DAQ-2024-011070

DAQE-AN102530016-24

{{$d1 }}

Taryn Weiner
UGC Midstream LTD, LLC
760 Horizon Drive, Suite 400
Grand Junction, CO 81506
[e-mail]

Dear Ms. Weiner:

Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN102530014-18 to
Replace a Generator with a Microturbine under R307-401-12 Reduction in Air Pollutants
Project Number: N102530016

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on April 3,
2024. UGC Midstream LTD, LLC must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is Katie Andersen, 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.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB:KA:jg

cc: Southeastern Utah District Health Department

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

September 10, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN102530016-24
Administrative Amendment to Approval Order
DAQE-AN102530014-18 to Replace a Generator with a
Microturbine under R307-401-12 Reduction in Air Pollutants

Prepared By
Katie Andersen, Engineer
[phone]
[e-mail]

Issued to
UGC Midstream LDT, LLC - Westwater Compressor Station

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

September 10, 2024
TABLE OF CONTENTS

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

DAQE-AN102530016-24
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
UGC Midstream LTD, LLC UGC Midstream LDT, LLC - Westwater Compressor Station

Mailing Address Physical Address
760 Horizon Drive, Suite 400 NE/4 NW/4 Sec. 9, T18S, R24E
Grand Junction, CO 81506 Westwater, UT 84515

Source Contact UTM Coordinates
Name: Taryn Weiner 649,575 m Easting
Phone: [phone],347,334 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 1311 (Crude Petroleum & Natural Gas)

SOURCE INFORMATION
General Description
UGC Midstream LTD, LLC (UGC Midstream) operates the Westwater Natural Gas Compressor Station
located near Westwater, Grand County. The Westwater Compressor Station is a rural facility used to
boost the pressure and dehydrate natural gas along a gathering line. Entrained water and hydrocarbon
liquids are separated from the natural gas stream in a slug catcher and routed to a pressurized storage
tank. The natural gas is compressed by natural gas-fueled engines and dehydrated by one (1) triethylene
glycol dehydration unit. The waste liquids are then routed to three (3) condensate storage tanks that are
out-loaded by trucks as needed.

NSR Classification
Administrative Amendment

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

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), OOOO: Standards of Performance for Crude Oil and Natural Gas Production,
Transmission and Distribution for which Construction, Modification, or Reconstruction
Commenced After August 23, 2011, and on or before September 18, 2015
NSPS (Part 60), OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities
DAQE-AN102530016-24
Page 4

for which Construction, Modification or Reconstruction Commenced After November 15, 2021
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines

Project Description
UGC Midstream will be replacing one (1) 72 hp natural gas-fired engine (Equipment ID II.A.4 in AO
DAQE-AN102530014-18) with one (1) 40.2 hp natural gas-fired microturbine. The removal of the engine
and addition of the microturbine result in a net decrease in criteria and hazardous air pollutant emissions.
This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12).

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 -115.86 19077.11
Carbon Monoxide -0.81 49.84
Nitrogen Oxides -0.96 50.69
Particulate Matter - PM10 -0.01 0.31
Particulate Matter - PM2.5 -0.01 0.31
Sulfur Oxides 0 0.10
Volatile Organic Compounds -0.03 25.01

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 360
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 600
Formaldehyde (CAS #50000) -60 2280
Generic HAPs (CAS #GHAPS) 0 20
Hexane (CAS #110543) 0 100
Toluene (CAS #108883) 0 380
Xylenes (Isomers And Mixture) (CAS #1330207) 0 80
Change (TPY) Total (TPY)
Total HAPs -0.03 1.91

SECTION I: GENERAL PROVISIONS

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-AN102530016-24
Page 5

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of construction or modification to
the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Westwater Natural Gas Compressor Station II.A.2 Compressor Engines Three (3) Natural Gas-Fired Compressor Engines Maximum hp: 1340 hp (each) Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO
II.A.3 Compressor Engine One (1) Natural Gas-Fired Compressor Engine Maximum hp: 655 hp Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO
DAQE-AN102530016-24
Page 6

II.A.4 Microturbine One (1) Microturbine Model: Capstone C30 NG Fuel Type: Natural Gas Rating: 40.2 hp Heat Rate: 0.43 MMBtu/hr Subject to: NSPS Subpart OOOOb
II.A.5 Facility Flare One (1) Facility Flare Burner Capacity: 0.5 MMBtu/hr

