DAQ-2024-010444

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DAQC-935-24
Site ID 14185 (B1)

MEMORANDUM

TO: FILE – DANISH FLATS WASTE DISPOSAL, LLC (Formerly OWL SWD
OPERATING, LLC)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: September 16, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Grand County,
FRS ID# UT0000004901900046

INSPECTION DATE: September 3, 2024

SOURCE ADDRESS: Remote location north of Cisco, UT
UTM coordinates 648,198 m Easting, 4,327,028 m Northing,
UTM Zone 12

MAILING ADDRESS: Jon Gaza
1540 P Road, Loma, CO 81524

SOURCE CONTACT: Jon Gaza, Owner: [phone]

SOURCE DIRECTIONS: Take I-80 to exit 214 Danish Flats. Turn left onto Cottonwood
Road (Highway 28). Continue straight for 2.5 miles. Take a
slight right onto Agate Oil Road. Travel 0.2 miles to the site. The
site is visible from a distance.

OPERATING STATUS: Not operating at time of inspection.

PROCESS DESCRIPTION: OWL SWD Operating, LLC/Danish Flats (Danish Flats)
operates a produced water evaporation pond operation. The
approved facility will operate as follows: Produced water
received by this operation is pretreated with separation tanks,
separation vaults, and an air stripper before entering the
evaporation ponds. The emissions from the pretreatment
processes are controlled by a combustor. The evaporation ponds
are repositories of treated water where the water and remaining
contaminants are evaporated. Condensate is collected from the
produced water during the pretreatment process and is stored in
condensate tanks that are controlled by the combustor.

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APPLICABLE
REGULATIONS: TVOP #1900046001, dated February 28, 2020
40 CFR 60 Subpart A-General Provisions, 40 CFR 60 Subpart
JJJJ-Standards of Performance for Stationary Spark Ignition
Internal Combustion Engines – incorporated into AO

40 CFR 63 Subpart A-General Provisions and 40 CFR 63
Subpart ZZZZ-National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE)-incorporated into AO

SOURCE INSPECTION
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements." (R307-415-6b)

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: See status of each condition below for details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the director, within a reasonable time, any information that
the director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))
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I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: See specific conditions below for compliance status.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In Compliance. The application for renewal was received August 27, 2024. No Permit has
been issued and the company is operating under the permit shield.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to
R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the
deadline specified in writing by the director any additional information identified as being
needed to process the application. (R307-415-7b(2))

Status: In Compliance. The application for renewal was received August 27, 2024. No Permit has
been issued and the company is operating under the permit shield.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

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I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: The permittee paid its emission inventory fee on September 30, 2023.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In Compliance. Entry was allowed.

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I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In Compliance. The certification statement has been included where required and is signed by
approved officials.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports):
(R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address, or to such other address as may be required by the director:
(R307-415-6c(5)(d))

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Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In Compliance. Compliance certifications have been submitted as required. The latest annual
certification was received April 12, 2024. Certifications are reviewed and approved by DAQ.
Reports are kept in the main source files.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: Permit shields, if applicable, are listed in Section III below.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

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I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the director within two working
days of the time when emission limitations were exceeded due to the emergency.
This notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken. This notice fulfills the requirement of
Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: No emergency events were reported during the 12-month period prior to this inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: Not Evaluated. This is a statement of fact and not an inspection item.

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I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

I.S.2.c The director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

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I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the director are to be sent to the following address, or to such other
address as may be required by the director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses, or to such
other address as may be required by the director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation
Program (mail code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In Compliance. Six-month reports have been submitted in the past year. Reports are reviewed
by DAQ staff and are in main source files.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

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I.T.1.c EPA or the director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

Status:
An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

In Compliance. The last inventory in SLEIS is dated April 10, 2024.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: Not Evaluated. This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Enclosed Combustor
One natural gas or propane-fired enclosed combustor rated at 1.0 MMBtu/hr. The combustor controls
emissions from all storage tanks.

II.A.3 De-sanding Tank
One tank, 500 bbl, contains produced water and is designed to capture suspended solids. Emissions are
controlled by the enclosed combustor.

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II.A.4 Separation/Surge Tanks
Four tanks, 1,000 bbl each, contain produced water and provide primary oil/water phase separation.
Emissions are controlled by the enclosed combustor.

