DAQ-2024-010415

DAQE-AN156680002-24

{{$d1 }}

Doug Betts
Water Disposal Inc.
2285 Lucky John Drive
Park City, UT 84060-6914
[e-mail]

Dear Mr. Betts:

Re: Approval Order: Minor Modification to Approval Order DAQE-AN156680001-17 to Increase
Crude Oil Production
Project Number: N156680002

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on December
20, 2023. Water Disposal Inc. 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: TriCounty Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

August 13, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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

APPROVAL ORDER
DAQE-AN156680002-24
Minor Modification to Approval Order DAQE-AN156680001-17
to Increase Crude Oil Production

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

Issued to
Water Disposal Inc. - Produced Water Disposal Facility

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

August 13, 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-AN156680002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Water Disposal Inc. Water Disposal Inc. - Produced Water Disposal
Facility

Mailing Address Physical Address
2285 Lucky John Drive
Park City, UT 84060-6914
Located 0.6 Miles along North Crescent Road
From Intersection of 2000 West & North
Crescent Road
Duchesne County, UT 84066

Source Contact UTM Coordinates
Name: Doug Betts 583,018 m Easting
Phone: [phone],467,513 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

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

SOURCE INFORMATION
General Description
Water Disposal Inc. (WDI) owns and operates a produced water treatment facility located approximately
4 miles northwest of Roosevelt in Duchesne County. Produced water is received by truck from oil and gas
operations and pumped into any of the produced water storage tanks. The produced water undergoes
phase separation using various decanting tanks and centrifuges for the recovery of oil and condensates.
The decanted water is routed to pre-injection tanks and pumped into the injection well on site. The oil
separated from the produced water decanting process is pumped to heated mixing tanks, where the oil is
mixed with coagulant and demulsifying agents. After a period of mixing, the solids and water that still
remain in the oil are removed by a centrifuge. The oil is piped to heated oil storage tanks for
transportation off site. Water from the centrifuging process is pumped back to the decanting tanks, and the
centrifuged solids are stored in a covered and sealed container before being transported and disposed of
offsite.

NSR Classification
Minor Modification at Minor Source

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

DAQE-AN156680002-24
Page 4

Applicable Federal Standards
None
Project Description
Water Disposal, Inc. has requested to increase the annual production limit of crude oil from 14,400 bbls to
30,000 bbls. Additionally, the Approved Equipment in Approval Order DAQE-AN156680001-17 has
been updated to reflect the correct number and capacities of tanks on site.

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 268 1825.00
Carbon Monoxide 0.63 2.85
Nitrogen Oxides 0 0.74
Particulate Matter - PM10 0 0.23
Particulate Matter - PM2.5 0 0.02
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 2.83 27.11

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 80
Ethyl Benzene (CAS #100414) 14 54
Generic HAPs (CAS #GHAPS) 35 423
Methanol (CAS #67561) 1 3
Toluene (CAS #108883) 50 160
Xylenes (Isomers And Mixture) (CAS #1330207) 80 280
Change (TPY) Total (TPY)
Total HAPs 0.09 0.50

SECTION I: GENERAL PROVISIONS

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

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

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

DAQE-AN156680002-24
Page 5

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

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

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

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

SECTION II: PERMITTED EQUIPMENT

II.A THE APPROVED EQUIPMENT

II.A.1 WDI-Produced Water Facility
Produced Water Treatment Facility

II.A.2 Twelve (12) Produced Water Storage Tanks
Maximum capacity: 1000 bbl (each)
All controlled by combustor

II.A.3 Two (2) Fresh Water/Injection Storage Tanks
Maximum capacity: 400 bbl (each)
All controlled by combustor

II.A.4 Two (2) Oil Storage Tanks
Maximum capacity: 480 bbl (each)
All controlled by combustor

II.A.5 Two (2) Oil Skim Tanks
Maximum capacity: 480 bbl (each)
Covered and controlled by combustor

II.A.6 One (1) Mixing Tank
Maximum capacity: 450 bbl
Covered and controlled by combustor

II.A.7 Sealed Solids Storage
Contents: Sludge from tanks, centrifuges, etc.
Controlled by combustor

DAQE-AN156680002-24
Page 6

II.A.8 One (1) Combustor
Capacity: 1.4 MMBtu/hr
Fuel: Natural Gas

II.A.9 Tank Heaters
Maximum rated capacity: less than 5.0 MMBtu/hr (each)
Fuel: Natural Gas

II.A.10 One (1) Pressure Washer Engine
Rating: 10 Horsepower
Fuel: Gasoline
Engine is a Portable Nonroad Engine

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

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

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2 Tank Requirements
II.B.2.a The owner/operator shall not produce more than 30,000 barrels (1 barrel = 42 gallons) of crude
oil per rolling 12-month period. [R307-401-8]

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

A. Determine production with sales receipts.

B. Record production on a monthly basis.

C. Use the production data to calculate a new rolling 12-month total by the 25th day
of each month using data from the previous 12 months.

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

[R307-401-8]

II.B.2.b The owner/operator shall store all centrifuge solids and tank sludge in an enclosed storage vessel
prior to the centrifuge solids and tank sludge being hauled off site. [R307-401-8]

II.B.2.c The owner/operator shall contain all centrifuge solids and tank sludge in the enclosed storage
vessel immediately after any centrifuge solids and tank sludge is produced. The owner/operator
shall have no standing centrifuge solids or tank sludge present outside the enclosed storage
vessel on site at any time. [R307-401-8]

II.B.2.d The owner/operator shall load all storage tanks and tanker trucks on site by the use of bottom
filling or a submerged fill pipe. [R307-401-8]

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

DAQE-AN156680002-24
Page 7

II.B.2.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief
hatches are closed and latched and the associated gaskets, if any, are in good working condition.
[R307-401-8]

II.B.2.f.1 Records of thief hatch inspections shall include the date of the inspection and the status of the
thief hatches. [R307-401-8]

II.B.3 Combustor Requirements
II.B.3.a The owner/operator shall route all exhaust gas and/or vapors from all storage tanks and the
sealed solids storage to the operating combustor. [R307-401-8]

II.B.3.b The combustor shall operate with a continuous pilot flame and be equipped with an auto-igniter.
[R307-401-8]

II.B.3.c The owner or operator shall maintain records demonstrating the date of installation and
manufacturer specifications for the auto-igniter required under R307-503-4. [R307-503-4]

II.B.3.d The combustor shall operate with no visible emissions. [R307-401-8]

II.B.3.d.1 Opacity observations of emissions from the combustor shall be conducted according to 40 CFR
60, Appendix A, Method 22. [R307-401-8]

II.B.3.e The owner/operator shall install a combustor that is certified to meet a VOC control efficiency of
no less than 98%. [R307-401-8]

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

II.B.4 Haul Road Requirements
II.B.4.a The owner/operator shall comply with all applicable requirements of UAC Rule R307-205 for
Fugitive Emission and Fugitive Dust sources on site. [R307-205]

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

DAQE-AN156680002-24
Page 8

II.B.4.c.1 Records of 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 and quantity of water applied.

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

[R307-401-8]

II.B.4.d The owner/ operator shall not exceed 2,112 feet (0.4 miles) of unpaved haul roads on site.
[R307-401-8]

II.B.4.d.1 The unpaved road length shall be determined through source records or GPS measurements.
[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-AN156680002-24
Page 9

II.B.5.b.1 Monitoring surveys shall be conducted according to the following schedule:

A. No later than 90 days after the issuance date of this Approval Order.

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 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.
[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:

Supersedes AO DAQE-AN156680001-17 dated May 24, 2017
Is Derived From NOI dated December 20, 2023
Incorporates Additional Information dated April 23, 2024
Incorporates Additional Information dated April 29, 2024

DAQE-AN156680002-24
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-IN156680002-24

July 3, 2024

Doug Betts
Water Disposal Incorporated
2285 Lucky John Drive
Park City, UT 84060-6914
[e-mail]

Dear Mr. Betts:

Re: Intent to Approve: Minor Modification to Approval Order DAQE-AN156680001-17 to Increase
Crude Oil Production.
Project Number: N156680002

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: TriCounty Health Department

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN156680002-24
Minor Modification to Approval Order
DAQE-AN156680001-17 to Increase Crude Oil Production

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

Issued to
Water Disposal Incorporated - Produced Water Disposal Facility

Issued On
July 3, 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 ................................................................................................. 4
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 6
PERMIT HISTORY ..................................................................................................................... 9
ACRONYMS ............................................................................................................................... 11

DAQE-IN156680002-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Water Disposal Incorporated Water Disposal Incorporated - Produced Water
Disposal Facility

Mailing Address Physical Address
2285 Lucky John Drive
Park City, UT 84060-6914
Located 0.6 Miles along North Crescent Road
From Intersection of 2000 W & North Crescent
Road
Duchesne County, UT 84066

Source Contact UTM Coordinates
Name: Doug Betts 583,018 m Easting
Phone: [phone],467,513 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12

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

SOURCE INFORMATION
General Description
Water Disposal Incorporated (WDI) owns and operates a produced water treatment facility located
approximately four (4) miles northwest of Roosevelt in Duchesne County. Produced water is received by
truck from oil and gas operations and pumped into any of the produced water storage tanks. The produced
water undergoes phase separation using various decanting tanks and centrifuges for the recovery of oil
and condensates. The decanted water is routed to pre-injection tanks and pumped into the injection well
on site. The oil separated from the produced water decanting process is pumped to heated mixing tanks,
where the oil is mixed with coagulant and demulsifying agents. After a period of mixing, the solids and
water that still remain in the oil are removed by a centrifuge. The oil is piped to heated oil storage tanks
for transportation offsite. Water from the centrifuging process is pumped back to the decanting tanks , and
the centrifuged solids are stored in a covered and sealed container before being transported and disposed
of offsite.
NSR Classification
Minor Modification at Minor Source

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

DAQE-IN156680002-24
Page 4

Applicable Federal Standards
None
Project Description
WDI has requested to increase the annual production limit of crude oil from 14,400 bbls to 30,000 bbls.
Additionally, the Approved Equipment in Approval Order DAQE-AN156680001-17 has been updated to
reflect the correct number and capacities of tanks on site.

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 268 1825.00
Carbon Monoxide 0.63 2.85
Nitrogen Oxides 0 0.74
Particulate Matter - PM10 0 0.23
Particulate Matter - PM2.5 0 0.02
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 2.83 27.11

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 80
Ethyl Benzene (CAS #100414) 14 54
Generic HAPs (CAS #GHAPS) 35 423
Methanol (CAS #67561) 1 3
Toluene (CAS #108883) 50 160
Xylenes (Isomers And Mixture) (CAS #1330207) 80 280
Change (TPY) Total (TPY)
Total HAPs 0.09 0.50

PUBLIC NOTICE STATEMENT

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

A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Uintah Basin Standard on July 10, 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.

DAQE-IN156680002-24
Page 5

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

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

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

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

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

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

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

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

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 WDI- Produced Water Facility
Produced Water Treatment Facility

II.A.2 Twelve (12) Produced Water Storage Tanks
Maximum capacity: 1000 bbl (each)
All controlled by combustor

DAQE-IN156680002-24
Page 6

II.A.3 Two (2) Fresh Water/Injection Storage Tanks
Maximum capacity: 400 bbl (each)
All controlled by combustor

II.A.4 Two (2) Oil Storage Tanks
Maximum capacity: 480 bbl (each)
All controlled by combustor

II.A.5 Two (2) Oil Skim Tanks
Maximum capacity: 480 bbl (each)
Covered and controlled by combustor

II.A.6 One (1) Mixing Tank
Maximum capacity: 450 bbl
Covered and controlled by combustor

II.A.7 Sealed Solids Storage
Contents: Sludge from tanks, centrifuges, etc.
Controlled by combustor

II.A.8 One (1) Combustor
Capacity: 1.4 MMBtu/hr
Fuel: Natural Gas

II.A.9 Tank Heaters
Maximum rated capacity: less than 5.0 MMBtu/hr (each)
Fuel: Natural Gas

II.A.10 One (1) Pressure Washer Engine
Rating: 10 Horsepower
Fuel: Gasoline
Engine is a Portable Nonroad Engine

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

II.B REQUIREMENTS AND LIMITATIONS

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

II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2 Tank Requirements
II.B.2.a The owner/operator shall not produce more than 30,000 barrels (1 barrel = 42 gallons) of crude
oil per rolling 12-month period. [R307-401-8]

DAQE-IN156680002-24
Page 7

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

A. Determine production with sales receipts.

B. Record production on a monthly basis.

C. Use the production data to calculate a new rolling 12-month total by the 25th day
of each month using data from the previous 12 months.

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

[R307-401-8]

II.B.2.b The owner/operator shall store all centrifuge solids and tank sludge in an enclosed storage vessel
prior to the centrifuge solids and tank sludge being hauled off site. [R307-401-8]

II.B.2.c The owner/operator shall contain all centrifuge solids and tank sludge in the enclosed storage
vessel immediately after any centrifuge solids and tank sludge is produced. The owner/operator
shall have no standing centrifuge solids or tank sludge present outside the enclosed storage
vessel on site at any time. [R307-401-8]

II.B.2.d The owner/operator shall load all storage tanks and tanker trucks on site by the use of bottom
filling or a submerged fill pipe. [R307-401-8]

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

II.B.2.f The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief
hatches are closed, latched, and the associated gaskets, if any, are in good working condition.
[R307-401-8]

II.B.2.f.1 Records of thief hatch inspections shall include the date of the inspection and the status of the
thief hatches. [R307-401-8]

II.B.3 Combustor Requirements
II.B.3.a The owner/operator shall route all exhaust gas and/or vapors from all storage tanks and the
sealed solids storage to the operating combustor. [R307-401-8]

II.B.3.b The combustor shall operate with a continuous pilot flame and be equipped with an auto-igniter.
[R307-401-8]

II.B.3.c The owner or operator shall maintain records demonstrating the date of installation and
manufacturer specifications for the auto-igniter required under R307-503-4. [R307-503-4]

II.B.3.d The combustor shall operate with no visible emissions. [R307-401-8]

II.B.3.d.1 Opacity observations of emissions from the combustor shall be conducted according to 40 CFR
60, Appendix A, Method 22. [R307-401-8]

II.B.3.e The owner/operator shall install a combustor that is certified to meet a VOC control efficiency of
no less than 98%. [R307-401-8]

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

DAQE-IN156680002-24
Page 8

II.B.4 Haul Road Requirements
II.B.4.a The owner/operator shall comply with all applicable requirements of UAC Rule R307-205 for
Fugitive Emission and Fugitive Dust sources on site. [R307-205]

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

II.B.4.c.1 Records of 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 and quantity of water applied.

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

[R307-401-8]

II.B.4.d The owner/ operator shall not exceed 2,112 feet (0.4 miles) of unpaved haul roads on site.
[R307-401-8]

II.B.4.d.1 The unpaved road length shall be determined through source records or GPS measurements.
[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-IN156680002-24
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 90 days after the issuance date of this Approval Order.

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.
[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:

Supersedes AO DAQE-AN156680001-17 dated May 24, 2017
Is Derived From NOI dated December 20, 2023
Incorporates Additional Information dated April 23, 2024
DAQE-IN156680002-24
Page 10

Incorporates Additional Information dated April 29, 2024

DAQE-IN156680002-24
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

Uintah Basin Standard
Publication Name:
Uintah Basin Standard
Publication URL:
Publication City and State:
Roosevelt, UT
Publication County:
Duchesne
Notice Popular Keyword Category:
Notice Keywords:
water disposal
Notice Authentication Number:
202407151030485538234
1761527914
Notice URL:
Back
Notice File:Notice Publish Date:
notice_exports_A3RMRew5jIdTgzQsBun5_f238._cropped-913.pdf Thursday, July 11, 2024
Notice Content
PLEASE NOTE: The following text was electronically converted from the PDF document above, and may not be 100% accurate. Because of this, please view the PDF for
the most accurate information.
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: Water Disposal Incorporated
Location: Water Disposal Incorporated - Produced Water Disposal Facility — Located 0.6
Miles along North Crescent Road, From Intersection of 2000 West & North
Crescent Road, Duchesne County, UT
Project Description: Water Disposal Incorporated (WDI) owns and operates a produced water
treatment facility located approximately 4 miles northwest of Roosevelt in
Duchesne County. Produced water is received by truck from oil and gas
operations and pumped into any of the produced water storage tanks. The
produced water undergoes p
Web display limited to 1,000 characters. Please view the PDF for the complete Public Notice.
Back

DAQE-NN156680002-24

July 3, 2024

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

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Uintah Basin Standard
on July 10, 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: Uintah Basin Association of Governments
cc: Duchesne County

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-NN156680002-24
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: Water Disposal Incorporated
Location: Water Disposal Incorporated - Produced Water Disposal Facility – Located 0.6
Miles along North Crescent Road, From Intersection of 2000 West & North
Crescent Road, Duchesne County, UT
Project Description: Water Disposal Incorporated (WDI) owns and operates a produced water
treatment facility located approximately 4 miles northwest of Roosevelt in
Duchesne County. Produced water is received by truck from oil and gas
operations and pumped into any of the produced water storage tanks. The
produced water undergoes phase separation using various decanting tanks and
centrifuges for the recovery of oil and condensates. The decanted water is routed
to pre-injection tanks and pumped into the injection well on site. The oil
separated from the produced water decanting process is pumped to heated mixing
tanks, where the oil is mixed with coagulant and demulsifying agents. After a
period of mixing, the solids and water that still remain in the oil are removed by a
centrifuge. The oil is piped to heated oil storage tanks for transportation offsite.
Water from the centrifuging process is pumped back to the decanting tanks, and
the centrifuged solids are stored in a covered and sealed container before being
transported and disposed of offsite.

