated December 28, 2023
Incorporates Additional Information dated January 15, 2024

DAQE-IN161620001-24
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-NN161620001-24

April 30, 2024

Times Independent Printing
Legal Advertising Dept.
P.O. Box 12935 E Center
Moab, UT 84532

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Times Independent
Printing on May 2, 2024.

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: Grand County
cc: Southeastern 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-NN161620001-24
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: Wesco Operating, Incorporated
Location: Wesco Operating, Incorporated - Long Canyon Helium Recovery Plant –
Remote, Approximately 10 Miles East of Moab, Grand County, UT
Project Description: Wesco Operating, Incorporated (Wesco) has requested to operate the Long
Canyon Helium Recovery Plant in Grand County. The facility will process
helium-rich gas the Long Canyon # 1 well, located approximately 3 miles to the
east. Natural gas will be sent via a flowline to the facility and first sent through
an amine contactor. The gas will then be processed by a glycol dehydrator and a
helium recovery unit (HRU). The extracted helium will be compressed and held
in a trailer-based tank to be hauled off-site by trucks for sale. Waste streams will
be controlled through the use of a thermal oxidizer (TO). The facility will not
process more than 4.83 million standard cubic feet per day (MMscf/day) of waste
gas.

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 June 1, 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: May 2, 2024

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

Times-Independent
Publication Name:
Times-Independent
Publication URL:
www.moabtimes.com
Publication City and State:
Moab, UT
Publication County:
Grand
Notice Popular Keyword Category:
Notice Keywords:
wesco
Notice Authentication Number:
202405021004049212834
1761527914
Notice URL:
Back
Notice Publish Date:
Thursday, May 02, 2024
Notice Content
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: Wesco Operating, Incorporated Location: Wesco Operating, Incorporated - Long
Canyon Helium Recovery Plant – Remote, Approximately 10 Miles East of Moab, Grand County, UT Project Description: Wesco Operating,
Incorporated (Wesco) has requested to operate the Long Canyon Helium Recovery Plant in Grand County. The facility will process helium-rich
gas the Long Canyon # 1 well, located approximately 3 miles to the east. Natural gas will be sent via a flowline to the facility and first sent
through an amine contactor. The gas will then be processed by a glycol dehydrator and a helium recovery unit (HRU). The extracted helium
will be compressed and held in a trailer-based tank to be hauled off-site by trucks for sale. Waste streams will be controlled through the use
of a thermal oxidizer (TO). The facility will not process more than 4.83 million standard cubic feet per day (MMscf/day) of waste gas. 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 June 1, 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: May 2, 2024 SLT0027364
Back
5/2/24, 9:04 AM utahlegals.com/(S(xrvfmrwulmx2ilml2zux01zi))/DetailsPrint.aspx?SID=xrvfmrwulmx2ilml2zux01zi&ID=183976
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DAQE-

RN161620001
April 15, 2024

Tom Kirkwood
Wesco Operating, Inc.
120 South Durbin Street
PO Box 1650
Casper, WY 82602
[e-mail]

Dear Tom Kirkwood,

Re: Engineer Review:
New Helium Recovery Plant
Project Number: N161620001

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. Wesco Operating,
Inc. should complete this review within 10 business days of receipt.

Wesco Operating, Inc. should contact Christine Bodell at [phone] if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email
Christine Bodell at [e-mail] the signed cover letter. Upon receipt of the signed cover letter,
the DAQ will prepare an 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 Wesco Operating, Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Wesco Operating, Inc. has concerns that cannot be resolved and
the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

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

Kimberly D. Shelley Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird Director

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N161620001
Owner Name Wesco Operating, Inc.
Mailing Address 120 South Durbin Street
PO Box 1650
Casper, WY, 82602

Source Name Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
Source Location Remote
Approximately 10 Miles East of Moab
Grand County, UT

UTM Projection 609,001 m Easting, 4,268,772 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 2813 (Industrial Gases)

Source Contact Tom Kirkwood
Phone Number [phone]
Email [e-mail]

Billing Contact Tom Kirkwood
Phone Number [phone]
Email [e-mail]

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

Notice of Intent (NOI) Submitted July 12, 2023
Date of Accepted Application February 8, 2024

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 2
SOURCE DESCRIPTION

General Description
Wesco Operating, Inc. (Wesco) has requested to operate the Long Canyon Helium Recovery
Plant in Grand County. The facility will process from helium-rich gas from the the Long Canyon
# 1 well, located approximately 3 miles to the east. Natural gas will be sent via flowline to the
facility and first sent through an amine contactor. The gas will then be processed by a glycol
dehydrator and a helium recovery unit (HRU). The extracted helium will be compressed and held
in a trailer-based tank to be hauled off site by trucks for sale. Waste streams will be controlled
through the use of a thermal oxidizer (TO). The facility will not process more than 4.83 million
standard cubic feet per day (MMscf/day) of waste gas.

NSR Classification:
New Minor Source

Source Classification
Located in Attainment Area,
Grand County
Airs Source Size: SM

Applicable Federal Standards

Project Proposal
New Helium Recovery Plant

Project Description
Wesco Operating, Inc. (Wesco) has requested a new minor source to produce helium through the
processing of natural gas.

EMISSION IMPACT ANALYSIS
The proposed SO2 emissions exceeds the modeling thresholds outlined in R307-410-4. Therefore, Wesco was
required to conduct modeling. No other criteria pollutant or HAPs emissions exceeded the modeling thresholds
outlined in R307-410-4 and R307-410-5.

The UDAQ conducted 1-hour and 3-hour SO2 modeling analyses. The results indicated that the highest SO2
impacts would be 37.74% and 4.34% of the SO2 NAAQS levels, respectively.

See Memorandum DAQE-MN161620001-24, dated February 6, 2024 for more details. [Last updated February
23, 2024]

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 3
SUMMARY OF EMISSIONS

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

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 26390.00
Carbon Monoxide 9.46
Nitrogen Oxides 15.55
Particulate Matter - PM10 1.68
Particulate Matter - PM2.5 1.68
Sulfur Dioxide 94.90
Volatile Organic Compounds 17.90

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Hexane (CAS #110543) 7640
Change (TPY) Total (TPY)
Total HAPs 3.82

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

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Helium Processing Equipment
Helium production equipment includes the amine skid, dehydrator, and helium recovery unit
(HRU). Air pollutants associated with each piece of equipment are VOCs and HAPs. Many HAP
components are emitted through the same process as VOCs and the control technologies for VOCs
also control HAPs.

Wesco has elected to control VOCs/HAPs with a thermal oxidizer (TO). TOs regularly achieve up
to 99% VOC/HAP destruction efficiencies. TOs typically consist of an enclosed combustion
chamber with an auxiliary burner fired with a conventional fuel. The firing rate of the burner is
automatically controlled to maintain a preset combustion-chamber temperature. TOs provide
maximum operating flexibility because they can handle CO and most known VOCs at a wide
range of concentrations and flows. The burner on the TO is a low-NOX burner (LNB), per the
requirement of UAC Section R307-401-4(3). It is guaranteed by the manufacturer that NOX
emissions will be <30 ppm and CO emissions will be <30 ppm, both at 50-100% design
conditions, corrected to 3% oxygen. It is also guaranteed to have a destruction efficiency of >99%
for VOCs.

Therefore, BACT to control VOC/HAP emissions from the helium production equipment is to
route gases, vapors, and fumes from the amine skid, dehydrator, and HRU to a TO. Wesco shall
install a TO that is certified to meet a VOC control efficiency of no less than 99%. The TO shall
also be certified not to exceed a NOx and CO concentration of 30 ppm, each, in the exhaust gas of
the TO. Wesco shall only use natural gas as fuel gas in the TO. BACT is also operating the TO at
or above the minimum operating temperature of 1,400oF to ensure proper destruction.

The gas steam from the amine skid will contain hydrogen sulfide (H2S). When combusted, H2S is
converted to SO2. A potential daily throughput of 4.83 MMscf/day through the TO results in an
uncontrolled PTE of 245 tpy of SO2. Therefore, a BACT analysis was conducted to reduce SO2
emissions from the TO.

[Last updated March 14, 2024]

2. BACT review regarding SO2 from TO
Technologies to reduce SO2 emissions include use of a wet caustic scrubber, fixed-bed activated
carbon, and an iron sponge media. Each technology aims to reduce H2S in the inlet stream,
therefore reducing SO2 emissions in the TO exhaust stream.
Wet Scrubber
A caustic scrubber is a device in which gas flows countercurrent to a solution of sodium hydroxide
(caustic) and water. H2S is highly soluble in water, which results in an acidic solution when
dissolved. The dissolved H2S readily reacts with the caustic solution to form sodium sulfide
(Na2S) and sodium bisulfide (NaSH), which precipitate out of the solution. Caustic scrubbers can
achieve 70-99% H2S control. The presence or absence of significant CO2 is also an important
consideration with caustic scrubbers. Caustic scrubbing of gases containing high CO2 levels is
particularly problematic because the CO2 can also react with the caustic, causing unwanted caustic
consumption and the possibility of precipitation of sodium carbonate solids.
Additionally, CO2 absorption causes unnecessary caustic usage and contamination of the sodium
hydrosulfite product solution with carbonate salts, which can lead to plugging and fouling of
process equipment. The TO inlet stream contains approximately 14.91 weight percent CO2. The
ratio of CO2 to H2S in the TO inlet stream is approximately 6:1. According to manufacturer

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 5
specifications, the CO2 to H2S in the TO inlet stream should be no more than 5:1. Given the high
CO2 content of the inlet stream, caustic scrubbing is not technically feasible.
Fixed-Bed Activated Carbon
Carbon adsorption utilizes a column or filter of activated carbon to adsorb targeted pollutants as
pollution-laden gas flows through them. In adsorption (as opposed to absorption, e.g., a wet
scrubber) the pollutant molecules are attracted to the carbon by a physical, rather than a chemical,
process. H2S from gaseous streams can be adsorbed onto the surface of the activated carbon. The
activated carbon is porous and allows for a large absorptive capacity, resulting in H2S control
efficiencies of 98-99%. Wesco reached out to a vendor that indicated that a fixed-carbon bed
system would require at least three (3) vessels, leading to inordinate operating, maintenance, and
waste removal activity and costs. The estimated annual media and disposal cost of more than
$17,000,000 per year. Assuming an H2S control efficiency of 99%, this equates to an annual cost-
effectiveness of approximately $70,000. The DAQ considers this cost-prohibitive.
[Last updated April 2, 2024]

3. BACT review regarding SO2 from TO (Continued)
Iron Sponge Media

Iron has the ability to readily donate electrons to a reaction, making it an excellent reducing agent
or catalyst for other sulfur reactions. H2S has the potential to react with iron hydroxides or oxides
to form iron sulfide. Iron sponge media consist of iron hydroxides or oxides that are impregnated
on support media such as steel wool, wood chips, or oxide pellets, which allow for the treatment of
H2S in the gaseous phase. The vessels containing the impregnated support media are referred to as
iron sponges. Iron sponges have H2S control efficiencies of up to 99%, per the manufacturer's
estimate.

Wesco conducted an economic feasibility analysis for both a multi-vessel iron sponge system that
controls all 4.83 MMscf/day of the waste stream as well as a single-vessel iron sponge system that
controls a portion of the waste stream. The former analysis resulted in a value of $15,142 per ton
of SO2 removed, while the second analysis resulted in a value of $14,696 per ton of SO2 removed.
The difference is primarily due to the additional costs necessary for redundant vessels and
additional maintenance, chemical replacement, and waste disposal in the multi-vessel system. The
multi-vessel system is also capable of controlling more SO2 than the single-vessel system; 244.76
tpy compared to 150 tpy, respectively.

Therefore, BACT to reduce H2S in the inlet gas stream, and therefore reduce SO2 emissions in the
TO exhaust stream, is the use of a single-vessel iron sponge H2S removal system. [Last updated
February 23, 2024]

4. BACT review regarding Haul Roads
Haul truck operations at the Wesco facility will create fugitive PM10 and PM2.5 emissions.

Controls for existing paved areas include sweeping, vacuum sweeping and/or watering. Paved
roadways, combined with sweeping and watering, provides a 90% control efficiency; the use of a
vacuum sweeper increases the control efficiency to 95%. For existing and proposed unpaved areas,
control technologies include watering (70% control efficiency), watering combined with the use of
a low silt content road base (75% control efficiency), the application of chemical dust suppressants
(85% control efficiency), and paving (>90% control efficiency).

The proposed haul road is unpaved. An economic feasibility analysis conducted by Wesco
demonstrates that the cost of paving the unpaved haul road is >$2,650,000 per ton removed of

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 6
PM10 and PM2.5. Therefore, paving the unpaved haul road is economically infeasible. Therefore,
BACT for the unpaved roads is water and chemical dust suppressant application and use of a road
base. Additionally, all haul roads on site will be treated as necessary to maintain visible emissions
at or below 20% opacity. The haul road will not exceed 700 feet in length. [Last updated February
23, 2024]

5. BACT review regarding Component Fugitive Emissions
Operations at the Wesco Facility will generate fugitive VOC emissions. BACT to control fugitive
VOC emissions is the implementation of a fugitive leak detection and repair program. [Last
updated January 8, 2024]

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

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

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

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 7
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
NEW
Long Canyon Recovery Helium Plant

II.A.2
NEW
One (1) Helium Recovery Unit
Control: Thermal Oxidizer and Iron Sponge Media

II.A.3
NEW
One (1) Glycol Dehydrator
Control: Thermal Oxidizer and Iron Sponge Media

II.A.4
NEW
One (1) Amine Membrane Skid
Control: Thermal Oxidizer and Iron Sponge Media

II.A.5
NEW
One (1) Thermal Oxidizer (TO)
Burner Rating: 4.0 MMBtu/hr
Maximum Inlet Heat Rating: 47.44 MMBtu/hr
Burner Fuel: Natural Gas
Minimum VOC Destruction Efficiency: 99%

II.A.6
NEW
Single-Vessel Iron Sponge Media
Minimum H2S Control Efficiency: 99%

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

II.B REQUIREMENTS AND LIMITATIONS

II.B.1
NEW
Site-Wide Requirements

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 8
II.B.1.a
NEW
Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions
from any source on site to exceed 10% opacity. [R307-401-8]

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

II.B.1.b
NEW
The owner/operator shall not produce more than 1,763 million standard cubic feet (MMscf) of
waste gas per rolling 12-month period. [R307-401-8]

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

A. Determine the production with flow meters

B. Record production on a daily basis

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

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

[R307-401-8]

II.B.2
NEW
Thermal Oxidizer (TO) Requirements
II.B.2.a
NEW
The owner/operator shall route all emissions from the glycol dehydrator, membrane skid, and
helium recovery unit through the TO before being vented to the atmosphere. [R307-401-8]

II.B.2.b
NEW
The owner/operator shall install a TO that is certified to meet a VOC control efficiency of no
less than 99%. [R307-401-8]

II.B.2.b.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the manufacturer's emissions guarantee for the installed TO. [R307-401-8]

II.B.2.c
NEW
The owner/operator shall operate the TO according to the manufacturer's recommendations.
[R307-401-8]

II.B.2.d
NEW
At all times while operating the TO, the owner/operator shall maintain a temperature at or
above 1,400oF in the TO. [R307-401-8]

II.B.2.d.1
NEW
The owner/operator shall monitor and record the operating temperature of the TO each
operating day, while the TO is operating. [R307-401-8]

II.B.2.d.2
NEW
The owner/operator shall monitor the operating temperature with equipment located such that
an inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.d.3
NEW
The owner/operator shall calibrate all temperature monitoring equipment according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.2.e
NEW
The owner/operator shall install a low-NOx burner on the TO that is certified to meet an
emission concentration of no more than 30 ppm of NOx and 30 ppm of CO. [R307-401-8]

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 9
II.B.2.e.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the manufacturer's emissions guarantee for the installed low-NOx burner on the TO.
[R307-401-8]

II.B.2.f
NEW
The owner/operator shall not exceed an H2S concentration of 1,850 ppmv at the inlet of the
TO at all times. [R307-401-8]

II.B.2.f.1
NEW
The owner/operator shall monitor and record the waste gas H2S concentration once weekly,
while the TO is operating. [R307-401-8]

II.B.2.f.2
NEW
The owner/operator shall monitor the H2S concentration at the inlet of the TO with equipment
located such that an inspector/operator can safely read the output at any time. [R307-401-8]

II.B.2.f.3
NEW
The owner/operator shall calibrate all H2S-monitoring instruments according to the
manufacturer's instructions at least once every 12 months. [R307-401-8]

II.B.3
NEW
Iron Sponge Requirements
II.B.3.a
NEW
The owner/operator shall route all acid gas streams from the amine membrane skid through an
iron sponge prior to entering the TO. [R307-401-8]

II.B.3.b
NEW
The owner/operator shall install an iron sponge that is certified to meet a hydrogen sulfide
(H2S) control efficiency of no less than 99% and a H2S capture efficiency of no less than 61%.
[R307-401-8]

II.B.3.b.1
NEW
To demonstrate compliance with the above condition, the owner/operator shall maintain
records of the manufacturer's emissions guarantee for the installed iron sponge. [R307-401-8]

II.B.4
NEW
Haul Road and Fugitive Dust Emissions Requirements
II.B.4.a
NEW
The owner/operator shall not allow visible emissions from haul roads and fugitive dust
sources on site to exceed 20% opacity. [R307-401-8]

II.B.4.a.1
NEW
Opacity observations of fugitive dust from intermittent sources shall be conducted according
to 40 CFR 60, Appendix A, Method 9; however, the requirement for observations to be made
at 15-second intervals over a six-minute period shall not apply. The number of observations
and the time period shall be determined by the length of the intermittent source. For fugitive
dust generated by mobile sources, visible emissions shall be measured at the densest point of
the plume but at a point not less than one-half vehicle length behind the vehicle and not less
than one-half the height of the vehicle. [R307-401-8]

II.B.4.b
NEW
The owner/operator shall cover all unpaved haul roads and wheeled-vehicle operational areas
with road base material. The owner/operator shall use chemical suppressant and water
application to maintain opacity limits listed in this AO. If the temperature is below freezing,
the owner/operator may stop applying chemical suppressant and water to the unpaved haul
roads and wheeled-vehicle operational areas. The owner/operator shall resume applying
chemical suppressant and water to the unpaved haul roads and wheeled-vehicle operational
areas when the temperature is above freezing. [R307-401-8]

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 10
II.B.4.b.1
NEW
Records of chemical suppressant and water application shall be kept for all periods when the
plant is in operation. The records shall include the following items:

A. Date and time treatments were made

B. Number of treatments made, quantity of water applied, and chemical dilution ratio
used

C. Rainfall amount received, if any

D. Records of temperature, if the temperature is below freezing.

[R307-401-8]

II.B.4.c
NEW
The owner/operator shall not allow the unpaved haul roads on site to exceed 700 feet in
length. [R307-401-8]

II.B.4.c.1
NEW
Compliance shall be determined through Global Positioning System (GPS) measurements or
aerial photographs. [R307-401-8]

II.B.5
NEW
Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)
II.B.5.a
NEW
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.5.a.1
NEW
The plan shall address monitoring for "difficult-to-monitor" and "unsafe-to-monitor"
components. [R307-401-8]

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April 15, 2024
Page 11
II.B.5.b
NEW
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.5.b.1
NEW
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. Semiannually 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.5.b.2
NEW
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.5.c
NEW
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]

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 12
II.B.5.c.1
NEW
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.5.d
NEW
The owner/operator shall maintain records of the fugitive emissions monitoring plan,
monitoring surveys, repairs, and resurveys. [R307-401-8]

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April 15, 2024
Page 13
PERMIT HISTORY

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

Is Derived From NOI dated July 12, 2023
Incorporates Additional Information dated August 7, 2023
Incorporates Additional Information dated December 28, 2023
Incorporates Additional Information dated January 15, 2024

REVIEWER COMMENTS

1. Comment regarding Source Classification as a Synthetic Minor:
A maximum daily throughput of 4.83 MMscf/day through the TO results in an uncontrolled PTE of
245 tpy of SO2 for the facility. The sponge reduces the SO2 to 94.90 tpy.