II.A.5 Gun Barrel Tanks
Two tanks, 500 bbl each, contain produced water and provide secondary separation. Emissions are
controlled by the enclosed combustor.

II.A.6

Oil Storage Tanks
Four tanks, 400 bbl each, contain condensate/oil. Emissions are controlled by the enclosed combustor.

II.A.7 Slop Oil Tank
One tank, 400 bbl, contains condensate/oil/solids. Emissions are controlled by the enclosed combustor.

II.A.8 Storage Tanks
Unit includes the de-sanding tank, gun barrel tanks, separation/surge tanks, oil storage tanks, and slop oil
tank.

II.A.9 Phase I Shallow Evaporation Ponds
Eight ponds, each 8 feet deep.

II.A.10 Phase 2 Deep Evaporation Ponds
Six ponds, 18 feet deep.

II.A.11 Truck Offloading/Loadout
Produced water is offloaded from tanker trucks in one of four offloading bays and pumped to the de-
sanding tank. Condensate/oil from the oil storage tanks is loaded onto tanker trucks and transported
offsite. The permittee shall load and unload all tanker trucks on site by the use of submerged loading.

II.A.12 Generators
Five propane-fired generators are used to power the facility: one rated at 70 kW (94 hp) and four rated at
125 kW (168 hp) each. The generators shall burn only propane or natural gas as fuel. [See Reviewer
Comment 5.] The generators are 4 stroke rich burn (4SRB) non-emergency spark ignition (SI) internal
combustion engines (ICE).

II.A.13 Roads, Unpaved Operational Areas, and Truck Pad
Trucks access the plant from an unpaved county road. Offloading bays are on a concrete apron and the
remaining drive through offloading area is unpaved.

Status: In Compliance. No unapproved equipment was noted. All equipment is correct except: II.A.9 and
II.A.10, one 8-foot pond and one 18-foot pond on site, II.A.12 only two generators on site – one 70
KW for office and one 25 KW for truck off loads. The current NOI and engineering review adds in
the three propane tanks which were previously on site and included in original NOI.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on Permitted Source (Source-wide)

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II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, 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. [Origin: DAQE-AN141850008-18]. [R307-401-8(2)]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be kept of all maintenance performed on permitted plant equipment. Records shall
be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. Maintenance records are maintained in database forms. Forms are available
during the inspection.

II.B.1.b Condition:

1) Combined emissions of Gasoline Range Organics (GRO) + Diesel Range Organics (DRO) from water
sent to the evaporation ponds shall not exceed 210.3 tons per rolling 12-month period. GRO shall be
considered the measurement of organics in the C6 - C10 range and DRO shall be considered the
measurement of organics in the C11 - C28 range.

2) Combined HAP emissions (excluding methanol) from water sent to the evaporation ponds shall not
exceed 20.66 tons per rolling 12-month period. [Origin: DAQE-AN141850008-18]. [R307-401-8]

II.B.1.b.1 Monitoring:

a) The permittee shall collect, handle, and analyze a sample of processed water as follows:

i. Sample shall be collected at the outfall of the treatment process prior to water being
discharged into the evaporation ponds. The sample shall be collected from the first batch
of water discharged during each calendar month.

ii. Sample shall be no less than eight ounces in volume.

iii. Sample shall be analyzed no less than seven days after collection. Prior to analysis,
samples shall be stored at a temperature no less than 32 degrees F and no more than 40
degrees F.
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iv. Samples shall be analyzed for methanol, BTEX, TPH-GRO (C6 - C10), and TPH-DRO
(C11 - C28) using appropriate EPA methods such as Method 8260 or 8015, or other EPA-
approved method as acceptable to the director.

If plant operations have been suspended for an entire calendar month, sampling is not
required. When operations resume, a sample shall be collected and analyzed as required
above.

b) The volume of produced water received shall be determined on a daily basis using billable
receipts.

c) Combined VOC (GRO + DRO), HAPs (excluding methanol), and methanol emissions shall
be calculated using the following formulas:
VOC (tons) = (water volume) x (VOC HAP BTEX + GRO + DRO sampled concentrations)
HAPs (tons) = (water volume) x (BTEX sampled concentrations)
Methanol (tons) = (water volume) x (methanol sampled concentration)

d) Compliance with each limitation shall be demonstrated with a rolling 12-month total. By the
last day of each month, the permittee shall calculate a new 12-month total using data from the
previous 12 months.