WDI has requested to increase the annual production limit of crude oil from
14,400 bbls to 30,000 bbls. Additionally, the Approved Equipment in Approval
Order DAQE-AN156680001-17 has been updated to reflect the correct number
and capacities of tanks on site.

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 August 9, 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: July 10, 2024

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

RN156680002
June 19, 2024

Doug Betts
Water Disposal Inc.
2285 Lucky John Drive
Park City, UT 840606914
[e-mail]

Dear Doug Betts,

Re: Engineer Review:
Minor Modification to Approval Order DAQE-AN156680001-17 to Increase Crude Oil
Production.
Project Number: N156680002

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. Water Disposal Inc.
should complete this review within 10 business days of receipt.

Water Disposal 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 Water Disposal Inc. does not respond to this letter within 10 business days, the project will move
forward without source concurrence. If Water Disposal 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 N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N156680002
Owner Name Water Disposal Inc.
Mailing Address 2285 Lucky John Drive
Park City, UT, 840606914

Source Name Water Disposal Inc. - Produced Water Disposal Facility
Source Location Located 0.6 Miles along North Crescent Road
From Intersection of 2000 W & North Crescent Road
Duchesne County, UT 84066

UTM Projection 583,018 m Easting, 4,467,513 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 1389 (Oil & Gas Field Services, NEC)

Source Contact Doug Betts
Phone Number [phone]
Email [e-mail]

Billing Contact Doug Betts
Phone Number [phone]
Email [e-mail]

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

Notice of Intent (NOI) Submitted December 20, 2023
Date of Accepted Application May 14, 2024

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 2
SOURCE DESCRIPTION

General Description
Water Disposal Inc. (WDI) owns and operates a produced water treatment facility located
approximately 4 miles northwest of Roosevelt in Duchesne County. Produced water is received
by truck from oil and gas operations and pumped into any of the produced water storage tanks.
The produced water undergoes phase separation using various decanting tanks and centrifuges for
the recovery of oil and condensates. The decanted water is routed to pre-injection tanks and
pumped into the injection well on site. The oil separated from the produced water decanting
process is pumped to heated mixing tanks where the oil is mixed with coagulant and demulsifying
agents. After a period of mixing the solids and water that still remain in the oil are removed by a
centrifuge. The oil is piped to heated oil storage tanks for transportation off site. Water from the
centrifuging process is pumped back to the decanting tanks and the centrifuged solids are stored
in a covered and sealed container before being transported and disposed offsite.

NSR Classification:
Minor Modification at Minor Source

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

Applicable Federal Standards
None

Project Proposal
Minor Modification to Approval Order DAQE-AN156680001-17 to Increase Crude Oil
Production.

Project Description
Water Disposal, Inc. has requested to increase the annual production limit of crude oil from
14,400 bbls to 30,000 bbls. Additionally, the Approved Equipment in Approval Order DAQE-
AN156680001-17 has been updated to reflect the correct number and capacities of tanks on site.

EMISSION IMPACT ANALYSIS
All criteria pollutant emissions are below the modeling thresholds contained in R307-410-4. All HAP
emissions are below their respective modeling thresholds contained in R307-410-5. Modeling is not required at
this time. [Last updated April 23, 2024]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 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 268 1825.00
Carbon Monoxide 0.63 2.85
Nitrogen Oxides 0 0.74
Particulate Matter - PM10 0 0.23
Particulate Matter - PM2.5 0 0.02
Sulfur Dioxide 0 0.02
Volatile Organic Compounds 2.83 27.11

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 80
Ethyl Benzene (CAS #100414) 14 54
Generic HAPs (CAS #GHAPS) 35 423
Methanol (CAS #67561) 1 3
Toluene (CAS #108883) 50 160
Xylenes (Isomers And Mixture) (CAS #1330207) 80 280
Change (TPY) Total (TPY)
Total HAPs 0.09 0.50

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

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 4
Review of BACT for New/Modified Emission Units

1. BACT review regarding Haul Roads
WDI's request to increase crude oil production will result in increased haul truck frequency. Haul
truck operations at the Produced Water 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 existing haul road on site is unpaved. Increased traffic on the haul roads will result in 0.70 tpy
of PM10 and 0.07 tpy of PM2.5. Water application with a low silt content road base reduces PM10
and PM2.5 emissions to 0.18 typ and 0.02 tpy, respectively. Additional controls, such as paving the
haul road and application of chemical dust suppressant, are economically infeasible due to the
minimal additional reduction in emissions.

BACT for the unpaved roads is water 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.
All haul roads on site will not exceed 1.3 miles (6864 feet) in length, combined.

[Last updated May 14, 2024]

2. BACT review regarding Storage Tanks
VOCs and HAPs are emitted from the produced water/oil storage tanks and the solids containment
tank. Uncontrolled VOC emissions from the produced water/oil storage tanks and solids
containment tank are 63.2 tpy and 212 tpy, respectively. Uncontrolled HAPs emissions from the
produced water/oil storage tanks and solids containment tank are 2.13 tpy and 3.30 tpy,
respectively.

Emissions from storage tanks result from displacement of headspace vapor during filling
operations (working losses) and from diurnal temperature and heating variations (breathing losses).
Typically, filling losses constitute 80-90% of the total losses for fixed roof tanks. For the storage
tanks, the control technologies that were evaluated include a vapor recovery system, submerged
filling of tanks, and flaring. Vapor recovery systems typically control highly volatile substances
with high VOC waste streams. The storage tanks operate at a very low vapor pressure, making this
option technically infeasible. The storage tanks will be submerged filled to reduce working losses.
Lastly, flaring is an effective and feasible control technology for these storage tanks. Emissions
from these storage tanks are routed to a combustor with 98% VOC destruction efficiency. This will
reduce the total VOC emissions from the produced water/oil storage tanks to 1.26 tons, annually.
The emissions from the solids containment tank shall also be routed to the combustor. However, a
90% control efficiency was applied to these emissions to account for the emissions during
operational handling. Therefore, VOC emissions from the solid containment are reduced from 212
tpy to 21.19 tpy.

Additional control technology for the storage tanks includes good operating practices and
maintenance. WDI will conduct proper maintenance and operating practices on the tank. Thief
hatches on the storage tank shall be kept closed and latched except during vessel unloading or
other maintenance activities. Closed vent systems including vessel openings, thief hatches, and

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 5
bypass devices, for defects that can result in air emissions are inspected regularly. To ensure the
combustor is properly maintained, it shall operate with no visible emissions. The controls and
measures listed above are considered BACT for the tanks on site. [Last updated May 14, 2024]

3. BACT review regarding Component Fugitive Emissions
Operations at the WDI 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 April 23, 2024]

4. BACT review regarding Truck Liquid Loading
Pollutants associated with crude oil loading are VOCs and HAPs. Crude oil loading operations at
the facility will result in 2.34 tpy of uncontrolled VOCs and 0.08 tpy of uncontrolled HAPs.
Emissions from liquid loading can often be controlled by the following: submerged-fill loading,
vapor adsorption onto activated carbon, a vapor recovery system, vapor combustion, or a vapor
balance system. Additional add-on controls, such as vapor adsorption or recovery, are technically
infeasible due to the inconsistent and low volume of VOC/HAPs emissions.
Truck loading is performed through submerged-fill loading. The fill tube extends towards the
bottom of the car. Therefore, BACT to control VOC and HAPs emissions from liquid loading
operations is submerged loading.
[Last updated April 23, 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]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 6
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]

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 WDI- Produced Water Facility
Produced Water Treatment Facility

II.A.2 Twelve (12) Produced Water Storage Tanks
Maximum capacity: 1000 bbl (each)
All controlled by combustor

II.A.3 Two (2) Fresh Water/Injection Storage Tanks
Maximum capacity: 400 bbl (each)
All controlled by combustor

II.A.4 Two (2) Oil Storage Tanks
Maximum capacity: 480 bbl (each)
All controlled by combustor

II.A.5 Two (2) Oil Skim Tanks
Maximum capacity: 480 bbl (each)
Covered and controlled by combustor

II.A.6 One (1) Mixing Tank
Maximum capacity: 450 bbl
Covered and controlled by combustor

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 7
II.A.7 Sealed Solids Storage
Contents: Sludge from tanks, centrifuges, etc.
Controlled by combustor

II.A.8 One (1) Combustor
Capacity: 1.4 MMBtu/hr
Fuel: Natural Gas

II.A.9 Tank Heaters
Maximum rated capacity: less than 5.0 MMBtu/hr (each)
Fuel: Natural Gas

II.A.10 One (1) Pressure Washer Engine
Rating: 10 Horsepower
Fuel: Gasoline
Engine is a Portable Nonroad Engine

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

II.B REQUIREMENTS AND LIMITATIONS

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

II.B.1.a.1
NEW
Unless otherwise specified in this AO, opacity observations of emissions from stationary
sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.2 Tank Requirements
II.B.2.a
NEW
The owner/operator shall not produce more than 30,000 barrels (1 barrel = 42 gallons) of
crude oil per rolling 12-month period. [R307-401-8]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 8
II.B.2.a.1
NEW
The owner/operator shall:

A. Determine production with sales receipts

B. Record production on a monthly basis

C. Use the production data to calculate a new rolling 12-month total by the 25th day
of each month using data from the previous 12 months

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

[R307-401-8]

II.B.2.b
NEW
The owner/operator shall store all centrifuge solids and tank sludge in an enclosed storage
vessel prior to the centrifuge solids and tank sludge being hauled off site. [R307-401-8]

II.B.2.c
NEW
The owner/operator shall contain all centrifuge solids and tank sludge in the enclosed storage
vessel immediately after any centrifuge solids and tank sludge is produced. The
owner/operator shall have no standing centrifuge solids or tank sludge present outside the
enclosed storage vessel on site at any time. [R307-401-8]

II.B.2.d
NEW
The owner/operator shall load all storage tanks and tanker trucks on site by the use of bottom
filling or a submerged fill pipe. [R307-401-8]

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

II.B.2.f
NEW
The owner/operator shall inspect the thief hatches at least once monthly to ensure the thief
hatches are closed, latched, and the associated gaskets, if any, are in good working condition.
[R307-401-8]

II.B.2.f.1
NEW
Records of thief hatch inspections shall include the date of the inspection and the status of the
thief hatches. [R307-401-8]

II.B.3 Combustor Requirements
II.B.3.a
NEW
The owner/operator shall route all exhaust gas and/or vapors from all storage tanks and the
sealed solids storage to the operating combustor. [R307-401-8]

II.B.3.b
NEW
The combustor shall operate with a continuous pilot flame and be equipped with an auto-
igniter. [R307-401-8]

II.B.3.c
NEW
The owner or operator shall maintain records demonstrating the date of installation and
manufacturer specifications for the auto-igniter required under R307-503-4. [R307-503-4]

II.B.3.d The combustor shall operate with no visible emissions. [R307-401-8]

II.B.3.d.1
NEW
Opacity observations of emissions from the combustor shall be conducted according to 40
CFR 60, Appendix A, Method 22. [R307-401-8]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 9
II.B.3.e
NEW
The owner/operator shall install a combustor that is certified to meet a VOC control efficiency
of no less than 98%. [R307-401-8]

II.B.3.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 combustor. [R307-401-8]

II.B.4 Haul Road Requirements
II.B.4.a
NEW
The owner/operator shall comply with all applicable requirements of UAC Rule R307-205 for
Fugitive Emission and Fugitive Dust sources on site. [R307-205]

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

II.B.4.c.1
NEW
Records of 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 and quantity of water applied

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

[R307-401-8]

II.B.4.d
NEW
The owner/ operator shall not exceed 2,112 feet (0.4 miles) of unpaved haul roads on site.
[R307-401-8]

II.B.4.d.1
NEW
The unpaved road length shall be determined through source records or GPS measurements.
[R307-401-8]

II.B.5
NEW
Monitoring Requirements of Fugitive Emissions (Leak Detection and Repair)

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 10
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]

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 90 days after the issuance date of this Approval Order

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]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 11
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]

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]

Commented [CB1]: This not a wellsite, by NSPS OOOOa
definition. Well on site is an injection well for water.

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 12
PERMIT HISTORY

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

Supersedes AO DAQE-AN156680001-17 dated May 24, 2017
Is Derived From NOI dated December 20, 2023
Incorporates Additional Information dated April 23, 2024
Incorporates Additional Information dated April 29, 2024

REVIEWER COMMENTS

1. Comment regarding Emission Calculations by Source and DAQ Acceptance:
Fugitive Dust Emissions
Emissions from haul road traffic were calculated using AP-42 Table 13.2.2-2 (Unpaved Roads). A
control efficiency of 75% was applied for water application and use of a road base.

Tank Emissions
Emissions from the tanks were estimated using the "EPA Tanks" program. Properties of the contents
of each tank were used in the estimate (i.e. produced water, gravity separation, sludge, and oil). A
control efficiency of 98% was applied, as all tanks are routed to a combustor with a 98% VOC
destruction efficiency.

Solids Emissions
Emission factors for VOC and HAP emissions were taken from samples that were collected by the
source. These solid and open containment emissions are controlled by a combustor with a 98% VOC
destruction efficiency once enclosed in the storage container. However, a 90% control efficiency was
applied to these emissions to account for the emissions during operational handling.

Combustor Emissions
Combustion emissions were calculated from AP-42 Section 13.5 and 1.5 (Industrial Flares &
Liquefied Petroleum Gas Combustion).

Tank Heater Emissions
AP-42 Section 1.4 (Natural Gas Consumption). was used to calculate the tank heater emissions.

Truck Loading Emissions
Emissions from loading and unloading the trucks were estimated using AP-42 method listed in
Section 5.2 (Transportation and Marketing of Petroleum Liquids).

Fugitive VOC Emissions
Emissions from the leaking equipment were calculated using EPA guidance document: Protocol for
Equipment Leak Emission Estimates (EPA-453/R95-017).

[Last updated May 22, 2024]

2. Comment regarding Federal Standard and Title V Applicability:
No NSPS or MACT standards apply to the facility.

Title V of the 1990 Clean Air Act (Title V) applies to the following:

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 13

1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the
Act, Standards of Performance for New Stationary Sources;
3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants.
4. 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), and/or 40 CFR 63 (MACT) regulations. There are no other
reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not
apply to this facility. [Last updated May 14, 2024]

Engineer Review N156680002: Water Disposal Inc. - Produced Water Disposal Facility
June 19, 2024
Page 14
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by 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