Per 40 CFR 70 (Title V), a major stationary source of air pollutants, as defined in section 302 of the
Act, is a source that directly emits, or has the potential to emit, 100 tpy or more of any air pollutant
subject to regulation. The Helium Processing Plant has the potential to emit 245 tpy of uncontrolled
SO2, but have taken restrictions so that the SO2 emissions are reduced to below the 100 tpy
threshold.

Therefore, this is a Synthetic Minor Source under 40 CFR 70. [Last updated March 13, 2024]

2. Comment regarding Federal Standard/Title V Applicability:
Title V of the 1990 CAA (Title V) applies to the following:

A. Any major source
B. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act,
Standards of Performance for New Stationary Sources
C. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants
D. Any Title IV-affected source

This facility is not a major source and is not a Title IV source. The facility is not subject to any 40
CFR 60 (NSPS), 40 CFR 61 (NESHAP), or 40 CFR 63 (MACT) regulations. Therefore, Title V does
not apply to this facility. [Last updated March 13, 2024]

3. Comment regarding Source Emission Estimates and DAQ Acceptance:
Thermal Oxidizer:
CO and NOx emissions from the TO are quantified based on outlet guarantees from the TO vendor of
0.042 lb/MMBtu and 0.069 lb/MMBtu, respectively. These emissions guarantees are inclusive of
supplemental natural gas used in the TO. These values are converted to a mass flow basis by
multiplying by the maximum heat content to the TO of 47.44 MMBtu/hr. Similarly, the vendor
guarantees a 99% destruction efficiency for emissions of VOC, post-TO, as hexane. Particulate
matter (PM10/PM2.5) emissions are quantified using the 7.60 lb/MMscf emission factor in AP-42,
Table 1.4-2 (Natural Gas Combustion). With a heating value of at 1,020 Btu/scf, the PM10/PM2.5
emission factor is 0.0075 lb/MMBtu. Sulfur dioxide (SO2) emissions are calculated from design
parameters of the sulfur removal step of the RNG process. The SO2 emissions were based on
proposed estimated H2S exhaust composition data provided by TO manufacturer in April 2023 and

Engineer Review N161620001: Wesco Operating, Inc.- Long Canyon Helium Recovery Plant
April 15, 2024
Page 14
adjusted for the difference in molecular weight. It was assumed that all H2S is combusted in the TO
to form SO2. Per the BACT analysis, the installation of a single-vessel iron sponge H2S control
system will capture 61.33% of the H2S resulting from 4.83 MMscf/day of waste gas. Of the captured
material, it is estimated to control 99.9% of it. The remaining 0.1% is returned to the TO and
combusted.
The TO is assumed to operate 8,760 hours, annually.

GHG emission factors from 40 CFR 98, Tables C-1 and C-2.

Haul Roads:
Emission estimations from haul roads were calculated from AP-42, Chapter 13.2.1 Unpaved Roads.
The application of water, chemical treatment and use of a road base result in a PM10/PM2.5 control
efficiency of 85%.

Fugitive Leaks
Fugitive Leaks Emissions were calculated based on the Texas Commission on Environmental
Quality Air Permits Division "Air Permit Technical Guidance for Chemical Sources Fugitive
Guidance" 2018 document. [Last updated March 13, 2024]

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April 15, 2024
Page 15
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

MODELING REPORT
SO2 1-hour and 3-hour NAAQS

Wesco Operating, Inc. / Long Canyon Helium Plant

Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard, Suite 200
Salt Lake City, UT 84124
[phone]

Prepared For:
Wesco Operating, Inc.
120 S Durbin Street P.O. Box 1650
Casper, WY 82602

January 2024

Project: 224502.0025
Wesco Companies | SO2 Modeling Analyses
Trinity Consultants i
TABLE OF CONTENTS
1. INTRODUCTION 1-1
1.1 General Information ................................................................................................. 1-1
1.2 Project Scope ............................................................................................................ 1-1
1.3 Plant Layout .............................................................................................................. 1-1
2. AIR DISPERSION MODELING DESCRIPTION 2-1
2.1 Model Selection ......................................................................................................... 2-1
2.2 Meteorological Data .................................................................................................. 2-1
2.3 Terrain Elevations ..................................................................................................... 2-1
2.4 Receptors .................................................................................................................. 2-1
2.5 UTM Coordinate System ............................................................................................ 2-4
2.6 Building Downwash .................................................................................................. 2-5
3. SO2 SOURCE PARAMETERS AND EMISSION RATES 3-1
3.1 SO2 Point Source Parameters and Emission Rates..................................................... 3-1
3.1.1 Combustion Equipment Modeling Parameters and Emission Rates ................................ 3-1
3.2 SO2 Volume Source Parameters and Emission Rates ................................................. 3-1
3.3 SO2 Area Source Parameters and Emission Rates...................................................... 3-1
3.4 SO2 Nearby Sources .................................................................................................. 3-1
4. SO2 MODELING ANALYSIS 4-1
4.1 Background SO2 Concentrations ............................................................................... 4-1
4.2 Modeled SO2 Concentration ...................................................................................... 4-1
4.3 1-hour and 3-hour SO2 NAAQS Analysis Results ........................................................ 4-2
APPENDIX A. PLANT MODELING PARAMETERS AND EMISSION RATES A-1

Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 1-1
1.INTRODUCTION
1.1 General Information
Wesco Operating, Inc. (Wesco) is proposing to construct a helium production plant approximately 10 miles
west of Moab, Utah, known as the Long Canyon Helium Plant (the Plant). Wesco has submitted a Notice of
Intent (NOI) air permit application to the Utah Division of Air Quality (UDAQ) to obtain an approval order
(AO) for the Plant. Modeling thresholds are surpassed for sulfur dioxide (SO2), resulting in the submittal of
this air dispersion modeling protocol and report.
The proposed Plant is located within an area of Grand County designated as an attainment area of the
National Ambient Air Quality Standards (NAAQS) for all criteria pollutants.
This modeling protocol and report outline the methodology that Wesco has used in conducting air dispersion
modeling. It describes the results that demonstrate compliance with the NAAQS for 1-hour and 3-hour SO 2
at the Plant. Dispersion modeling has been conducted in accordance with R307-410-3 and 40 Code of
Federal Regulations (CFR) Part 51, Appendix W Guideline on Air Quality Models.
1.2 Project Scope
Wesco’s Plant will process natural gas from wells. The gas will be processed using a variety of equipment
that separates helium from the natural gas. Waste streams will be controlled through the use of a single-
vessel iron sponge system for H2S removal and a thermal oxidizer (TO) for H2S destruction. The Plant will
have a maximum capacity of 4.83 million standard cubic feet per day (MMscf/day). Product helium will be
compressed, loaded into trucks, and trucked off site for sale. Emissions of SO 2 will result from the
destruction of H2S through combustion of waste gas at the TO.
1.3 Plant Layout
The current site layout is shown in Figure 1-1, below. Figure 1-2 also below, presents a basic layout of the
primary equipment at the Plant. Natural gas will be produced from a well or wells and sent via flowline to
the Plant. That gas will be processed to isolate and remove helium. This will occur first through an amine
contactor. The gas will then be processed by a glycol dehydrator, a membrane skid, and a helium recovery
unit (HRU). The extracted helium will be compressed and held in a trailer-based tank to be hauled off site
by trucks for sale. Waste gases are controlled throughout the process by a single-vessel iron sponge system
and a TO. Heat from the TO is recycled through hot oil for use at the Plant.
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 1-2
Figure 1-1. Site Layout
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 1-3
Figure 1-2. Process Flow Diagram of the Plant.
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-1
2.AIR DISPERSION MODELING DESCRIPTION
This section describes the air quality dispersion modeling analysis performed to estimate the ambient air
impacts of Wesco’s operation of the Plant. All modeling results were compared to the SO2 NAAQS for the 1-
hour and 3-hour averaging periods. The objective of the NAAQS analysis is to demonstrate through air
quality dispersion modeling that emissions from the Plant do not cause or contribute to an exceedance of 1-
hour and 3-hour SO2 NAAQS. No nearby offsite area sources were required to be included, at the direction
of UDAQ. Dispersion Modeling was conducted in accordance with R307-410-3 and 40 CFR Part 51, Appendix
W Guideline on Air Quality Models.
2.1 Model Selection
Near-field dispersion modeling was performed using the latest version of the AERMOD modeling system,
version 21112, which is an EPA approved, steady-state Gaussian mathematical plume model. AERMOD is
composed of three (3) modular components: AERMAP, the terrain preprocessor that characterizes the
terrain and generates source and receptor elevations and surrounding hill height scales; AERMET, the
meteorological preprocessor that processes raw surface and upper air meteorological observations for use
by AERMOD; and AERMOD, the control module and modeling processor.
2.2 Meteorological Data
Meteorological data used in the dispersion modeling analysis was processed and provided by UDAQ. Data
consists of five (5) individual years (2016 through 2020) of National Weather Service (NWS) surface data
collected at UDAQ’s Canyonlands station in Utah that were then concatenated into a five (5)-year file.
Concurrent upper air observations used in AERMET were obtained from the Salt Lake City Airport.
2.3 Terrain Elevations
Terrain elevations for the Plant’s sources, receptors and buildings were determined using National Elevation
Dataset (NED), the primary elevation data product of the United States Geologic Survey (USGS).1 NED data
are distributed in geographic coordinates in units of decimal degrees, and in conformance with the North
American Datum of 1983 (NAD 83). The NED used for this analysis is at a resolution of 1/3 arc-second
(about 10 meter) grid spacing. Elevations were converted from the NED grid spacing to the air dispersion
model receptor spacing using the AERMOD preprocessor, AERMAP version 18081. All data obtained from the
NED files was checked for completeness and spot-checked for accuracy.
2.4 Receptors
A modeling domain was developed for the near-field analysis to encompass the location of the maximum
modeled concentration from Wesco’s sources. Discrete receptor locations in AERMOD were based on UTM
coordinates in the NAD83 datum, Zone 12S. An initial modeling grid extending a minimum of 10.0
kilometers from the Plant’s center was established. The receptor grid was developed to ensure that
maximum pollutant concentrations were captured by the model. The facility boundary is based on the
proposed Plant fenceline.
1 NED data obtained at https://viewer.nationalmap.gov/basic/#/ downloaded December 23, 2020.
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-2
The model receptors consisted of boundary receptors and gridded receptors with the following spacing:
►The ambient air boundary was placed at the facility property line and consists of discrete receptors
placed at 25-meter intervals.
►The fine grid contains 50-meter spaced receptors extending to at least 300 meters from the center of
the facility.
►The medium grid contains 100-meter spaced receptors extending to at least 2,100 meters from the
center of the facility.
►The coarse grid contains 1,000-meter spaced receptors extending to 10 kilometers from the center of
the facility.
Figure 2-1 and Figure 2-2 below show the ambient air boundary receptors (shown in purple below) and
gridded off-site receptors (yellow).
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-3
Figure 2-1. Boundary Receptors.
Legend
___ Boundary Location
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-4
Figure 2-2. Fine, Medium, and Coarse Grid Receptors
2.5 UTM Coordinate System
In all modeling analyses, input and output data files, the locations of emission sources, structures, and
receptors were represented in the Universal Transverse Mercator (UTM) coordinate system and based on
NAD83. In this grid, the world is divided into 60 north-south zones, each covering a strip 6° wide in
longitude. The general area of the site is located in UTM Zone 12S. In each UTM zone, coordinates are
measured north and east in meters. The northing values are measured continuously from zero at the
Legend
+Receptor
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-5
equator, in a northerly direction. A central meridian through the middle of each 6° zone is assigned an
easting value of 500,000 meters. Grid values to the east of this central meridian, as in the case of the site,
are greater than 500,000 meters.
2.6 Building Downwash
Emission sources were evaluated in terms of their proximity to nearby structures. No structures were
included for the Building Profile Input Program (BPIP), which predicts the effects of building downwash, as
no major structures are present.
Wesco Operating, Inc. | SO2 Modeling Analysis
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3.SO2 SOURCE PARAMETERS AND EMISSION RATES
3.1 SO2 Point Source Parameters and Emission Rates
The SO2 point sources at the Plant consist of one (1) TO. Point sources require release height, stack
temperature, stack velocity, and stack diameter. All inputs for stack source parameters can be found in
Appendix A of this modeling analysis.
3.1.1 Combustion Equipment Modeling Parameters and Emission Rates
The modeled point sources of combustion at the Plant consist of the following equipment and their release
parameters. Stack information was provided by Wesco.
Table 3-1. Release Parameters for SO2 Point Sources
Unit
Stack
Height
(m)
Stack
Temp.
(K)
Stack
Velocity
(m/s)
Stack
Diameter
(m)
TO 12.29 1,088.71 14.15 1.25
The Plant’s emissions calculations and modeling analysis were conducted based on the combustion of 4.83
MMscf/day of waste gas in the TO, and a maximum of 0.0035 MMscf/hr of fuel gas during startup and
shutdown activities. A maximum heat input of 51.44 MMBtu/hr is given for the TO system (TO and TO
burner) by the vendor.
Modeling parameters for all point sources and emission rates can be found in Appendix A, Table A-1.
3.2 SO2 Volume Source Parameters and Emission Rates
No volume sources at the Plant emit SO2. Thus, none were included in the modeling.
3.3 SO2 Area Source Parameters and Emission Rates
No area sources are present at the Plant. Thus, none were included in the modeling.
3.4 SO2 Nearby Sources
No nearby sources were required by UDAQ to be included as part of this air dispersion model.
Wesco Operating, Inc. | SO2 Modeling Analysis
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4.SO2 MODELING ANALYSIS
The modeling analysis predicts ambient concentrations of SO2 due to emissions from the Plant and
surrounding sources. The modeling output includes tabulated modeling results as compared to the SO2 1-
hour and 3-hour NAAQS.
4.1 Background SO2 Concentrations
Background concentrations for SO2 for this modeling analysis were given by UDAQ from their Moab
monitoring station. The background data consists of monthly tabulated maximums of 1-hour and 3-hour SO 2
for the years 2001-2003. The value used in the modeling analysis is the highest first high (H1H) monthly 1-
hour or 3-hour value, except for the highest annual background value of each year. This approach has been
directed by UDAQ in accordance with the form of the 1-hour and 3-hour SO2 NAAQS standard.2,3 The
background concentrations used for the modeling are presented in Table 5-1 below.
Table 4-1. UDAQ-Provided 1-hour and 3-hour SO2 Background Concentrations (µg/m3)
Year 2018 2019 Monthly Average Month Max Max
1 - 0.9 0.9
2 - 1.2 1.2
3 - 0.8 0.8
4 0.3 -0.3
5 0.3 -0.3
6 0.5 -0.5
7 0.4 -0.4
8 0.4 -0.4
9 0.3 -0.3
10 0.4 -0.4
11 0.5 -0.5
12 0.5 -0.5
3-hour H2H 0.4 0.6 0.6
1-hour 99%0.6 1.2 1.2
4.2 Modeled SO2 Concentration
The resulting concentration of SO2 from this air dispersion modeling analysis was compared against the 1-
hour and 3-hour SO2 NAAQS to demonstrate that emissions from the Plant do not cause or contribute to an
exceedance of the 1-hour and 3-hour SO2 NAAQS. The primary NAAQS is the maximum concentration
ceiling, measured in terms of total concentration of a pollutant in the atmosphere, which define the “level of
air quality which the United States Environmental Protection Agency (U.S. EPA) judges are necessary, with
an adequate margin of safety, to protect the public health.”4 The 1-hour SO2 NAAQS requires the 3-year
2 NAAQS standard for 1-hour SO2 given as, “3 year average of the 99th percentile of the annual distribution of daily maximum
1-hour concentrations.”
3 NAAQS standard for 2-hour SO2 given as, “Not to be exceeded more than once per calendar year.”
4 40 CFR 50.2(b).
Wesco Operating, Inc. | SO2 Modeling Analysis
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average of the 99th percentile of the annual distribution of daily, maximum, 1-hour concentrations
compared to the standard. The 3-hour SO2 NAAQS requires the maximum individual year's high-second-high
from a 5-year meteorological data set be compared to the standard. The modeled concentration was added
to the monthly background concentrations for comparison to the NAAQS. This calculation was completed
within the AERMOD modeling system.
4.3 1-hour and 3-hour SO2 NAAQS Analysis Results
A NAAQS analysis considers the impact from all sources at the Plant and background concentrations to yield
a total concentration which is then compared to the NAAQS which, for 1-hour and 3-hour SO2, are 196
µg/m3 and 1,300 µg/m3, respectively. Table 5-2 presents the model-predicted concentrations from the Plant
plus background concentration, and 1-hour and 3-hour SO2 NAAQS comparison.
Table 4-2. SO2 1-hour and 3-hour NAAQS Compliance Demonstration
Operating
Scenario Pollutant Averaging
Period
Model-Predicted
Concentration
Including
Background
Modeling
Standard
NAAQS
Percent
of
NAAQS
(µg/m3) (µg/m3) (%)
Complete
Operations SO2 1-hour 74.25 H4H 196 37.88%
Complete
Operations SO2 3-hour 57.43 H2H 1,300 4.42%
In addition to this report, Wesco is providing the AERMOD Input and Output files for UDAQ’s review in a
separate submittal.
Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants A-1
APPENDIX A. PLANT MODELING PARAMETERS AND EMISSION RATES
Table A-1. SO2 Point Source Input Parameters
ID Description X Coordinate
(m)
Y Coordinate
(m)
Elevation
(m)
Emission
Rate
(g/s)
Stack
Height
(m)
Stack
Temp.
(K)
Stack
Velocity
(m/s)
Stack
Diameter
(m)
TO Thermal
Oxidizer 609021.70 4268703.20 1817.81 2.73 12.29 1,088.71 14.15 1.25

DAQE-MN161620001-24

M E M O R A N D U M
TO: Christine Bodell NSR Engineer FROM: Jason Krebs, Air Quality Modeler DATE: February 6, 2024 SUBJECT: Modeling Analysis Review for the Notice of Intent for Wesco Operating, LLC – Long Canyon Helium Plant, Grand County, Utah _____________________________________________________________________________________
This is not a Major Prevention of Significant Deterioration (PSD) Source. I. OBJECTIVE
Wesco Operating, Inc. (Applicant) is seeking an approval order for their Long Canyon Helium Plant
located in Grand County, Utah. The helium plant will produce helium-rich gas from the Long
Canyon # 1 well, located approximately 3 miles to the east. Natural gas will be sent via flowline to
the facility and first sent through an amine contactor. The gas will then be processed by a glycol
dehydrator, a membrane skid, and a helium recovery unit (HRU). The extracted helium will be
compressed and held in a trailer-based tank to be hauled off site by trucks for sale. Waste streams
will be controlled through the use of a thermal oxidizer (TO), and the facility will have a maximum
capacity of 12 million standard cubic feet per day (MMscf/day).

This report, prepared by the Staff of the New Source Review Section (NSR), contains a review of
the air quality impact analysis (AQIA) including the information, data, assumptions and modeling
results used to determine if the facility will be in compliance with applicable State and Federal
concentration standards.
II. APPLICABLE RULE(S) Utah Air Quality Rules: R307-401-6 Condition for Issuing an Approval Order R307-410-3 Use of Dispersion Models R307-410-4 Modeling of Criteria Pollutants in Attainment Areas

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

CB

DAQE- MN161620001-24
Page 2
III. MODELING METHODOLOGY A. Applicability Emissions from the facility include PM10, NOx, CO, SO2, and HAPs. This modeling is part of a new approval order. The emission rates for SO2 triggered the requirement to model under R307-410. Modeling was performed by the Applicant.