II.A.6 Dehydration Unit One (1) Glycol Dehydration Unit with Reboiler Capacity: 2 MMscfd II.A.7 Condensate Storage Tanks with Heaters
Three (3) Condensate Storage Tanks
Tank Capacity: 300 bbl (each) Heater Capacity: 0.25 to 0.5 MMBtu/hr (each)

II.A.8 Process Storage Tanks Seven (7) Process Storage Tanks Tank Contents: new oil, used oil, lube oil, antifreeze, and Triethylene Glycol

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities 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 in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]

II.B.1.b The owner/operator shall route all exhaust gas/vapors from the condensate storage tanks and natural gas dehydration unit to the operating combustor/flare. [R307-401-8]
II.B.1.c The owner/operator shall not produce more than 3,000 barrels (1 barrel = 42 gallons) of
condensate per rolling 12-month period. [R307-401-8]
DAQE-AN102530016-24
Page 7

II.B.1.c.1 The owner/operator shall: A. Determine production with process flow meters and/or sales records. B. Record production on a daily basis. C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.1.d The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401]
II.B.1.e The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401] II.B.1.e.1 The owner/operator shall inspect the thief hatches at least once every six (6) months to ensure the
thief hatches are closed, latched, and the associated gaskets, if any, are in good working
condition. [R307-401-8]
II.B.1.e.2 The owner/operator shall keep records of thief hatch inspections, which shall include the date of the inspection and the status of the thief hatches. [R307-401-8] II.B.2 Stack Testing Requirements
II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]

II.B.2.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.2.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]

II.B.2.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8]
II.B.2.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]

DAQE-AN102530016-24
Page 8

II.B.2.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8]
II.B.2.b.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K).
B. Pressure - 29.92 in Hg (101.3 kPa).
C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.b.2 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.b.3 CO
40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]
II.B.3 Engine Requirements
II.B.3.a The owner/operator shall not emit more than the following rates and concentrations from EACH
Caterpillar 3516 Natural Gas Compressor Engine:
Pollutant lb/hr ppmdv
NOx 2.79 76.6
CO 2.79 125.7
Concentration (ppmdv) is corrected to 15% oxygen, dry basis. [R307-401-8]

II.B.3.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] II.B.3.a.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]
II.B.3.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within two (2) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.3.b The owner/operator shall replace the reciprocating compressor rod packing before the
compressor has operated for 26,000 hours or 36 months, whichever comes first. The
owner/operator shall continuously monitor the hours of operation upon initial startup of the
reciprocating compressor or the date of the most recent rod packing replacement, whichever is
later. [40 CFR 60 Subpart OOOO]

DAQE-AN102530016-24
Page 9

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN102530014-18 dated April 6, 2018 Is Derived From NOI received April 3, 2024 Incorporates Additional Information dated April 3, 2024 Incorporates Additional Information dated July 22, 2024

DAQE-AN102530016-24
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-

RN102530016 August 22, 2024 Taryn Weiner UGC Midstream, LTD, LLC 760 Horizon Drive Suite 400 Grand Junction, CO 81506
[e-mail] Dear Taryn Weiner,
Re: Engineer Review: Administrative Amendment to Approval Order DAQE-AN102530014-18 to Replace a Generator with a Microturbine under R307-401-12 Reduction in Air Pollutants
Project Number: N102530016 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 (NSR) permitting program. UGC Midstream, LTD, LLC should complete this review within 10 business days of receipt.
UGC Midstream, LTD, LLC should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If UGC Midstream, LTD, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If UGC Midstream, LTD, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting
construction.
Approval Signature _______________________________________________ (Signature & Date)

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N102530016 Owner Name UGC Midstream, LTD, LLC Mailing Address 760 Horizon Drive Suite 400 Grand Junction, CO, 81506 Source Name UGC Midstream LDT, LLC- Westwater Compressor Station Source Location NE/4 NW/4 Sec. 9, T18S, R24E Westwater, UT 84515
UTM Projection 649,575 m Easting, 4,347,334 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12
SIC Code 1311 (Crude Petroleum & Natural Gas) Source Contact Taryn Weiner
Phone Number [phone] Email [e-mail]
Billing Contact Taryn Weiner Phone Number [phone] Email [e-mail] Project Engineer Katie Andersen, Engineer Phone Number [phone] Email [e-mail]
Notice of Intent (NOI) Submitted April 3, 2024 Date of Accepted Application April 24, 2024