No.Tanks Content Capacity
1 Storage Produced 1000 fixed vertical
2 Storage Produced 1000 fixed vertical
3 Storage Produced 1000 fixed vertical
4 Storage Produced 500 fixed vertical
5 Storage Produced 500 fixed vertical
6 Storage Produced 500 fixed vertical
7 Storage Produced 500 fixed vertical *includes mixing and storage
8 Storage Produced 500 fixed vertical
9 Storage Produced 400 fixed vertical
10 Storage Produced 400 fixed vertical
11 Storage Produced 400 fixed vertical
12 Storage Produced 400 fixed vertical
13 Storage*Oil 480 fixed vertical
14 Storage*Oil 480 fixed vertical
15 Storage*Oil 480 fixed vertical
16 Sorage*Oil 480 fixed vertical
17 Mixing*Oil 480 fixed vertical
*heated
Storage Tanks
*Using EPA Tanks
VOC Benzene Toluene Ethyl Benz Xylene HAPs
Uncontrolled 55.97 0.17 0.3 0.1 0.45 1.89
Controlled 1.12 0.00 0.01 0.00 0.01 0.04
(80 % control)
tpy
7,000 BTU/hp-hr
Equipment Details
Rating 6.00 hp = (4.5 kw)Table 3.3-1
Operational Hours 104 hours/year <600 hp
Sulfur Content 15 ppm or 0.0015%lb/hp-hr lb/hr Ton/year Check EF x S lb/hp-hr lb/hr Ton/year Check
Nox - Uncontrolled 0.031 0.19 0.01 Match 0.024 0.14 0.01
Criteria Pollutant
Emission
Standards
(g/hp-hr)
Emission
Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference Nox - Controlled 0.013 0.08 0.00
NOX 0.031 0.19 0.01 CO 6.68E-03 0.04 0.00 Match 5.50E-03 0.03 0.00
CO 6.68E-03 0.04 0.00 SO2 2.05E-03 0.01 0.00 8.09E-03 1.21E-05 0.00 0.00 Match Used>600 hp to allow for sulfur content of fuel
PM10 2.20E-03 0.01 0.00 PM10 2.20E-03 0.01 0.00 Match 0.0007 0.00 0.00 Table 3.3-1 does not allow for a sulfur content.
PM2.5 2.20E-03 0.01 0.00 CO2 1.15E+00 7 0 Match 1.16 7 0 To be more representatvie, Table 3.4-1 was used for all engine sizes.
VOC 2.51E-03 0.02 0.00 Aldehydes 4.63E-04 Not used, included in HAP below.SO2 1.21E-05 0.00 0.00 AP-42 Table 3.4-1 TOC 2.51E-03 0.02 0.00 7.05E-04 0.00 0.00 for engines >600 hp, TOC is 91% VOC & 9% methane
HAP 0.00 0.00 See Below VOC 2.51E-03 0.02 0.00 Match 91%6.42E-04 0.00 0.00
Methane Match 9%6.35E-05 0.00 0.00
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/hp-hr)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference Exhaust 2.47E-03CO2 (mass basis)1 1.15E+00 7 0 Evaporative 0.00
Methane (mass basis)25 0 0 Crankcase 4.41E-05CO2e0Refueling0.00
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference HAP
Table 3.3-2
<600 hp
(lb/MMBtu)lb/hp-hr lb/hr Ton/year Check
Table 3.4-3
>600 hp
(lb/MMBtu)lb/hp-hr lb/hr Ton/year Check
Benzene 9.33E-04 3.92E-05 2.04E-06 Benzene 9.33E-04 6.53E-06 3.92E-05 2.04E-06 Match 7.76E-04 5.43E-06 3.26E-05 1.69E-06
Toluene 4.09E-04 1.72E-05 8.93E-07 Toluene 4.09E-04 2.86E-06 1.72E-05 8.93E-07 Match 2.81E-04 1.97E-06 1.18E-05 6.14E-07
Xylenes 2.85E-04 1.20E-05 6.22E-07 Xylenes 2.85E-04 2.00E-06 1.20E-05 6.22E-07 Match 1.93E-04 1.35E-06 8.11E-06 4.22E-07
1,3-Butadiene 3.91E-05 1.64E-06 8.54E-08 1,3-Butadiene 3.91E-05 2.74E-07 1.64E-06 8.54E-08 Match
Formaldehyde 1.18E-03 4.96E-05 2.58E-06 Formaldehyde 1.18E-03 8.26E-06 4.96E-05 2.58E-06 Match 7.89E-05 5.52E-07 3.31E-06 1.72E-07
Acetaldehyde 7.67E-04 3.22E-05 1.68E-06 Acetaldehyde 7.67E-04 5.37E-06 3.22E-05 1.68E-06 Match 2.52E-05 1.76E-07 1.06E-06 5.50E-08
Acrolein 9.25E-05 3.89E-06 2.02E-07 Acrolein 9.25E-05 6.48E-07 3.89E-06 2.02E-07 Match 7.88E-06 5.52E-08 3.31E-07 1.72E-08
Naphthalene 8.48E-05 3.56E-06 1.85E-07 Naphthalene 8.48E-05 5.94E-07 3.56E-06 1.85E-07 Match 1.30E-04 9.10E-07 5.46E-06 2.84E-07
Acenaphthylene 5.06E-06 2.13E-07 1.11E-08 Acenaphthylene 5.06E-06 3.54E-08 2.13E-07 1.11E-08 Match 9.23E-06 6.46E-08 3.88E-07 2.02E-08
Acenaphthene 1.42E-06 5.96E-08 3.10E-09 Acenaphthene 1.42E-06 9.94E-09 5.96E-08 3.10E-09 Match 4.68E-06 3.28E-08 1.97E-07 1.02E-08
Fluorene 2.92E-05 1.23E-06 6.38E-08 Fluorene 2.92E-05 2.04E-07 1.23E-06 6.38E-08 Match 1.28E-05 8.96E-08 5.38E-07 2.80E-08
Phenanthrene 2.94E-05 1.23E-06 6.42E-08 Phenanthrene 2.94E-05 2.06E-07 1.23E-06 6.42E-08 Match 4.08E-05 2.86E-07 1.71E-06 8.91E-08
Anthracene 1.87E-06 7.85E-08 4.08E-09 Anthracene 1.87E-06 1.31E-08 7.85E-08 4.08E-09 Match 1.23E-06 8.61E-09 5.17E-08 2.69E-09
Fluoranthene 7.61E-06 3.20E-07 1.66E-08 Fluoranthene 7.61E-06 5.33E-08 3.20E-07 1.66E-08 Match 4.03E-06 2.82E-08 1.69E-07 8.80E-09
Pyrene 4.78E-06 2.01E-07 1.04E-08 Pyrene 4.78E-06 3.35E-08 2.01E-07 1.04E-08 Match 3.71E-06 2.60E-08 1.56E-07 8.10E-09
Benz(a)anthracene 1.68E-06 7.06E-08 3.67E-09 Benz(a)anthracene 1.68E-06 1.18E-08 7.06E-08 3.67E-09 Match 6.22E-07 4.35E-09 2.61E-08 1.36E-09
Chrysene 3.53E-07 1.48E-08 7.71E-10 Chrysene 3.53E-07 2.47E-09 1.48E-08 7.71E-10 Match 1.53E-06 1.07E-08 6.43E-08 3.34E-09
Benzo(b)fluoranthene 9.91E-08 4.16E-09 2.16E-10 Benzo(b)fluoranthene 9.91E-08 6.94E-10 4.16E-09 2.16E-10 Match 1.11E-06 7.77E-09 4.66E-08 2.42E-09
Benzo(k)fluoranthene 1.55E-07 6.51E-09 3.39E-10 Benzo(k)fluoranthene 1.55E-07 1.09E-09 6.51E-09 3.39E-10 Match 2.18E-07 1.53E-09 9.16E-09 4.76E-10
Benzo(a)pyrene 1.88E-07 7.90E-09 4.11E-10 Benzo(a)pyrene 1.88E-07 1.32E-09 7.90E-09 4.11E-10 Match 2.57E-07 1.80E-09 1.08E-08 5.61E-10
Indeno(1,2,3-cd)pyrene 3.75E-07 1.58E-08 8.19E-10 Indeno(1,2,3-cd)pyrene 3.75E-07 2.63E-09 1.58E-08 8.19E-10 Match 4.14E-07 2.90E-09 1.74E-08 9.04E-10
Dibenz(a,h)anthracene 5.83E-07 2.45E-08 1.27E-09 Dibenz(a,h)anthracene 5.83E-07 4.08E-09 2.45E-08 1.27E-09 Match 3.46E-07 2.42E-09 1.45E-08 7.56E-10
Benzo(g,h,l)perylene 4.89E-07 2.05E-08 1.07E-09 Benzo(g,h,l)perylene 4.89E-07 3.42E-09 2.05E-08 1.07E-09 Match 5.56E-07 3.89E-09 2.34E-08 1.21E-09
AP-42 Table 3.3-1
& Table 3.4-1
Emission Factor
(lb/MMBtu)
AP-42 Table 3.3-2,
Table 3.4-3, &
Table 3.4-4
(1,3-Butadiene will
not popluate if the
engine size is greater
than 600 hp. AP-42
does not list 1,3-
Butadiene for
engines greater than
600 hp.)
Diesel-Fired Engines
Emergency Engines should
equal 100 hours of
operation per year
Table 3.4-1
>600 hp
Manufacturer Data,
AP-42 Table 3.3-1,
& Table 3.4-1
Page 2 of Version 1.1 February 21, 2019
Heating Value of Natural Gas 1020 BTU/scf or MMBtu/MMscf
Equipment Details
Rating 5 MMBtu/hour 15000 MMBtu NOx Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
Operational Hours 3,000 hours/year 3000 >100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)280 0.2745 1.37 2.06
Firing Normal >100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)190 0.1863 0.93 1.40
>100 MMBtu/hr Controlled - Low Nox burners 140 0.1373 0.69 1.03
Criteria Pollutant
Concentration
(ppm)
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference >100 MMBtu/hr Controlled - Flue gas recirculation (FGR)100 0.0980 0.49 0.74 Match
NOX 100 0.49 0.74 1470.588 <100 MMBtu/hr Uncontrolled 100 0.0980 0.49 0.74 Match
CO 84 0.41 0.62 1235.294 <100 MMBtu/hr Controlled - Low Nox burners 50 0.0490 0.25 0.37
PM10 7.6 0.04 0.06 <100 MMBtu/hr Controlled - Low Nox burners/FGR 32 0.0314 0.16 0.24
PM2.5 7.6 0.04 0.06 Tangential-Fired Uncontrolled 170 0.1667 0.83 1.25
SO2 0.6 0.00 0.00 Tangential-Fired Controlled - FGR 76 0.0745 0.37 0.56
VOC 5.5 0.03 0.04
Lead 0.0005 0.00 0.00 CO Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
HAP 0.01 0.01 See Below >100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)84 0.0824 0.41 0.62 Match
>100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)84 0.0824 0.41 0.62 Match
Green House Gas Pollutant
Global
Warming
Potential
Emission
Factor
(lb/10^6 scf)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference >100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 0.41 0.62 MatchCO2 (mass basis)1 120,000 588 882 >100 MMBtu/hr Controlled - Flue gas recirculation (FGR)84 0.0824 0.41 0.62 Match
Methane (mass basis)25 2.3 0.01 0.02 <100 MMBtu/hr Uncontrolled 84 0.0824 0.41 0.62 MatchN2O (mass basis)298 2.2 0.01 0.02 <100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 0.41 0.62 Match
CO2e 888 <100 MMBtu/hr Controlled - Low Nox burners/FGR 84 0.0824 0.41 0.62 Match
Tangential-Fired Uncontrolled 24 0.0235 0.12 0.18
Hazardous Air Pollutant
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)Reference Tangential-Fired Controlled - FGR 98 0.0961 0.48 0.72
2-Methylnaphthalene 2.40E-05 1.18E-07 1.76E-07
3-Methylchloranthrene 1.80E-06 8.82E-09 1.32E-08 Any Size Table 1.4-2 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
7,12-Dimethylbenz(a)anthracene 1.60E-05 7.84E-08 1.18E-07 CO2 120,000 117.6471 588 882 Match
Acenaphthene 1.80E-06 8.82E-09 1.32E-08 Lead 0.0005 0.0000 0.00 0.00 Match
Acenaphthylene 1.80E-06 8.82E-09 1.32E-08 N2O Uncontrolled 2.2 0.0022 0.01 0.02 Match
Anthracene 2.40E-06 1.18E-08 1.76E-08 Controlled - Low Nox burners 0.64 0.0006 0.00 0.00
Benz(a)anthracene 1.80E-06 8.82E-09 1.32E-08 PM (total)7.6 0.0075 0.04 0.06 Match
Benzene 2.10E-03 1.03E-05 1.54E-05 PM (cond)5.7 0.0056 0.03 0.04
Benzo(a)pyrene 1.20E-06 5.88E-09 8.82E-09 PM (filter)1.9 0.0019 0.01 0.01
Benzo(b)fluoranthene 1.80E-06 8.82E-09 1.32E-08 SO2 0.6 0.0006 0.00 0.00 Match
Benzo(g,h,i)perylene 1.20E-06 5.88E-09 8.82E-09 TOC 11 0.0108 0.05 0.08
Benzo(k)fluoranthene 1.80E-06 8.82E-09 1.32E-08 Methane 2.3 0.0023 0.01 0.02 Match
Chrysene 1.80E-06 8.82E-09 1.32E-08 VOC 5.5 0.0054 0.03 0.04 Match
Dibenzo(a,h)anthracene 1.20E-06 5.88E-09 8.82E-09
Dichlorobenzene 1.20E-03 5.88E-06 8.82E-06 Global Warming Potential lb/hr Ton/year
Fluoranthene 3.00E-06 1.47E-08 2.21E-08 CO2 1 588 882
Fluorene 2.80E-06 1.37E-08 2.06E-08 Methane 25 0 0
Formaldehyde 7.50E-02 3.68E-04 5.51E-04 N2O 298 3 5
Hexane 1.80E+00 8.82E-03 1.32E-02 CO2e Total CO2e 592 888 Match
Indeno(1,2,3-cd)pyrene 1.80E-06 8.82E-09 1.32E-08
Naphthalene 6.10E-04 2.99E-06 4.49E-06 HAP - Organic Table 1.4-3 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
Phenanathrene 1.70E-05 8.33E-08 1.25E-07 2-Methylnaphthalene 2.40E-05 2.35E-08 1.18E-07 1.76E-07 Match
Pyrene 5.00E-06 2.45E-08 3.68E-08 3-Methylchloranthrene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Toluene 3.40E-03 1.67E-05 2.50E-05 7,12-Dimethylbenz(a)anthracene 1.60E-05 1.57E-08 7.84E-08 1.18E-07 Match
Arsenic 2.00E-04 9.80E-07 1.47E-06 Acenaphthene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Beryllium 1.20E-05 5.88E-08 8.82E-08 Acenaphthylene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Cadmium 1.10E-03 5.39E-06 8.09E-06 Anthracene 2.40E-06 2.35E-09 1.18E-08 1.76E-08 Match
Chromium 1.40E-03 6.86E-06 1.03E-05 Benz(a)anthracene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Cobalt 8.40E-05 4.12E-07 6.18E-07 Benzene 2.10E-03 2.06E-06 1.03E-05 1.54E-05 Match
Manganese 3.80E-04 1.86E-06 2.79E-06 Benzo(a)pyrene 1.20E-06 1.18E-09 5.88E-09 8.82E-09 Match
Mercury 2.60E-04 1.27E-06 1.91E-06 Benzo(b)fluoranthene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Nickel 2.10E-03 1.03E-05 1.54E-05 Benzo(g,h,i)perylene 1.20E-06 1.18E-09 5.88E-09 8.82E-09 Match
Selenium 2.40E-05 1.18E-07 1.76E-07 Benzo(k)fluoranthene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Chrysene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Dibenzo(a,h)anthracene 1.20E-06 1.18E-09 5.88E-09 8.82E-09 Match
Dichlorobenzene 1.20E-03 1.18E-06 5.88E-06 8.82E-06 Match
Fluoranthene 3.00E-06 2.94E-09 1.47E-08 2.21E-08 Match
Fluorene 2.80E-06 2.75E-09 1.37E-08 2.06E-08
Formaldehyde 7.50E-02 7.35E-05 3.68E-04 5.51E-04 Match
Hexane 1.80E+00 1.76E-03 8.82E-03 1.32E-02 Match
Indeno(1,2,3-cd)pyrene 1.80E-06 1.76E-09 8.82E-09 1.32E-08 Match
Naphthalene 6.10E-04 5.98E-07 2.99E-06 4.49E-06 Match
Phenanathrene 1.70E-05 1.67E-08 8.33E-08 1.25E-07 Match
Pyrene 5.00E-06 4.90E-09 2.45E-08 3.68E-08 Match
Toluene 3.40E-03 3.33E-06 1.67E-05 2.50E-05 Match
HAP - Metal Table 1.4-4 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check
Arsenic 2.00E-04 1.96E-07 9.80E-07 1.47E-06 Match
Beryllium 1.20E-05 1.18E-08 5.88E-08 8.82E-08 Match
Cadmium 1.10E-03 1.08E-06 5.39E-06 8.09E-06 Match
Chromium 1.40E-03 1.37E-06 6.86E-06 1.03E-05 Match
Cobalt 8.40E-05 8.24E-08 4.12E-07 6.18E-07 Match
Manganese 3.80E-04 3.73E-07 1.86E-06 2.79E-06 Match
Mercury 2.60E-04 2.55E-07 1.27E-06 1.91E-06 Match
Nickel 2.10E-03 2.06E-06 1.03E-05 1.54E-05 Match
Selenium 2.40E-05 2.35E-08 1.18E-07 1.76E-07 Match
Total HAP Total HAP lb/hr Ton/year Check
0.01 0.01 Match
ppm to lb/MMBtu Conversion.
Source: AQMD Permit Sample Evaluation Natural Gas Fired Boiler 5-20 MMBTU/HR, 2007
Nox Molecular Weight 46.1 lb/lb-mole
CO Molecular Weight 28.01 lb/lb-mole
Concentration lb/MMBtu lb/hr Ton/year Check
Nox 0 0 0.00 0.00
CO 0 0 0.00 0.00
AP-42 Table 1.4-3
AP-42 Table 1.4-4
Natural Gas-Fired Boilers & Heaters
Manufacturer Data
or AP-42 Table 1.4-1
AP-42 Table 1.4-2
AP-42 Table 1.4-2
&
Table A-1 to
Subpart A of Part 98
Emission Factor
(lb/10^6 scf)
Page 3 of Version 1.0 November 29, 2018
Silt Content 4.8 surface material silt content (%)
Production Rates
Hourly Rates tons/hour 70%Basic Watering - (70% control)
Annual Production tons/year 75%Road Base with Watering - (75% control)
85%Chemical Suppressant & Watering - (85% control)
Truck Information 90%Paving with Sweeping & Watering - (90% control)
Mean Weight 33 tons 95%Paving with Vacuum Sweeping & Watering - (95% control)
tons
tons PM10 PM2.5
k (lb/VMT)1.5 0.15
Haul Road Information a 0.9 0.9
Haul Road One-Way Length 3,432 feet b 0.45 0.45
Hourly Vehicle Miles Traveled 0.1 miles
Annual Vehicle Miles Traveled 785 miles
Type of Control
Pollutant
Uncontrolled
Emission
Factor
(lb/VMT)
Controlled
Emission
Factor
(lb/VMT)
Emission
Rate
(lbs/hr)
Emission
Total
(tons/year)ReferencePM101.93 0.48 0.04 0.19
PM2.5 0.193 0.048 0.00 0.02
Haul Roads
Road Base with Watering - (75% control)
AP-42 13.2.2 & DAQ
Haul Road Guidance
Page 4 of Version 1.0 November 29, 2018
Heavy Oil Light Oil Water/Oil Heavy Oil Light Oil Water/Oil Heavy Oil Light Oil Water/Oil
Valves 8.40E-06 2.50E-03 9.80E-05 1.85E-05 5.51E-03 2.16E-04 5 20
Pump Seals NA 1.30E-02 2.40E-05 NA 2.87E-02 5.29E-05 0 6
Other 3.20E-05 7.50E-03 1.40E-02 7.05E-05 1.65E-02 3.09E-02 0 0
Connectors 7.50E-06 2.10E-04 1.10E-04 1.65E-05 4.63E-04 2.43E-04 12 48
Flanges 3.90E-07 1.10E-04 2.90E-06 8.60E-07 2.43E-04 6.39E-06 6 6
Open ended Lines 1.40E-04 1.40E-03 2.50E-04 3.09E-04 3.09E-03 5.51E-04 6 6
lb/hr
Heavy Oil Light Oil Total (lb/hrtpy
Valves 9.26E-05 1.10E-01 1.10E-01 4.83E-01
Pump Seals 1.72E-01 1.72E-01 7.53E-01
Other 0.00E+00 0.00E+00 0.00E+00 0.00E+00
Connectors 1.98E-04 2.22E-02 2.24E-02 9.82E-02
Flanges 5.16E-06 1.46E-03 1.46E-03 6.40E-03
Open ended Lines 1.85E-03 1.85E-02 2.04E-02 8.92E-02
3.27E-01 1.43E+00
kg/hr/source lb/hr/source Components