B. Assumptions

1. Topography/Terrain

The Plant is at an elevation 5969 feet with terrain features that have an affect on
concentration predictions.

a. Zone: 12 b. Approximate Location: UTM (NAD83): 609001 meters East 4268772 meters North 2. Urban or Rural Area Designation After a review of the appropriate 7.5 minute quadrangles, it was concluded the area is “rural” for air modeling purposes. 3. Ambient Air It was determined the Plant boundary used in the AQIA meets the State’s definition of ambient air. 4. Building Downwash The source was modeled with the AERMOD model. All structures at the plant were used in the model to account for their influence on downwash. 5. Meteorology Five (5) years of off-site surface and upper air data were used in the analysis consisting of the following: Surface – Canyon Lands, UT NWS: 2016 - 2020 Upper Air – Salt Lake Airport, UT NWS: 2016 - 2020 6. Background
The background concentrations were based on concentrations measured in Moab, Utah.

DAQE- MN161620001-24
Page 3
7. Receptor and Terrain Elevations
The modeling domain used by the Applicant consisted of receptors including property
boundary receptors. This area of the state contains mountainous terrain and the modeling
domain has simple and complex terrain features in the near and far fields. Therefore,
receptor points representing actual terrain elevations from the area were used in the
analysis. 8. Model and Options The State-accepted AERMOD model was used to predict air pollutant concentrations under a simple/complex terrain/wake effect situation. In quantifying concentrations, the regulatory default option was selected. 9. Air Pollutant Emission Rates
Source
UTM Coordinates Modeled Emission Rates
Easting Northing SO2
(m) (m) (lb/hr) (tons/yr) hrs/year
TO 609022 4268703 21.67 94.90 8760

Total 21.67 94.90
10. Source Location and Parameters
Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
TO POINT 5963.9 12.3 40.3 1089 14.15 1.25
IV. RESULTS AND CONCLUSIONS
A. National Ambient Air Quality Standards
The below table provides a comparison of the predicted total air quality concentrations with the NAAQS. The predicted total concentrations are less than the NAAQS.

DAQE- MN161620001-24
Page 4

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
SO2
1-
Hour 73.2 6 0.4 0.0 73.6 195 37.74%
3- Hour 55.5 25.0 0.9 0.0 56.4 1300 4.34%
JK:jg

Christine Bodell <[e-mail]>
Wesco Long Canyon Helium Plant - NOI Supplement 2
Chase Peterson <[e-mail]>Thu, Mar 14, 2024 at 1:55 PM
To: Christine Bodell <[e-mail]>
Cc: Brian Mensinger <[e-mail]>, Tom Kirkwood <[e-mail]>
Christine,

Thank you for your question. We have confirmed with the TO folks that the minimum operating temperature is 1,400
deg. F. Please let us know if you have any further questions.
[Quoted text hidden]
MODELING REPORT
SO2 1-hour and 3-hour NAAQS

Wesco Operating, Inc. / Long Canyon Helium Plant

Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard, Suite 200
Salt Lake City, UT 84124
[phone]

Prepared For:
Wesco Operating, Inc.
120 S Durbin Street P.O. Box 1650
Casper, WY 82602

November 2023

Project: 224502.0025
Wesco Companies | SO2 Modeling Analyses
Trinity Consultants i
TABLE OF CONTENTS
1. INTRODUCTION 1-1
1.1 General Information ................................................................................................. 1-1
1.2 Project Scope ............................................................................................................ 1-1
1.3 Plant Layout .............................................................................................................. 1-1
2. AIR DISPERSION MODELING DESCRIPTION 2-1
2.1 Model Selection ......................................................................................................... 2-1
2.2 Meteorological Data .................................................................................................. 2-1
2.3 Terrain Elevations ..................................................................................................... 2-1
2.4 Receptors .................................................................................................................. 2-1
2.5 UTM Coordinate System ............................................................................................ 2-4
2.6 Building Downwash .................................................................................................. 2-5
3. SO2 SOURCE PARAMETERS AND EMISSION RATES 3-1
3.1 SO2 Point Source Parameters and Emission Rates..................................................... 3-1
3.1.1 Combustion Equipment Modeling Parameters and Emission Rates ................................ 3-1
3.2 SO2 Volume Source Parameters and Emission Rates ................................................. 3-1
3.3 SO2 Area Source Parameters and Emission Rates...................................................... 3-1
3.4 SO2 Nearby Sources .................................................................................................. 3-1
4. SO2 MODELING ANALYSIS 4-2
4.1 Background SO2 Concentrations ............................................................................... 4-2
4.2 Modeled SO2 Concentration ...................................................................................... 4-2
4.3 1-hour and 3-hour SO2 NAAQS Analysis Results ........................................................ 4-3
APPENDIX A. PLANT MODELING PARAMETERS AND EMISSION RATES A-1

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1. INTRODUCTION
1.1 General Information
Wesco Operating, Inc. (Wesco) is proposing to construct a helium production plant approximately 10 miles
west of Moab, Utah, known as the Long Canyon Helium Plant (the Plant). Wesco has submitted a Notice of
Intent (NOI) air permit application to the Utah Division of Air Quality (UDAQ) to obtain an approval order
(AO) for the Plant. The NOI air permit application consists of two (2) phases, Phase I and Phase II.
Modeling thresholds were surpassed for sulfur dioxide (SO2) in Phase I, resulting in the submittal of this air
dispersion modeling protocol and report. This report is only representative of Phase I; Phase II does not
trigger modeling thresholds due to the implementation of additional control devices not present in Phase I.
See NOI air permit application supplement for details on the two (2) phases.

The proposed Plant is located within an area of Grand County designated as an attainment area of the
National Ambient Air Quality Standards (NAAQS) for all criteria pollutants.

This modeling protocol and report outline the methodology that Wesco has used in conducting air dispersion
modeling. It describes the results that demonstrate compliance with the NAAQS for 1-hour and 3-hour SO2
at the Plant. Dispersion modeling has been conducted in accordance with R307-410-3 and 40 Code of
Federal Regulations (CFR) Part 51, Appendix W Guideline on Air Quality Models.
1.2 Project Scope
Wesco’s Plant will process natural gas from wells. The gas will be processed using a variety of equipment
that separates helium from the natural gas. Waste streams will be controlled through the use of a thermal
oxidizer (TO). The Plant will have a maximum capacity of 4.83 million standard cubic feet per day
(MMscf/day). Product helium will be compressed, loaded into trucks, and trucked off site for sale. Emissions
of SO2 will result from the destruction of H2S through combustion of waste gas at the TO.
1.3 Plant Layout
The general facility layout is shown in Error! Reference source not found., below. Error! Reference
source not found., also below, presents a basic layout of the primary equipment at the Plant. Natural gas
will be produced from a well or wells and sent via flowline to the Plant. That gas will be processed to isolate
and remove helium. This will occur first through an amine contactor. The gas will then be processed by a
glycol dehydrator, a membrane skid, and a helium recovery unit (HRU). The extracted helium will be
compressed and held in a trailer-based tank to be hauled off site by trucks for sale. Waste gases are
controlled throughout the process by a TO. Heat from the TO is recycled through hot oil for use at the Plant.

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Figure 1-1. Plant Site Plan

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Figure 1-2. Process Flow Diagram of the Plant.

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2. AIR DISPERSION MODELING DESCRIPTION
This section describes the air quality dispersion modeling analysis performed to estimate the ambient air
impacts of Wesco’s operation of the Plant. All modeling results were compared to the SO2 NAAQS for the 1-
hour and 3-hour averaging periods. The objective of the NAAQS analysis is to demonstrate through air
quality dispersion modeling that emissions from the Plant do not cause or contribute to an exceedance of 1-
hour and 3-hour SO2 NAAQS. No nearby offsite area sources were required to be included, at the direction
of UDAQ. Dispersion Modeling was conducted in accordance with R307-410-3 and 40 CFR Part 51, Appendix
W Guideline on Air Quality Models.
2.1 Model Selection
Near-field dispersion modeling was performed using the latest version of the AERMOD modeling system,
version 21112, which is an EPA approved, steady-state Gaussian mathematical plume model. AERMOD is
composed of three (3) modular components: AERMAP, the terrain preprocessor that characterizes the
terrain and generates source and receptor elevations and surrounding hill height scales; AERMET, the
meteorological preprocessor that processes raw surface and upper air meteorological observations for use
by AERMOD; and AERMOD, the control module and modeling processor.
2.2 Meteorological Data
Meteorological data used in the dispersion modeling analysis was processed and provided by UDAQ. Data
consists of five (5) individual years (2016 through 2020) of National Weather Service (NWS) surface data
collected at UDAQ’s Canyonlands station in Utah that were then concatenated into a five (5)-year file.
Concurrent upper air observations used in AERMET were obtained from the Salt Lake City Airport.
2.3 Terrain Elevations
Terrain elevations for the Plant’s sources, receptors and buildings were determined using National Elevation
Dataset (NED), the primary elevation data product of the United States Geologic Survey (USGS).1 NED data
are distributed in geographic coordinates in units of decimal degrees, and in conformance with the North
American Datum of 1983 (NAD 83). The NED used for this analysis is at a resolution of 1/3 arc-second
(about 10 meter) grid spacing. Elevations were converted from the NED grid spacing to the air dispersion
model receptor spacing using the AERMOD preprocessor, AERMAP version 18081. All data obtained from the
NED files was checked for completeness and spot-checked for accuracy.
2.4 Receptors
A modeling domain was developed for the near-field analysis to encompass the location of the maximum
modeled concentration from Wesco’s sources. Discrete receptor locations in AERMOD were based on UTM
coordinates in the NAD83 datum, Zone 12S. An initial modeling grid extending a minimum of 10.0
kilometers from the Plant’s center was established. The receptor grid was developed to ensure that
maximum pollutant concentrations were captured by the model. The facility boundary is based on the
proposed Plant fenceline.

1 NED data obtained at https://viewer.nationalmap.gov/basic/#/ downloaded December 23, 2020.

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The model receptors consisted of boundary receptors and gridded receptors with the following spacing:

► The ambient air boundary was placed at the facility property line and consists of discrete receptors
placed at 25-meter intervals.
► The fine grid contains 50-meter spaced receptors extending to at least 300 meters from the center of
the facility.
► The medium grid contains 100-meter spaced receptors extending to at least 2,100 meters from the
center of the facility.
► The coarse grid contains 1,000-meter spaced receptors extending to 10 kilometers from the center of
the facility.

Figure 2-1 and Figure 2-2 below show the ambient air boundary receptors (shown in purple below) and
gridded off-site receptors (yellow).

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Figure 2-1. Boundary Receptors.

Legend
___ Boundary Location

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Trinity Consultants 2-4
Figure 2-2. Fine, Medium, and Coarse Grid Receptors

2.5 UTM Coordinate System
In all modeling analyses, input and output data files, the locations of emission sources, structures, and
receptors were represented in the Universal Transverse Mercator (UTM) coordinate system and based on
NAD83. In this grid, the world is divided into 60 north-south zones, each covering a strip 6° wide in
longitude. The general area of the site is located in UTM Zone 12S. In each UTM zone, coordinates are
measured north and east in meters. The northing values are measured continuously from zero at the
Legend
+ Receptor

Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 2-5
equator, in a northerly direction. A central meridian through the middle of each 6° zone is assigned an
easting value of 500,000 meters. Grid values to the east of this central meridian, as in the case of the site,
are greater than 500,000 meters.
2.6 Building Downwash
Emission sources were evaluated in terms of their proximity to nearby structures. No structures were
included for the Building Profile Input Program (BPIP), which predicts the effects of building downwash, as
no major structures are present.

Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 3-1
3. SO2 SOURCE PARAMETERS AND EMISSION RATES
3.1 SO2 Point Source Parameters and Emission Rates
The SO2 point sources at the Plant consist of one (1) TO. Point sources require release height, stack
temperature, stack velocity, and stack diameter. All inputs for stack source parameters can be found in
Appendix A of this modeling analysis.
3.1.1 Combustion Equipment Modeling Parameters and Emission Rates
The modeled point sources of combustion at the Plant consist of the following equipment and their release
parameters. Stack information was provided by Wesco.
Table 3-1. Release Parameters for SO2 Point Sources
Unit
Stack
Height
(m)
Stack
Temp.
(K)
Stack
Velocity
(m/s)
Stack
Diameter
(m)
TO 12.29 1,088.71 14.15 1.25

The Plant’s emissions calculations and modeling analysis were conducted based on the combustion of 4.83
MMscf/day of waste gas in the TO, and a maximum of 0.0035 MMscf/hr of fuel gas during startup and
shutdown activities. A maximum heat input of 51.44 MMBtu/hr is given for the TO system (TO and TO
burner) by the vendor.

Modeling parameters for all point sources and emission rates can be found in Appendix A, Table A-1.

3.2 SO2 Volume Source Parameters and Emission Rates
No volume sources at the Plant emit SO2. Thus, none were included in the modeling.
3.3 SO2 Area Source Parameters and Emission Rates
No area sources are present at the Plant. Thus, none were included in the modeling.
3.4 SO2 Nearby Sources
No nearby sources were required by UDAQ to be included as part of this air dispersion model.

Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants 4-2
4. SO2 MODELING ANALYSIS
The modeling analysis predicts ambient concentrations of SO2 due to emissions from the Plant and
surrounding sources. The modeling output includes tabulated modeling results as compared to the SO2 1-
hour and 3-hour NAAQS.
4.1 Background SO2 Concentrations
Background concentrations for SO2 for this modeling analysis were given by UDAQ from their Moab
monitoring station. The background data consists of monthly tabulated maximums of 1-hour and 3-hour SO 2
for the years 2001-2003. The value used in the modeling analysis is the highest first high (H1H) monthly 1-
hour or 3-hour value, except for the highest annual background value of each year. This approach has been
directed by UDAQ in accordance with the form of the 1-hour and 3-hour SO2 NAAQS standard.2,3 The
background concentrations used for the modeling are presented in Table 5-1 below.
Table 4-1. UDAQ-Provided 1-hour and 3-hour SO2 Background Concentrations (µg/m3)
Year 2018 2019 Monthly Average Month Max Max
1 - 0.9 0.9
2 - 1.2 1.2
3 - 0.8 0.8
4 0.3 - 0.3
5 0.3 - 0.3
6 0.5 - 0.5
7 0.4 - 0.4
8 0.4 - 0.4
9 0.3 - 0.3
10 0.4 - 0.4
11 0.5 - 0.5
12 0.5 - 0.5
3-hour H2H 0.4 0.6 0.6
1-hour 99% 0.6 1.2 1.2
4.2 Modeled SO2 Concentration
The resulting concentration of SO2 from this air dispersion modeling analysis was compared against the 1-
hour and 3-hour SO2 NAAQS to demonstrate that emissions from the Plant do not cause or contribute to an
exceedance of the 1-hour and 3-hour SO2 NAAQS. The primary NAAQS is the maximum concentration
ceiling, measured in terms of total concentration of a pollutant in the atmosphere, which define the “level of
air quality which the United States Environmental Protection Agency (U.S. EPA) judges are necessary, with

2 NAAQS standard for 1-hour SO2 given as, “3 year average of the 99th percentile of the annual distribution of daily maximum
1-hour concentrations.”
3 NAAQS standard for 2-hour SO2 given as, “Not to be exceeded more than once per calendar year.”

Wesco Operating, Inc. | SO2 Modeling Analysis
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an adequate margin of safety, to protect the public health.”4 The 1-hour SO2 NAAQS requires the 3-year
average of the 99th percentile of the annual distribution of daily, maximum, 1-hour concentrations
compared to the standard. The 3-hour SO2 NAAQS requires the maximum individual year's high-second-high
from a 5-year meteorological data set be compared to the standard. The modeled concentration was added
to the monthly background concentrations for comparison to the NAAQS. This calculation was completed
within the AERMOD modeling system.
4.3 1-hour and 3-hour SO2 NAAQS Analysis Results
A NAAQS analysis considers the impact from all sources at the Plant and background concentrations to yield
a total concentration which is then compared to the NAAQS which, for 1-hour and 3-hour SO2, are 196
µg/m3 and 1,300 µg/m3, respectively. Table 5-2 presents the model-predicted concentrations from the Plant
plus background concentration, and 1-hour and 3-hour SO2 NAAQS comparison.
Table 4-2. SO2 1-hour and 3-hour NAAQS Compliance Demonstration

Operating
Scenario Pollutant Averaging
Period
Model-Predicted
Concentration
Including
Background
Modeling
Standard
NAAQS
Percent
of
NAAQS
(µg/m3) (µg/m3) (%)
Complete
Operations SO2 1-hour 184.46 H4H 196 94.11%
Complete
Operations SO2 3-hour 150.43 H2H 1,300 11.57%

In addition to this report, Wesco is providing the AERMOD Input and Output files for UDAQ’s review in a
separate submittal.

4 40 CFR 50.2(b).

Wesco Operating, Inc. | SO2 Modeling Analysis
Trinity Consultants A-1
APPENDIX A. PLANT MODELING PARAMETERS AND EMISSION RATES
Table A-1. SO2 Point Source Input Parameters
ID Description X Coordinate
(m)
Y Coordinate
(m)
Elevation
(m)
Emission
Rate
(g/s)
Stack
Height
(m)
Stack
Temp.
(K)
Stack
Velocity
(m/s)
Stack
Diameter
(m)
TO Thermal
Oxidizer 609048.33 4268789.57 1817.81 7.048 12.29 699.82 14.15 1.25

Christine Bodell <[e-mail]>
UTAH DIVISION OF AIR QUALITY - Wesco Operating, Inc.'s NOI for the Long Canyon Helium
Plant
8 messages
Christine Bodell <[e-mail]>Wed, Jul 19, 2023 at 10:44 AM
To: Chase Peterson <[e-mail]>, [e-mail]
Good Morning,
I am currently conducting my preliminary review of Wesco Operating, Inc.'s NOI for the Long Canyon Helium Plant, located
approximately 10 miles from Moab, Utah.
The NOI mentions that this helium plant will be located on the existing pad for the Cane Creek Unit 7-1/7-2 production wells. Based on
the CAERs profile, the pad has tanks, engines and a thermal combustor on site.
Facilities are to be considered the same stationary source if:
1. They share the same industrial grouping (SIC code), or one facility is a "support facility to the other"
2. They are contiguous or adjacent
3. They are under Common Control.
It appears that this criteria is satisfied for Wesco's well pad and the proposed adjacent helium plant. Therefore, these facilities need to
be permitted as a single source. The NOI needs to be modified or redone to consolidate the sites to account for all the air-emitting
equipment.
Please let me know if you have any questions or concerns.
Thank you,
Christine
--
Christine Bodell
Environmental Engineer
Email | [e-mail]
Phone| [phone]
Emails to and from this email address may be considered public records and
thus subject to Utah GRAMA requirements
Chase Peterson <[e-mail]>Wed, Jul 26, 2023 at 5:54 PM
To: Christine Bodell <[e-mail]>
Christine,

Just letting you know that we are working on a response to your email. We will get it back to you as soon as we can. The timeline
is uncertain, as there are several parties involved, but we appreciate your patience in the meantime.

Thanks very much,

Chase Peterson
Consultant
Trinity Consultants, Inc.

P 801-971-8291
4525 Wasatch Blvd, Suite 200,
Salt Lake City, Utah 84124
Email: [e-mail]
[Quoted text hidden]
CAUTION: This email originated from outside of the Trinity Consultants organization. Do not click links or open attachments unless
you recognize the sender's name, sender's email address and know the content is safe.

Christine Bodell <[e-mail]>Wed, Jul 26, 2023 at 8:24 PM
To: Chase Peterson <[e-mail]>
Hello Chase,
I appreciate the response. Thank you for the update.
Best,
Christine
[Quoted text hidden]
Chase Peterson <[e-mail]>Tue, Aug 1, 2023 at 4:55 PM
To: Christine Bodell <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Brian Mensinger <[e-mail]>
Christine,

Would you be available for a call between the four of us this Friday, August 4, at 9:00 am?