II.B.1.b.2 Recordkeeping:

Records of produced water received shall be kept for all periods when the plant is in operation.
Records of methanol emissions shall be kept on a monthly basis. All records and results of
monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

If plant operations have been suspended, the permittee shall record in a log the date operations are
suspended and the date operations are resumed.

II.B.1.b.3 Reporting:

The rolling 12-month totals shall be submitted semi-annually to DAQ, Attn: Compliance Section.
Documentation supporting the 12-month total shall be included and shall, at a minimum, include:
sampling reports, variables used to calculate emissions, and calculations. There are no additional
reporting requirements for this provision except those specified in Section I of this permit.

Status: In Compliance. The rolling totals are submitted semi-annually. The last report was received
April 15, 2024. The 12-month total of GRO + DRO ending February 28, 2024, was 7.993 tons and
HAP (BTEX) was 0.3799 tons. The seven-day analysis time has been changed to 14 days in the
recent AO.

II.B.1.c

Condition:

1) General requirements for prevention of emissions and use of good air pollution control practices.

(a) All crude oil, condensate, and intermediate hydrocarbon liquids collection, storage, processing
and handling operations, regardless of size, shall be designed, operated, and maintained so as to
minimize emission of volatile organic compounds to the atmosphere to the extent reasonably
practicable.

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(b) At all times, including periods of start-up, shutdown, and malfunction, the installation and air
pollution control equipment shall be maintained and operated in a manner consistent with good
air pollution control practices for minimizing emissions.

(c) Determination of whether or not 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, infrared camera images, opacity observations, review of
operating and maintenance procedures, and inspection of the source.

2) General requirements for air pollution control equipment.

(a) All air pollution control equipment shall be operated and maintained pursuant to the
manufacturing specifications or equivalent to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices.

(b) In addition, all such air pollution control equipment shall be adequately designed and sized to
achieve the control efficiency rates established in rules or in approval orders issued under
R307-401 and to handle reasonably foreseeable fluctuations in emissions of VOCs during
normal operations. Fluctuations in emissions that occur when the separator dumps into the tank
are reasonably foreseeable. [Origin: R307-501-4]. [R307-501-4]

II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.c.2 Recordkeeping:

The permittee shall keep manufacturer specifications or equivalent on file and shall document
activities performed to assure proper operation and maintenance. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The air pollution control equipment is installed, and maintenance was completed in
2023. Source was not operating at the time of this inspection.

II.B.2 Conditions on Enclosed Combustor

II.B.2.a Condition:

The combustor shall operate with a continuous pilot flame and be equipped with an operational auto-
igniter. [Origin: DAQE-AN141850008-18, R307-503]. [R307-503-4]

II.B.2.a.1 Monitoring:

The pilot flame shall be monitored using a thermocouple or any other equivalent device to detect
the continuous presence of a flame. The combustor shall be operated and maintained in
accordance with the manufacturer's specifications. Records required for this permit condition will
15
also serve as monitoring.

If plant operations have been suspended and operation of the affected emission unit has been
suspended, monitoring is not required. Monitoring shall be performed before resuming
operations.

II.B.2.a.2 Recordkeeping:

Records shall be kept that demonstrate the combustor operates with a continuous pilot flame. The
permittee shall maintain records of the manufacturer's specifications for the combustor and
document activities performed to assure proper operation and maintenance. The permittee shall
maintain records of the date of installation and manufacturer specifications for the auto-igniter.
The records shall be maintained in accordance with Provision I.S.1 of this permit.

If plant operations have been suspended and operation of the affected emission unit has been
suspended, the permittee shall record in a log the date operations are suspended and the date
operations are resumed.

II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The combustor was not operating during this inspection. The combustor had a
pilot light but has not fired off gas for several months due to low volumes. The ignition control is
set at 5 oz, but normal operations have been at 2 oz or less.

II.B.2.b Condition:

The combustor shall operate with no visible emissions. [Origin: DAQE-AN141850008-18].
[R307-401-8]

II.B.2.b.1 Monitoring:

Visible emission observations shall be conducted once each month, while the combustor is
operating. The observation period shall be 2 hours and shall be conducted using 40 CFR 60,
Appendix A, Method 22. The observer shall be trained and knowledgeable with respect to the
general procedures for determining the presence of visible emissions as specified in Method 22,
Section 2.3.

