DAQ-2024-011718

1
DAQC-CI129200001-24
Site ID 12920 (B1)

MEMORANDUM

TO: FILE – URBAN OIL AND GAS GROUP, LLC – Orangeville Natural Gas
Compressor Facility

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: November 13, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Emery County

INSPECTION DATE: September 23, 2024

SOURCE LOCATION: 39.24146516 -111.0940361
Orangeville, UT 84537

DIRECTIONS: 1095 North Highway 57. Head to Orangeville on Highway 29,
go through town and at the intersection take a right. At Highway
57 take a left and go one mile south of the Highway 29 and
Highway 57 junction, west of Orangeville. West side of
Highway 57.

SOURCE CONTACTS: Kirt Rasmussen:
435-820-9801
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: This facility extracts CO2, removes moisture, and compresses
the natural gas which is introduced to the sales pipeline. Natural
gas processed at this facility is also used to operate the on-site
boiler and tank heaters.

APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN129200009-22, dated
May 11, 2022

40 CFR Part 63 Subpart HH: National Emission Standards for
Hazardous Air Pollutants From Oil and Natural Gas Production
Facilities

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SOURCE EVALUATION:

Name of Permittee: Permitted Location:

Urban Oil and Gas Group, LLC
Orangeville Natural Gas Compressor Facility

1000 East 14th Street, Suite 300 39.24146516 -111.0940361
Plano, TX 75074 Orangeville, UT 84537

SIC Code: 1311: (Crude Petroleum & Natural Gas)

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]

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 R307-150 Series. Inventories, Testing and Monitoring.
[R307-150]

I.7 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

Status: In Compliance. The source reported that there had been no breakdowns that
resulted in excessive emissions. An emission inventory is currently not requested for this
facility in Emery County. Urban Oil and Gas Group, LLC provided records showing that
the dehydration unit is in compliance with its emission limits in 40 CFR Part 63 Subpart
HH. See attached record.

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Section II: SPECIAL PROVISIONS

II.A The approved installations shall consist of the following equipment:

II.A.1 Urban Oil and Gas Group, LLC
Orangeville Natural Gas Compressor Station

II.A.2 Boiler
Rating: 7.5 MMBtu/hr

II.A.3 Six (6) Storage Tanks
Contents: Organic Liquid

II.A.4 One (1) Storage Tank
Contents: Amine

II.A.5 Dehydrator
Rating: 1.0 MMBTU/hr

II.A.6 Listed for Informational Purposes Only
Five (5) Electric Compressor Motor
Rating: 1245 hp, 9.5 MMBTU/hr

Seven (7) Tank Heaters
Rating: 325,000 BTU/hr each

Status: In Compliance. There is only two (2) electric compressor engines on-site. The
amine unit was shut-in during the time of inspection. All other equipment is
on-site.

II.B Requirements and Limitations

II.B.1 Facility-Wide Requirements and Limitation

II.B.1.a The owner/operator shall not allow visible emissions to exceed the following limits:

A. Tank heaters - 10% opacity

B. Other stationary point or fugitive emission source associated with the source or with
the control facilities - 20% opacity. [R307-201-3, R307-401-8]

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

Status: In Compliance. Records reviewed by Kirt Rasmussen, with Urban Oil and Gas
Group, LLC, show that there have been no observations of visible emissions exceeding the
site’s limits. There have been no public complaints of the source having visible emissions in
the DAQ records.

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II.B.2 Fuel

II.B.2.a The owner/operator shall use pipeline quality natural gas as fuel in all-natural gas combustion
units. [R307-401-8]

Status: In Compliance. Kirt Rasmussen, with Urban Oil and Gas Group, LLC, has
confirmed that only natural gas is used to fuel the boiler, dehydrator, and tank heaters
on-site.

Section III: APPLICABLE FEDERAL REQUIREMENTS

In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including
UAC R307.

40 CFR Part 63 Subpart HH: — National Emission Standards for Hazardous Air Pollutants From
Oil and Natural Gas Production Facilities

Status: In Compliance. The records showing that the actual average emissions of benzene from the
glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year have
been provided. This meets the compliance requirements of 40 CFR 63.764(e)(1) to show that the
dehydrator is exempt from the emission requirements of Subpart HH as stated in 40 CFR
63.764(e)(1)(ii). See attached records.

EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Urban Oil and Gas
Group, LLC – Orangeville Natural Gas Compressor Facility on the Approval Order (AO)
DAQE-AN129200009-22, dated May 11, 2022. PTE are supplied for supplemental purposes only.