Thanks very much,

Chase Peterson
Consultant
Trinity Consultants, Inc.

P 801-971-8291
4525 Wasatch Blvd, Suite 200,
Salt Lake City, Utah 84124
Email: [e-mail]

From: Christine Bodell <[e-mail]>
Sent: Wednesday, July 19, 2023 10:45
To: Chase Peterson <[e-mail]>; [e-mail]
[Quoted text hidden]
[Quoted text hidden]
CAUTION: This email originated from outside of the Trinity Consultants organization. Do not click links or open attachments unless
you recognize the sender's name, sender's email address and know the content is safe.

Christine Bodell <[e-mail]>Tue, Aug 1, 2023 at 5:21 PM
To: Chase Peterson <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Brian Mensinger <[e-mail]>
Hello Chase,
I only have availability from 9-9:30 am on Friday. Will 30 minutes be adequate? If so, I would be happy to send a meeting invite.
Best,
Christine
[Quoted text hidden]
Chase Peterson <[e-mail]>Tue, Aug 1, 2023 at 5:24 PM
To: Christine Bodell <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, Brian Mensinger <[e-mail]>
Christine,

That should be enough time. If not, we can continue the meeting next week. Thank you for being accommodating.

Thanks,
[Quoted text hidden]
Tom Kirkwood <[e-mail]>Mon, Aug 7, 2023 at 9:55 AM
To: Chase Peterson <[e-mail]>, Christine Bodell <[e-mail]>
Cc: Brian Mensinger <[e-mail]>
Christine,

Sorry I didn’t get this out on Friday. Please let me know if you have any questions.

Wesco (Kirkwood Oil and Gas) owns and operates the Cane Creek 7-2R2 well which is located on the CCU 7-2 pad and is currently
regulated under Permitted-by-Rule. The 7-2R2 is an oil well producing out of the Cane Creek Formation.

Wesco (Kirkwood Oil and Gas) also owns and operates the Long Canyon # 1 well. The well is ~ 3 miles to the east of the CCU 7-2R2
well pad. Wesco intends to permit and construct a Helium Recovery Plant (Long Canyon plant) on the CCU 7-2R2 well pad to process
gas from the Long Canyon # 1 well. The gas produced from the Long Canyon is very low BTU and helium rich. The Long Canyon
plant will not be use in the process associated to the Cane Creek Unit 7-2R2 well, nor will the Cane Creek Unit 7-2R2 processes be
associated with the Long Canyon plant’s processes. This pad was selected for the Long Canyon plant due to proximity to Rocky
Mountain Power Poles which will be required to power the Long Canyon plant’s equipment.

Although the Cane Creek 7-2R2 and Long Canyon plant are both under Kirkwood’s control, they do not support one another, nor do
they share equipment (except an electrical power source). Whereas the Cane Creek 7-2R2 well pad is under an SIC code for oil, the
Long Canyon plant is under another SIC code entirely (2813), for industrial gases. Due to their separate function, operation, and
production, they are proposed to be permitted separately; Cane Creek 7-2R2 under CAERS, and the Long Canyon plant under NSR.

Please let me know if you have any questions.