If plant operations have been suspended and operation of the affected emission unit has been
suspended, monitoring is not required.

II.B.2.b.2 Recordkeeping:

The date, time, and results of visible emission observations shall be recorded and maintained in
accordance with Provision I.S.1 of this permit.

If plant operations have been suspended and operation of the affected emission unit has been
suspended, the permittee shall record in a log the date operations are suspended and the date
operations are resumed.
16
II.B.2.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The combustor was not operating during this inspection. Maintenance and repairs
to the combustor were completed in 2023. Monthly VEOs are completed.

II.B.3 Conditions on Storage Tanks

II.B.3.a Condition:

The permittee shall keep the storage tank thief hatches and other tank openings closed and sealed except
during tank unloading or other maintenance activities. [Origin: DAQE-AN141850008-18]. [R307-401-8]

II.B.3.a.1 Monitoring:

If produced water or any intermediate liquids and products are contained in a storage tank, the
permittee shall inspect the thief hatches and other tank openings at least once each month to
ensure they are closed, latched, and the associated gaskets are in good working condition.

If plant operations have been suspended and the storage tank contains no produced water or any
intermediate liquids and products, monitoring is not required. Monitoring shall be performed
before resuming operations.

II.B.3.a.2 Recordkeeping:

Records shall include the date of the inspection, the status of the thief hatches and other tank
openings, and any maintenance performed. Records shall be maintained in accordance with
Provision I.S.1 of this permit.

If plant operations have been suspended and the storage tank contains no produced water or any
intermediate liquids and products, the permittee shall record in a log the date operations are
suspended and the date operations are resumed.

II.B.3.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. Maintenance logs confirm compliance. The operator has a log sheet which shows all
required items.

II.B.3.b Condition:

Crude oil production shall not exceed 23,000 barrels (1 barrel = 42 gallons) per rolling 12-month period.
[Origin: DAQE-AN141850008-18]. [R307-401-8]

17
II.B.3.b.1 Monitoring:

Compliance with the limitation shall be demonstrated with a rolling 12-month total. By the last
day of each month, the permittee shall calculate a new 12-month total using data from the
previous 12 months. Production shall be determined by sales data, recorded via sales receipts.

II.B.3.b.2 Recordkeeping:

Records of crude oil sales shall be kept on a daily basis for all periods when the facility is in
operation. Records and results of monitoring shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.3.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. For the period ending February 1, 2023, the 12-month rolling total was 914 barrels.
No oil sales have occurred since the 2023 entry. Totals are submitted with the semi-annual report.
New Engineering review adds submerged loading. This is confirmed during NOI process.

II.B.3.c

Condition:

Exhaust gas/vapors from all storage tanks on site shall be routed to the operating combustor. [Origin:
DAQE-AN141850008-18]. [R307-401-8]

II.B.3.c.1 Monitoring:

If produced water or any intermediate liquids and products are contained in a storage tank, the
permittee shall inspect each storage tank monthly to ensure exhaust gas and vapors are being
captured and routed to the operating combustor and that the capture and routing system is being
adequately maintained.

If plant operations have been suspended and the storage tank contains no produced water or any
intermediate liquids and products, monitoring is not required. Monitoring shall be performed
before resuming operations.

II.B.3.c.2 Recordkeeping:

Results of each monthly inspection shall be kept in a log. Records shall include identification of
each storage tank, verification that tank emissions are being captured and routed to the operating
combustor, documentation of required maintenance, and documentation of maintenance
performed. Records shall be maintained in accordance with Provision I.S.1 of this permit.

If plant operations have been suspended and the storage tank contains no produced water or any
intermediate liquids and products, the permittee shall record in a log the date operations are
suspended and the date operations are resumed.

18
II.B.3.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. The plant was not operating. Overhead piping from the tanks shows all emissions
go to the combustor.

II.B.4 Conditions on Generators

II.B.4.a Condition:

Visible emissions shall not exceed 10 percent opacity. [Origin: DAQE-AN141850008-18]. [R307-401-8]

II.B.4.a.1 Monitoring:

In lieu of monitoring via visible emission observations, records required for this permit condition
will serve as monitoring.

II.B.4.a.2 Recordkeeping:

Records shall be kept for any period that a fuel other than propane is used in the affected
emission unit. The records shall be recorded in a log that is kept in a readily accessible location
onsite. All records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. Only two generators are in use. Inspection showed no connections other than
propane.