Criteria Pollutant PTE tons/yr
CO2 Equivalent 3888.00
Carbon Monoxide 3.77
Nitrogen Oxides 4.49
Particulate Matter - PM10 0.34
Particulate Matter - PM2.5 0.34
Sulfur Dioxide 0.02
Volatile Organic Compounds 13.94

Hazardous Air Pollutant PTE lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 180
Ethyl Benzene (CAS #100414) 160
Hexane (CAS #110543) 460
Toluene (CAS #108883) 160
Xylenes (Isomers And Mixture) (CAS #1330207) 80

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PREVIOUS ENFORCEMENT
ACTIONS: None

COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN129200009-22,
dated May 11, 2022, the overall status is: In Compliance. The
dehydration unit has an average emissions of benzene less than
0.90 megagrams per year. This is in compliance with the
emission limits of 40 CFR Part 63 Subpart HH.

HPV STATUS: Not Applicable.

RECOMMENDATION FOR
NEXT INSPECTION: Not Applicable

NSR RECOMMENDATIONS: Not Applicable

ATTACHMENTS: Dehydration Unit’s Average Emissions Record
Case Name: Orangeville #1
File Name:
Date:
Description:
3.10 MMSCFD
1.45 lb/MMSCF
0.22 sgpm
3.00 gal/lb
8760 hrs
100.00
34.75
70.00
600.00
3.10
3.00
14.300
95.000
99.000
12.66
0.00
0.80
83.65
1.94
0.70
0.14
0.06
0.02
0.01
0.00
0.01
0.00
0.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Total 100.00
Component lbs/hr lbs/day tons/yr
1.68 40.44 7.38
0.00 0.00 0.00
0.00 0.04 0.01
0.32 7.70 1.41
0.05 1.14 0.21
0.05 1.11 0.20
0.02 0.36 0.07
0.01 0.26 0.05
0.01 0.16 0.03
0.00 0.08 0.01
0.00 0.00 0.00
0.01 0.16 0.03
0.00 0.11 0.02
0.01 0.22 0.04
0.01 0.17 0.03
0.00 0.01 0.00
0.04 0.91 0.17
0.09 2.10 0.38
0.00 0.00 0.00
0.05 1.22 0.22
0.04 0.88 0.16
0.03 0.81 0.15
0.22 5.34 0.97
0.00 0.00 0.00
4.30 103.16 18.83
0.00 0.00 0.00
0.00 0.00 0.00
0.00 0.00 0.00
Total Emissions 6.93 166.41 30.37
Total HC Emissions 0.95 22.77 4.15
Total VOC Emissions 0.58 13.92 2.54
Total HAP Emissions 0.25 6.10 1.11
Total GHG Emissions 2.01 48.14 8.79
ProMax Dehydration Emissions Report
C:\Users\dpalmer\OneDrive - h2eincorporated.com\Desktop\ProMax\Dehydration Tool\Orangeville 1 Dehy
Model_0924_2024\ProMax_Dehydration_Tool.pmx
Dry Gas Flow Rate
Dry Gas Water Content
Glycol Circulation Rate
Glycol Circulation Ratio
Pressure (psig)
Flow Rate (MMSCFD)
Lean Glycol Specifications
Glycol Circulation Ratio (gal/lb)
Annual Operating Hours
INPUT SUMMARY:
Feed Stream Specifications
Fraction of Water Saturaton (%)
Water Content (lbm/MMSCF)
Temperature (°F)
General Specifications
Atmospheric Pressure (psia)
Flash Gas Flare Destruction Efficiency (%)
Regenerator Flare Destruction Efficiency (%)
Feed Composition Data (mol %)
Carbon Dioxide
Hydrogen Sulfide
SO2
EMISSIONS REPORTS:
n-Hexane
Cyclohexane
n-Heptane
Methylcyclohexane
p-Xylene
Triethylene Glycol
Ethylene Glycol
Water
Methanol
O2
2,2,4-Trimethylpentane
Benzene
Toluene
Ethylbenzene
o-Xylene
m-Xylene
SO2
i-Butane
n-Butane
i-Pentane
n-Pentane
Nitrogen
Methane
Ethane
Propane
i-Butane
n-Butane
i-Pentane
n-Pentane
Cyclopentane
Nitrogen
Methane
Ethane
Propane
COMBINED REGENERATOR VENT/FLASH GAS EMISSIONS
Carbon Dioxide
Hydrogen Sulfide
Benzene
Toluene
Ethylbenzene
o-Xylene
m-Xylene
p-Xylene
Cyclopentane
n-Hexane
Cyclohexane
n-Heptane
Methylcyclohexane
2,2,4-Trimethylpentane
Triethylene Glycol
Ethylene Glycol
Water
Methanol
O2