Thanks

Tom

Thomas C. Kirkwood
Wesco Operating, Inc / Kirkwood Oil and Gas LLC
Engineer
307-577-5328
[Quoted text hidden]
This email and any attached files are confidential and intended solely for the intended recipient(s). If you are not the named recipient
you should not read, distribute, copy or alter this email. Any views or opinions expressed in this email are those of the author and do
not represent those of Kirkwood Companies. Warning: Although precautions have been taken to make sure no viruses are present in
this email, Kirkwood Companies cannot accept responsibility for any loss or damage that arise from the use of this email or
attachments.
Christine Bodell <[e-mail]>Tue, Aug 8, 2023 at 9:12 AM
To: Tom Kirkwood <[e-mail]>
Cc: Chase Peterson <[e-mail]>, Brian Mensinger <[e-mail]>
Hello Tom,
Thank you for taking the time to explain this. The DAQ will permit the Long Canyon Helium Plant separately from the CCU 7-2R2 well
pad and Long Canyon # 1 well.
Best,
Christine
[Quoted text hidden]
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 1
NOI SUPPLEMENT – WESCO OPERATING, INC.
To: Christine Bodell, Utah Division of Air Quality
Source: Wesco Operating, Inc., Long Canyon Helium Plant
NOI Submittal Date: July 12, 2023
NOI Supplement Date: November 16, 2023
Date of NOI Supplement: December 28, 2023
From: Tom Kirkwood, Wesco Operating, Inc.
Subject: Notice of Intent Air Permit Application Supplement, Update to Emissions
Wesco Operating, Inc.’s Long Canyon Helium Plant
Introduction
Wesco Operating, Inc. (Wesco) submitted a Notice of Intent (NOI) air permit application to the Utah
Division of Air Quality (UDAQ) on July 12, 2023, for its Long Canyon Helium Plant (the Plant). The potential
to emit (PTE) calculations for the Plant were developed based on process data provided by the engineering
firm working on the Plant. This data was rounded to two (2) decimal points, which led to rounding
errors. Following additional investigation into the Thermal Oxidizer (TO), it was discovered that the Acid Gas
Stream from the Amine Plant was not included in the available calculations. The mass balance calculations
were updated for additional precision, and the Acid Gas Stream was included in the PTE values for criteria
pollutants and Hazardous Air Pollutants (HAPs). The updated PTE values triggered air dispersion modeling
for sulfur dioxide (SO2).
These updates were represented in an NOI Supplement that was submitted to the UDAQ on November 16,
2023. That document proposed to permit the Plant in two (2) phases. Phase I would have limited the Plant’s
throughput to 4.83 million standard cubic feet per day (MMscf/day). Phase II would have been
representative of the Plant’s potential 12 MMscf/day. After meeting with the UDAQ on November 21, 2023,
the phased approach was abandoned to ensure that BACT is met from the outset of the project. This NOI
Supplement represents the Plant’s operations as they are intended to be permitted. In the event of further
changes, a new NOI air permit application will be submitted for modification. Air dispersion modeling for SO2
is triggered by this project and will be submitted under a separate proposal.
This NOI Supplement provides the most up-to-date PTE and the resulting emissions profile of the Plant.
Furthermore, it outlines each section of the NOI air permit application that has been affected by the
updates, including the following sections.
►Section 1. Executive Summary;
►Section 2. General Information;
►Section 4. Emissions Related Information;
►Section 6. Emissions Impact Analysis;
►Appendix A: Form 3; and
►Appendix B: Emissions Calculations.
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 3
NOI LANGUAGE REVISIONS
Wesco would like to request updates and/or revisions to the following language contained in the
following subsections of the NOI air permit application that was previously submitted for the Long
Canyon Helium Plant on June 12, 2023.
1.EXECUTIVE SUMMARY
►Please redact the strikethrough text, below, with the language that follows immediately thereafter.
The Plant will process natural gas from wells. The gas will be processed using a variety of equipment that
separates helium from the natural gas. Waste streams will be controlled through the use of a thermal
oxidizer (TO). The Plant will have a maximum capacity of 12 million standard cubic feet per day
(MMscf/day). Product helium will be compressed, loaded into trucks, and trucked off site for sale. Emissions
of criteria pollutants will result from the combustion of gases at the TO and fugitive releases anticipated
through the equipment (e.g., valves, flanges, seals, connections, etc.).
Criteria pollutants that will be included under this project are: particulate matter (PM) with an aerodynamic
diameter of 10 microns or less (PM10), PM with an aerodynamic diameter of 2.5 microns (PM2.5), oxides of
nitrogen (NOX), carbon monoxide (CO), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
Hazardous air pollutants (HAPs) and greenhouse gases (GHGs) will also be emitted; the latter is represented
as carbon dioxide equivalent (CO2e). The increase in potential-to-emit (PTE) emissions will be as follows:
PM10 = 16.65 (tpy); PM2.5 = 16.64 (tpy); NOX = 26.23 (tpy); CO = 15.97 (tpy); SO2 = 0.00 (tpy); VOCs =
0.48 (tpy); HAPs = 4.24 (tpy); and CO2e = 44,534 (tpy). The PTE represents an operating schedule of
8,760 hours per year.
The Plant will process natural gas from multiple wells. The potential throughput of processed gas will be
4.83 MMscf/day. The gas will be processed using a variety of equipment that separates helium from the
natural gas. The waste stream will be controlled through the use of a thermal oxidizer (TO). Produced
helium will be compressed, loaded into trucks, and trucked off site for sale. Emissions of criteria pollutants
will result from the combustion of gases at the TO, from fugitive releases anticipated from the equipment
(e.g., valves, flanges, seals, connections, vents, etc.), and from road emissions from haul trucks that take
product off site. The project is proposed to mitigate SO2 through the implementation of an iron sponge
system, which removes H2S from the waste stream prior to its combustion in the TO.
Criteria pollutants that will be included under this project are: particulate matter (PM) with an aerodynamic
diameter of 10 microns or less (PM10), PM with an aerodynamic diameter of 2.5 microns (PM2.5), oxides of
nitrogen (NOX), carbon monoxide (CO), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
Hazardous air pollutants (HAPs) and greenhouse gases (GHGs) will also be emitted; the latter is represented
as carbon dioxide equivalent (CO2e). The potential-to-emit (PTE) is based on a potential throughput of 4.83
MMscf/day through the TO; it will be as follows, given in tpy: PM10 = 1.68; PM2.5 = 1.68; NOX = 15.55; CO
= 9.46; SO2 = 94.90; VOCs = 17.90; HAPs = 3.82; and CO2e = 26,390.
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 4
2.GENERAL INFORMATION
►No changes are required in this section of the NOI air permit application.
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 5
3. DESCRIPTION OF PROJECT AND PROCESS
►Please add the figure and text, below, to the end of the corresponding section.
The Plant is proposed to process gas resulting from one (1) existing well, with a potential gas throughput of
4.83 MMscf/day. A TO will be used to control VOCs, H2S, and HAPs, and an iron sponge system will be used
to control H2S prior to its combustion in the TO. This will mitigate the emissions of SO2 resulting from the
TO. The iron sponge system will result in a media waste that will be hauled off site for processing and
disposal. Figure 3-2 shows the setup of major equipment at the Plant.
Figure 3-2. Process Box Flow Diagram
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 6
4. EMISSIONS RELATED INFORMATION
►Please add the following text, below, which accounts for the calculation of emissions of SO 2.
TO SO2 Emissions Calculations
The Thermal oxidizer’s (TO’s) SO2 emissions were based on proposed estimated H2S exhaust composition
data provided by manufacturer in April 2023 and adjusted for the difference in molecular weight. It was
assumed that all H2S is combusted in the TO to form SO2. The BACT analysis in this NOI Supplement
proposes the installation of a single-vessel iron sponge H2S control system. A single-vessel system is not
large enough to control all of the H2S at the Plant. It is estimated that it could capture 61.33% of the H2S
resulting from 4.83 MMscf/day of waste gas. Of the captured material, it is estimated to control 99.9% of it.
The remaining 0.1% is returned to the TO and combusted. This results in the following equation:
Potential Annual SOଶ Emissions [tpy]
= ൫Hଶ S Flow Rate [tpy]−(Hଶ S Flow Rate [tpy]× Iron Sponge Capture Efficiency
[%])
+ Hଶ S Flow Rate [tpy]× Iron Sponge Capture Efficiency
[%]
× (1 − Iron Sponge Hଶ S Control Efficiency [%])൯ × ቌ
SOଶ Molecular Weightቂ lb
lbmolቃ
Hଶ S Molecular Weight ቂ lb
lbmolቃ
ቍ
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 7
5. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS
►Please use the following to replace Section 5 of the November 16, 2023, NOI Supplement, as additional
information has been acquired since that time. Notably, activated carbon has been deemed technically
infeasible, while economic feasibility analyses have been performed for the liquid redox and iron sponge
systems.
5.5 H2S and SO2 BACT
The TO inlet stream contains not insignificant amounts of hydrogen sulfide (H2S), of which 100 percent is
converted to SO2 in the thermal oxidizer, per manufacturer specifications. A potential daily throughput of
4.83 MMscf/day through the TO results in an uncontrolled PTE of 245 tpy of SO2. This BACT review
addresses technologies that could reduce H2S in the inlet stream and therefore reduce SO2 emissions
resulting from the TO.
Step 1 – Identify All Available Control Technologies
The first step in the BACT analysis is to identify all available control technologies. Control technologies
identified in this review are as follows:
►Wet Scrubber - Caustic Scrubber
►Fixed-bed Activated Carbon
►Iron Sponge Media
►Liquid Redox
►Biological Methods
►Internal Combustion Engine
►Thermal Oxidation
Step 2 – Eliminate Technically Infeasible Options
Wet Scrubber - Caustic Scrubber
A caustic scrubber is a device in which gas flows countercurrent to a solution of sodium hydroxide (caustic)
and water. H2S is highly soluble in water, which results in an acidic solution when dissolved. The dissolved
H2S readily reacts with the caustic solution to form sodium sulfide (Na2S) and sodium bisulfide (NaSH),
which precipitate out of the solution. Caustic scrubbers are most often applied in situations where small
volumes of H2S need to be removed, typically referred to as “scavenging” when combined with other control
technologies.1 This system is generally used for systems with a sulfur production capacity between 0.1 ton
per day and 10 tons per day and may achieve 70-99 percent control, depending on the equipment
configuration and design.2,3 It is estimated that the sulfur production capacity of the site is on the low end
of the technical capacity limits for this type of system (0.36 ton/day on average).
The presence or absence of significant CO2 is also an important consideration with caustic scrubbers.
Caustic scrubbing of gases containing high CO2 levels is particularly problematic because the CO2 can also
react with the caustic, causing unwanted caustic consumption and the possibility of precipitation of sodium
1 Caustic Scrubber Designs for H2S Removal from Refinery Gas Streams, Presented at the 2014 AFPM Annual Meeting AM-14-
48, March 2014
2 Ibid.
3 EPA Air Pollution Control Technology Fact Sheet, Packed Bed/Packed Tower Wet Scrubber; EPA-452/F-03-015.
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 8
carbonate solids.4 Additionally, CO2 absorption causes unnecessary caustic usage and contamination of the
sodium hydrosulfite product solution with carbonate salts, which can lead to plugging and fouling of
process equipment.5 The TO inlet stream contains approximately 14.91 weight percent CO2. The ratio of
CO2 to H2S in the TO inlet stream is approximately 6:1.
Some caustic scrubbing systems can be designed to handle high levels of CO2 by utilizing the fact that CO2
reacts significantly slower than H2S.6 These systems are designed to use down-flow static mixers to limit the
contact time of the caustic and tail gas and therefore selectively react with H2S.7 According to a
manufacturer, this scrubber design should be considered if the gas stream can meet the following
specifications:
►H2S to scrub is less than about 10-20 ton per day;
►CO2 is present and does not need to be scrubbed to meet CO2 specifications;
►CO2 to H2S ratio is significant but not too high (ratio should be less than 5:1);
►Product NaSH solution has a potential market, and volume of NaSH to be generated is high enough to
merit the added effort of dealing with this product stream; and
►The total sulfur to be removed is on the lower end of the aforementioned range and a NaSH solution
disposal route has been identified.8
The system at the Plant does not meet all of the recommended specifications. Most significantly, the CO2 to
H2S ratio is too high.
While the sodium hydrosulfite solution resulting from caustic scrubbing has uses in paper, mining, tanning,
and other industries, the value of this product can vary locally and will also vary as a function of its strength
and purity.9 Due to the high concentration of CO2 present in the waste gas at the Plant, it is anticipated that
all caustic salts would need to be treated as a solid waste.
In addition to the CO2 content, a reliable supply of water and processing of liquid effluent need to be
considered with caustic scrubbing. Managing water with a caustic scrubber involves many operational
difficulties, including complicated flow streams associated with the preparation of solution properties, as well
as higher energy demands for pumps and blowers. The addition of water into the solution is required for
absorption and cooling since neutralization of H2S is exothermic. Cooling is required to maintain a
reasonable temperature resulting from the reaction. Consequently, water is necessary for both keeping the
packing wetted or trays filled to achieve gas-liquid contact and provide thermal mass to absorb the reaction
heat.10 Additionally, the resultant liquid effluent is required to be treated, creating a solid waste stream
which would be landfilled, as well as water discharge, which would require National Pollutant Discharge
Elimination System (NPDES) permitting.
4 Caustic Scrubber Designs for H2S Removal from Refinery Gas Streams, Presented at the 2014 AFPM Annual Meeting AM-14-
48, March 2014
5 American Fuel and Petrochemical Manufacturers Paper AM-14-48, differs from power plants, cement, and lime as they use
CaCO3 caustic
6 Use of Caustic in a Short Time Approach to Selectively Scrub H2S from CO2 Contaminated Gas Stream, by Trimeric
Corporation
7 Use of Caustic in a Short Time Approach to Selectively Scrub H2S from CO2 Contaminated Gas Stream, by Trimeric
Corporation
8 Use of Caustic in a Short Time Approach to Selectively Scrub H2S from CO2 Contaminated Gas Stream, by Trimeric
Corporation
9 American Fuel and Petrochemical Manufacturers Paper AM-14-48
10 Hydrogen Sulfide Mitigation Strategy for a Class I Landfill, Massachusetts Institute of Technology (MIT), July 15, 2015
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 9
Given the high CO2 content, high use of water, installation of water treatment, and generation of significant
amounts of waste, caustic scrubbing is not technically feasible.
Fixed-bed Activated Carbon
Carbon adsorption utilizes a column or filter of activated carbon to adsorb targeted pollutants as pollution-
laden gas flows through them. In adsorption (as opposed to absorption, e.g., a wet scrubber) the pollutant
molecules are attracted to the carbon by a physical, rather than a chemical, process. H 2S from gaseous
streams can be adsorbed onto the surface of the activated carbon. The activated carbon is porous and
allows for a large absorptive capacity. Activated carbon is sensitive to humidity and temperature as water
can block the adsorption sites.11 Additionally, when activated carbon cannot be regenerated and the
activated carbon is spent, it must be replaced. The spent carbon is usually sent to a treatment facility,
where it is heated to high temperatures to destroy or remove contaminants.12 Fixed-bed activated carbon
systems can achieve H2S control efficiencies of 98-99 percent.13
Wesco requested an evaluation from a vendor for a determination of the technical feasibility of controlling
H2S at the Plant with an activated carbon system. The vendor stated that “carbon is not a viable option for
this application due to the [high] H2S concentration and moisture content.” In their experience, H2S
concentrations of greater than 10 ppm are not feasibly controlled by carbon adsorption systems.
The vendor also stated that the life of the activated carbon media would be significantly reduced due to
water-clogged pores and/or the adsorption of other compounds present in the waste gas stream. This low
life expectancy of the adsorption media would lead to frequent media change outs and could result in
“considerable carbon ‘dusting’” at the Plant, according to the vendor. The vendor estimated that the system
would require at least three (3) vessels to be installed at the Plant, leading to inordinate operating,
maintenance, and waste removal activity and costs. As a point of information, these factors lead to an
estimated annual media and disposal cost of more than $17,000,000 per year.
Due to the high H2S loading, the presence of other pollutants within the waste gas stream, the clogging of
the activated carbon due to high humidity, the frequency of media change out, the volume of solid waste
generated, and the likelihood for carbon dusting at the Plant, this control method is technically infeasible.
Iron Sponge Media
Iron has the ability to readily donate electrons to a reaction, making it an excellent reducing agent or
catalyst for other sulfur reactions. H2S has the potential to react with iron hydroxides or oxides to form iron
sulfide.14 Iron sponge media consist of iron hydroxides or oxides that are impregnated on support media
such as steel wool, wood-chips, or oxide pellets, which allow for the treatment of H2S in the gaseous
phase.15 The vessels containing the impregnated support media are referred to as iron sponges. Iron
sponges have H2S control efficiencies of up to 99 percent, per manufacturer estimate.16
In a single-vessel iron sponge configuration, the vessel must be taken out of service and the media replaced
when the iron media is spent. This causes either an interruption in production or uncontrolled emissions.17
Installing parallel sulfur treatment vessels would be required to avoid interruptions in production. The use of
11 Technologies for Controlling H2S, By Christopher Ristevski and Rosanna Kronfli, MacroTek, June 1, 2019
12 Community Guide to Granular Activated Carbon Treatment, EPA, 2021
13 CarbonPure Adsoprtion Systems, Air Emission Control Systems and Service, APC Technologies Inc.
14 Technologies for Controlling H2S, By Christopher Ristevski and Rosanna Kronfli, MacroTek, June 1, 2019
15 Iron Sponge, Connelly Products, GPM Products
16 Small Capacity Sulfur Recovery Units, Merichem Company
17 Iron Sponge, Connelly Products, GPM Products
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 10
an iron sponge in either a single- or multi-vessel configuration is technically feasible and is evaluated further
in Step 4.
Liquid Redox
The liquid redox process employs aqueous-based solutions containing metal ions, usually iron, which are
capable of transferring electrons in reduction-oxidation (redox) reactions.18 Companies that offer this
technology use a proprietary liquid redox catalyst that converts H2S to solid elemental sulfur by carrying out
the direct oxidation of H2S as follows:
Hଶ S +
1
2 Oଶ → HଶO + S
Iron serves two (2) purposes in the process chemistry. First, it serves as an electron donor and acceptor, or
in other words, a reagent. Second, it serves as a catalyst in accelerating the overall reaction.19 Because of
this dual purpose, the iron is often called a “catalytic reagent”. The chelating agents are organic compounds
that wrap around the iron in a claw-like fashion, preventing the iron ions from forming precipitates.20
The liquid redox process operates at ambient temperature; consequently, the sulfur is produced as a solid
that is most often removed in the form of a filter cake that is 65 percent sulfur, 35 percent water.21 This
sulfur product can be used as fertilizer product, acting as a soil amendment and plant nutrient.22
Liquid redox systems can have a control efficiency of up to 99 percent, per manufacturer estimate. This
technology is technically feasible for the Plant and is evaluated further in Step 4.
Biological Methods
There are a variety of biological agents that process H2S and reduce the potential for air emissions. These
agents have been implemented as a method for reducing the sulfur content of the tail gas prior to its
combustion with control efficiencies of up to 99 percent.23 All biological methods use bacteria to process the
sulfur content. 24 In these methods, bacteria must come in contact with the sulfur which could only be done
at the Plant using biological filters or bioreactors.25 Biological filters require relatively low concentrations
(1,000-15,000 ppm) of sulfur whereas bioreactors are designed for higher sulfur concentrations (2,000-
35,000 ppm).26 Bioreactors us caustic chemicals as well, but require less caustic than conventional caustic
scrubbers due to the biological sulfide oxidation reaction of the bacteria. 27
Due to the high concentration of sulfur in the TO inlet stream (26,900 ppm) biological filters are technically
infeasible. Bioreactors use caustic chemicals in combination with bacteria to remove sulfur. As described
previously, using caustic chemicals is infeasible due to the high CO 2 content, high use of water, and
installation of water treatment. As such, bioreactors are technically infeasible.
18 Small Capacity Sulfur Recovery Units, Merichem Company
19 LO-CAT: A Flexible Hydrogen Sulfide Removal Process, Merichem Company
20 LO-CAT: A Flexible Hydrogen Sulfide Removal Process, Merichem Company
21 LO-CAT: A Flexible Hydrogen Sulfide Removal Process, Merichem Company
22 Small Capacity Sulfur Recovery Units, Merichem Company
23 Meat & Livestock Australia Limited Review of Biogas Cleaning, Anthony Allan, June 2012
24 Meat & Livestock Australia Limited Review of Biogas Cleaning, Anthony Allan, June 2012
25 Meat & Livestock Australia Limited Review of Biogas Cleaning, Anthony Allan, June 2012
26 Meat & Livestock Australia Limited Review of Biogas Cleaning, Anthony Allan, June 2012
27 Meat & Livestock Australia Limited Review of Biogas Cleaning, Anthony Allan, June 2012
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 11
Internal Combustion Engine
Generators can be used to burn gas to produce electricity for sale to the local utility, another utility, or for
internal use. The TO inlet stream has a small heating value which is too low to efficiently operate an internal
combustion engine. Additionally, the Plant’s electricity is supplied by line power. Therefore, the use of an
engine is technically infeasible.
Thermal Oxidation
The TO inlet stream contains unwanted byproducts, including H2S. This pollutant must be treated prior to
entering the environment due to documented adverse health effects. The proposed TO is expected to
achieve 100 percent control of H2S emissions, per manufacturer specifications.28 The use of a TO is
technically feasible.
Steps 3 – Rank Remaining Control Technologies by Control Effectiveness
Table 5-3. H2S Control Technologies and Efficiencies
Control Method Control Efficiency (%)
Thermal Oxidation 100
Liquid Redox 99
Iron Sponge 99
Step 4 – Evaluate Most-Effective Controls
Economic Feasibility Analysis of Iron Sponge
Wesco conducted an economic feasibility analysis for both a multi-vessel iron sponge system that controls
all 4.8 MMscf/day of the waste stream as well as a single-vessel iron sponge system that controls a portion
of the waste stream. The former analysis resulted in a value of $15,142 per ton of SO2 removed, while the
second analysis resulted in a value of $14,696 per ton of SO2 removed. The difference is primarily due to
the additional costs necessary for redundant vessels and additional maintenance, chemical replacement,
and waste disposal in the multi-vessel system. The multi-vessel system is also capable of controlling more
SO2 than the single-vessel system; 244.76 tpy compared to 150 tpy, respectively. At these rates, using a
single-vessel system to control a portion of the waste gas stream results in cost savings of over $1.63MM
per year. A multi-vessel system is economically infeasible, while a single-vessel system is economically
feasible.
Economic Feasibility Analysis of Liquid Redox
Wesco conducted an economic feasibility analysis for a liquid redox system that controls all 4.8 MMscf/day
of the waste stream. It resulted in a value of $21,411 per ton of SO2 removed. This is economically
infeasible.
Step 5 – Select BACT
The remaining, feasible control technologies for emissions of SO2 at the Long Canyon Helium Plant are a
single-vessel iron sponge H2S removal system and a TO H2S destruction system. Both will be implemented
as BACT.
28 Bioreactors for treatment of VOC and Odors – A review, published by the Journal of Environmental Management, available
online February 2010
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 12
6.EMISSION IMPACT ANALYSIS
►Please redact the strikethrough text, below, with the language that follows immediately thereafter.
Comparison to Modeling Thresholds
As noted in the emission calculations and described below, the proposed site-wide emission changes are
less than the UDAQ modeling thresholds contained in UAC R307-410-4. As a result, no criteria pollutant
modeling analysis is required.
Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained
in R307-403-4 through 7, and R307-410-4.
Table 6-1. Projected Emissions Summary of the Project
Emission
Source PM10 PM2.5 NOX CO SO2 VOC HAPs CO2e
Thermal
Oxidizer 16.64 16.64 15.87 9.66 0.00 0.00 4.13 26,927
Roads 2.58E-03 2.58E-04 - - - - - -
Fugitives - - - - -0.48 0.10 12.48
Total Project
Emissions 16.65 16.64 15.87 9.66 0.00 0.48 4.24 26,939
Modeling
Limit1 15 -40 100 40 - See HAP
Summary -
Modeling
Required? Yes No No No No No No No
Major Source
Thresholds2,3 100 100 100 100 100 100 10/25 75,000
Exceeding
Major Source
Thresholds?
No No No No No No No No
1. Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled
Emission Rates for New Sources
2. Major source thresholds are defined by 40 CFR section 51.165(a)(1)(iv)(A).
3. Total HAP Threshold is stated in 40 CFR Section 63.2 under definition of a Major Source.
The Plant’s emissions indicate that the project’s emission surpass UDAQ modeling thresholds for PM 10.
Modeling is assumed to be conducted by UDAQ.29
6.1 Comparison to Modeling Thresholds
Table 6-1 compares the proposed emissions of criteria pollutants to applicable modeling thresholds
contained in R307-403-4 through 7, and R307-410-4.
29 R307-406-2
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant 13
Table 6-1. Projected Emissions Summary of the Project
Emission Source PM10 PM2.5 NOX CO SO2 VOC HAPs CO2e
(tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)
Thermal Oxidizer 1.55 1.55 14.34 8.73 94.90 17.01 3.76 24,331
Thermal Oxidizer
Burner 0.13 0.13 1.21 0.74 0.00 0.16 0.00 2,052
Roads 2.58E-03 2.58E-03 - - - - - -
Fugitives - - - - - 0.73 0.06 6.93
Total Project
Emissions 1.68 1.68 15.55 9.46 94.90 17.90 3.82 26,390
Modeling Limit1 15/5 - 40 100 40 -
See HAP
Summary -
Modeling Required? No No No No Yes No No No
Major Source
Thresholds2,3 250 250 250 250 250 250 10/25 75,000
Exceeding Major
Source Thresholds? No No No No No No No No
1. Modeling Limit is stated in the UDAQ’s Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission
Rates for New Sources
2. Major source emission thresholds are defined by 40 CFR 52.21(b)(1)(i)(b) for all criteria pollutants, as the Plant is in
attainment for all criteria pollutants.
3. Total HAP Threshold is given in 40 CFR Section 63.2 under definition of a Major Source.
The Plant’s emissions indicate that the project’s emission surpass the UDAQ modeling thresholds for SO 2.
Modeling will be submitted to the UDAQ under a separate submittal.30
30 R307-410-4
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant A
APPENDIX A. FORMS
Page 1 of 1
Form 3 Company____________________
Process Information Site________________________
Utah Division of Air Quality
New Source Review Section
Process Information
1. Name of process: 2. End product of this process:
3. Process Description*:
Operating Data
4. Maximum operating schedule:
__________hrs/day
__________days/week
__________weeks/year
5. Percent annual production by quarter:
Winter ________ Spring _______
Summer ________ Fall _______
6. Maximum Hourly production (indicate units.): 7. Maximum annual production (indicate units):
________________
8. Type of operation:
Continuous Batch Intermittent
9. If batch, indicate minutes per cycle ________
Minutes between cycles ________
10. Materials and quantities used in process.*
Material Maximum Annual Quantity (indicate units)
11.Process-Emitting Units with pollution control equipment*
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If additional space is required, please create a spreadsheet or Word processing document and attach to form.
4.38 MMCFD (Phase I), 12 MMCFD (Phase II)
Notice of Intent Air Permit Application Supplement
Wesco Operating – Long Canyon Helium Plant B
APPENDIX B. EMISSIONS CALCULATIONS
►Please replace the submitted tables with those of the same label, below. The following, updated tables
contain the emission modification details which reflect the changes in this NOI supplement.
Appendix B - Emissions Calculations
Description Value Unit
Potential Waste Gas Throughput 4.83 (MMscf/day)
Annual Operating Hours 8,760 (hr/yr)
Daily Operating Hours 24 (hr/day)
Table B-2. Inlet Stream Analysis
Plant Inlet
(wt%)
Nitrogen 91.63%
Helium 0.22%
CO2 1.13%
H2S 0.20%
Methane 2.74%
Ethane 0.79%
Propane 0.65%
Butane 0.67%
Pentane 0.48%
Hexane 0.63%
Heptane 0.19%
Octane 0.15%
Nonane 0.07%
SO2 0.00%
Water 0.46%
Total 100.00%
Parameter Value Unit Notes
Site Elevation 5,960 ft MSL -
Site Air Pressure 23.98 in Hg Based on elevation
Site Air Pressure 11.78 psia Conversion factor
(%)
Valves - Gas 132 -
Connectors/Flanges - Gas 134 -
Flanges - Gas 298 -
Relief Valves - Gas 13 -
Pump Seals - Light Oil 3 -
Table B-3. Atmospheric Pressure
Table B-1. Site-Wide Parameters
Component
Table B-4. Piping Component Counts in VOC Service
Equipment Type Source
Count
Control
Efficiency
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 1 of 11
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December 2023
Appendix B - Emissions Calculations
Emission Source PM10 PM2.5 NOX CO SO2 VOC HAPs
CO2e
Thermal Oxidizer 1.55 1.55 14.34 8.73 94.90 17.01 3.76 24,331
Thermal Oxidizer Burner 0.13 0.13 1.21 0.74 0.00 0.16 0.00 2,052
Roads 2.58E-03 2.58E-04 - - - - - -
Fugitives - - - - - 0.73 0.06 6.93
Total Project Emissions 1.68 1.68 15.55 9.46 94.90 17.90 3.82 26,390
Modeling Limit1 15/5 - 40 100 40 - See HAP Summary -
Modeling Required? No No No No Yes No No No
Major Source Thresholds2,3 250 250 250 250 250 250 10/25 75,000
Exceeding Major Source Thresholds? No No No No No No No No
Table B-5. Wesco Long Canyon Helium Plant's Potenital to Emit (tpy)
1. Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled Emission Rates for New Sources
2. Major source thresholds are defined by 40 CFR section 52.21(b)(1)(i)(b).
3. Total HAP Threshold is stated in 40 CFR Section 63.2 under definition of a Major Source.
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 2 of 11
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December 2023
Appendix B - Emissions Calculations
Hourly Emissions ETV1
(lb/hr) (lb/hr)
Hexane 0.87 34.89 No
Max HAPs (tpy)3.82 - -
Total HAPs (tpy)3.82 - -
Table B-7. HAPs Emission Summary
Pollutant Modeling
Required?
1. The Emission Threshold Value (ETV) assumes <50 m distance to the fenceline and vertically unrestricted
releases.
Wesco Operating, Inc.
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Appendix B - Emissions Calculations
Table B-9. TO Parameters for Waste Gas
Parameter Value Units
Max. Annual Operation 8,760 (hr/yr)
Potential Inlet Volume Flow Rate 4.83 (MMscf/day)
Average Inlet Heating Value 86.00 (Btu/scf)
Max. Inlet Heat Rating 47.44 (MMBtu/hr)
Min. Inlet Heat Rating 5.14 (MMBtu/hr)
Molecular Weight 28.21 (lb/lbmol)
TO VOC Destruction Efficiency 99.00% -
TO H2S Destruction Efficiency 100.00% -
Iron Sponge H2S Control Efficiency 99.90% -
Iron Sponge H2S Capture Efficiency 61.33% -
PM10 Emission Factor 0.0075 (lb/MMBtu)
PM2.5 Emission Factor 0.0075 (lb/MMBtu)
NOX Emission Factor 0.069 (lb/MMBtu)
CO Emission Factor 0.042 (lb/MMBtu)
10% of max. heat rating
--
Manufacturer specification
Manufacturer specification
Manufacturer specification
--
AP-42, Table 1.4-2, gives an
emission factor for PM10/PM2.5 of
7.60 lb/MMscf at 1,020 Btu/scf.
The emission factor used here
converts that value to lb/MMBtu
using 7.60 lb/MMscf to account
for the low heating value of
combusted waste gas.
Notes
Manufacturer specification
Manufacturer specification
Manufacturer specification
Manufacturer specification
Manufacturer specification
Engineering estimate
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 4 of 11
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Appendix B - Emissions Calculations
Table B-10. TO Criteria Pollutants from Waste Gas Combustion
MW
(lb/lbmol)(tpy)(lb/hr)
PM10 ---- --1.55 0.35
PM2.5 ---- --1.55 0.35
NOX ---- --14.34 3.27
CO --
-- --8.73 1.99
SO2 1 64.07 0.00 tpy 94.90 21.67
H2S 2 34.08 50.48 tpy 0.00 0.00
VOCs 3 -1701.12 tpy 17.01 3.88
Propane 44.10
414.28 tpy 4.14 0.95
Butane 58.12
429.10 tpy 4.29 0.98
Pentane 72.15
304.37 tpy 3.04 0.69
Hexane 86.18
375.95 tpy 3.76 0.86
Heptane 102.37 tpy 1.02 0.23
Octane 58.64 tpy 0.59 0.13
Nonane 16.41 tpy 0.16 0.04
HAPs -- 426.43 tpy 3.76 0.86
Table B-11. TO - GHG Potential Emissions (Waste Gas)
Pollutant
Emission
Factor
(kg/MMBtu)1
PTE
(lb/hr)
PTE
(tpy)
CO2 53.06 5,549 24,306
CH4 1.00E-03 0.105 0.46
N2O 1.00E-04 0.0105 0.05
CO2e 2 53.11 5,555 24,331
2.2046 pound/kilogram conversion
3. VOCs consist of propane, butane, pentane, hexane, heptane, octane, and nonane. Uncontrolled values are given in
the "TO Inlet" column and controlled values are given in the "TO Exhaust" column.
1. SO2 is not present in the inlet stream to the TO. SO2 emissions are based on the total conversion of controlled H2S.
2. Emissions of H2S (tpy) take the TO H2S Desctruction Efficiency into account, i.e., uncontrolled values are given in
the "TO Inlet" column and controlled values are given in the "TO Exhaust" column.
1. GHG emission factors from 40 CFR 98, Tables C-1 and C-2.
2. CO2e is the sum of GHG constituents multiplied by their respective global warming potential
(i.e. 1 for CO2, 25 for CH4, and 298 for N2O), per Table A-1, 40 CFR 98, Subpart A.
UnitsTO InletPollutant TO Exhaust
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 5 of 11
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December 2023
Appendix B - Emissions Calculations
Parameter Value Units
Max. Annual Operation 8,760 (hr/yr)
Max. Inlet Mass Flow Rate 61.01 (lb/hr)
Proj. Inlet Volume Flow Rate 3.49E-03 (MMscf/hr)
Inlet Molar Flow Rate 3.14 (lbmol/hr)
Avg. Inlet Heating Value - Fuel 1,145 (Btu/scf)
Max. Inlet Heat Rate - Fuel 4.00 (MMBtu/hr)
Molecular Weight 19.40 (lb/lbmol)
TO VOC Destruction Efficiency 99.00% -
TO H2S Destruction Efficiency 100.00% -
PM10 Emission Factor 0.0075 (lb/MMBtu)
PM2.5 Emission Factor 0.0075 (lb/MMBtu)
NOX Emission Factor 0.069 (lb/MMBtu)
CO Emission Factor 0.042 (lb/MMBtu)
Table B-16. TO Exhaust Emissions from Fuel Gas Combustion
Component MW (lb/lbmol)
Fuel Gas
Composition1
TO Exhaust
(lbmol/hr)
TO Exhaust
(lb/hr)
TO Exhaust
(tpy)
PM10 ---0.030 0.13
PM2.5 ---0.030 0.13
NOX - - - 0.28 1.21
CO 28.01 - - 0.17 0.74
SO2 1 64.07 0.00% 0.00 0.00 0.00
Hydrogen Sulfide 2 34.10 0.00% 0.00 0.00 0.00
VOCs 3 - - 8.05E-04 0.04 0.16
Propane 44.10 2.39% 7.52E-04 0.03 0.15
Butane 58.12 0.17% 5.35E-05 3.11E-03 0.01
Pentane 72.15 0.00% 0.00 0.00 0.00
Hexane 86.18 0.00% 0.00 0.00 0.00
Total HAPS --0.00E+00 0.00E+00 0.00E+00
2. SO2 is not present in the inlet stream to the TO. SO2 emissions are based on the total conversion of controlled H2S.
3. Emissions of H2S (lb/mol) take the TO Desctruction Efficiency into account, i.e., controlled, not uncontrolled emissions, are shown.
4. VOCs consist of propane, butane, pentane, and hexane. Controlled, not uncontrolled emissions, are shown.
Calculated
1. Fuel Gas Composition given by Thermal Oxidizer engineering firm.
--
--
Table B-15. TO Burner Parameters (Fuel Gas)
Source
Manufacturer specification
Manufacturer specification
AP-42, Table 1.4-2, gives an emission factor for
PM10/PM2.5 of 7.60 lb/MMscf at 1,020 Btu/scf. The
emission factor used here converts that value to
lb/MMBtu using 7.60 lb/MMscf to account for the
low heating value of combusted waste gas.
Manufacturer specification
Manufacturer specification
Manufacturer specification
Manufacturer specification
Client specification
Calculated
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 6 of 11
Trinity Consultants
December 2023
Appendix B - Emissions Calculations
Table B-17. Fuel Gas Composition
Component MW (lb/lbmol)
Fuel Gas
Composition1
N2 28.01 0.47%
Methane 16.04 80.22%
Ethane 30.07 15.26%
Propane 44.10 2.39%
Butane 58.12 0.17%
Pentane 72.15 0.00%
Hexane 86.18 0.00%
Carbon Dioxide 44.01 1.49%
Helium 4.00 0.00%
Oxygen 32.00 0.00%
Hydrogen Sulfide 34.10 0.00%
SO2 64.07 0.00%
Water 18.02 0.00%
Carbon Monoxide 28.01 0.00%
Methanol 32.04 0.00%
Total 100.00%
Table B-18. TO - GHG Potential Emissions (Fuel Gas)
Pollutant Emission Factor
(kg/MMBtu)1
Potential to Emit
(lb/hr)
Potential to Emit
(tons/yr)
CO2 53.06 467.91 2,049
CH4 1.00E-03 0.0088 0.039
N2O 1.00E-04 8.82E-04 0.0039
CO2e 53.11 468.39 2,052
2.20462
1. Fuel Gas Composition given by Thermal Oxidizer engineering firm.
1. GHG emission factors from 40 CFR 98, Tables C-1 and C-2.
2. CO2e is the sum of GHG constituents multiplied by their respective global warming potential (i.e. 1 for CO2,
25 for CH4, and 298 for N2O), per Table A-1, 40 CFR 98, Subpart A.
pound/kilogram conversion
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 7 of 11
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December 2023
Appendix B - Emissions Calculations
PM10 PM2.5 PM10 PM2.5
Unpaved roads 0.04 4.24E-03 2.58E-03 2.58E-04
Total 0.04 4.24E-03 2.58E-03 2.58E-04
Empty Vehicle Loaded Vehicle
Daily
(VMT/day)
Annual4
(VMT/yr)
Semi Trucks 8,000 40.60 41.50 0.90 1 0.13 0.13 16.13
1,800
83,000
700
122
PM10 PM2.5
Unpaved None 0% 2.13 0.21
Unpaved
Chemical
Suppressant and
Watering
85% 0.32 0.03
where E = Size-specific emission factor (lb/VMT)
k, a, b = Constants for equation 1a
PM PM10 PM2.5
k = 4.90 1.50 0.15
a =0.70 0.90 0.90
b =0.45 0.45 0.45
s = surface material silt content (%)
s = 4.80
W = 41.05
1. Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the vehicular
miles traveled per day (paved and unpaved).
Table B-19. Roads Emissions - PTE Emissions
Road Source
Controlled Emissions
Daily Emissions (lb/day)1 Annual Emissions (tpy)1
Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - Control Efficiency [%])
Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - Control Efficiency [%])
Table B-20. Paved Roads Emissions - Traveling Parameters (Supporting Operations)
Road Source
Product
Throughput
(tpy)
Vehicle Weights (tons)1
Vehicle Haul Capacity
(ton/haul)Hauls/Day2
Total Travel
Distance per Haul
(miles/haul)3
Total Vehicle Miles
Table B-21. Roads Emissions - Emission Factors
1. Empty and loaded vehicle weights. Client specification:
Haul Capacity (lb)
Loaded vehicle weight (lb)
2. Client specification.
3. Round-trip distance of semi truck on plant. Client specification: (ft)
4. Annual Days Vehicles Operate, Client Specification: (days)
Mean wieght of all vehicles (tons), per UDAQ guidance given in Emission Factors for Paved and Unpaved
Haul Roads, January 2015.
Road Surface Controls 1 Control Efficiency
(%)
Haul Truck Emission Factors 1
1. Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads,
January 2015, in conjunction with U.S. EPA AP-42 Section 13.2.2, November 2006.
Per UDAQ guidance given in Emission Factors for Paved and Unpaved Haul Roads, January 2015.
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Supplement Page 8 of 11
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December 2023
Appendix B - Emissions Calculations
Table B-22. Fugitive Emission Factors for VOCs and HAPs
(lb/hr/
source)(wt%) (%)
Valves - Gas 9.92E-03 132 3.63% 0.00%
Connectors/Flanges - Gas 8.60E-04 432 3.63% 0.00%
Flanges - Gas 8.60E-04 298 3.63% 0.00%
Relief Valves - Gas 0.02 13 3.63% 0.00%
Pump Seals - Light Oil 0.03 3 100.00% 0.00%
Annual Hours of Operation
Table B-23. Fugitive Emission Rates for VOCs & CO2
Uncontrolled Uncontrolled Uncontrolled Uncontrolled
(lb/hr)(lb/hr)(tpy)(lb/hr)(lb/hr)(tpy)(lb/hr)(lb/hr)(tpy)(lb/hr)(lb/hr)(tpy)
Valves - Gas 0.05 0.05 0.21 0.01 0.01 0.06 0.04 0.04 0.16 0.91 0.91 3.99
Connectors/Flanges - Gas 0.01 0.01 0.06 4.19E-03 4.19E-03 0.02 0.01 0.01 0.04 0.26 0.26 1.13
Flanges - Gas 9.30E-03 9.30E-03 0.04 2.89E-03 2.89E-03 0.01 7.01E-03 7.01E-03 0.03 0.18 0.18 0.78
Relief Valves - Gas 9.15E-03 9.15E-03 0.04 2.85E-03 2.85E-03 0.01 6.90E-03 6.90E-03 0.03 0.18 0.18 0.77
Pump Seals - Light Oil 0.09 0.09 0.38 9.72E-04 9.72E-04 4.26E-03 2.36E-03 2.36E-03 0.01 0.06 0.06 0.26
Total 0.17 0.17 0.72 0.03 0.03 0.11 0.06 0.06 0.27 1.58 1.58 6.93
Methane Emission Rate
Controlled
CO2e Emission Rate
Controlled
CO2 Emission Rate
Controlled
Equipment Type
Emission
Factor1 Source
Count2
VOC C3+
8760.00
Control
Efficiency
1. Factors are from TCEQ Air Permit Technical Guidance for Chemical Sources: Fugitive Guidance.
Emission Factors - Oil and Gas Production Operations, June 2018.
Equipment Type Controlled
VOC Emission Rate
2. Source counts are site-specific.
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Appendix B - Emissions Calculations
Table B-24. Fugitive Emission Rates for HAPs & Sulfur Dioxide
Uncontrolled Uncontrolled
(lb/hr)(lb/hr)(tpy)(lb/hr)(lb/hr)(tpy)
Valves - Gas 2.67E-03 2.67E-03 0.01 8.23E-03 8.23E-03 0.04
Connectors/Flanges - Gas 7.56E-04 7.56E-04 3.31E-03 2.33E-03 2.33E-03 0.01
Flanges - Gas 5.22E-04 5.22E-04 2.28E-03 1.61E-03 1.61E-03 7.05E-03
Relief Valves - Gas 5.13E-04 5.13E-04 2.25E-03 1.58E-03 1.58E-03 6.94E-03
Pump Seals - Light Oil 1.75E-04 1.75E-04 7.68E-04 5.41E-04 5.41E-04 2.37E-03
Total 0.00 0.00 0.02 0.01 0.01 0.06
Table B-25. Speciated Fugitive VOCs & HAPs
Component (wt%)
Nitrogen 91.63%
Helium 0.22%
CO2 1.13%
H2S 0.20%
Methane 2.74%
Ethane 0.79%
Propane 0.65%
Butane 0.67%
Pentane 0.48%
Hexane 0.63%
Heptane 0.19%
Octane 0.15%
Nonane 0.07%
SO2 0.00%
Water 0.46%
HAP wt% 0.63%
H2S wt%0.20%
CO2 wt%1.13%
Methane wt% 2.74%
Controlled
Hexane Emission Rate
Controlled
H2S Emission Rate
Equipment Type
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Appendix B - Emissions Calculations
Pollutant Value Units Value Units
PM10 -- -- -- --
PM2.5 -- -- -- --
NOX -- -- -- --
CO -- -- -- --
SO2 0.00E+00 (tpy) 0.00E+00 (lb/hr)
VOCs 3.35E-03 (tpy) 7.66E-04 (lb/hr)
Propane 1.09E-03 (tpy) 2.49E-04 (lb/hr)
Butane 9.86E-04 (tpy) 2.25E-04 (lb/hr)
Pentane 7.06E-04 (tpy) 1.61E-04 (lb/hr)
Hexane 5.23E-04 (tpy) 1.19E-04 (lb/hr)
Heptane 3.33E-05 (tpy) 7.60E-06 (lb/hr)
Octane 1.29E-05 (tpy) 2.95E-06 (lb/hr)
Nonane 5.93E-07 (tpy) 1.35E-07 (lb/hr)
HAPs 5.23E-04 (tpy) 1.19E-04 (lb/hr)
Hexane 5.23E-04 (tpy) 1.19E-04 (lb/hr)
CO2 1.84E-05 (tpy) 4.20E-06 (lb/hr)
Table B-26. Fugitive Emissions from Dehy Still Vent
1. Stream values estimated by TO manufacturer.
Wesco Operating, Inc.
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UTAH DIVISION OF AIR QUALITY – NOTICE OF INTENT