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 2
SOURCE DESCRIPTION General Description
UGC Midstream, LTD, LLC (UGC Midstream) operates the Westwater Natural Gas Compressor Station located near Westwater, Grand County. The Westwater Compressor Station is a rural facility used to boost the pressure and dehydrate natural gas along a gathering line. Entrained
water and hydrocarbon liquids are separated from the natural gas stream in a slug catcher and routed to a pressurized storage tank. The natural gas is compressed by natural gas-fueled engines and dehydrated by one triethylene glycol dehydration unit. The waste liquids are then routed to
three condensate storage tanks that are out-loaded by trucks as needed. NSR Classification:
Administrative Amendment Source Classification
Located in an Attainment Area Grand County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification, or Reconstruction
Commenced After August 23, 2011, and on or before September 18, 2015 NSPS (Part 60), OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After November 15, 2021
MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
Project Proposal Administrative Amendment to Approval Order DAQE-AN102530014-18 to Replace a Generator
with a Microturbine under R307-401-12 Reduction in Air Pollutants Project Description
UGC Midstream, LTD, LLC (UGC Midstream) will be replacing one (1) 72 hp natural gas-fired engine (Equipment ID II.A.4 in AO DAQE-AN102530014-18) with one (1) 40.2 hp natural gas-fired microturbine. The removal of the engine and addition of the microturbine results in a net decrease in criteria and hazardous air pollutant emissions. This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). EMISSION IMPACT ANALYSIS No criteria air pollutants and/or HAPs emissions are increasing. Therefore, no modeling is required at this time. [Last updated April 23, 2024]

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 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 -115.86 19077.11
Carbon Monoxide -0.81 49.84
Nitrogen Oxides -0.96 50.69
Particulate Matter - PM10 -0.01 0.31
Particulate Matter - PM2.5 -0.01 0.31
Sulfur Oxides 0 0.10 Volatile Organic Compounds -0.03 25.01 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 360
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 600
Formaldehyde (CAS #50000) -60 2280
Generic HAPs (CAS #GHAPS) 0 20 Hexane (CAS #110543) 0 100 Toluene (CAS #108883) 0 380
Xylenes (Isomers And Mixture) (CAS #1330207) 0 80
Change (TPY) Total (TPY)
Total HAPs -0.03 1.91

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

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding Engine Replacement
This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). Under UAC R307-401-12(1), the source is not required to submit a notice of intent. Therefore, no BACT is required at this time. [Last updated May 13, 2024]

SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 5
I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Westwater Natural Gas Compressor Station

II.A.2 Compressor Engines Three (3) Natural Gas-Fired Compressor Engines Maximum hp: 1340 hp (each) Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO
II.A.3 Compressor Engine One (1) Natural Gas-Fired Compressor Engine Maximum hp: 655 hp Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO
II.A.4 NEW Microturbine One (1) Microturbine Model: Capstone C30 NG
Fuel Type: Natural Gas Rating: 40.2 hp Heat Rate: 0.43 MMBtu/hr
Subject to: NSPS Subpart OOOOb II.A.5 Facility Flare One (1) Facility Flare
Burner Capacity: 0.5 MMBtu/hr II.A.6 Dehydration Unit One (1) Glycol Dehydration Unit with Reboiler
Capacity: 2 MMscfd II.A.7 Condensate Storage Tanks with Heaters Three (3) Condensate Storage Tanks Tank Capacity: 300 bbl (each) Heater Capacity: 0.25 to 0.5 MMBtu/hr (each)

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 6
II.A.8 Process Storage Tanks Seven (7) Process Storage Tanks Tank Contents: new oil, used oil, lube oil, antifreeze and Triethylene Glycol

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 Site 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 associated with the source or with the control facilities 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 in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b
NEW
The owner/operator shall route all exhaust gas/vapors from the condensate storage tanks and
natural gas dehydration unit to the operating combustor/flare. [R307-401-8]
II.B.1.c NEW The owner/operator shall not produce more than 3,000 barrels (1 barrel = 42 gallons) of condensate per rolling 12-month period. [R307-401-8]
II.B.1.c.1
NEW
The owner/operator shall:
A. Determine production with process flow meters and/or sales records
B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of
each month using data from the previous 12 months.
D. Keep the production records for all periods the plant is in operation. [R307-401-8]
II.B.1.d The owner/operator shall load the tanker trucks on site by the use of submerged loading.
[R307-401] II.B.1.e NEW The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401]