Pollutant Tanks Engine Heater Haul Roads VOC leaks
NOX 0.01 0.74
CO 0.00 0.62
PM10 0.00 0.06 0.19
PM2.5 0.00 0.06 0.02
VOC 1.12 0.00 0.04 1.43
SO2 0.00 0.00
HAP 0.06 0.00 0.01
0.5
0.2113
TPY
Flare Unloading Solids Total NOI Current AO Change
0.74 0.74 0.74 0
2.23 2.85 2.85 2.22 0.63
0.25 0.23 0.23 0
0.08 0.02 0.02 0
0.84 2.34 21.19 26.96 27.11 24.28 2.83
0.00 0.01 0.02 0
0.04 0.08 0.33 0.52 0.5 0.41 0.09
*NOI values match DAQ values within tolerance
Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-1

C-1.0 Storage Tanks and Containment
The emissions of VOCs from the storage tanks and containment were estimated using the EPA
Tanks program (EPA, 2012). The tanks at this facility have cone shaped fixed roofs that are
equipped with pressure relief valves. The oil tanks are heated to approximately 140˚F. The
unheated tanks remain at ambient temperatures. The following lists the method used to estimate
the VOC emissions.
C-1.1 Methods
The total emissions from the storage tanks and containment were estimated using the EPA
Tanks. This program estimates the emissions of organic chemicals from storage tanks based on
AP-42 methods. An inventory of all the tanks and containment at the facility is listed in Table
C-1.
C-1.1.1 HAPs Emissions Correlations
The Hazardous Air Pollutants (HAPs) emissions were estimated using VOC emissions to
specific HAP emission ratios as reported in the report “Emission Estimate Protocol for
petroleum Refineries” written by RTI International (RTI, 2011). The ratios are listed in Table C-
2.
C-1.1 Results
C-1.1.1 Assumptions for All Facility Tanks
The total throughput of each tank, tank contents and throughput per tank is provided in Table C-
3. The uncontrolled VOCs and HAPs emissions from the tanks are listed in Table C-4. The
results from the EPA Tanks analysis are included in Appendix H.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-2

Table C-1. Tank and Containment Inventory and Specifications
Tank ID # of
Tanks Contents Type Shell
Diameter
Shell
Height
Volume
(bbls
Ave. Liquid
Height Heated
Tank
Temp.
(F)
Har_Wat_1.0_1000 3 Water Vertical 16 28 1000 17 No Ambient
Har_Wat_1.0_500 5 Water Vertical 12 25 500 16 No Ambient
Har_Wat_1.0_400 4 Water Vertical 12 20 400 12 No Ambient
Har_Oil_1.0_500 5 Oil Vertical 12 25 500 16 Yes ~140°

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

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-3

Table C-3. Tank Flow Rates
Tank ID # of Tanks Volume
(bbl) Total Throughput (bbl)
Har_Wat_1.0_1000 3 1000 270,000
Har_Wat_1.0_500 5 500 270,000
Har_Wat_1.0_400 4 400 270,000
Har_Oil_1.0_500 5 500 30,000

Table C-4. EPA Tanks Results and Uncontrolled Emissions Estimates
Tank ID # of
Tanks
Uncontrolled Emissions (tons/yr)
VOC HAPs Benzene Toluene
Ethyl
Benzene Xylene
Har_Wat_1.0_1000 3 11.7 0.39 0.04 0.06 0.02 0.09
Har_Wat_1.0_500 5 14.7 0.50 0.05 0.08 0.03 0.12
Har_Wat_1.0_400 4 11.6 0.39 0.04 0.06 0.02 0.09
Har_Oil_1.0_500 5 17.99 0.61 0.06 0.10 0.03 0.15
Tot Harmston Ucontrolled
Emissions (tons/yr) 55.97 1.89 0.17 0.30 0.10 0.45
Tot Harmston Controlled (Flare)
Emissions (tons/yr) 1.12 0.04 0.003 0.01 0.002 0.01

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-4

C-2.0 Centrifuge Solids
In-house solids are generated during cleaning of the oil in the centrifuge separation equipment.
Emissions for the in-house solids were estimated using analytical data from samples collected at
the WDI facility. The soils were analyzed for TPH-GRO, TPH-DRO, and VOCs.
C-2.1 Methods
C-2.1.1 Uncontrolled Emissions
The centrifuged solids at the Harmston Facility were sampled four (4) times. The sample
analysis data is included in Appendix G.

The estimated annual throughput of centrifuged solids is 87 cubic yards (yd3) per year (95.32 dry
tons/yr). The mean concentration of the constituents was multiplied by the total dry throughput
of material to determine the total annual and hourly uncontrolled emissions from the facility
solids.
C-2.1.2 Controlled Emissions
The centrifuge solids will be contained in sealed containers and will be regularly transported
offsite.
C-2.2 Calculations and Results
The mean concentrations of VOCs (TPH-GRO and TPH-DRO) and HAPS and estimated
emissions are included in Table C-5 for the centrifuged solids.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-5

Table C-5. Centrifuged Solids Uncontrolled Emissions.
Solids
Analyte Mean Concentration
(mg/kg)
Emissions Per Year
(tons/yr)
Emissions
(lbs/yr)
Sulfer 18036 1.72 3438
1,2,3-Trimethylbenzene 196 0.02 37.3
1,2,4-Trimethylbenzene 510 0.05 97.2
1,3,5-Trimethylbenzene 246 0.02 46.9
Benzene 15.2 0.001 2.90
Bromobenzene 0.02 1.86E-06 0.004
Ethylbenzene 182 0.02 34.8
Isopropylbenzene 21.2 0.002 4.04
Naphthalene 35.3 0.003 6.74
n-Butylbenzene 6.70 6.39E-04 1.28
n-Propylbenzene 31.4 0.003 5.99
p-Isopropyltoluene 13.4 0.001 2.55
sec-Butylbenzene 7.85 7.48E-04 1.50
tert-Butylbenzene 3.56 3.39E-04 0.68
Toluene 563 0.05 107
TPH (GC/FID) High Fraction 1181144 113 225169
TPH (GC/FID) Low Fraction 45000 4.29 8579
Xylenes, Total 1817 0.17 346
Methanol 175 0.02 33

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-6

C-3.0 Engines
The emissions from the one engine at the WDI facility were estimated using the methods listed
AP-42 Section 3.3 (Gasoline and Diesel Industrial Engines). This engine is used to operate a
pressure washer. The emission factors and assumptions are included below.
C-3.1 Method and Results
The emissions factors for the engine on site were obtained from AP-42 emission factors listed in
Section 3.3. The emission factors, annual hours of operation, engine capacity, and annual
emissions are listed in Table C-6.

Table C-6. Gasoline Pressure Washer Criteria Pollutant Emissions.
Analyte Emission Factor
(lbs/hp-hr) hrs/yr1 hp Emissions
(tons/yr) Source
PM10 0.0007
104 6
0.0002 AP-42 Table 3.3-1
NOX 0.0110 0.003 AP-42 Table 3.3-1
SOX 5.91E-04 0.0002 AP-42 Table 3.3-1
CO 0.0070 0.002 AP-42 Table 3.3-1
CO2 1.08 0.34 AP-42 Table 3.3-1
VOC 0.022 0.007 AP-42 Table 3.3-1
Notes 1: Estimated use is a maximum of 2 hours a week.

It is assumed that the engine at the WDI facility has a Break-Specific Fuel Consumption (BCFC)
of 0.007 MMBtu/hp-hr (AP-42 Table 3.3-1). The annual HAPs emissions based on fuel
consumption and hours of operation are provided in Tables C-7.

Table C-7. Gasoline Pressure Washer HAPs Emissions.
Analyte lb/MMBtu MMBtu/yr lbs/hr lb/yr tons/yr Source
Benzene 0.000933
4
3.9E-05 4.1E-03 2.04E-06 AP-42 Table 3.3-2
Toluene 0.000409 1.7E-05 1.8E-03 8.93E-07 AP-42 Table 3.3-2
Xylenes 0.000285 1.2E-05 1.2E-03 6.22E-07 AP-42 Table 3.3-2
Formaldehyde 0.00118 5.0E-05 5.2E-03 2.58E-06 AP-42 Table 3.3-2
Acetaldehyde 0.000767 3.2E-05 3.4E-03 1.68E-06 AP-42 Table 3.3-2
Acrolein 0.0000925 3.9E-06 4.0E-04 2.02E-07 AP-42 Table 3.3-2
Naphthalene 0.0000848 3.6E-06 3.7E-04 1.85E-07 AP-42 Table 3.3-2
Total HAPS - - 1.6E-04 1.6E-02 8.19E-06 Calc.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-7

C-4.0 Tank Heaters
The emissions from tank heaters were estimated using the method listed in AP-42 Section 1.4
(Natural Gas Consumption). The emission factors and assumptions are included below.
C-4.1 Method and Results
The emission factors for the tank heaters are listed in Table C-8. The heaters are assumed to
operate year round and consume a maximum 15,000 MMBtu of natural gas annually. The
number of assumed annual hours of operation is conservative in that 2 tank heaters are rarely
used.

Table C-8. Tank Heaters Emissions Estimates.
Tank Heater Parameters
Parameter Unit Value Comments/Reference
Tank Heaters ea 5 Facility Design
Total Heat Input MMBtu/yr 15,000 Facility Records
Emission Factors1
Parameter Unit Value Comments/Reference
Particulate Matter lbs/MMBtu 0.00745098 AP-42 Table 1.4-2
Sulfur Oxides (as SO2) lbs/MMBtu 0.000588235 AP-42 Table 1.4-2
Nitrogen Oxides lbs/MMBtu 0.098039216 AP-42 Table 1.4-1
Carbon Dioxide lbs/MMBtu 117.6470588 AP-42 Table 1.4-2
Carbon Monoxide lbs/MMBtu 0.082352941 AP-42 Table 1.4-1
Volatile Organic Compounds lbs/MMBtu 0.005392157 AP-42 Table 1.4
Methane lbs/MMbtu 0.002254902 AP-42 Table 1.4
Emissions Estimates
Parameter Unit Value Comments/Reference
Particulate Matter lbs/yr 112 Calc.
Sulfur Oxides (as SO2) lbs/yr 9 Calc.
Nitrogen Oxides lbs/yr 1471 Calc.
Carbon Dioxide lbs/yr 1764706 Calc.
Carbon Monoxide lbs/yr 1235 Calc.
Volatile Organic Compounds lbs/yr 81 Calc.
Methane lbs/yr 34 Calc.
Notes: 1. These emissions factors were converted from lbs/106 scf to lbs/MMBtu per AP-42 Table 1.4-2
(footnote a).

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-8

C-5.0 Flare
The emissions from the flare were estimated using the methods listed in AP-42 Section 3.15 and
1.5 (Industrial Flares & Liquefied Petroleum Gas Combustion). The emission factors and
assumptions are included below.
C-5.1 Method and Results
The flow and total energy content (MMBtu/yr) of the tanks at the site are listed in Table C-9.
The emission factors for the flare are listed in Table C-10. The emissions of the total
hydrocarbons (including ethane and other organics), CO, NOX, and Soot were estimated using
emission factors from AP-42 Tables 3.15-1 and 3.15-2. The emission factor for CO2 was
assumed to be equivalent to the combustion of propane as defined in AP-42 Section 1.5. It is
assumed that the flare combustion gas contains 300 Btu/ft3 of heat value (AP-42 Section 3.15).
The flare controls vapors from 20 tanks with throughputs (i.e. vapor flow rates) listed in Table C-
9.

Table C-9. Vapor Flow Rates.
Tank Emissions Group
ID
Quantity of
Tanks
Throughput
per Group
(bbls/yr)
Energy
Content
(Btu/ft3)
Annual Energy
Throughput
(MMBtu/yr)
Wat_1.0_1000 3 1,080,000
300
1819
Wat_1.0_500 7 2,520,000 4245
Wat_1.0_400 4 1,440,000 2425
Oil_1.0_500 4 120,000 202
CovMix_Oil_1.0_250 2 60,000 101
Pilot 1
613,200
(SCF) 950 3271
Total 21 5,220,000 12,063
Notes: 1. Only the tanks at the southern (Harmston) site will be controlled by the flare.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-9

Table C-10. Flare Emission Factors and Estimated Emissions.
Analyte
Emission
Factor
(lb/MMBtu)
Annual
Combustion
(MMBtu/yr)
Annual
Emissions
(tons/yr) Source
Total hydrocarbons 0.14
12,063
0.84 AP-42, 3.5
Methane 0.077 0.46 AP-42, 3.5
Ethane/Ethylene 0.0112 0.07 AP-42, 3.5
Acetylene 0.007 0.04 AP-42, 3.5
Propane 0.0098 0.06 AP-42, 3.5
Propylene 0.035 0.21 AP-42, 3.5
CO 0.37 2.23 AP-42, 3.5
CO21 156 943 AP-42, 1.5-1
NOX 0.068 0.41 AP-42, 3.5
Soot 177 1068 AP-42, 3.5

Notes: 1. Assumes equivalent CO2 emission factor as combustion of propane.
Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-10

C-6.0 Truck Loading Operation
The emissions from the truck loading operation were estimated using the AP-42 method listed in
Section 5.2 (Transportation and Marketing of Petroleum Liquids). The truck loading operation is
assumed to have a throughput of 14,400 bbls/yr of crude oil. The truck loading operations will
employ a submerged loading technique. The following lists the method used to estimate the
emissions from the truck loading operation.
C-6.1 Methods and Results
The VOC emissions from truck loading operation for crude oil was estimated by using the
submerged loading saturation factor of 0.6, as listed in the AP-42 Table 5.2-1. At a total facility
throughput of 14,400 bbls/yr, the expected annual VOC emissions and calculations are listed in
Table C-11. The HAPS emissions were estimated using the VOC correlation ratios listed in
Table C-2 and the results of the estimate are included in Table B-2 and B-3 of the NOI.

Table C-11. Truck Loading Emissions Estimates.
Crude Oil Parameters
Parameter Symbol Unit Value Comments/Reference
Facility Oil Flow Rate Qf bbl/year 30,000 Design Spec; 11 bbl/day
True Vapor Pressure PVA psi 5.70 AP-42 Figure 7.1-13a
Molecular Weight MV lb/lb-mole 50 AP-42 Table 7.1-2
Liquid Bulk Temperature TB °R 574 AP-42 equ 1-28; 115 °F
Calculated Parameters
Parameter Symbol Unit Value Comments/Reference
Loading Saturation Factor S NA 0.6 AP-42 Table 5.2-1
Loading Losses LL lb/103 gal 3.71 AP-42 5.2 Equ (1)
Annual Loading Emissions LT Tons/yr 2.34 Calc.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-11

C-7.0 Unpaved Access Road
The emissions from the unpaved roads were estimated using the AP-42 method listed in Section
13.2.2 (Unpaved Roads).
C-7.1 Methods
The PM emissions generated from vehicle traffic on the unpaved road were estimated using AP-
42 Section 13.2.2 equation 1a.