Wesco Operating, Inc. – Casper, WY

Prepared By:
TRINITY CONSULTANTS

Chase Peterson – Consultant
Nate Taylor – Associate Consultant
4525 Wasatch Boulevard
Suite 200
Salt Lake City, UT 84124
[phone]

July 2023

Project 224502.0025

ii
TABLE OF CONTENTS
1. EXCECUTIVE SUMMARY 1-1
2. GENERAL INFORMATION 2-1
2.1. Description of Facility ................................................................................................... 2-1
2.1.1. Attainment Status ...................................................................................................... 2-1
2.1.2. Source Size Determination .......................................................................................... 2-1
2.2. Fees .............................................................................................................................. 2-2
2.3. Forms ............................................................................................................................ 2-2
3. DESCRIPTION OF PROJECT AND PROCESS 3-1
3.1. Description of Project ................................................................................................... 3-1
3.2. Description of Process .................................................................................................. 3-1
4. EMISSIONS RELATED INFORMATION 4-1
4.1. Thermal Oxidizer Emissions .......................................................................................... 4-1
4.2. Road Emissions ............................................................................................................. 4-2
4.3. Fugitive VOC & HAPs Emissions .................................................................................... 4-2
4.4. Source Size Determination ........................................................................................... 4-2
5. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS 5-1
5.1. Fugitive Emissions ........................................................................................................ 5-1
5.2. Vehicle Travel ............................................................................................................... 5-2
5.3. Helium Production Equipment ...................................................................................... 5-4
5.4. Thermal Oxidation ........................................................................................................ 5-4
6. EMISSION IMPACT ANALYSIS 6-6
6.1. Comparison to Modeling Thresholds ............................................................................ 6-6
7. NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING 7-1
8. APPLICABLE REGULATIONS 8-1
8.1. General Introduction – Utah Regulations ..................................................................... 8-4
8.1.2. UAC R307-107 General Requirements: Breakdowns ...................................................... -
8.1.3. UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust ...................... -
8.1.4. UAC R307-305 Nonattainment and Maintenance Areas for PM10: Emission Standards ...... -
8.1.5. UAC R307-401-8: Approval Order ................................................................................ -
8.1.6. UAC R307-414-Permits: Fees for Approval Orders ......................................................... -
8.1.7. UAC R307-501 through R307-511: Oil and Gas Industry ............................................... -
8.2. Federal Regulations ...................................................................................................... 8-6
8.2.1. NSPS Subpart A: General Provisions ............................................................................ 8-6
8.2.2. NESHAP Subpart A ..................................................................................................... 8-6
A-1
B-1
$33(1',;$FORMS
$33(1',;%EMISSIONSCALCULATIONS
$33(1',;&BACT ECONOMIC ANALYSIS
Wesco Operating, Inc. | NOI Air Permit Application Trinity
Consultants
C-1
Wesco Operating, Inc. | NOI Air Permit Application
Trinity Consultants 1-1
1.EXCECUTIVE SUMMARY
This Notice of Intent (NOI) air permit application is being submitted to the Utah Division of Air Quality
(UDAQ) by Trinity Consultants (Trinity) on behalf of Wesco Operating, Inc. (Wesco) to permit its proposed
operations at a new facility. The new facility will be called the Long Canyon Helium Plant (the Plant), and it
lies approximately 10 miles west of Moab, Utah. The Plant will produce helium through the processing of
natural gas. The Plant will be located on the existing pad for the Cane Creek Unit 7-1/7-2 production wells.
The Plant will process natural gas from wells. The gas will be processed using a variety of equipment that
separates helium from the natural gas. Waste streams will be controlled through the use of a thermal
oxidizer (TO). The Plant will have a maximum capacity of 12 million standard cubic feet per day
(MMscf/day). Product helium will be compressed, loaded into trucks, and trucked off site for sale. Emissions
of criteria pollutants will result from the combustion of gases at the TO and fugitive releases anticipated
through the equipment (e.g., valves, flanges, seals, connections, etc.).
Criteria pollutants that will be included under this project are: particulate matter (PM) with an aerodynamic
diameter of 10 microns or less (PM10), PM with an aerodynamic diameter of 2.5 microns (PM2.5), oxides of
nitrogen (NOX), carbon monoxide (CO), sulfur dioxide (SO2), and volatile organic compounds (VOCs).
Hazardous air pollutants (HAPs) and greenhouse gases (GHGs) will also be emitted; the latter is represented
as carbon dioxide equivalent (CO2e). The increase in potential-to-emit (PTE) emissions will be as follows:
PM10 = 16.65 (tpy); PM2.5 = 16.64 (tpy); NOX = 26.23 (tpy); CO = 15.97 (tpy); SO2 = 0.00 (tpy); VOCs =
0.48 (tpy); HAPs = 4.24 (tpy); and CO2e = 44,534 (tpy). The PTE represents an operating schedule of
8,760 hours per year.
This NOI air permit application has been developed pursuant to UAC R307-401-5 and Utah’s NOI air permit
application guidance. It includes required supporting information for the modifications specified above,
namely:
Ź NOI Forms and Fees;
Ź Process Description;
Ź Site Plan;
Ź Potential Emission Calculations;
Ź Best Available Control Technology (BACT) Analysis;
Ź Applicable Regulatory Requirements; and
Ź Emission Impact Analysis.

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2. GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ Form 1 Notice of Intent (NOI) Application Checklist.
2.1. Description of Facility
Ź Company Name: Wesco Operating, Inc.
Ź Address: Latitude: 38.560710, Longitude: -109.748930
Ź County: Grand County
Ź UTM Coordinates: Easting: 609,001 m, Northing: 4,268,772 m, Zone 12
Ź Primary SIC Code: 2813 (Industrial Gases)

All correspondence regarding this submission should be addressed to:

Ź Mr. Tom Kirkwood
Ź Title: Engineer
Ź Office: 307-577-5328
Ź Mobile: [phone]
Ź Email: [e-mail]
2.1.1. Attainment Status
The Plant is located in Grand County, Utah, which is classified as an attainment area for all criteria
pollutants.
2.1.2. Source Size Determination
The Plant’s PTE is less than major source thresholds, as described in the following NOI air permit
application, and is therefore subject to minor New Source Review (NSR).

Ź Precursors to PM2.5 (NOx, SO2, VOC, and NH3) are less than 100 tons per year (tpy);
Ź PM10 and carbon monoxide (CO) are less than 100 (tpy); and,
Ź Individual hazardous air pollutants (HAPs) and aggregate HAPs are below 10 and 25 (tpy); respectively.

Therefore, the Plant will be classified as a minor source.

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2.2. Fees
Kirkwood will use the UDAQ’s Payment Portal to prepay the following UDAQ NOI air permit application fees
associated with this submittal:

Ź “Application Filing Fee” for the “Major or Minor Modification” category = $500
Ź “Application Review Fee” for the “Existing major source with a minor modification” category in
maintenance or non-attainment areas = $2,200
Ź Total UDAQ fees = $2,700

Kirkwood understands that the total permit review fee is based on the total actual time spent by UDAQ staff
processing this NOI air permit application, and that, if the total review time is more than 20 standard hours,
UDAQ will invoice Kirkwood at $110 per hour for the additional time above 20 standard hours.
2.3. Forms
The following UDAQ forms are included in Appendix A to this application:

Ź Form 1: Notice of Intent Application
Ź Form 2: Company Information
Ź Form 3: Process Information
Ź Form 4: Project Information
Ź Form 5: Emissions Information
Ź Form 12: Incinerators

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3. DESCRIPTION OF PROJECT AND PROCESS
3.1. Description of Project
Wesco proposes to install and operate gas-processing equipment that will allow for the separation of helium.
This will occur at the Long Canyon Helium Plant, a proposed processing facility approximately 10 miles west
of Moab, Utah. All processes at the Plant will be controlled by a TO. Fugitive emissions are anticipated but
will not be controlled by the TO.

Emissions of criteria pollutants will be generated by the TO and in the form of fugitives. Fugitive emissions
are accounted for at valves, flanges, seals, and connections.
3.2. Description of Process
This section contains the information required by UDAQ Form 1, (R307-401-5(2)(a) and (e)).

Natural gas will be produced from a well or wells and sent via flowline to the Plant. That gas will be
processed to isolate and remove helium. This will occur first through an amine contactor. The gas will then
be processed by a glycol dehydrator, a membrane skid, and a helium recovery unit (HRU). The extracted
helium will be compressed and held in a trailer-based tank to be hauled off site by trucks for sale. Waste
gasses are controlled throughout the process by a TO. Heat from the TO is recycled through hot oil for use
at the Plant.

Images and process flow diagrams (PFDs) of the process and its location are provided below.

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Figure 3-1. Site Layout

Wesco Operating Inc. / Notice of Intent 3-3
Trinity Consultants
Figure 3-2. Process Box Flow Diagram

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4. EMISSIONS RELATED INFORMATION
This section details the methodology used to calculate controlled and uncontrolled emissions for criteria
pollutants, greenhouse gases, and HAPs associated with the increase in throughputs and their associated
emissions, as regulated by R307-401-5(2)(b). Additionally, a comparison to major source thresholds was
conducted. Detailed emission calculation tables are included at the end of this section.
4.1. Thermal Oxidizer Emissions
TO VOC & HAP Emissions Calculations
Thermal oxidizers (TO) VOC & HAP emissions were based on proposed estimated exhaust composition data
provided by manufacturer in April 2023. They were used in the following equation:

Potential Annual Emissions (tpy)
=Exhaust Flow Rate ൬lbmol
hr ൰ × Pollutant Moleculer Weight൬
lb
lbmol൰ × 8760 ൬
hr
yr൰× 1
2000 ൬ton
lb ൰
TO PM Emissions Calculations
TO PM emissions were based on EPA emission factors in AP 42 Table 1.4: Natural Gas Combustion for
External Combustion and were used in the following equation:

Potential Annual Emissions (tpy)
=EF ൬ lb
MMscf൰×Inlet Flow Rate൬MMscf
day ൰× 1
24 ൬day
hr ൰ × 8760൬
hr
yr൰× 1
2000 ൬ton
lb ൰
TO CO & NOX Emissions Calculations
TO CO & NOX emissions were based on vendor guarantee emission factors and were used in the following
equation:

Potential Annual Emissions (tpy)=EF ൬ lb
MMBtu൰×Heat Input൬MMBtu
day ൰× 1
24 ൬day
hr ൰ × 8760൬
hr
yr൰× 1
2000 ൬ton
lb ൰
Greenhouse Gas Emissions
Greenhouse gas (GHG) emissions for all units previously listed were calculated similarly. In order to
calculate total Carbon Dioxide Equivalent (CO2e, equivalent to GHG) emissions, total fuel usage was
multiplied by fuel-specific emission factors and global warming potentials (GWP) provided in 40 Code of
Federal Regulations (CFR) 98 Tables A-1, C-1 and C-2.