II.B.1.e.1
NEW
The owner/operator shall inspect the thief hatches at least once every six (6) months to ensure
the thief hatches are closed, latched and the associated gaskets, if any, are in good working condition. [R307-401-8]

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II.B.1.e.2 NEW The owner/operator shall keep records of thief hatch inspections which shall include the date of the inspection and the status of the thief hatches. [R307-401-8] II.B.2 NEW Stack Testing Requirements
II.B.2.a
NEW
The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]
II.B.2.a.1 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]
II.B.2.a.2
NEW
Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.2.a.3
NEW
Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]

II.B.2.a.4 NEW Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8] II.B.2.a.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.2.b NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed
below. [R307-401-8] II.B.2.b.1 NEW Standard Conditions
A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]

II.B.2.b.2 NEW NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

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II.B.2.b.3 NEW CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.3 Engine Requirements
II.B.3.a
NEW
The owner/operator shall not emit more than the following rates and concentrations from
EACH Caterpillar 3516 Natural Gas Compressor Engine: Pollutant lb/hr ppmdv
NOx 2.79 76.6
CO 2.79 125.7 Concentration (ppmdv) is corrected to 15% oxygen, dry basis. [R307-401-8]
II.B.3.a.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained
in this AO. [R307-165-2, R307-401-8] II.B.3.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days
after startup of the emission unit. [R307-165-2] II.B.3.a.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within two (2) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8]
II.B.3.b NEW The owner/operator shall replace the reciprocating compressor rod packing before the compressor has operated for 26,000 hours or 36-months, whichever comes first. The
owner/operator shall continuously monitor the hours of operation upon initial startup of the reciprocating compressor or the date of the most recent rod packing replacement, whichever is later. [40 CFR 60 Subpart OOOO]

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PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN102530014-18 dated April 6, 2018
Incorporates Additional Information dated April 3, 2024 Incorporates Additional Information dated July 22, 2024
REVIEWER COMMENTS 1. Comment regarding Reduction in Air Pollutants: UGC Midstream has requested the replacement of one (1) 72 hp natural gas-fired engine with one
(1) 40.2 hp natural gas-fired microturbine. The engine and the microturbine are assumed to operate 8,760 hours annually with the same source of natural gas fuel. The equipment replacement results in a reduction of 0.96 tpy of NOx, 0.03 tpy of VOCs, 0.81 tpy of CO, 1.15 lbs per year of SO2, 0.01 tpy of PM10/2.5, and 0.03 tpy of HAPs.
R307-401-12 applies to owners or operators of a stationary source of air pollutants that reduce or eliminate air pollutants. The change must not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. The proposed changes have resulted in a total reduction in
site-wide PTE. Therefore, this amendment qualifies as a Reduction in Air Pollutants. In addition to updating the equipment list to the permit, the 2018 AO has been updated to reflect current DAQ language and formatting standards. The 2018 AO was issued to "Red Rock Gathering Company, LLC". In 2020, the owner/operator was changed to "UGC Midstream LTC, LLC". See
Letter DAQE-GN102530015-20 for details. In 2015, the DAQ approved a Replacement-In-Kind to replace the Condensate Storage Tanks (400-bbl) with smaller capacity tanks (300-bbl). This update was not included in the 2018 AO and has been added as a part of this Reduction in Air Pollutants.
[Last updated August 22, 2024] 2. Comment regarding Emission Estimates:
Emissions were estimated from the following sources: The emissions estimated for the generator engine used manufactures data for NOx, CO, and VOC's. The Natural Gas Standby Emission Factors for NOx, CO, and VOC's are 6.9, 34.5, and 2.0 g/HP-hr,
respectively. The PM10, PM2.5 and SO2 emissions estimates for the existing generator used AP-42 Table 3.2-3 and gas consumption data. Existing generator emissions for CO2e emissions were estimated by using emission factors from 40 CFR 98 Subpart C Table C-2.
Emissions for the replacement microturbine were calculated based on the uncontrolled emission factors from manufacturer data, AP-42 Table 3.1-2a, AP-42 Table 3.1-3, 40 CFR 98 Subpart C Table C-2. The manufacturer emission factors for the C30 Natural gas Microturbine for NOx, CO, and VOC's are 0.22, 0.60, and 0.078 g/HP-hr, respectively. [Last updated May 30, 2024]
3. Comment regarding Engine NSPS & MACT Applicability: 40 CFR 60 NSPS Subpart JJJJ applies to owners and operators of stationary SI ICE that commence construction after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1,
2008, for engines with a maximum engine power less than 500 hp. The generator engine at this facility was manufactured in 2007 and installed at the site in 2008. Therefore, NSPS Subpart JJJJ does not apply to this facility.