𝐸=𝑘(𝑠/12)𝑎(𝑊/3)𝑎

Where s is the surface material silt content, W is the average weight of the vehicles, and a & b
are the constants listed in AP-42 Table 13.2.2-2.
C-7.2 Calculations and Results
The parameters K, a, and b were estimated using values in AP-42 Table 13.2.2-2 and are listed in
Table C-12. The calculated emission factors using equation (1a) are listed in Table C-13 through
C-15 for each traffic type. It is assumed that the facility traffic includes the following:

1. Produced Water Harmston Site:
a. 1,825 loads per year
b. Trucks travel 0.4 miles (roundtrip) or 730 vehicle miles traveled (VMT)/yr
c. Mean vehicle weight is 38 tons
2. Oil Sales Harmston Site:
a. 72 loads per year
b. Trucks travel 0.4 miles (roundtrip) or 28.8 VMT/yr
c. Mean vehicle weight is 33 tons
3. Centrifuged Solids Harmston Site:
a. 52 loads per year
b. Trucks travel 0.5 miles (roundtrip) or 26 VMT/yr
c. Mean vehicle weight is 28 tons

The percent silt of the road is 4% (AP-42 Table 13.2.2-1). The regular application of water to the
roads is assumed to control the emissions by 75%.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-12

Table C-12. Unpaved Road Parameters.
Total PM PM10 PM2.5
K (particle size multiplier)
4.9 1.5 0.15
a (particle size multiplier)
0.7 0.9 0.9
b (particle size multiplier)
0.45 0.45 0.45

Table C-13. Emission Factors and Rates of PM Emissions – Produced Water (Harmston).
Parameters Total PM PM10 PM2.5
Emission Factor (lb/VMT) 7.12 1.75 0.17
Miles Traveled Per Day 2
Emission Rate (tons/yr) 2.6 0.63 0.06
Controlled Emissions (75%) 0.64 0.16 0.02

Table C-14. Emission Factors and Rates of PM Emissions – Oil Sales (Harmston).
Parameters Total PM PM10 PM2.5
Emission Factor (lb/VMT) 6.68 1.64 0.16
Miles Traveled Per Day 0.08
Emission Rate (tons/yr) 0.0975 0.0240 0.0024
Controlled Emissions (75%) 0.0244 0.0060 0.0006

Table C-15. Emission Factors and Rates of PM Emissions – Solids (Harmston).
Parameters Total PM PM10 PM2.5
`Emission Factor (lb/VMT) 6.20 1.52 0.15
Miles Traveled Per Day 0.07
Emission Rate (tons/yr) 0.081 0.020 0.0020
Controlled Emissions (75%) 0.020 0.005 0.0005

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-13

C-8.0 Equipment Leaks
Fugitive VOC emissions from leaking equipment were estimated using the method described in
the EPA guidance document: Protocol for Equipment Leak Emissions Estimates (EPA-453/R-
95-017). The following describes the method used to estimate the emissions from leaking
equipment at the WDI Facility.
C-8.1 Methods
The emissions from the equipment were estimated based on emissions factors listed in EPA-
453/R-95-017 Table 2-4, Oil and Gas Production Operations Average Emission Factors.

The emissions factors correlate the pounds of pollutant emitted compared to the number of
connector types and contents of the connections (i.e. Gas, Heavy Oil, or Water). The emission
factors for the equipment leaks are listed in Table C-18.

Table C-18. Emission Factors for Equipment Leaks
EPA Method Lists
EPA Emission Factor (lbs/hr/component)1
Gas Heavy Oil Light Oil
Connectors 4.4E-04 1.7E-05 4.6E-04
Flanges 8.6E-04 8.6E-07 2.4E-04
Open Ended Lines 4.4E-03 3.1E-04 3.1E-03
Pump Seals 5.3E-03 NA 2.9E-02
Valves 9.9E-03 1.9E-05 5.5E-03
Other 1.9E-02 7.1E-05 1.7E-02
Notes: 1: Source: EPA Protocol form Equipment Leak Emissions Estimates; Table 2-4 (pg 2-15)
C-8.2 Calculations and Results
The emissions from equipment leaks are calculated by multiplying the emission factors listed in
Table C-18 by the annual operation time of the equipment and by the number of components.
The emissions estimates for the equipment are included in Table C-19. The equipment is
assumed to operate for 365 days 24 hrs/day (8760 hrs/yr). The quantity of connections and
valves were estimated using best engineering judgment. The HAPS emissions were estimated
using the VOC correlation ratios listed in Table C-2 and the results of the estimate are included
in Table B-2 and B-3 of the NOI.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-14

Table C-19. Equipment VOC Leaks Estimates.
EPA Method
Lists
Component Count Estimated Emissions (lbs/yr)
Gas Heavy
Oil
Water/Light
Oil Gas Heavy
Oil
Water/Light
Oil Total
Connectors 0 12 48 0 1.73 195 196
Flanges 0 6 6 0 0.05 12.75 12.79
Open Ended
Lines 0 6 6 0 16.2 162.2 178.5
Pumps Seals 0 NA 6 0 NA 1506.37 1506.37
Valves 0 5 20 0 0.81 965.7 966.5
Other 0 0 0 0 0 0 0
Totals: 0 29 86 0 18.8 2842 2861

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2024 GeoStrata Page | C-15

C-9.0 References

RTI international; Emission Estimation Protocol For Petroleum Refineries Version 2.1.1 – Final
ICR Version. March 2011.

Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-1

Table B-1. Approximate Equipment Locations and Stack Height Information.
Source Location (UTM Zone 12)1 Release Height (ft) Easting (m) Northing (m)
Southern (Harmston) Site
Tanks (Approximate) 583009.8 4467518.3 NA
Oil Mixing Equipment 582998.9 4467545.6 8
Solids Containment 582992.1 4467558.5 3
Injection Well 582955.8 4467255.6 NA
Flare 583071.3 4467544.3 18
Notes: 1. All locations are approximate.
Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-2

Table B-2a. Facility Uncontrolled Emissions (tons/yr).
Estimated Emissions in tons/yr (Uncontrolled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks 63.2 2.13 0.20 0.34 0.12 0.51 NA NA NA NA NA NA NA NA NA AP-42
Solids/Open Containment 212 3.30 0.23 0.55 0.17 1.04 NA 0.02 NA NA NA NA NA NA 0.71 Measured
Engines 0.007 8.2E-06 2.0E-06 8.9E-07 NA 6.2E-07 NA NA 0.34 0.002 2.2E-04 NA 1.8E-04 0.003 NA AP-42
Tank Heaters 0.04 NA NA NA NA NA 0.02 NA 882 0.62 0.06 NA 0.004 0.74 NA AP-42
Loading 2.34 0.08 0.007 0.013 0.004 0.019 NA NA NA NA NA NA NA NA NA AP-42
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.70 0.07 NA NA NA AP-42
Fugitive VOCs (Leaks) 1.43 0.048 4.46E-03 7.8E-03 2.66E-03 1.2E-02 NA NA NA NA NA NA NA NA NA AP-42
Total Emissions 279 5.56 0.44 0.92 0.30 1.58 0.02 0.017 883 0.62 0.76 0.07 0.005 0.74 0.71
Notes: NA: Not Applicable

Table B-2b. Facility Controlled Emissions (tons/yr).
Estimated Emissions in tons/yr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks (With Flare) 1.26 0.04 0.004 0.007 0.002 0.01 NA NA NA NA NA NA NA NA NA Calc.
Solids/Open Containment 21.19 0.33 0.02 0.06 0.02 0.10 NA 1.7E-03 NA NA NA NA NA NA 0.07 Calc.
Engines 0.007 8.2E-06 2.0E-06 8.9E-07 NA 6.2E-07 NA NA 0.34 0.002 2.2E-04 NA 1.8E-04 0.003 NA Calc.
Tank Heaters 0.04 NA NA NA NA NA 0.02 NA 882 0.62 0.06 NA 0.004 0.74 NA Calc.
Flare (combustion) 0.84 NA NA NA NA NA 0.46 NA 943 2.23 NA NA NA NA NA Calc.
Loading 2.34 0.08 0.007 0.013 0.004 0.019 NA NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.18 0.02 NA NA NA Calc.
Fugitive VOCs (Leaks) 1.43 0.048 4.5E-03 7.8E-03 2.7E-03 1.2E-02 NA NA NA NA NA NA NA NA NA Calc.
Total Emissions 27.11 0.50 0.038 0.08 0.027 0.14 0.48 1.7.E-03 1,825 2.85 0.23 0.02 0.005 0.74 0.07
Notes: NA: Not Applicable

Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-3

Table B-3. Facility Controlled Emissions (lbs/hr).
Estimated Emissions in lbs/hr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks (With Flare) 0.29 0.01 9.00E-04 0.002 5.4E-04 0.002 NA NA NA NA NA NA NA NA NA Calc.
Solids/Open Containment 4.84 0.075 5.2E-03 1.3E-02 3.9E-03 2.4E-02 NA 3.8E-04 NA NA NA NA NA NA 0.016 Calc.
Engines 0.002 1.9E-06 4.7E-07 2.0E-07 NA 1.4E-07 NA NA 0.08 5.0E-04 5.1E-05 NA 4.2E-05 7.8E-04 NA Calc.
Tank Heaters 0.009 NA NA NA NA NA 0.004 NA 201 0.14 0.01 NA 0.001 0.17 NA Calc.
Flare (combustion) 0.19 NA NA NA NA NA 0.11 NA 215 0.51 NA NA NA NA NA Calc.
Loading 0.53 0.018 1.7E-03 0.003 9.9E-04 0.004 NA NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.04 0.004 NA NA NA Calc.
Fugitive VOCs (Leaks) 0.33 1.1E-02 1.0E-03 1.8E-03 6.1E-04 2.6E-03 NA NA NA NA NA NA NA NA NA Calc.
Notes: 1: Assumes emissions occur 365 days per year and 24 hours per day
2: Assumes a running time of 104 hrs/yr (two hours per week)

Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Process Benzene Toluene Ethyl Benzene Xylene Methane Methanol Distance to
Boundary (m)
Vertically
Restricted?
TLV HAPS Analysis
Category
Leaks (Fugitive VOCs) 1.0E-03 1.8E-03 6.1E-04 2.6E-03 NA NA 60 Yes
50-100 m (restricted) Loading 1.7E-03 0.003 9.9E-04 0.004 NA NA 90 Yes
TLV Limit 0.197 9.27 10.68 106.81 6.45 34.25 -- --
Engines 4.7E-07 2.0E-07 NA 1.4E-07 NA NA 50 No 50-100 m (unrestricted)
TLV Limit 0.358 16.88 19.45 194.52 11.74 62.37 -- --
Flare NA NA NA NA NA NA 150 No
>100 m (unrestricted)
TLV Limit 0.588 27.73 31.96 319.57 19.29 102.47 -- --
Notes: NA: Not Applicable
ND: Not Detected

Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-4

Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Estimated Emissions in Tons/yr (Controlled)
Process CO Fugitive PM10 Nonfugitive PM10 SOX NOX
Total Emissions (Controlled) 2.9 0.18 0.06 0.005 0.74
Criteria Pollutants Mod. Threshold 100 15 5 40 40

Table B-6. Regulatory Review.
State Regulatory Determinations
State Requirements Requirement Applicability Determination
R307-401. Permit:
New and Modified
Sources
Obtain an Approval Order
prior to construction
Applicable - facility exceeds the small
source exemption threshold for VOC as
outlined in R307-401-9
R307-405. Permits:
Major Sources in
Attainment Areas
Federal PSD
implementation
Not Applicable - the facility is not located in
a nonattainment or maintenance area.
R3074-415. Permits:
Operating Permit
Requirements
Federal Title V
implementation
Not Applicable - facility emissions are
below the Title V threshold limits.
40 CFR Part 63
Subpart DD
National Emission
Standards for Hazardous
Air Pollutants from Off-
Site Waste and Recovery
Operations
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single
HAP or 25 tons/yr of any combination of
HAPs)
40 CFR Part 63
Subpart ZZZZ
National Emissions
Standards for Hazardous
Air Pollutants for
Stationary Reciprocating
Internal Combustion
Engines
Not Applicable - Facility does not operate
engines that may be subject to standards
applicable to area or major sources of HAP
40 CFR Part 63
Subpart DDDDD
National Emissions
Standards for Hazardous
Air Pollutants for Major
Sources: Industrial,
Commercial, and
Institutional Boilers and
Process Heaters
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single
HAP or 25 tons/yr of any combination of
HAPs)
40 CFR Part 60
Subpart Dc
Standards of Performance
for Small Industrial-
commercial-Institutional
Steam Generating units
Not Applicable - Facility does not operate
any steam generating units with maximum
heat input greater than 10 MMBtu/hr
Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-5

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

Water Disposal Inc., - NOI
Appendix B
Copyright © 2024 GeoStrata Page | B-6

Table B-7a. BACT Controls Analysis of VOC Reductions and Emissions.
Control Source Control Capital
Cost
Annual
Cost
Life Span
(yrs)
Interest
Rate
Annualized
Cost
VOC
Reduction
(tons)
HAPs
Reduction
(tons)
VOC
Reduction Costs
($/ton)
Methanol
Reduction Costs
($/ton)
HAPs
Reduction Costs
($/ton)
Cost per
barrel of
water1
Solids Containment Centrifuge Solids $26,950 $2,572 20 3% $3,381 142 3 $24 NA $1,096 $0.01
Flare System Tank Vapors $261,860 $36,565 20 $36,565 47 2 $784 NA $23,206.10 $0.10
Notes: 1: Assumes 360,000 bbls of produced water processed annually.

Table B-7b. BACT Controls Analysis of PM Reductions and Emissions.
Control Source
Control
Capital
Cost
Annual
Cost
Life
Span
(yrs)
Interest
Rate
Annualized
Cost
PM10
Reduction
(tons)
PM10
Reduction
Costs
($/ton)
Water
Road dust
control
$130,000 $1,200 20
3%
$9,938 0.50 $19,876
MgCL2 $130,000 $8,000 20 $16,738 0.57 $29,365
Asphalt
Pavement $172,151 $6,000 20 $17,571 0.60 $29,285

Water Disposal Inc.
Produced Water Facility

Notice of Intent (NOI)
Permit Modification

December 2023

Prepared by:

14425 S. Center Point Way, Bluffdale, Utah 84065
T: [phone] F: [phone]
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | i
Table of Contents
1.0 INTRODUCTION ................................................................................................................... 1
1.1 Process Flow: ................................................................................................................... 1
1.1.1 Water ......................................................................................................................... 1
1.1.2 Oil ............................................................................................................................. 1
1.1.3 Solids......................................................................................................................... 2
2.0 EQUIPMENT DETAILS ........................................................................................................ 2
2.1 Storage Tanks and Containment ...................................................................................... 2
2.1.1 Emissions Controls ................................................................................................... 2
2.2 Solids ................................................................................................................................ 2
2.2.1 Emissions Controls ................................................................................................... 3
2.3 Engines ............................................................................................................................. 3
2.3.1 Emissions Controls ................................................................................................... 3
2.4 Tank Heaters .................................................................................................................... 3
2.4.1 Emissions Controls ................................................................................................... 3
2.5 Truck Loading .................................................................................................................. 3
2.5.1 Emissions Controls ................................................................................................... 3
2.6 Unpaved Access Roads .................................................................................................... 3
2.6.1 Emissions Controls ................................................................................................... 4
2.7 Equipment Leaks .............................................................................................................. 4
2.7.1 Emissions Controls ................................................................................................... 4
3.0 FACILITY THROUGHPUT ................................................................................................... 4
4.0 EMISSIONS INFORMATION ............................................................................................... 4
4.1 Storage Tanks and Containment ...................................................................................... 5
4.2 Centrifuged Solids ............................................................................................................ 5
4.3 Stationary Engines ............................................................................................................ 5
4.4 Tank Heaters .................................................................................................................... 5
4.5 Flare .................................................................................................................................. 5
4.6 Truck Loading Operation (Oil Sales) ............................................................................... 5
4.7 Unpaved Access Road ...................................................................................................... 6
4.8 Equipment Leaks .............................................................................................................. 6
4.9 Facility Wide Greenhouse Gas Emissions ....................................................................... 6
5.0 EMISSIONS IMPACT ASSESSMENT (EIA) ....................................................................... 6
6.0 REGULATORY REVIEW...................................................................................................... 7
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | ii
7.0 BACT ANALYSIS .................................................................................................................. 7
7.1 Storage Tanks ................................................................................................................... 7
7.2 Centrifuged Solids ........................................................... Error! Bookmark not defined.
7.3 Stationary Engines ........................................................... Error! Bookmark not defined.
7.4 Tank Heaters ................................................................... Error! Bookmark not defined.
7.5 Truck Loading .................................................................................................................. 8
7.6 Unpaved Roads ................................................................................................................ 8
8.0 REFERENCES ........................................................................................................................ 9

Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | iii
List of Figures
Figure A-1. Facility Location
Figure A-2. Harmston Facility Site Boundary
Figure A-3. Harmston Facility Site Layout
Figure A-4. Harmston Facility Process Flow Diagram
List of Tables
Table B-1. Equipment Location and Stack Height Information
Table B-2. Facility Controlled and Uncontrolled Emissions (tons/yr)
Table B-3. Facility Controlled Emissions (lbs/hr)
Table B-4. Facility Emissions Compared to the ETVs (lbs/hr)
Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values
Table B-6. Regulatory Review
Table B-7. BACT Controls Analysis Reductions and Emissions
List of Appendices
Appendix A. Figures
Appendix B. Tables
Appendix C. Emissions Estimates
Appendix D. Utah DAQ Forms
Appendix E. EPA Tanks Results
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 1
1.0 INTRODUCTION
Water Disposal, Inc. (WDI) is submitting this Notice of Intent (NOI) to the New Minor Source
Review group for a modification to the existing approval order (AO) DAQE-AN156680001-17.
The AO is for the WDI produced water facility located in Duchesne County at approximately
UTM coordinates 583017.9 meters (m) East 4467512.5 m North (zone 12 NAD 1983). This
facility is identified as the Harmston Facility and is located approximately 3.8 miles north of
Roosevelt, Utah. Figure A-1 illustrates the location of the Harmston facility. The current layout
for the Harmston facility is illustrated in Figures A-2 and A-3. The following emissions sources
are associated with the facility’s processes:
1.Storage tanks for produced water and crude oil
2.Mechanical oil, water, and solids separation equipment, (i.e. equipment leaks)
3.Centrifuged solids
4.Tank heaters
5.Truck loading
6.Unpaved roads
1.1 Process Flow:
1.1.1 Water
The Harmston site pumps produced water from trucks and into a set of three (3) 1000 barrels
(bbls) storage tanks and six (6) other tanks, ranging in size from 400 bbls to 500 bbls, used as
overflow storage when needed. Produced water is then pumped into a set of three (3) 500 bbls
decanting tanks. Decanted water is routed to a set of two (2) 400 bbls pre-injection tanks and
then pumped into the injection well on site. Water from the centrifuging process is pumped back
to the decanting tanks.
1.1.2 Oil
At the Harmston site the oil separated from the produced water decanting process is pumped to
two (2) heated (~165°F) ~250 bbl mixing tanks where the oil is mixed with coagulant and
demulsifying agents. Crude oil may also be delivered to the site for cleaning by the same
process. After a period of mixing the solids and water that still remain in the oil are removed by a
centrifuge. The oil is piped to the four (4) heated (~165°F) oil sales/storage tanks for
transportation off site.
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 2
1.1.3 Solids
The centrifuged solids are stored in a covered and sealed container before being transported and
disposed offsite.
2.0 EQUIPMENT DETAILS
The equipment with associated emission sources and emission controls at the Harmston facility
are described in the original NOI and there are no proposed changes or additions to the
equipment that is utilized at the facility. The following section details the equipment that was
also presented in the original NOI. A list of all of the emission sources, approximate coordinates
and the stack heights are presented in Table B-1.
2.1 Storage Tanks and Containment
There are a total of eighteen (20) fixed roof tanks, two (2) open containers for skimming and two
(2)covered containers for mixing at the facility each with various capacities and contents. Most
tanks and containers at both sites have fixed roofs equipped with a thief hatch. All Tanks on the
Harmston site have vapor control ports.
Of the 20 fixed roof tanks fourteen (14) vertical tanks are used as produced water process
equalization tanks. These tanks include four (4) 400 bbl tanks, seven (7) 500 bbl tanks, and three
(3) 1000 bbl tanks.
Two (2) vertical 400 bbl tanks are used for pre-injection storage. These tanks feed processed
water into the on-site injection well located at the Harmston site.
Four (4) 500 bbl tanks, two (2) skimming containers, and two (2) mixing containers (chemical
mixing) are used for oil cleaning and storage.
2.1.1 Emissions Controls
All emissions from the twenty (20) tanks and containers located at the Harmston site will be
controlled by a vapor collection system that will discharge the collected vapors to a flare. The
destruction efficiency of the flare is estimated to be 98% (Appendix D, TCI Specification Sheet).
2.2 Solids
Solids generated from the centrifuge are stockpiled in a sealed storage container and will be
regularly hauled to an offsite disposal.
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 3
2.2.1 Emissions Controls
The emissions from the solids will be controlled by a vapor collection system that will discharge
the collected vapors to a flare.
2.3 Engines
At the facility there is one pressure washer (10 bhp gasoline engine) that has de minimis use.
2.3.1 Emissions Controls
Emissions will be controlled by routine maintenance and limiting run time. Estimated annual run
time is listed in Appendix C.
2.4 Tank Heaters
Each heated tank is equipped with an individual heater that has a bonnet rating no more than one
million British Thermal Units (MMBtu) per hour.
2.4.1 Emissions Controls
Tank heater emissions are a small fraction of the estimated emissions total for the facility (See
Table B-2). The tank heater emissions will be controlled by routine maintenance and limiting run
time.
2.5 Truck Loading
The tanker trucks (oil sales) loading oil will be performed using submerged loading techniques to
reduce VOC emissions. It is assumed that an average of 34 trucks (Approximately 180 bbl
capacity each) per year will be loaded at the site.
2.5.1 Emissions Controls
Truck loading will be performed using the submersed loading. The emission reduction efficiency
is estimated to be 40% (AP-42 Section 7.1.2.1).
2.6 Unpaved Access Roads
Trucks that haul produced water, oil, and processed solids on and off each site use unpaved
access roads. The roundtrip travel distances that the trucks will travel on unpaved roads at the
site are listed below.
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 4
1. Harmston Site
a. Produced Water Trucks: 0.4 miles
b. Oil Sales Trucks: 0.4 miles
2.6.1 Emissions Controls
The dust emissions from the unpaved roads at the Harmston site will be controlled by applying
water to the road way to maintain a crust or compacted soil. Magnesium chloride or similar
water vapor absorbent will be used as determined by operators.
2.7 Equipment Leaks
Equipment leaks associated with the facility are from all connections, valves, and manifolds used
in processing, storing and transporting produced water and oil.
2.7.1 Emissions Controls
The emissions from the equipment leaks will be controlled by perform regular and proper
maintenance on all of the facilities components.

3.0 FACILITY THROUGHPUT
The annual maximum throughput volumes of waste materials at the Harmston facility are
summarized below. WDI is requesting at this time an increase to the allowable throughput for the
oil that is processed and sold at the facility. The original NOI had an estimated oil throughput of
14,400 bbls of oil annually. The increased volume associated with this permit modification is
30,000 bbls per year. The estimated maximum throughputs for all other waste materials in this
permit modification will remain unchanged.

1. Produced Water Received (oil/water mix): 270,000 bbls
2. Oil (separated and sold): 30,000 bbls
3. Centrifuged Solids (wet): 87 yds3 (95.32 tons dry)
4. Natural Gas Consumption (tank heaters): 15,000 MMBtu

4.0 EMISSIONS INFORMATION
This section lists the estimated controlled and uncontrolled emissions from the facility and a
description of the methods used to estimate the emissions. The emission estimates for the oil
tanks have been updated for this NOI. Emissions related to the flare and truck loading are
updated from the original NOI to account for the increased oil throughput. Please refer to
Appendix B for updated emission totals and Appendix C for emission estimates
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 5
4.1 Storage Tanks and Containment
The emissions from the storage tanks and containment were estimated using the “EPA Tanks”
program. The assumptions, calculations, and results from the AP-42 emissions estimates are
included in Appendix C. The uncontrolled and controlled annual emissions from the tanks are
listed in Table B-2 and the hourly controlled emissions are included in Table B-3.
4.2 Centrifuged Solids
The uncontrolled emissions from the solids were estimated by sampling centrifuged solids from
the WDI facility. The soils were analyzed for total TPH-GRO, TPH-DRO, and VOCs. The
centrifuged solids were sampled four (4) times in October 2015.

The assumptions, calculations, and results for the emissions estimates for both controlled and
uncontrolled emissions are included in Appendix C. The uncontrolled and controlled annual
emissions from the solids are listed in Table B-2 and the hourly controlled emissions are
included in Table B-3.
4.3 Stationary Engines
The emissions from the Reciprocating Internal Combustion Engines (RICE) were estimated
using the AP-42 Section3.3 method (Gasoline and Diesel Industrial Engines). The assumptions,
calculations, and results are included in Appendix C. The uncontrolled and controlled annual
emissions from the engines are listed in Table B-2 and the hourly controlled emissions are
included in Table B-3.
4.4 Tank Heaters
The emissions from tank heaters were estimated using AP-42 Section 1.4 (Natural Gas
Combustion). The assumptions, calculations, and results are included in Appendix C. The
uncontrolled and controlled annual emission from the tank heaters are listed in Table B-2 and the
hourly controlled emissions are included in Table B-3.
4.5 Flare
The combustion emissions from the flare were estimated using AP-42 Section 3.15 (Industrial
Flares). The assumptions, calculations, and results from the AP-42 emissions estimates are
included in Appendix C. The annual emissions from the flare are listed in Table B-2 and the
hourly controlled emissions are included in Table B-3.
4.6 Truck Loading Operation (Oil Sales)
The emissions from truck loading operations (oil sales) were estimated using AP-42 Section 5.2
method (Transportation and Marketing of Petroleum Liquids). The assumptions, calculations,
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 6
and results are included in Appendix C. The uncontrolled and controlled annual emissions from
the loading operations are listed in Table B-2 and the hourly controlled emissions are included in
Table B-3.
4.7 Unpaved Access Road
The emissions from unpaved access roads were estimated using AP-42 Section 13.2.2 (Unpaved
Roads). The assumptions, calculations, and results are included in Appendix C. The uncontrolled
and controlled annual emissions from the roads (Fugitive Dust) are listed in Table B-2 and the
hourly controlled emissions are included in Table B-3.
4.8 Equipment Leaks
The equipment leaks emissions were estimated using the methods listed in the document “EPA
Protocol for Equipment Leak Emissions Estimates” (EPA, 1995). The assumptions, calculations,
and results for the emissions estimates are included in Appendix C. The uncontrolled and
controlled annual emission from the equipment leaks are listed in Table B-2 and the hourly
controlled emissions are included in Table B-3.
4.9 Facility Wide Greenhouse Gas Emissions
The total greenhouse gas emissions were summed from the totals listed in Table B-2. The
methane emissions are assumed to have a carbon dioxide equivalent (CO2e) factor of 25 parts
methane per one part CO2.
5.0 EMISSIONS IMPACT ASSESSMENT (EIA)
Following the Utah DAQ Guidelines (UDAQ, 2012) an Emissions Impact Assessment (EIA)
was performed for all the sources at the WDI Harmston facility to determine if any of the
emission rates were above the Emission Threshold Value (ETV) and if the emission levels
exceed the modeling requirement. The ETVs for each pollutant were determined using the
American Conference of Governmental Industrial Hygienists (ACGIH) spreadsheet (UDAQ,
2013).

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

The total facility criteria pollutant emissions from the facility are compared to the Utah DAQ
dispersion modeling threshold values in Table B-5 (UDAQ, 2012). None of the annual facility
emissions exceed the modeling threshold values.
Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 7
6.0 REGULATORY REVIEW
Relevant state and federal regulations are identified in Table B-6 with a description of the
applicability to the facility.

7.0 BACT ANALYSIS
This permit modification requests an increased throughput of oil that is processed at the facility.
The increase of oil processed has resulted in minor increases of emissions from the tanks, truck
loading, unpaved roads and flare. The original NOI evaluated all applicable equipment under
this permit and there is no new equipment added in this permit modification. The increased
though put has not changed the applicable controls that are included in the BACT analysis that
was part of the original NOI. However as part of this NOI the equipment and processes that have
increased emissions are evaluated in the following sections. Please refer to the BACT analysis
that was included in the 2017 NOI for information on all equipment and processes that were
evaluated for the entire facility.

7.1 Storage Tanks
The emissions from the storage tanks that must be controlled are VOCs and HAPs. BACT for
these emissions usually consists of 1) Vapor Recovery, 2) VOC/HAP Destruction (using flares,
thermal oxidizers, etc) or some combination of the two.

Vapor recovery systems are most often used to reduce product loss as well as to control
emissions. For fixed roof tanks a condenser is often installed at the tank thief hatch or other
pressure relief device. Captured vapors are condensed in to a liquid state and returned to the tank.
The efficiency of a vapor recovery system ranges from 90% to 98% (AP-42 Section 7.2.1).

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

WDI has chosen to use a flare to control the VOC and HAP emissions from tanks and other
containments. Although, the control efficiencies for the condenser and the flare are similar the
flare is mechanically easier to control and operate. Therefore, the use of a flare is considered
BACT. The flare is an existing control at the facility and the increased emissions from the tanks
will be controlled by use of the flare. The annualized cost of flare installation and operation is
included in Table B-7.

Water Disposal, Inc. - NOI
December 2023
Copyright © 2023 GeoStrata Notice of Intent
Page | 8
7.2 Truck Loading
The constituents emitted from the truck loading operations are VOCs and HAPs. The proposed
control of the loading emissions is the implementation of the submerged loading technique.
Submerged loading involves filling the tank truck with the fill nozzle below the surface of the
oil. The control efficiency of using submerged loading is 40% (AP-42 Table 5.2-1) and is
considered BACT.
7.3 Unpaved Roads
At the Harmston facility there is approximately 1700 feet of unpaved roads that are utilized by
the water disposal trucks and oil sales trucks. Currently WDI controls dust on the roadway by
watering as the control technology for PM10 and visible dust emissions. A control efficiency of
75% is common and will be used in the BACT analysis. Other methods to control dust are using
a chemical dust suppressant or replacing unpaved roads with hard pavement.

The use of a chemical dust suppressant (e.g. magnesium chloride) would cost $8,000/year to
purchase and. This control has an annual life cycle cost of $29,365/ton of PM10 removed and is
not considered to be an economically achievable BACT (Table B-7).

The capital cost to hard-pave the sections of roadways would be approximately $172,150.
Annual maintenance of hard paving is approximately $6,000. The Annual life cycle cost to hard-
pave and maintain roads is $29,285/ton of PM10 removed which is not considered to be an
economical BACT(detailed cost analysis included in Appendix E). Although hard pavement and
chemical suppressants have a greater reduction of dust emissions they are economically
unfeasible to use at the subject site. Therefore, watering and regular maintenance of the road will
be utilized as a dust control method.

Integrated Water Management - NOI
April 2015
Copyright © 20 GeoStrata Notice of Intent
Page | 9

8.0 REFERENCES

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

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

Appendix A
Figures

1:60,000
Water Disposal, Inc. Water Disposal FacilityRoosevelt, UTProject Number: 1129-001 Facility Location
0 0.5 1 1.5 20.25 Miles
FigureA-1
Copyright GeoStrata, 2016
Legend
Harmston Fa cility
Harmston Fa cility
1:3,600
Water Disposal, Inc. Water Disposal FacilityRoosevelt, UTProject Number: 1129-001Harmston Fa cility Site B oundary
0 200 400 600 800100Feet
FigureA-2
Copyright GeoStrata, 2016Legend
Injection Well
Location of Disposal Equip me nt
Site Bound ary
CentrifugeSolids Containment
Unloading Area
Injection Tank
Mixing Equipment
Oil Sales
1:900
Water Disposal, Inc. Water Disposal FacilityRoosevelt, UTProject Number: 1129-001 Harmston Fa cility Site Layout
0 50 100 150 20025Feet
FigureA-3
Copyright GeoStrata, 2016
Legend
Prop osed Flare L ocation
Piplin e to In jection We ll
Copyright GeoStrata, 2016
Harmston Facility Process Flow Diagram
Water Disposal Inc.
Water Disposal Facility
Project Number: 1129-001
Figure
A-4

Appendix B
Tables

Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-1

Table B-1. Approximate Equipment Locations and Stack Height Information.
Source Location (UTM Zone 12)1 Release Height (ft) Easting (m) Northing (m)
Southern (Harmston) Site
Tanks (Approximate) 583009.8 4467518.3 NA
Oil Mixing Equipment 582998.9 4467545.6 8
Solids Containment 582992.1 4467558.5 3
Injection Well 582955.8 4467255.6 NA
Flare 583071.3 4467544.3 18
Notes: 1. All locations are approximate.
Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-2

Table B-2a. Facility Uncontrolled Emissions (tons/yr).
Estimated Emissions in tons/yr (Uncontrolled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks 65.4 2.21 0.20 0.35 0.12 0.53 NA NA NA NA NA NA NA NA NA AP-42
Solids/Open Containment 212 3.30 0.23 0.55 0.17 1.04 NA 0.02 NA NA NA NA NA NA 0.71 Measured
Engines 0.007 8.2E-06 2.0E-06 8.9E-07 NA 6.2E-07 NA NA 0.34 0.002 2.2E-04 NA 1.8E-04 0.003 NA AP-42
Tank Heaters 0.04 NA NA NA NA NA 0.02 NA 882 0.62 0.06 NA 0.004 0.74 NA AP-42
Loading 2.34 0.08 0.007 0.013 0.004 0.019 NA NA NA NA NA NA NA NA NA AP-42
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.70 0.07 NA NA NA AP-42
Fugitive VOCs (Leaks) 0.10 0.003 2.98E-04 5.2E-04 1.78E-04 7.7E-04 NA NA NA NA NA NA NA NA NA AP-42
Total Emissions 280 5.59 0.44 0.92 0.30 1.59 0.02 0.017 883 0.62 0.76 0.07 0.005 0.74 0.71
Notes: NA: Not Applicable