Potential Annual Emissions (tpy)
= ൬Emission Factor COଶ ൬ kg
MMBtu൰ + Emission Factor CHସ ൬ kg
MMBtu൰×GWP CHସ
+ Emission Factor Nଶ O ൬ kg
MMBtu൰×GWP Nଶ O൰ × Heat Input൬
MMBtu
hr ൰ × Operating Hours൬
hr
yr൰
×൬ ton
907.185 kg൰

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4.2. Road Emissions
The haul roads at the Plant affected by this project consist of unpaved roads. PM10 and PM2.5 emissions
were derived using UDAQ’s guidance given in “Emission Factors for Paved and Unpaved Haul Roads”,
January 2015 in conjunction with U.S. EPA AP-42 Section 13.2.2, November 2006. Emissions from these
roads were calculated using the following equation:

PM = k × ቀ
s
12ቁ
ୟ
×൬W
3 ൰
ୠ
× D × 1 ton
2,000 lb × (1െ Ʉ)
Where:
PM = PM/PM10/PM2.5 emissions (tpy)
k = PM/PM10/PM2.5 k-Factor (lb/VMT)
s = Average silt content (%)
W = Mean vehicle weight (tons)
D = Distance traveled (VMT/yr)
a = Constant for equation (varies for PM/PM10/PM2.5) (unit less)
b = Constant for equation (varies for PM/PM10/PM2.5) (unit less)
dž = Control efficiency (%)

Parameter (W) is determined by taking the mean weight of all vehicles per UDAQ guidance given in
“Emission Factors for Paved and Unpaved Haul Roads”, January 2015. Parameter (D) is determined by using
the product throughput divided by the difference in full and empty vehicle weight to determine the total
number of hauls required. This value is multiplied by the round-trip distance traveled by the customer
trucks. The average silt content used in this equation is also per UDAQ guidance given in “Emission Factors
for Paved and Unpaved Haul Roads”, January 2015.

As a means of control, chemicals will be applied to the roads and a watering truck regularly applies water to
the roads, which are all unpaved.1 Emissions were projected based on the Plant’s road layouts, vehicle
weights, and hauling capacity.
4.3. Fugitive VOC & HAPs Emissions
Fugitive emissions were calculated by equipment type and pollutant concentrations. Emission factors were
based on TCEQ Air Permit Technical Guidance for Chemical Sources: Fugitive Guidance. Emission Factors –
Oil and Gas Production Operations, June 2018. They were used in the following equation:

Potential Annual Emissions (tpy)
=EF ൬ lb
hr െ source
൰ × Source Count × Pollutant Mol % × 8760൬
hr
yr ൰× 1
2000 ൬ton
lb ൰
4.4. Source Size Determination
As presented in the emission calculations summary in this NOI air permit application, proposed emissions at
the Plant are less than major source thresholds (MST) (i.e., 100 tons for any criteria pollutant). Therefore,
the Plant will be classified as a minor source.

1 “Emission Factors for Paved and Unpaved Haul Roads”, UDAQ, January 12, 2015.

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5. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant into the air, must consider BACT for a proposed
new source or modification. The BACT analysis prepared for this application only addresses units which will
be modified, installed or otherwise addressed in the modified Approved Order. Specifically, the BACT
analysis addresses PM10, PM2.5, and VOC emissions from the Plant’s equipment. It will follow United States
Environmental Protection Agency’s (EPA’s) preferred “top-down” methodology.2

Control technologies were identified from Trinity’s search based on the following references:

Ź Bay Area Air Quality Management District (BAAQMD);
Ź San Diego County Air Pollution Control District (SDCAPCD)
Ź South Coast Air Quality Management District (SCAQMD);
Ź San Joaquin Valley Air Pollution Control District (SJVAPCD);
Ź Texas Commission for Environmental Quality (TCEQ); and
Ź Search of the RACT/BACT/LAER Clearinghouse (RBLC), conducted on June 16, 2023.
5.1. Fugitive Emissions
Fugitive emissions result from valves, connectors, flanges, seals, and other related pieces of equipment.
VOCs and HAPs are the primary pollutants associated with fugitive emissions on site. This is due to material
transfer from wellhead to facility to product trucks.
SS t e p 1 – I d e n t i f y A l l A v a i l a b l e C o n t r o l T e c h n o l o g i e s
The first step in the BACT analysis is to identify all available control technologies. Control technologies were
identified from Trinity’s search and are described below.

Leak Detection and Repair
Leak Detection and Repair (LDAR) includes the regulation of equipment leaks and the monitoring required
to do so. This and compliance with federal standards are the only control methods listed for fugitive
emissions.

S t e p s 2 – 5 E l i m i n a t e Te c h n i c a l l y I n f e a s i b l e O p t i o n s , R a n k R e m a i n i n g C o n t r o l T e c h n o l o g i e s
b y C o n t r o l E f f e c t i v e n e s s , E v a l u a t e M o s t -E f f e c t i v e C o n t r o l s , a n d S e l e c t B A C T
LDAR is technically feasible for control of fugitive emissions. As it is the only control technology listed, no
ranking of control technologies is necessary. There are no economic, environmental, or energetic
infeasibilities associated with applying LDAR. As LDAR is the only feasible and remaining control technology,
it is BACT for fugitive emissions.

2 EPA. Office of Air and Radiation. Memorandum from J.C. Potter to the Regional Administrators. Washington D.C. December
1, 1987.

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5.2. Vehicle Travel
Fugitive PM10 and PM2.5 Emissions
There is one (1) primary haul road used for offsite shipments of helium. It leads from the fenceline into the
facility where helium is loaded into trucks, and back to the fenceline. The haul road is unpaved with a road
base of aggregate material. Fugitive emissions are generated from road use by helium product trucks that
will take product offsite for sale and delivery. Roads beyond the fenceline will be maintained by the County.

R o a d s P M 1 0 a n d P M 2 .5 S t e p 1 - I d e n t i f y A l l C o n t r o l Te c h n o l o g i e s
Control technologies identified for PM10 and PM2.5 emissions from roads are as follows, based on May 6,
2020 review of relevant entries in EPA’s RBLC:
Ź Chemical Treatment (Applicable to Unpaved Roads Only)
Ź Reduced Speed (Applicable to Unpaved Roads Only)
Ź Road Paving (Applicable to Unpaved Roads Only)
Ź Silt Content Reduction by Road Base (Applicable to Unpaved Roads Only)
Ź Street Sweeping (Applicable to Paved Roads Only)
Ź Watering and Material Moisture Content
R o a d s P M 1 0 a n d P M 2 .5 S t e p 2 – E l i m i n a t e Te c h n i c a l l y I n f e a s i b l e O p t i o n s
Chemical Treatment
Applying chemical treatment to unpaved roads binds surface particles together and inhibits fugitive
emissions by up to 85%3. This control technology is technically feasible.
Reduced Speed
Reducing the speed on plant roads reduces the generation of fugitive dust. The Western Regional Air
Partnership (WRAP) Fugitive Dust Handbook reports that a 57% reduction in emissions occurs when speeds
are restricted to less than fifteen miles per hour (15 mph), and a 44% reduction in emissions when speeds
are restricted to 25 mph4. This control method is technically feasible.
Road Paving
Paving provides effective controls on fugitive road emissions. Guidelines from UDAQ indicate that paved
roadways, combined with sweeping and watering, provide a 90% control efficiency for particulate
emissions; the use of a vacuum sweeper increases the control efficiency to 95%5. Paving the haul road is
technically feasible.
Silt Content Reduction
Silt content reduction involves covering unpaved road surfaces with material that has a lower silt content
than what is naturally present, e.g., gravel or slag. Combined with watering, this method achieves up to
75% control efficiency6. This is technically feasible.
Street Sweeping
Street sweeping is a method of PM control that utilizes a mobile street sweeping unit to remove loose
material from paved road surfaces. This control technology is technically feasible on paved roads but not on

3 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015
4 Western Regional Air Partnership, Fugitive Dust Handbook. Executive Summary, p 3, September 2006.
5 UDAQ Guidelines: Emission Factors for Paved and Unpaved Haul Roads, January 2015
6 Ibid.

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unpaved road surfaces. This is technically feasible only if road paving proves feasible as well. Otherwise, it is
technically infeasible.
Watering and Material Moisture Content
Watering of haul roads reduces fugitive PM2.5 and PM10 emissions by binding soil particles together,
preventing their being picked up by wind or vehicles. Water is applied on a scheduled basis and
supplemented as needed based on driver observation of dust conditions. Basic watering results in a dust
control efficiency of up to 70%7. This control technology is technically feasible.
RR o a d s P M 1 0 a n d P M 2 .5 S t e p 3 – R a n k R e m a i n i n g C o n t r o l Te c h n o l o g i e s b y C o n t r o l E f f e c t i v e n e s s
Table 5-3. Fugitive PM10 and PM2.5 Control Technologies and Efficiencies for Roads.
Control Method Control Efficiency (%)
Paved Road, Vacuum-Sweeping, and Watering 95
Paved Road, Sweeping, and Watering 90
Chemical Suppressant and Watering 85
Basic Watering and Road Base 75
Basic Watering 70
Reduced Speed 44-57
For the technologies applied to unpaved roads, any grouping of silt-content reduction, watering, and speed
reduction can be applied together, as they are not competitive. For the technologies applied to paved roads,
sweeping and watering are not competitive. Note that variable control technologies include:

Ź Silt Content Reduction: Varies with current, uncontrolled road conditions, per AP-42 13.2.2.
R o a d s P M 1 0 a n d P M 2 .5 S t e p 4 – E v a l u a t e M o s t E f f e c t i v e C o n t r o l s a n d D o c u m e n t R e s u l t s
Paving of the haul road would provide the highest control efficiencies, with 95% and 90% control with
vacuum-sweeping and standard sweeping, in coordination with watering, respectively. However, an
economic feasibility analysis demonstrates that the cost of paving the unpaved haul road is >$2,650,000 per
ton removed of PM10 and PM2.5. Therefore, paving the unpaved haul road is economically infeasible. See
Appendix C for the detailed economic feasibility analysis.

As the haul road is unpaved, chemical suppressant application, water application, and the use of a road
base are used in conjunction one with the other to achieve the highest possible control efficiency for
unpaved roads. As this is the highest available control technology, no economic, energetic, or environmental
impact evaluations are considered.

R o a d s P M 1 0 a n d P M 2 .5 S t e p 5 – S e l e c t B A C T
Fugitive road emissions are generated from road use by product trucks and on-site vehicles. BACT for the
haul road consists of the combination of chemical application, watering, and implementation of road base.
Wesco’s Long Canyon Helium Plant will implement these controls.

7 Ibid.

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5.3. Helium Production Equipment
Helium production equipment includes dehydrators and compressors, both of which were found in the
search for control technologies. VOCs are the criteria pollutant controlled from this equipment.
SS t e p 1 – I d e n t i f y A l l A v a i l a b l e C o n t r o l T e c h n o l o g i e s
The first step in the BACT analysis is to identify all available control technologies. Control technologies were
identified from Trinity’s search and are described below.

Thermal Oxidizer
Thermal oxidizers (TOs) regularly achieve up to 98% destruction efficiencies because of the inherent
efficiency of the combustion processes.8 TOs typically consist of an enclosed combustion chamber with an
auxiliary burner fired with a conventional fuel. The firing rate of the burner is automatically controlled to
maintain a preset combustion-chamber temperature. TOs provide maximum operating flexibility because
they can handle CO and most known VOCs at a wide range of concentrations and flows. Heat recovery is
frequently used with TO systems to minimize the fuel operating cost, especially with low concentrations of
VOC. Heat recovery devices used in VOC systems are most commonly indirect recuperative heat exchangers
or thermal mass regenerative heat exchangers.
S t e p s 2 – 5 E l i m i n a t e Te c h n i c a l l y I n f e a s i b l e O p t i o n s , R a n k R e m a i n i n g C o n t r o l T e c h n o l o g i e s
b y C o n t r o l E f f e c t i v e n e s s , E v a l u a t e M o s t -E f f e c t i v e C o n t r o l s , a n d S e l e c t B A C T
A TO is technically feasible for control of the helium-production equipment. As it is the only control
technology listed, no ranking of control technologies is necessary. There are no economic, environmental, or
energetic infeasibilities associated with installing a TO. As a TO is the only feasible and remaining control
technology, it is BACT for helium-production equipment.
5.4. Thermal Oxidation
The manufacture of helium at the facility includes the use of a thermal oxidizer (TO) for off-spec or leftover
gas. Gas combustion results in emissions of all criteria pollutants.
S t e p 1 – I d e n t i f y A l l A v a i l a b l e C o n t r o l T e c h n o l o g i e s
The first step in the BACT analysis is to identify all available control technologies. Control technologies were
identified from Trinity’s search and are described below.

Low-NOX Burner
The burner on the TO is a low-NOX burner (LNB), per the requirement of UAC Section R307-401-4(3). It is
guaranteed by the manufacturer that NOX emissions will be <30 ppm and CO emissions will be <30 ppm,
both at 50-100% design conditions, corrected to 3% oxygen. It is also guaranteed to have a destruction
efficiency of >99% for VOCs. This meets BACT for the State of Utah.

Good Operating Practices
Good combustion practices may include the use of low-emitting fuels (e.g., natural gas), proper equipment
design, proper maintenance of equipment, good housekeeping, and general operating practices that follow
manufacturer recommendations, where appropriate. This technology is technically feasible.