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40 CFR 60 NSPS Subpart KKKK applies to stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBtu per hour, based on the higher heating value of the fuel,
which commenced construction, modification, or reconstruction after February 18, 2005. The source has one (1) turbine on site that has a heat rate of 0.43 MMBtu per hour. The heat rate of the turbine is less than the applicability threshold of 10 MMBtu per hour. This subpart does not apply to the
source. 40 CFR 60 NSPS Subpart OOOO applies to owners and operators of onshore affected facilities as listed in the subpart for which construction, modification, or reconstruction commence after August 23, 2011, and on or before September 18, 2015. The list of affected facilities includes each
reciprocating compressor affected facility. The source has four (4) compressors that are subject to this subpart. 40 CFR 60 NSPS Subpart OOOOb applies to owners and operators of onshore affected facilities as listed in the subpart for which construction, modification, or reconstruction commence after December 6, 2022. A turbine is defined as a centrifugal compressor in Subpart OOOOb. The source has one (1) turbine that is subject to this subpart. 40 CFR 63 MACT Subpart YYYY applies to owners and operators of stationary combustion turbines located at major sources of HAP emissions. The Westwater Compressor Station is not a major source of HAP emissions. Therefore, the source is not subject to this subpart.
40 CFR 63 MACT Subpart ZZZZ applies to owners and operators of stationary RICE at a major or
area source of HAP emissions. Since this source will have a stationary RICE at an area source of HAP emissions, MACT Subpart ZZZZ will apply to this facility. A new or reconstructed stationary RICE located at an area source must meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting
the requirements of 40 CFR part 60 subpart JJJJ. No further requirements apply for such engines under MACT Subpart ZZZZ. [Last updated August 22, 2024]
4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source
2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source; however, the facility is subject to 40 CFR 60 NSPS Subpart JJJJ, 40 CFR 60 NSPS Subpart OOOO, 40 CFR 60 NSPS Subpart OOOOb,
and 40 CFR 63 MACT Subpart ZZZZ regulations. However, Title V does not apply because NSPS Subpart JJJJ, NSPS Subpart OOOO, NSPS Subpart OOOOb, and MACT Subpart ZZZZ each exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the
source is not otherwise required by law to obtain a permit. No such reason exists. Therefore, Title V does not apply to this facility. [Last updated August 22, 2024]

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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
DAQE-
RN102530016 August 22, 2024 Taryn Weiner UGC Midstream, LTD, LLC 760 Horizon Drive Suite 400 Grand Junction, CO 81506 [e-mail] Dear Taryn Weiner, Re: Engineer Review: Administrative Amendment to Approval Order DAQE-AN102530014-18 to Replace a Generator with a Microturbine under R307-401-12 Reduction in Air Pollutants Project Number: N102530016 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 (NSR) permitting program. UGC Midstream, LTD, LLC should complete this review within 10 business days of receipt. UGC Midstream, LTD, LLC should contact Katie Andersen at [phone] if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Katie Andersen at [e-mail] the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If UGC Midstream, LTD, LLC does not respond to this letter within 10 business days, the project will move forward without source concurrence. If UGC Midstream, LTD, LLC has concerns that cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 1
UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW
SOURCE INFORMATION Project Number N102530016 Owner Name UGC Midstream, LTD, LLC Mailing Address 760 Horizon Drive Suite 400 Grand Junction, CO, 81506 Source Name UGC Midstream LDT, LLC- Westwater Compressor Station Source Location NE/4 NW/4 Sec. 9, T18S, R24E Westwater, UT 84515 UTM Projection 649,575 m Easting, 4,347,334 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 1311 (Crude Petroleum & Natural Gas) Source Contact Taryn Weiner Phone Number [phone] Email [e-mail] Billing Contact Taryn Weiner Phone Number [phone] Email [e-mail] Project Engineer Katie Andersen, Engineer Phone Number [phone] Email [e-mail] Notice of Intent (NOI) Submitted April 3, 2024 Date of Accepted Application April 24, 2024