II.B.4.b

Condition:

(1) Stationary SI ICE with a maximum engine power greater than 19 KW (25 HP) manufactured on or
after July 1, 2008, that are rich burn engines that use LPG shall comply with the emission standards
in 40 CFR 60.4231(c).

(2) For stationary SI ICE that are required to meet standards that reference 40 CFR 1048.101 the
permittee shall, if testing their engines in use, meet the standards in that section applicable to field
testing.

(3) The permittee shall operate and maintain stationary SI ICE that achieve the emission standards as
required in 40 CFR 60.4233 over the entire life of the engine.

(4) After July 1, 2010, the permittee shall not install stationary SI ICE with a maximum engine power of
less than 500 HP that do not meet the applicable requirements in 40 CFR 60.4233.

19
(5) In addition to the requirements specified in 40 CFR 60.4231 and 40 CFR 60.4233, it is prohibited to
import stationary rich burn LPG SI ICE that do not meet the applicable requirements specified in 40
CFR 60.4233 after July 1, 2010.

[Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4233(c), 40 CFR 60.4233(h), 40 CFR 60.4234, 40 CFR
60.4236(a), 40 CFR 60.4236(d), 40 CFR 63 Subpart ZZZZ]

II.B.4.b.1 Monitoring:

(a) The permittee shall comply with the emission standards specified in 40 CFR 60.4233(c) by
purchasing an engine certified to the emission standards in 40 CFR 60.4231(c), for the same
engine class and maximum engine power. In addition, the permittee shall meet one of the
requirements specified in (a)(1) and (2) of this section.

(1) If the permittee operates and maintains the certified stationary SI internal combustion
engine and control device according to the manufacturer's emission-related written
instructions, the permittee shall keep records of conducted maintenance to demonstrate
compliance, but no performance testing is required. The permittee shall also meet the
requirements as specified in 40 CFR part 1068, subparts A through D, as they apply. If
the permittee adjusts engine settings according to and consistent with the manufacturer's
instructions, the affected emission unit will not be considered out of compliance.

(2) If the permittee does not operate and maintain the certified stationary SI internal
combustion engine and control device according to the manufacturer's emission-related
written instructions, the engine will be considered a non-certified engine, and the
permittee shall demonstrate compliance according to (a)(2)(i) through (ii) of this
section, as appropriate.

(i) If the affected emission unit is less than 100 HP, the permittee shall keep a
maintenance plan and records of conducted maintenance to demonstrate compliance
and shall, to the extent practicable, maintain and operate the engine in a manner
consistent with good air pollution control practice for minimizing emissions, but no
performance testing is required.

(ii) If the affected emission unit is greater than or equal to 100 HP and less than or
equal to 500 HP, the permittee shall keep a maintenance plan and records of
conducted maintenance and shall, to the extent practicable, maintain and operate the
engine in a manner consistent with good air pollution control practice for
minimizing emissions. In addition, the permittee shall conduct an initial
performance test within 1 year of engine startup to demonstrate compliance.

(b) For affected emission units less than or equal to 500 HP, if the permittee purchases a non-
certified engine or the permittee does not operate and maintain the certified affected
emission unit and control device according to the manufacturer's written emission-related
instructions, the permittee is required to perform initial performance testing as indicated in
this section, but the permittee is not required to conduct subsequent performance testing
unless the stationary engine is rebuilt or undergoes major repair or maintenance.

(c) The permittee shall conduct performance tests in accordance with the procedures in 40 CFR
60.4244(a) through (f).

20
(d) The air-to-fuel ratio (AFR) controller, if used, shall be maintained and operated
appropriately in order to ensure proper operation of the engine and control device to
minimize emissions at all times.

(40 CFR 60.4243(a), (f), (g)).

II.B.4.b.2

Recordkeeping:

(a) The permittee shall keep records of the information in paragraphs (a)(1) through (4).

(1) All notifications submitted to comply with 40 CFR 60 Subpart JJJJ and all
documentation supporting any notification.

(2) Maintenance conducted on each engine.

(3) If the affected emission unit is a certified engine, documentation from the manufacturer
that the engine is certified to meet the emission standards and information as required in
40 CFR parts 90, 1048, 1054, and 1060, as applicable.