8 Per EPA Air Pollution Control Technology Fact Sheet, Thermal Incinerator. EPA-452/F-03-022.

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SS t e p s 2 – 5 E l i m i n a t e Te c h n i c a l l y I n f e a s i b l e O p t i o n s , R a n k R e m a i n i n g C o n t r o l T e c h n o l o g i e s
b y C o n t r o l E f f e c t i v e n e s s , E v a l u a t e M o s t -E f f e c t i v e C o n t r o l s , a n d S e l e c t B A C T
The use of an LNB, good operating practices, and the use of natural gas as a supplemental fuel are
technically feasible for the TO. As they are the only control technologies listed, and as each method has a
variable control efficiency, no ranking of control technologies is necessary. There are no economic,
environmental, or energetic infeasibilities associated with implementing these three (3) control methods on
the TO. The use of an LNB, implementation of good operating practices, and use of natural gas as a
supplemental fuel are the only feasible and remaining control technologies and are therefore BACT for the
TO.
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6. EMISSION IMPACT ANALYSIS
6.1. Comparison to Modeling Thresholds
As noted in the emission calculations and described below, the proposed site-wide emission changes are
less than the UDAQ modeling thresholds contained in UAC R307-410-4. As a result, no criteria pollutant
modeling analysis is required.
Table 6-1 compares criteria pollutant total proposed emissions to applicable modeling thresholds contained
in R307-403-4 through 7, and R307-410-4.
Table 6-1. Projected Emissions Summary of the Project
Emission
Source PM10 PM2.5 NOX CO SO2 VOC HAPs CO2e
Thermal
Oxidizer 16.64 16.64 15.87 9.66 0.00 0.00 4.13 26,927
Roads 2.58E-03 2.58E-04 - - - - - -
Fugitives - - - - - 0.48 0.10 12.48
Total Project
Emissions 16.65 16.64 15.87 9.66 0.00 0.48 4.24 26,939
Modeling
Limit1 15 - 40 100 40 - See HAP
Summary -
Modeling
Required? Yes No No No No No No No
Major Source
Thresholds2,3 100 100 100 100 100 100 10/25 75,000
Exceeding
Major Source
Thresholds?
No No No No No No No No
1. Modeling Limit is stated in UDAQ Emissions Impact Assessment Guidelines under Table 1: Total Controlled
Emission Rates for New Sources
2. Major source thresholds are defined by 40 CFR section 51.165(a)(1)(iv)(A).
3. Total HAP Threshold is stated in 40 CFR Section 63.2 under definition of a Major Source.
The Plant’s emissions indicate that the project’s emission surpass UDAQ modeling thresholds for PM10.
Modeling is assumed to be conducted by UDAQ.9
9 R307-406-2
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7. NONATTAINMENT/MAINTENANCE AREAS - OFFSETTING
The Plant is located in Grand County in Utah. Grand County is classified as an attainment area for all criteria
pollutants. The UDAQ offset requirements in R307-403, R307-420, and R307-421 are not applicable to the
proposed modifications.
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8. APPLICABLE REGULATIONS
In accordance with UDAQ’s Form 1, this NOI air permit application includes a discussion of Federal and
State requirements and their applicability to the project. The regulations that Trinity reviewed include
NAAQS, State Implementation Plans (SIP), New Source Performance Standards (NSPS), and National
Emission Standards for Hazardous Air Pollutants (NESHAP) and Utah Air Quality Regulations.
8.1. General Introduction – Utah Regulations
Trinity evaluated the applicability of each rule under the UAC Title R307. The rules applicable to the
proposed Plant have been addressed in the table below.
Table 8-1. Evaluation of UDAQ Air Quality Rules (Specific to this Modification)
Reference Regulation Name Applicability
Yes No
R307-101 1 General Requirements X
R307-102 1 General Requirements: Broadly Applicable
Requirements X
R307-103 1 Administrative Procedures X
R307-104 Conflict of Interest X
R307-105 1 General Requirements: Emergency controls X
R307-107 General Requirements: Breakdowns X
R307-110 1 General Requirements: State Implementation
Plan X
R307-115 1 General Conformity X
R307-120 General Requirements: Tax Exemption for Air
Pollution Control Equipment X
R307-121 General Requirements: Clean Air and Efficient
Vehicle Tax Credit X
R307-122 General Requirements: Heavy Duty Vehicle Tax
Credit X
R307-123 General Requirements: Clean Fuels and Vehicle
Technology Grant and Loan Program X
R307-124 General Requirements: Conversion to Alternative
Fuel Grant Program X
R307-125 Clean Air Retrofit, Replacement, and Off-Road
Technology Program X
R307-130 General Penalty Policy X
R307-135 Enforcement Policy for Asbestos Hazard
Emergency Response Act X
R307-150 Emission Inventories X
R307-165 Emission Testing X
Wesco Operating, Inc. | NOI Air Permit Application 2
Trinity Consultants
Reference Regulation Name Applicability
Yes No
R307-170 Continuous Emission Monitoring Program X
R307-201 1 Emission Standards: General Emission Standards X
R307-202 Emission Standards: General Burning X
R307-203 Emission Standards: Sulfur Content of Fuels X
R307-204 Emission Standards: Smoke Management X
R307-205 Emission Standards: Fugitive Emissions and
Fugitive Dust X
R307-206 Emission Standards: Abrasive Blasting X
R307-207 Residential Fireplaces and Solid Fuel Burning
Devices X
R307-208 Outdoor Wood Boilers X
R307-210 2 Standards of Performance for New Stationary
Sources X
R307-214 2 National Emission Standards for Hazardous Air
Pollutants X
R307-220 Emission Standards: Plan for Designated
Facilities X
R307-221 Emission Standards: Emission Controls for
Existing Municipal Solid Waste Landfills X
R307-222 Emission Standards: Existing incinerator for
Hospital, Medical, Infectious Waste X
R307-223 Emission Standards: Existing Small Municipal
Waste Combustion Units X
R307-224 Mercury Emission Standards: Coal Fired Electric
Generating Units X
R307-230 NOX Emission Limits for Natural Gas-Fired Water
Heaters X
R307-250 Western Backstop Sulfur Dioxide Trading
Program X
R307-301 Utah and Weber Counties: Oxygenated Gasoline
Program as a Contingency Measure X
R307-302 Solid Fuel Burning Devices X
R307-303 Commercial Cooking X
R307-304 Solvent Cleaning X
R307-305 Nonattainment and Maintenance Areas for PM10:
Emission Standards X
R307-306 PM10 Nonattainment and Maintenance Areas:
Abrasive Blasting X
R307-307 Road Salting and Sanding X
Wesco Operating, Inc. | NOI Air Permit Application 3
Trinity Consultants
Reference Regulation Name Applicability
Yes No
R307-309 Nonattainment and Maintenance Areas for PM10
and PM2.5: Fugitive Emissions and Fugitive Dust X
R307-310 Salt Lake County: Trading of Emission Budgets
for Transportation Conformity X
R307-311 Utah County: Trading of Emission Budgets for
Transportation Conformity X
R307-312 Aggregate Processing Operations for PM2.5
Nonattainment Areas X
R307-320 Ozone Maintenance Areas and Ogden City:
Employer Based Trip Reduction X
R307-325 Ozone Nonattainment and Maintenance Areas:
General Requirements X
R307-326
Ozone Nonattainment and Maintenance Areas:
Control of Hydrocarbon Emissions in Petroleum
Refineries
X
R307-327 Ozone Nonattainment and Maintenance Areas:
Petroleum Liquid Storage X
R307-328 Gasoline Transfer and Storage X
R307-335 Degreasing X
R307-341 Ozone Nonattainment and Maintenance Areas:
Cutback Asphalt X
R307-342 Adhesives and Sealants X
R307-343 Wood Furniture Manufacturing Operations X
R307-344 Paper, Film, and Foil Coatings X
R307-345 Fabric and Vinyl Coatings X
R307-346 Metal Furniture Surface Coatings X
R307-347 Large Applicable Surface Coatings X
R307-348 Magnet Wire Coatings X
R307-349 Flat Wood Panel Coating X
R307-350 Misc. Metal Parts and Product Coating X
R307-351 Graphic Arts X
R307-352 Metal Container, Closure, and Coil Coatings X
R307-353 Plastic Parts Coatings X
R307-354 Automotive Refinishing Coatings X
R307-355 Aerospace Manufacture and Rework Facilities X
R307-356 Appliance Pilot Light X
R307-357 Consumer Products X
R307-361 Architectural Coatings X
Wesco Operating, Inc. | NOI Air Permit Application 4
Trinity Consultants
Reference Regulation Name Applicability
Yes No
R307-401 Permit: New and Modified Sources X
R307-403 Permits: New and Modified Sources in
Nonattainment and Maintenance Areas X
R307-405 Permits: Major Sources in Attainment or
Unclassified Areas (PSD) X
R307-406 Visibility X
R307-410 Permits: Emission Impact Analysis X
R307-414 Permits: Fees for Approval Orders X
R307-415 Permits: Operating Permit Requirements X
R307-417 Permits: Acid Rain Sources X
R307-420 Permits: Ozone Offset Requirements in Salt Lake
County and Utah County X
R307-421 Permits: PM10 Offset Requirements in Salt Lake
County and Utah County X
R307-424 Permits: Mercury Requirements for Electric
Generating Units X
R307-501 to
511 Oil and Gas Industry X
R307-801 Utah Asbestos Rule X
R307-840 Lead-Based Paint Program Purpose, Applicability,
and Definitions X
R307-841 Residential Property and Child-Occupied Facility
Renovation X
R307-842 Lead-Based Paint Activities X
1. The subject rule is applicable to the Plant; however, this rule is not specific to operational compliance
requirements, and is therefore not discussed in this NOI air permit application.
2. Applicable NSPS and NESHAP regulations are detailed under appropriate project headings.
8.1.2. UAC R307-107 General Requirements: Breakdowns
Wesco will report breakdowns at the Plant within 24 hours via telephone, electronic mail, fax, or other
similar method and provide detailed written description within 14 days of the onset of the incident to UDAQ.
8.1.3. UAC R307-205 Emission Standards: Fugitive Emissions and Fugitive Dust
Wesco will comply and conform to the definitions, terms, abbreviations, and references used in the UAC
R307-205 and 40 CFR.
8.1.4. UAC R307-305 Nonattainment and Maintenance Areas for PM10: Emission
Standards
Wesco will comply and conform to the definitions, terms, abbreviations, and references used in the UAC
R307-305 and 40 CFR.
Wesco Operating, Inc. | NOI Air Permit Application 5
Trinity Consultants
8.1.5. UAC R307-401-8: Approval Order
Wesco’s NOI air permit application for a new AO meets the conditions required under R307-401-8 for UDAQ
to approve the NOI air permit application.
(1) The director will issue an AO if all conditions and regulations have been met.
(a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust, is at
least best available control technology. When determining best available control technology for a
new or modified source in an ozone nonattainment or maintenance area that will emit VOC or NOX,
best available control technology shall be at least as stringent as any Control Technique Guidance
document that has been published by EPA that is applicable to the source.
(b) The proposed installation will meet the applicable requirements of:
(i) R307-403, Permits: New and Modified Sources in Nonattainment Areas and Maintenance
Areas;
(ii) R307-405, Permits: Major Sources in Attainment or Unclassified Areas (PSD);
(iii) R307-406, Visibility;
(iv) R307-410, Emissions Impact Analysis;
(v) R307-420, Permits: Ozone Offset Requirements in Davis and Salt Lake Counties;
(vi) R307-210, National Standards of Performance for New Stationary Sources;
(vii) National Primary and Secondary Ambient Air Quality Standards;
(viii) R307-214, National Emission Standards for Hazardous Air Pollutants;
(ix) R307-110, Utah State Implementation Plan; and
(x) All other provisions of R307.
(2) The AO requires that all pollution control equipment be adequately and properly maintained.
(3) Receipt of an AO does not relieve any owner or operator of the responsibility to comply with the
provisions of R307 or the State Implementation Plan.
The Long Canyon Helium Plant will establish and maintain compliance through the following:
(1) All pollution control equipment will be properly maintained; and
(2) Provisions of R307 or SIP will be followed.
BACT provisions specified in UAC R307-401 have been applied through control equipment installed and
monitoring conditions.
8.1.6. UAC R307-414-Permits: Fees for Approval Orders
Wesco will comply and conform to the definitions, terms, abbreviations, and references used in the UAC
R307-414 and 40 CFR.
8.1.7. UAC R307-501 through R307-511: Oil and Gas Industry
The Plant’s SIC code does not match those applicable to these rules. Therefore, they do not apply.
Wesco Operating, Inc. | NOI Air Permit Application 6
Trinity Consultants
8.2. Federal Regulations
The Plant is subject to NSPS Subpart Dc Small Industrial-Commercial-Institutional Steam Generating Units
and NESHAP Subpart JJJJJJ Industrial, Commercial, and Institutional Boilers Area Sources. However, this
rule is not specific to operational compliance requirements from the increased throughput described in this
project and is therefore not discussed in this NOI air permit application.
8.2.1. NSPS Subpart A: General Provisions
All affected sources subject to an NSPS are also subject to the general provisions of NSPS Subpart A unless
specifically excluded by the source-specific NSPS. NSPS Subpart A requires the following of facilities subject
to a source specific NSPS:
Ź Initial construction/reconstruction notification;
Ź Initial startup notification;
Ź Performance tests;
Ź Performance test date initial notification;
Ź General monitoring requirements;
Ź General recordkeeping requirements; and
Ź Semiannual monitoring system and/or excess emission reports.
8.2.2. NESHAP Subpart A: General Provisions
NESHAP Subpart A, General Provisions, applies to any stationary source which contains an affected facility,
whose construction or modification commenced after the date of publication of this part. The Plant will
comply with all pertinent provisions of this subpart.
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1. Attach process diagrams of the incinerators described on this form
2. Describe the source of waste:
3. Manufacturer of incinerator: 4. Model name and number:
5. Type of incinerator: Ƒ Flue Ƒ Single Chamber
Ƒ Multiple Chamber
6. Maximum amount of waste to be incinerated:
____________lb/hr
7. Estimated daily amount of waste to be
incinerated:_________lb
8. Height of stack above grade:__________ft
9. Height of tallest structures within 150 feet:
Feet
10. Primary burner used: Ƒ Yes Ƒ No
Maximum rating __________ BTU/hr
11. Secondary Burner used: Ƒ Yes Ƒ No Maximum rating _______________BTU/hr
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12. Type of waste to be incinerated:
Ƒ Type 0 Trash with 8,500 BTU/lb Ƒ Type 4 Human and animal parts, with 1,000 BTU/lb
85% moisture, 5% incombustible 10% moisture, 5% incombustible
Ƒ Type 1 Rubbish with 6,500 BTU/lb Ƒ Type 5 Industrial by-product wastes which are gaseous,
25% moisture, 10% incombustible liquid, & semi-liquid
Ƒ Type 2 Refuse with 4,300 BTU/lb Ƒ Type 6 Industrial solid byproduct waste rubber,
50% moisture, 7% incombustible plastic, wood wastes
Ƒ Type 3 Garbage with 2,500 BTU/lb Ƒ Type 7 Municipal sewage sludge wastes residue
70% moisture, 5% incombustible from processing of raw sludge
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13. Average operation time of incinerator: _____ hrs/day ______ days/week ______ weeks/year
14. Maximum operation time of incinerator: _____ hrs/day ______ days/week ______ weeks/year
15. Average Temperature: Primary ______
oF Secondary ______
oF
16. Residence time: Primary: _______seconds Secondary: _______ seconds
17. Type of feed to incinerator: Ƒ Manual Ƒ Ram Ƒ Other _____________________________
18. Proposed Control Technology:
Ƒ Quench Tower
Ƒ Heat Exchanger
Ƒ Dry Scrubber (attach DAQ Form 9)
Ƒ Wet Scrubber (attach DAQ Form 9)
Ƒ Baghouse (attach DAQ Form 10)
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19. Number of identical sources (describe)
20.$YHUDJH2SHUDWLRQ
Pollutants Concentration or emission rate per identical source Method used to determine
concentration or emission rate
Particulate matter
(PM10)gr/dscf Ƒ lb/106 BTU Ƒ lb/hr
Particulate matter
(PM2.5)gr/dscf Ƒ lb/106 BTU Ƒ lb/hr
Carbon monoxide
(CO)ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Nitrogen oxides
(NOx)ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Volatile organic
Compounds (VOCs) ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Sulfur dioxide (SO2) ppm (vol)
Ƒ lb/106 BTU Ƒ lb/hr
Carbon dioxide
(CO2)ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Methane (CH4) ppm (vol)Ƒ lb/106 BTU Ƒ lb/hr
Nitrous oxide (N2O) ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
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Contaminant Concentration or Emission Rate per Identical Source Method used to determine
concentration or emission rate
Particulate matter
(PM10)gr/dscf Ƒ lb/106 BTU Ƒ lb/hr
Particulate matter
(PM2.5)gr/dscf Ƒ lb/106 BTU Ƒ lb/hr
Carbon monoxide
(CO)ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Nitrogen oxides
(NOx)ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Volatile organic
Compounds (VOCs) ppm (vol) Ƒ lb/106 BTU Ƒ lb/hr
Sulfur dioxide (SO2) ppm (vol)
Ƒ lb/106 BTU Ƒ lb/hr
Carbon dioxide CO2) ppm (vol)
Ƒ lb/106 BTU Ƒ lb/hr
Methane (CH4) ppm (vol)
Ƒ lb/106 BTU Ƒ lb/hr
Nitrous oxide (N2O) ppm (vol)
Ƒ lb/106 BTU Ƒ lb/hr
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Arsenic pounds/hour Manganese pounds/hour
Barium pounds/hour Mercury pounds/hour
Cadmium pounds/hour Nickel pounds/hour
Hexavalent chromium pounds/hour Selenium pounds/hour
Total chromium pounds/hour Silver pounds/hour
Copper pounds/hour Tin pounds/hour
Lead pounds/hour Dioxins/furans pounds/hour
21.([KDXVW3RLQW,QIRUPDWLRQ
Flow diagram designation(s) of exhaust point(s):
Description of exhaust point (location in relation to buildings, direction, hooding, etc.):
Exhaust height above grade: Feet Exhaust diameter: Inches
Greatest height of nearby buildings: Feet Exhaust distance from nearest plant boundary: Feet
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Exhaust gas temperature:qF Exhaust gas temperature:qF
Gas flow rate through each exhaust point: Gas flow rate through each exhaust point:
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NOTE: 1. 6XEPLWWKLVIRUPLQFRQMXQFWLRQZLWK)RUPDQG)RUP
2. Call the Division of Air Quality (DAQ) atif you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to help!
1. Attach flow diagram of the described incinerator.
2. Please describe the source of waste to be incinerated.
3. Supply the name of the manufacturer of the incinerator.
4. Supply the model and number of the incinerator.
5. Indicate the type of incinerator.
6. Specify the maximum amount of waste to be incinerated.
7. Specify the daily amount of waste to be incinerated.
8. Indicate the height of the stack above ground level.
9. Indicate the height of tallest structure within 150 feet.
10. Supply the specifications for primary burner used.
11.Supply the specifications for secondary burner used.
12. Indicate the type of typical waste to be incinerated.
13. Supply the average operation time of the incinerator.
14. Supply the maximum operation time of the incinerator.
15. Supply the average temperature in the primary and secondary chambers.
16. Supply the residence time in the primary and secondary chambers.
17. Indicate what type of feed is used to load the incinerator.
18.Indicate the control technology to be use. Submit the corresponding form, if available, for the control
technology. Submit specifications for control technology which a form is not available for. Forms
available are the following:
Form 3 Afterburners
Form 4 Flares
Form 5 Adsorption Unit
Form 6 Cyclone
Form 7 Condenser
Form 8 Electrostatic Precipitators
Form 9 Scrubber
Form 10 Fabric Filter
19. Indicate how many incinerators units are being used.
20. Specify the concentration or emission rate of the listed contaminants for both the average and
maximum feed rate.
21. Supply the exhaust specifications listed.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form12 Incinerators.doc
Revised 12/20/10
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Appendix C - Paved Road Cost Analysis
Table C-1. Wesco - Inputs
Parameter Value Units Notes
Road width 27.00 ft Google Earth estimate.
Road length to pave 350 ft Standard UDAQ request.
Price of paving 2.50 $/square foot
Based on paving quotation provided on 04/19/2021. Estimate
includes preparing a road base.
Total cost of paving 23,625.00 $ Calculated
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Page 1 of 3
Trinity Consultants
Juȍˊ 2023
Appendix C - Paved Road Cost Analysis
Table C-2. Roads Emissions - Traveling Parameters (Supporting Operations)
Empty Single-
Trailer Trucks
Loaded Single-
Trailer Trucks Daily Annual
(tpy) (tons) (tons) (tons/haul) (miles/haul) (VMT/day) (VMT/yr)
Main Haul Road (Entry) 8,000   1  




Table C-3. Roads Emissions - Emission Factors
PM10 PM2.5
Unpaved None 0% 2.13 0.21
Unpaved Watering 70% 0.64 0.06
Unpaved Watering and Road Base 75% 0.53 0.05
Unpaved Chemical Suppressant and
Watering 85% 0.32 0.03
Paved Pave Road Surface with
Sweeping and Watering 90% 0.21 0.02
Unpaved Roads
Where,
where E = Size-specific emission factor (lb/VMT)
k, a, b = Constants for equation 1a
PM PM10 PM2.5
k = 4.90 1.50 0.15
a =0.70 0.90 0.90
b =0.45 0.45 0.45
s = surface material silt content (%)
s = 4.80
WHT =41.05 Mean haul truck weight (tons)
Table C-4. Main Haul Road Emissions - PTE Emissions
PM10 PM2.5 PM10 PM2.5
Unpaved, No Controls (Trucks) 0.28 0.03 1.72E-02 1.72E-03
Paved Roads 0.03 2.83E-03 1.72E-03 1.72E-04
2 Emission factors for vehicular traffic on unpaved roads for sand and gravel processing per U.S. EPA AP-42, Section 13.2.2 (Unpaved Roads),
November 2006.
Controls 1 Control Efficiency
(%)
Annual Emissions (tpy) = Miles Travelled per Day (VMT/yr) * Uncontrolled Emission Factor (lb/VMT) * (1 - ߟ)
Road Source1 Daily Emissions (lb/day)2 Annual Emissions (tpy)2
2 Daily and annual controlled emissions are calculated by applying the controlled emission factor (per UDAQ's control efficiencies) to the
vehicular miles traveled per day (paved and unpaved).
Daily Emissions (lb/day) = Miles Travelled per Day (VMT/day) * Uncontrolled Emission Factor (lb/VMT) * (1 - ߟ)
1 Calculations are made based on the paving of the Main Haul Road (Entry).
Per UDAQ Guidance on Paved and Unpaved Haul Roads, 2015.
1 Emission controls for vehicular traffic on paved and unpaved roads per UDAQ guidelines: Emission Factors for Paved and Unpaved Haul Roads,
January 2015.
Single Trailer Haul
Total Travel
Distance per
Haul
Total Vehicle Miles Traveled
/RDGHGYHKLFOHZHLJKW OE
Product Throughput
Mean Trailer Weight, Single Trailer
(tons)1
Road Surface
Haul Truck Emission Factor 2
(lb/VMT)
Haul/
Day2Road Source1
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Wesco Operating, Inc.
Long Canyon Helium Plant NOI Page 2 of 3
Trinity Consultants
Juȍˊ 2023
Appendix C - Paved Road Cost Analysis
Value Units Value Reference
PM10 Reduction %90% [1]
PM10 Unpaved Application tpy 0.02 [2]
PM10 Paved tpy 0.00 [3]
PM10 Reduced by Paving tpy 0.02 Calculated
Total Capital Cost $ $23,625 [4]
Capital Recovery Factor % 14.24% [5]
Annualized Cost $/yr $3,364 Calculated
Admin, Taxes, Insurance $/yr $945 [6]
Street Sweeping $/yr $36,777 [7]
Total Annual Cost $/yr $41,085 Calculated: Sum of Annualized Costs
Cost of Control $/ton removed $2,652,195 Calculated: Cost per ton removed
7%Per EPA Air Pollution Control Cost Manual,
Seventh Ed., 2017, Sect. 2.5.2, pg 14-17.
10
Per EPA's 2015 report of Construction and
Demolition Debris Generation in the United
States, Table 2.
14.24%Per EPA Air Pollution Control Cost Manual,
Seventh Ed., 2017, Sect. 2.5.4.2, pg 22.
6 Admin, Taxes, Insurance assumed to be:4.00%Per EPA Air Pollution Control Cost Manual,
Seventh Ed., 2017, Sect. 2.6.5.8, pg 2-35.
$190
Per Western Regional Air Partnership
(WRAP) Fugitive Dust Handbook, 2006,
Appendix B, pg B-1.
Capital Implementation Costs
Cost of Compliance (Statutory Factor 1)
Table C-5. Wesco - Haul Roads - Paving Cost Analysis
Paving Haul RoadsParameter
Potential PM10 Reduction
2 Per potential to Emit Calculation for haul truck travel on unpaved haul roads.
3 Per potential to Emit Calculation for haul truck travel on paved haul roads.
4 Based on quote from competitor, provided on 04/19/2021.
5 Capital Recovery factor (CRF) calculated as follows. Paving minus the cost of chemical application.
1 Per paved road surface with sweeping and watering control from UDAQ's Guidelines on "Emission Factors for Paved
and Unpaved Haul Roads", January 12, 2015.
Assumes that street sweeping is done four (4) times per day.
Capital Recovery Factor
Useful life of source
Interest Rate
7 Street Sweeping Costs
Wesco Operating, Inc.
Long Canyon Helium Plant NOI Page 3 of 3
Trinity Consultants
Juȍˊ 2023