Table B-2b. Facility Controlled Emissions (tons/yr).
Estimated Emissions in tons/yr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks (With Flare) 1.31 0.04 0.004 0.007 0.002 0.01 NA NA NA NA NA NA NA NA NA Calc.
Solids/Open Containment 2.34 0.007 2.9E-05 0.001 3.5E-04 0.003 NA 1.4E-04 NA NA NA NA NA NA 0.01 Calc.
Engines 0.007 8.2E-06 2.0E-06 8.9E-07 NA 6.2E-07 NA NA 0.34 0.002 2.2E-04 NA 1.8E-04 0.003 NA Calc.
Tank Heaters 0.04 NA NA NA NA NA 0.02 NA 882 0.62 0.06 NA 0.004 0.74 NA Calc.
Flare (combustion) 0.62 NA NA NA NA NA 0.34 NA 687 1.63 NA NA NA NA NA Calc.
Loading 2.34 0.08 0.007 0.013 0.004 0.019 NA NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.18 0.02 NA NA NA Calc.
Fugitive VOCs (Leaks) 0.10 0.003 3.0E-04 5.2E-04 1.8E-04 7.7E-04 NA NA NA NA NA NA NA NA NA Calc.
Total Emissions 6.74 0.13 0.012 0.02 0.007 0.03 0.36 1.4.E-04 1,570 2.25 0.23 0.02 0.005 0.74 0.01
Notes: NA: Not Applicable

Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-3

Table B-3. Facility Controlled Emissions (lbs/hr).
Estimated Emissions in lbs/hr (Controlled)
Process VOC HAPs Benzene Toluene Ethyl Benzene Xylene Methane Methanol CO2 CO PM10 PM2.5 SOX NOX Sulfer Source
All Tanks (With Flare) 0.30 0.01 9.32E-04 0.002 5.6E-04 0.002 NA NA NA NA NA NA NA NA NA Calc.
Solids/Open Containment 0.53 0.002 6.6E-06 2.5E-04 7.9E-05 7.9E-04 NA 3.2E-05 NA NA NA NA NA NA 0.003 Calc.
Engines 0.002 1.9E-06 4.7E-07 2.0E-07 NA 1.4E-07 NA NA 0.08 5.0E-04 5.1E-05 NA 4.2E-05 7.8E-04 NA Calc.
Tank Heaters 0.009 NA NA NA NA NA 0.004 NA 201 0.14 0.01 NA 0.001 0.17 NA Calc.
Flare (combustion) 0.14 NA NA NA NA NA 0.08 NA 157 0.37 NA NA NA NA NA Calc.
Loading 0.53 0.018 1.7E-03 0.003 9.9E-04 0.004 NA NA NA NA NA NA NA NA NA Calc.
Unpaved Roads NA NA NA NA NA NA NA NA NA NA 0.04 0.004 NA NA NA Calc.
Fugitive VOCs (Leaks) 0.02 7.4E-04 6.8E-05 1.2E-04 4.1E-05 1.8E-04 NA NA NA NA NA NA NA NA NA Calc.
Notes: 1: Assumes emissions occur 365 days per year and 24 hours per day
2: Assumes a running time of 104 hrs/yr (two hours per week)

Table B-4. Facility Emissions Compared to the ETVs (lbs/hr).
Process Benzene Toluene Ethyl Benzene Xylene Methane Methanol Distance to
Boundary (m)
Vertically
Restricted?
TLV HAPS Analysis
Category
Leaks (Fugitive VOCs) 6.8E-05 1.2E-04 4.1E-05 1.8E-04 NA NA 60 Yes
50-100 m (restricted) Loading 1.7E-03 0.003 9.9E-04 0.004 NA NA 90 Yes
TLV Limit 0.197 9.27 10.68 106.81 6.45 34.25 -- --
Engines 4.7E-07 2.0E-07 NA 1.4E-07 NA NA 50 No 50-100 m (unrestricted) TLV Limit 0.358 16.88 19.45 194.52 11.74 62.37 -- --
Flare NA NA NA NA NA NA 150 No >100 m (unrestricted)
TLV Limit 0.588 27.73 31.96 319.57 19.29 102.47 -- --
Notes: NA: Not Applicable
ND: Not Detected

Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-4

Table B-5. Total Facility Emissions Compared to the Dispersion Modeling Threshold Values.
Estimated Emissions in Tons/yr (Controlled)
Process CO Fugitive PM10 Nonfugitive PM10 SOX NOX
Total Emissions (Controlled) 2.2 0.18 0.06 0.005 0.74
Criteria Pollutants Mod. Threshold 100 15 5 40 40

Table B-6. Regulatory Review.
State Regulatory Determinations
State Requirements Requirement Applicability Determination
R307-401. Permit:
New and Modified
Sources
Obtain an Approval Order
prior to construction
Applicable - facility exceeds the small
source exemption threshold for VOC as
outlined in R307-401-9
R307-405. Permits:
Major Sources in
Attainment Areas
Federal PSD
implementation
Not Applicable - the facility is not located in
a nonattainment or maintenance area.
R3074-415. Permits:
Operating Permit
Requirements
Federal Title V
implementation
Not Applicable - facility emissions are
below the Title V threshold limits.
40 CFR Part 63
Subpart DD
National Emission
Standards for Hazardous
Air Pollutants from Off-
Site Waste and Recovery
Operations
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single
HAP or 25 tons/yr of any combination of
HAPs)
40 CFR Part 63
Subpart ZZZZ
National Emissions
Standards for Hazardous
Air Pollutants for
Stationary Reciprocating
Internal Combustion
Engines
Not Applicable - Facility does not operate
engines that may be subject to standards
applicable to area or major sources of HAP
40 CFR Part 63
Subpart DDDDD
National Emissions
Standards for Hazardous
Air Pollutants for Major
Sources: Industrial,
Commercial, and
Institutional Boilers and
Process Heaters
Not Applicable - The facility is not a major
source of HAPs (10 tons/yr of any single
HAP or 25 tons/yr of any combination of
HAPs)
40 CFR Part 60
Subpart Dc
Standards of Performance
for Small Industrial-
commercial-Institutional
Steam Generating units
Not Applicable - Facility does not operate
any steam generating units with maximum
heat input greater than 10 MMBtu/hr
Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-5

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

Water Disposal Inc., - NOI
Appendix B
Copyright © 2023 GeoStrata Page | B-6

Table B-7a. BACT Controls Analysis of VOC Reductions and Emissions.
Control Source Control Capital
Cost
Annual
Cost
Life Span
(yrs)
Interest
Rate
Annualized
Cost
VOC
Reduction
(tons)
HAPs
Reduction
(tons)
VOC
Reduction Costs
($/ton)
Methanol
Reduction Costs
($/ton)
HAPs
Reduction Costs
($/ton)
Cost per
barrel of
water1
Solids Containment Centrifuge Solids $26,950 $2,572 20 3% $3,381 142 3 $24 NA $1,096 $0.01
Flare System Tank Vapors $261,860 $36,565 20 $36,565 47 2 $784 NA $23,206.10 $0.10
Notes: 1: Assumes 360,000 bbls of produced water processed annually.

Table B-7b. BACT Controls Analysis of PM Reductions and Emissions.
Control Source
Control
Capital
Cost
Annual
Cost
Life
Span
(yrs)
Interest
Rate
Annualized
Cost
PM10
Reduction
(tons)
PM10
Reduction
Costs
($/ton)
Water
Road dust
control
$130,000 $1,200 20
3%
$9,938 0.50 $19,876
MgCL2 $130,000 $8,000 20 $16,738 0.57 $29,365
Asphalt
Pavement $172,151 $6,000 20 $17,571 0.60 $29,285

Appendix C
Emissions Estimates

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-1

C-1.0 Storage Tanks and Containment
The emissions of VOCs from the storage tanks and containment were estimated using the EPA
Tanks program (EPA, 2012). The tanks at this facility have cone shaped fixed roofs that are
equipped with pressure relief valves. Five (5) of the twenty (20) tanks and containment are
heated to approximately 165°F. The unheated tanks remain at ambient temperatures. The
following lists the method used to estimate the VOC emissions.
C-1.1 Methods
The total emissions from the storage tanks and containment were estimated using the EPA
Tanks. This program estimates the emissions of organic chemicals from storage tanks based on
AP-42 methods. An inventory of all the tanks and containment at the facility is listed in Table
C-1.
C-1.1.1 HAPs Emissions Correlations
The Hazardous Air Pollutants (HAPs) emissions were estimated using VOC emissions to
specific HAP emission ratios as reported in the report “Emission Estimate Protocol for
petroleum Refineries” written by RTI International (RTI, 2011). The ratios are listed in Table C-
2.
C-1.1 Results
C-1.1.1 Assumptions for All Facility Tanks
The total throughput of each tank, tank contents and throughput per tank is provided in Table C-
3. The uncontrolled VOCs and HAPs emissions from the tanks are listed in Table C-4. The
results from the EPA Tanks analysis are included in Appendix H.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-2

Table C-1. Tank and Containment Inventory and Specifications
Tank ID # of
Tanks Contents Type Shell
Diameter
Shell
Height
Volume
(bbls
Ave. Liquid
Height Heated
Tank
Temp.
(F)
Har_Wat_1.0_1000 3 Water Vertical 16 28 1000 17 No Ambient
Har_Wat_1.0_500 7 Water Vertical 12 25 500 16 No Ambient
Har_Wat_1.0_400 4 Water Vertical 12 20 400 12 No Ambient
Har_Oil_1.0_500 4 Oil Vertical 12 25 480 16 Yes ~165°
Har_MixOil_1.0_250 2 Oil Horizontal 12 25 250 10 Yes ~165°

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

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-3

Table C-3. Tank Flow Rates
Tank ID # of Tanks Volume
(bbl) Total Throughput (bbl)
Har_Wat_1.0_1000 3 1000 270,000
Har_Wat_1.0_500 7 500 270,000
Har_Wat_1.0_400 4 400 270,000
Har_Oil_1.0_500 4 480 30,000
Har_MixOil_1.0_250 2 250 30,000

Table C-4. EPA Tanks Results and Uncontrolled Emissions Estimates
Tank ID # of
Tanks
Uncontrolled Emissions (tons/yr)
VOC HAPs Benzene Toluene
Ethyl
Benzene Xylene
Har_Wat_1.0_1000 3 11.7 0.39 0.04 0.06 0.02 0.09
Har_Wat_1.0_500 7 20.6 0.69 0.06 0.11 0.04 0.17
Har_Wat_1.0_400 4 11.6 0.39 0.04 0.06 0.02 0.09
Har_Oil_1.0_500 4 14.39 0.49 0.04 0.08 0.03 0.12
Har_MixOil_1.0_250 2 7.20 0.24 0.02 0.04 0.013 0.06
Total Uncontrolled (tons/yr) 65.44 2.21 0.20 0.35 0.12 0.53
Total Controlled (tons/yr) 1.31 0.04 0.004 0.01 0.002 0.01

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-4

C-2.0 Centrifuge Solids
In-house solids are generated during cleaning of the oil in the centrifuge separation equipment.
Emissions for the in-house solids were estimated using analytical data from samples collected at
the WDI facility. The soils were analyzed for TPH-GRO, TPH-DRO, and VOCs.
C-2.1 Methods
C-2.1.1 Uncontrolled Emissions
The centrifuged solids at the Harmston Facility were sampled four (4) times. The sample
analysis data is included in Appendix G.

The estimated annual throughput of centrifuged solids is 87 cubic yards (yd3) per year (95.32 dry
tons/yr). The mean concentration of the constituents was multiplied by the total dry throughput
of material to determine the total annual and hourly uncontrolled emissions from the facility
solids.
C-2.1.2 Controlled Emissions
The centrifuge solids will be contained in sealed containers and will be regularly transported
offsite.
C-2.2 Calculations and Results
The mean concentrations of VOCs (TPH-GRO and TPH-DRO) and HAPS and estimated
emissions are included in Table C-5 for the centrifuged solids.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-5

Table C-5. Centrifuged Solids Uncontrolled Emissions.
Solids
Analyte Mean Concentration
(mg/kg)
Emissions Per Year
(tons/yr)
Emissions
(lbs/yr)
Sulfer 18036 1.72 3438
1,2,3-Trimethylbenzene 196 0.02 37.3
1,2,4-Trimethylbenzene 510 0.05 97.2
1,3,5-Trimethylbenzene 246 0.02 46.9
Benzene 15.2 0.001 2.90
Bromobenzene 0.02 1.86E-06 0.004
Ethylbenzene 182 0.02 34.8
Isopropylbenzene 21.2 0.002 4.04
Naphthalene 35.3 0.003 6.74
n-Butylbenzene 6.70 6.39E-04 1.28
n-Propylbenzene 31.4 0.003 5.99
p-Isopropyltoluene 13.4 0.001 2.55
sec-Butylbenzene 7.85 7.48E-04 1.50
tert-Butylbenzene 3.56 3.39E-04 0.68
Toluene 563 0.05 107
TPH (GC/FID) High Fraction 1181144 113 225169
TPH (GC/FID) Low Fraction 45000 4.29 8579
Xylenes, Total 1817 0.17 346
Methanol 175 0.02 33

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-6

C-3.0 Engines
The emissions from the one engine at the WDI facility were estimated using the methods listed
AP-42 Section 3.3 (Gasoline and Diesel Industrial Engines). This engine is used to operate a
pressure washer. The emission factors and assumptions are included below.
C-3.1 Method and Results
The emissions factors for the engine on site were obtained from AP-42 emission factors listed in
Section 3.3. The emission factors, annual hours of operation, engine capacity, and annual
emissions are listed in Table C-6.

Table C-6. Gasoline Pressure Washer Criteria Pollutant Emissions.
Analyte Emission Factor
(lbs/hp-hr) hrs/yr1 hp Emissions
(tons/yr) Source
PM10 0.0007
104 6
0.0002 AP-42 Table 3.3-1
NOX 0.0110 0.003 AP-42 Table 3.3-1
SOX 5.91E-04 0.0002 AP-42 Table 3.3-1
CO 0.0070 0.002 AP-42 Table 3.3-1
CO2 1.08 0.34 AP-42 Table 3.3-1
VOC 0.022 0.007 AP-42 Table 3.3-1
Notes 1: Estimated use is a maximum of 2 hours a week.

It is assumed that the engine at the WDI facility has a Break-Specific Fuel Consumption (BCFC)
of 0.007 MMBtu/hp-hr (AP-42 Table 3.3-1). The annual HAPs emissions based on fuel
consumption and hours of operation are provided in Tables C-7.

Table C-7. Gasoline Pressure Washer HAPs Emissions.
Analyte lb/MMBtu MMBtu/yr lbs/hr lb/yr tons/yr Source
Benzene 0.000933
4
3.9E-05 4.1E-03 2.04E-06 AP-42 Table 3.3-2
Toluene 0.000409 1.7E-05 1.8E-03 8.93E-07 AP-42 Table 3.3-2
Xylenes 0.000285 1.2E-05 1.2E-03 6.22E-07 AP-42 Table 3.3-2
Formaldehyde 0.00118 5.0E-05 5.2E-03 2.58E-06 AP-42 Table 3.3-2
Acetaldehyde 0.000767 3.2E-05 3.4E-03 1.68E-06 AP-42 Table 3.3-2
Acrolein 0.0000925 3.9E-06 4.0E-04 2.02E-07 AP-42 Table 3.3-2
Naphthalene 0.0000848 3.6E-06 3.7E-04 1.85E-07 AP-42 Table 3.3-2
Total HAPS - - 1.6E-04 1.6E-02 8.19E-06 Calc.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-7

C-4.0 Tank Heaters
The emissions from tank heaters were estimated using the method listed in AP-42 Section 1.4
(Natural Gas Consumption). The emission factors and assumptions are included below.
C-4.1 Method and Results
The emission factors for the tank heaters are listed in Table C-8. The heaters are assumed to
operate year round and consume a maximum 15,000 MMBtu of natural gas annually. The
number of assumed annual hours of operation is conservative in that 2 tank heaters are rarely
used.