(4) If the affected emission unit is not a certified engine or is a certified engine operating in
a non-certified manner and subject to section (a)(2) of the monitoring condition,
documentation that the engine meets the emission standards.
(Origin: 40 CFR 60.4245(a))

(b) The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart JJJJ for the respective model year engine.

All records and results of monitoring shall be maintained in accordance with 40 CFR 60.4245 and
Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

For affected emission units that are subject to performance testing, the permittee shall submit a
copy of each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has
been completed. (40 CFR 60.4245(d)).

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In Compliance. Previous inspections confirmed that all engines have certification plates. All
maintenance is completed based on manufacturers guidelines which meet or exceed NSPS
requirements.

II.B.5

Conditions on Roads, Unpaved Operating Areas, and Truck Pad

II.B.5.a Condition:

Visible emissions shall not exceed 20 percent opacity from the haul-road and mobile equipment in
operational areas. [Origin: DAQE-AN1411850008-18, R307-205]. [R307-401-8]
21
II.B.5.a.1 Monitoring:

A visual opacity survey shall be performed on a weekly basis by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions are observed,
an opacity determination shall be performed by a certified observer and shall use procedures
similar to Method 9. The normal requirement for observations to be made at 15-second intervals
over a six-minute period, however, shall not apply. Visible emissions shall be measured at the
densest point of the plume but at a point not less than 1/2 vehicle length behind the vehicle and
not less than 1/2 the height of the vehicle.

Additionally, a maximum haul road speed limit of 15 miles per hour shall be posted within 50
feet of the entrance to the permittee's property.

If plant operations have been suspended on roads and other operational areas, monitoring is not
required.

II.B.5.a.2 Recordkeeping:

A log of visual opacity survey(s) shall be maintained containing the following information for
each observed visible emission: date and time visible emissions observed, emission point location
and description, time and date of opacity test, and percent opacity. All data required by 40 CFR
60, Appendix A, Method 9 shall also be maintained. Records and results of monitoring shall be
maintained in accordance with Provision I.S.1 of this permit.

If plant operations on roads and other operational areas have been suspended, the permittee shall
record in a log the date operations are suspended and the date operations are resumed.

II.B.5.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In Compliance. Site staff indicated that the haul road is owned by the county, so weekly readings of
the haul road are not taken. The mobile equipment area is covered with gravel. Weekly readings of
the operational areas are maintained. A speed limit sign is posted.

II.B.5.b

Condition:

All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water
sprayed to control fugitive dust. The application of water shall be used except when the ambient
temperature is below freezing. Treatment shall be of sufficient frequency and quantity to meet the opacity
limits listed in this permit, or as determined necessary by the director.
[Origin: DAQE- AN1411850008-18]. [R307-401-8]

II.B.5.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

22
II.B.5.b.2 Recordkeeping:

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

a) Date of treatment

b) Number of treatments made

c) Records of temperature if the temperature is below freezing

The permittee shall maintain records in accordance with Provision I.S.1 of this permit.

If plant operations on roads and other operational areas have been suspended, the permittee shall
record in a log the date operations are suspended and the date operations are resumed.

II.B.5.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Not Applicable. The entire operational area is freshly graveled to minimize dust.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

Engineering Review RN141850011.

This review is for project to update equipment list and to change sample analyzed time to 14 days from
the current 7 day limit. Submerged filling of tanks is also added. See condition above for specifics.

23
EMISSIONS INVENTORY: 2023 Emissions Inventory (Tons)

Pollutant Tons/Year
PM10 0.009
PM2.5 0.002
SO2 0.0002
NOX 0.134
VOC 29.86
CO 0.268
Methanol: 17.91
Toluene: 0.12
Xylenes: 0.36
Benzene: 0.02
Ethyl Benzene: 0.03

PREVIOUS ENFORCEMENT
ACTIONS: Warning Letter dated April 26, 2023 (DAQC-084-23).

COMPLIANCE STATUS &
RECOMMENDATIONS: Danish Flats Waste Disposal, LLC should be found in
compliance with the conditions evaluated in the Title V permit
and Approval Order, during this inspection cycle.

HPV STATUS: Not Applicable

COMPLIANCE ASSISTANCE: None

RECOMMENDATION
FOR NEXT INSPECTION: Note company has changed ownership. Inspect as usual. Call
before inspection as this is a remote site and not manned every
day.

ATTACHMENTS: VEO sheet