Table C-8. Tank Heaters Emissions Estimates.
Tank Heater Parameters
Parameter Unit Value Comments/Reference
Tank Heaters ea 5 Facility Design
Total Heat Input MMBtu/yr 15,000 Facility Records
Emission Factors1
Parameter Unit Value Comments/Reference
Particulate Matter lbs/MMBtu 0.00745098 AP-42 Table 1.4-2
Sulfur Oxides (as SO2) lbs/MMBtu 0.000588235 AP-42 Table 1.4-2
Nitrogen Oxides lbs/MMBtu 0.098039216 AP-42 Table 1.4-1
Carbon Dioxide lbs/MMBtu 117.6470588 AP-42 Table 1.4-2
Carbon Monoxide lbs/MMBtu 0.082352941 AP-42 Table 1.4-1
Volatile Organic Compounds lbs/MMBtu 0.005392157 AP-42 Table 1.4
Methane lbs/MMbtu 0.002254902 AP-42 Table 1.4
Emissions Estimates
Parameter Unit Value Comments/Reference
Particulate Matter lbs/yr 112 Calc.
Sulfur Oxides (as SO2) lbs/yr 9 Calc.
Nitrogen Oxides lbs/yr 1471 Calc.
Carbon Dioxide lbs/yr 1764706 Calc.
Carbon Monoxide lbs/yr 1235 Calc.
Volatile Organic Compounds lbs/yr 81 Calc.
Methane lbs/yr 34 Calc.
Notes: 1. These emissions factors were converted from lbs/106 scf to lbs/MMBtu per AP-42 Table 1.4-2
(footnote a).

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-8

C-5.0 Flare
The emissions from the flare were estimated using the methods listed in AP-42 Section 3.15 and
1.5 (Industrial Flares & Liquefied Petroleum Gas Combustion). The emission factors and
assumptions are included below.
C-5.1 Method and Results
The flow and total energy content (MMBtu/yr) of the tanks at the site are listed in Table C-9.
The emission factors for the flare are listed in Table C-10. The emissions of the total
hydrocarbons (including ethane and other organics), CO, NOX, and Soot were estimated using
emission factors from AP-42 Tables 3.15-1 and 3.15-2. The emission factor for CO2 was
assumed to be equivalent to the combustion of propane as defined in AP-42 Section 1.5. It is
assumed that the flare combustion gas contains 300 Btu/ft3 of heat value (AP-42 Section 3.15).
The flare controls vapors from 20 tanks with throughputs (i.e. vapor flow rates) listed in Table C-
9.

Table C-9. Vapor Flow Rates.
Tank Emissions Group
ID
Quantity of
Tanks
Throughput
per Group
(bbls/yr)
Energy
Content
(Btu/ft3)
Annual
Energy
Throughput
(MMBtu/yr)
Wat_1.0_1000 3 1,080,000
300
1819
Wat_1.0_500 7 2,520,000 4245
Wat_1.0_400 4 1,440,000 2425
Oil_1.0_500 4 120,000 202
CovMix_Oil_1.0_250 2 60,000 101
Total 20 5,220,000 8,792
Notes: 1. Only the tanks at the southern (Harmston) site will be controlled by the flare.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-9

Table C-10. Flare Emission Factors and Estimated Emissions.
Analyte
Emission
Factor
(lb/MMBtu)
Annual
Combustion
(MMBtu/yr)
Annual
Emissions
(tons/yr) Source
Total hydrocarbons 0.14
8,635
0.62 AP-42, 3.5
Methane 0.077 0.34 AP-42, 3.5
Ethane/Ethylene 0.0112 0.05 AP-42, 3.5
Acetylene 0.007 0.03 AP-42, 3.5
Propane 0.0098 0.04 AP-42, 3.5
Propylene 0.035 0.15 AP-42, 3.5
CO 0.37 1.63 AP-42, 3.5
CO21 156 687 AP-42, 1.5-1
NOX 0.068 0.30 AP-42, 3.5
Soot 177 778 AP-42, 3.5

Notes: 1. Assumes equivalent CO2 emission factor as combustion of propane.
Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-10

C-6.0 Truck Loading Operation
The emissions from the truck loading operation were estimated using the AP-42 method listed in
Section 5.2 (Transportation and Marketing of Petroleum Liquids). The truck loading operation is
assumed to have a throughput of 14,400 bbls/yr of crude oil. The truck loading operations will
employ a submerged loading technique. The following lists the method used to estimate the
emissions from the truck loading operation.
C-6.1 Methods and Results
The VOC emissions from truck loading operation for crude oil was estimated by using the
submerged loading saturation factor of 0.6, as listed in the AP-42 Table 5.2-1. At a total facility
throughput of 14,400 bbls/yr, the expected annual VOC emissions and calculations are listed in
Table C-11. The HAPS emissions were estimated using the VOC correlation ratios listed in
Table C-2 and the results of the estimate are included in Table B-2 and B-3 of the NOI.

Table C-11. Truck Loading Emissions Estimates.
Crude Oil Parameters
Parameter Symbol Unit Value Comments/Reference
Facility Oil Flow Rate Qf bbl/year 30,000 Design Spec; 11 bbl/day
True Vapor Pressure PVA psi 5.70 AP-42 Figure 7.1-13a
Molecular Weight MV lb/lb-mole 50 AP-42 Table 7.1-2
Liquid Bulk Temperature TB °R 574 AP-42 equ 1-28; 115 °F
Calculated Parameters
Parameter Symbol Unit Value Comments/Reference
Loading Saturation Factor S NA 0.6 AP-42 Table 5.2-1
Loading Losses LL lb/103 gal 3.71 AP-42 5.2 Equ (1)
Annual Loading Emissions LT Tons/yr 2.34 Calc.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-11

C-7.0 Unpaved Access Road
The emissions from the unpaved roads were estimated using the AP-42 method listed in Section
13.2.2 (Unpaved Roads).
C-7.1 Methods
The PM emissions generated from vehicle traffic on the unpaved road were estimated using AP-
42 Section 13.2.2 equation 1a.

𝐸=𝑘(𝑠/12)𝑎(𝑊/3)𝑎

Where s is the surface material silt content, W is the average weight of the vehicles, and a & b
are the constants listed in AP-42 Table 13.2.2-2.
C-7.2 Calculations and Results
The parameters K, a, and b were estimated using values in AP-42 Table 13.2.2-2 and are listed in
Table C-12. The calculated emission factors using equation (1a) are listed in Table C-13 through
C-15 for each traffic type. It is assumed that the facility traffic includes the following:

1. Produced Water Harmston Site:
a. 1,825 loads per year
b. Trucks travel 0.4 miles (roundtrip) or 730 vehicle miles traveled (VMT)/yr
c. Mean vehicle weight is 38 tons
2. Oil Sales Harmston Site:
a. 72 loads per year
b. Trucks travel 0.4 miles (roundtrip) or 28.8 VMT/yr
c. Mean vehicle weight is 33 tons
3. Centrifuged Solids Harmston Site:
a. 52 loads per year
b. Trucks travel 0.5 miles (roundtrip) or 26 VMT/yr
c. Mean vehicle weight is 28 tons

The percent silt of the road is 4% (AP-42 Table 13.2.2-1). The regular application of water to the
roads is assumed to control the emissions by 75%.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-12

Table C-12. Unpaved Road Parameters.
Total PM PM10 PM2.5
K (particle size multiplier)
4.9 1.5 0.15
a (particle size multiplier)
0.7 0.9 0.9
b (particle size multiplier)
0.45 0.45 0.45

Table C-13. Emission Factors and Rates of PM Emissions – Produced Water (Harmston).
Parameters Total PM PM10 PM2.5
Emission Factor (lb/VMT) 7.12 1.75 0.17
Miles Traveled Per Day 2
Emission Rate (tons/yr) 2.6 0.63 0.06
Controlled Emissions (75%) 0.64 0.16 0.02

Table C-14. Emission Factors and Rates of PM Emissions – Oil Sales (Harmston).
Parameters Total PM PM10 PM2.5
Emission Factor (lb/VMT) 6.68 1.64 0.16
Miles Traveled Per Day 0.08
Emission Rate (tons/yr) 0.0975 0.0240 0.0024
Controlled Emissions (75%) 0.0244 0.0060 0.0006

Table C-15. Emission Factors and Rates of PM Emissions – Solids (Harmston).
Parameters Total PM PM10 PM2.5
`Emission Factor (lb/VMT) 6.20 1.52 0.15
Miles Traveled Per Day 0.07
Emission Rate (tons/yr) 0.081 0.020 0.0020
Controlled Emissions (75%) 0.020 0.005 0.0005

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-13

C-8.0 Equipment Leaks
Fugitive VOC emissions from leaking equipment were estimated using the method described in
the EPA guidance document: Protocol for Equipment Leak Emissions Estimates (EPA-453/R-
95-017). The following describes the method used to estimate the emissions from leaking
equipment at the WDI Facility.
C-8.1 Methods
The emissions from the equipment were estimated based on emissions factors listed in EPA-
453/R-95-017 Table 2-4, Oil and Gas Production Operations Average Emission Factors.

The emissions factors correlate the pounds of pollutant emitted compared to the number of
connector types and contents of the connections (i.e. Gas, Heavy Oil, or Water). The emission
factors for the equipment leaks are listed in Table C-18.

Table C-18. Emission Factors for Equipment Leaks
Connections
EPA Emission Factor (lbs/hr/component)1
Gas Heavy
Oil
Light
Oil
Water/Light
Oil
Connectors 4.4E-04 1.7E-05 2.4E-04 4.4E-04
Flanges 8.6E-04 8.6E-07 6.4E-06 8.6E-04
Open Ended Lines 4.4E-03 3.1E-04 5.5E-04 4.4E-03
Pump Seals 5.3E-03 NA 5.3E-05 5.3E-03
Valves 9.9E-03 1.9E-05 2.2E-04 9.9E-03
Other 1.9E-02 7.1E-05 3.1E-02 1.9E-02
Notes: 1: Source: EPA Protocol form Equipment Leak Emissions Estimates; Table 2-4 (pg 2-15)
C-8.2 Calculations and Results
The emissions from equipment leaks are calculated by multiplying the emission factors listed in
Table C-18 by the annual operation time of the equipment and by the number of components.
The emissions estimates for the equipment are included in Table C-19. The equipment is
assumed to operate for 365 days 24 hrs/day (8760 hrs/yr). The quantity of connections and
valves were estimated using best engineering judgment. The HAPS emissions were estimated
using the VOC correlation ratios listed in Table C-2 and the results of the estimate are included
in Table B-2 and B-3 of the NOI.

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-14

Table C-19. Equipment VOC Leaks Estimates.
EPA Method
Lists
Component Count Estimated Emissions (lbs/yr)
Gas Heavy
Oil
Water/Light
Oil Gas Heavy
Oil
Water/Light
Oil Total
Connectors 0 12 48 0 1.73 102 104
Flanges 0 6 6 0 0.05 0.34 0.38
Open Ended Lines 0 6 6 0 16.2 28.9 45.1
Pumps Seals 0 NA 6 0 NA 2.78 2.78
Valves 0 5 20 0 0.81 37.8 38.7
Other 0 0 0 0 0 0 0
Totals: 0 29 86 0 18.8 172 191

Water Disposal, Inc. - NOI
Appendix C
Copyright © 2023 GeoStrata Page | C-15

C-9.0 References

RTI international; Emission Estimation Protocol For Petroleum Refineries Version 2.1.1 – Final
ICR Version. March 2011.

Appendix D
Utah DAQ Forms
Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2)
4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD)
9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced
3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]
A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)
B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent
(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
AN156680001-17 05 24 2017
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________

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

End product of this process:

_______________________________

3. Permit Change Type: New Increase*

Equipment

Process

Condition Change ____________________

Other ______________________________

Other ______________________________

Other ______________________________

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

Yes No
5. Condition(s) Changing:

6. Description of Permit/Process Change**

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

8. New or modified process emitting units **

Emitting Unit(s)

Capacity(s)

Manufacture Date(s)

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

Doc.uim:i'ii D^lc: 02/28/2018
DAQ 2018-002274
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Jccumonl Dcjlc: 02/28/2018
Appendix E h
EPA Tanks Program Results
TANKS 4.0.9d
Emissions Report - Detail Format
Tank Indentification and Physical Characteristics
Identification
User Identification: WDI 500 OIL
City: Salt Lake City
State: Utah
Company: Water Disposal Inc
Type of Tank: Vertical Fixed Roof Tank
Description: Harmston
Tank Dimensions
Shell Height (ft): 25.00
Diameter (ft): 12.00
Liquid Height (ft) : 20.00
Avg. Liquid Height (ft): 16.00
Volume (gallons): 16,920.59
Turnovers: 74.47
Net Throughput(gal/yr): 1,260,000.00
Is Tank Heated (y/n): Y
Paint Characteristics
Shell Color/Shade: White/White
Shell Condition Good
Roof Color/Shade: White/White
Roof Condition: Good
Roof Characteristics
Type: Cone
Height (ft) 1.00
Slope (ft/ft) (Cone Roof) 0.17
Breather Vent Settings
Vacuum Settings (psig): 0.00
Pressure Settings (psig) 0.00
Meterological Data used in Emissions Calculations: Salt Lake City, Utah (Avg Atmospheric Pressure = 12.64 psia)
Page 1 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
TANKS 4.0.9d
Emissions Report - Detail Format
Liquid Contents of Storage Tank
WDI 500 OIL - Vertical Fixed Roof Tank
Salt Lake City, Utah
Daily Liquid Surf.
Temperature (deg F)
Liquid
Bulk
Temp Vapor Pressure (psia)
Vapor
Mol.
Liquid
Mass
Vapor
Mass Mol. Basis for Vapor Pressure
Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations
Crude oil (RVP 5) All 140.00 140.00 140.00 140.00 11.2303 11.2303 11.2303 50.0000 207.00 Option 4: RVP=5
Page 2 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
TANKS 4.0.9d
Emissions Report - Detail Format
Detail Calculations (AP-42)
WDI 500 OIL - Vertical Fixed Roof Tank
Salt Lake City, Utah
Annual Emission Calcaulations
Standing Losses (lb): 0.0000
Vapor Space Volume (cu ft): 1,055.5751
Vapor Density (lb/cu ft): 0.0873
Vapor Space Expansion Factor: 0.0000
Vented Vapor Saturation Factor: 0.1525
Tank Vapor Space Volume:
Vapor Space Volume (cu ft): 1,055.5751
Tank Diameter (ft): 12.0000
Vapor Space Outage (ft): 9.3333
Tank Shell Height (ft): 25.0000
Average Liquid Height (ft): 16.0000
Roof Outage (ft): 0.3333
Roof Outage (Cone Roof)
Roof Outage (ft): 0.3333
Roof Height (ft): 1.0000
Roof Slope (ft/ft): 0.1700
Shell Radius (ft): 6.0000
Vapor Density
Vapor Density (lb/cu ft): 0.0873
Vapor Molecular Weight (lb/lb-mole): 50.0000
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 11.2303
Daily Avg. Liquid Surface Temp. (deg. R): 599.6700
Daily Average Ambient Temp. (deg. F): 51.9625
Ideal Gas Constant R
(psia cuft / (lb-mol-deg R)): 10.731
Liquid Bulk Temperature (deg. R): 599.6700
Tank Paint Solar Absorptance (Shell): 0.1700
Tank Paint Solar Absorptance (Roof): 0.1700
Daily Total Solar Insulation
Factor (Btu/sqft day): 1,452.1184
Vapor Space Expansion Factor
Vapor Space Expansion Factor: 0.0000
Daily Vapor Temperature Range (deg. R): 0.0000
Daily Vapor Pressure Range (psia): 0.0000
Breather Vent Press. Setting Range(psia): 0.0000
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 11.2303
Vapor Pressure at Daily Minimum Liquid
Surface Temperature (psia): 11.2303
Vapor Pressure at Daily Maximum Liquid
Surface Temperature (psia): 11.2303
Daily Avg. Liquid Surface Temp. (deg R): 599.6700
Daily Min. Liquid Surface Temp. (deg R): 599.6700
Daily Max. Liquid Surface Temp. (deg R): 599.6700
Daily Ambient Temp. Range (deg. R): 23.3583
Vented Vapor Saturation Factor
Vented Vapor Saturation Factor: 0.1525
Vapor Pressure at Daily Average Liquid:
Surface Temperature (psia): 11.2303
Vapor Space Outage (ft): 9.3333
Working Losses (lb): 7,195.5851
Vapor Molecular Weight (lb/lb-mole): 50.0000
Vapor Pressure at Daily Average Liquid
Surface Temperature (psia): 11.2303
Annual Net Throughput (gal/yr.): 1,260,000.0000
Annual Turnovers: 74.4655
Turnover Factor: 0.5695
Maximum Liquid Volume (gal): 16,920.5925
Maximum Liquid Height (ft): 20.0000
Tank Diameter (ft): 12.0000
Working Loss Product Factor: 0.7500
Total Losses (lb): 7,195.5851
Page 3 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
Page 4 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
TANKS 4.0.9d
Emissions Report - Detail Format
Individual Tank Emission Totals
Emissions Report for: Annual
WDI 500 OIL - Vertical Fixed Roof Tank
Salt Lake City, Utah
Losses(lbs)
Components Working Loss Breathing Loss Total Emissions
Crude oil (RVP 5) 7,195.59 0.00 7,195.59
Page 5 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm
Page 6 of 6TANKS 4.0 Report
12/6/2023file:///C:/Program%20Files%20(x86)/Tanks409d/summarydisplay.htm