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SOURCE DESCRIPTION General Description UGC Midstream, LTD, LLC (UGC Midstream) operates the Westwater Natural Gas Compressor Station located near Westwater, Grand County. The Westwater Compressor Station is a rural facility used to boost the pressure and dehydrate natural gas along a gathering line. Entrained water and hydrocarbon liquids are separated from the natural gas stream in a slug catcher and routed to a pressurized storage tank. The natural gas is compressed by natural gas-fueled engines and dehydrated by one triethylene glycol dehydration unit. The waste liquids are then routed to three condensate storage tanks that are out-loaded by trucks as needed. NSR Classification: Administrative Amendment Source Classification Located in an Attainment Area Grand County Airs Source Size: B Applicable Federal Standards NSPS (Part 60), A: General Provisions NSPS (Part 60), OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and on or before September 18, 2015 NSPS (Part 60), OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After November 15, 2021 MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Project Proposal Administrative Amendment to Approval Order DAQE-AN102530014-18 to Replace a Generator with a Microturbine under R307-401-12 Reduction in Air Pollutants Project Description UGC Midstream, LTD, LLC (UGC Midstream) will be replacing one (1) 72 hp natural gas-fired engine (Equipment ID II.A.4 in AO DAQE-AN102530014-18) with one (1) 40.2 hp natural gas-fired microturbine. The removal of the engine and addition of the microturbine results in a net decrease in criteria and hazardous air pollutant emissions. This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). EMISSION IMPACT ANALYSIS No criteria air pollutants and/or HAPs emissions are increasing. Therefore, no modeling is required at this time. [Last updated April 23, 2024]

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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 -115.86 19077.11
Carbon Monoxide -0.81 49.84 Nitrogen Oxides -0.96 50.69 Particulate Matter - PM10 -0.01 0.31 Particulate Matter - PM2.5 -0.01 0.31
Sulfur Oxides 0 0.10 Volatile Organic Compounds -0.03 25.01 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 360
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 600 Formaldehyde (CAS #50000) -60 2280 Generic HAPs (CAS #GHAPS) 0 20 Hexane (CAS #110543) 0 100
Toluene (CAS #108883) 0 380
Xylenes (Isomers And Mixture) (CAS #1330207) 0 80 Change (TPY) Total (TPY) Total HAPs -0.03 1.91
Note: Change in emissions indicates the difference between previous AO and proposed modification.
Commented [KA1]: Enter Manually.

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Review of BACT for New/Modified Emission Units 1. BACT review regarding Engine Replacement This project is an administrative amendment for a reduction in air pollutants (UAC Rule R307-401-12). Under UAC R307-401-12(1), the source is not required to submit a notice of intent. Therefore, no BACT is required at this time. [Last updated May 13, 2024]
SECTION I: GENERAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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I.8 The owner/operator shall submit documentation of the status of construction or modification to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT II.A.1 Westwater Natural Gas Compressor Station II.A.2 Compressor Engines Three (3) Natural Gas-Fired Compressor Engines Maximum hp: 1340 hp (each) Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO II.A.3 Compressor Engine One (1) Natural Gas-Fired Compressor Engine Maximum hp: 655 hp Control: Oxidation Catalyst Subject to: NSPS Subpart OOOO
II.A.4 NEW Microturbine One (1) Microturbine Model: Capstone C30 NG Fuel Type: Natural Gas Rating: 40.2 hp Heat Rate: 0.43 MMBtu/hr Subject to: NSPS Subpart OOOOb
II.A.5 Facility Flare One (1) Facility Flare Burner Capacity: 0.5 MMBtu/hr II.A.6 Dehydration Unit One (1) Glycol Dehydration Unit with Reboiler Capacity: 2 MMscfd II.A.7 Condensate Storage Tanks with Heaters Three (3) Condensate Storage Tanks Tank Capacity: 300 bbl (each) Heater Capacity: 0.25 to 0.5 MMBtu/hr (each)

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II.A.8 Process Storage Tanks Seven (7) Process Storage Tanks Tank Contents: new oil, used oil, lube oil, antifreeze and Triethylene Glycol
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 Site 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 associated with the source or with the control facilities 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 in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
II.B.1.b NEW The owner/operator shall route all exhaust gas/vapors from the condensate storage tanks and natural gas dehydration unit to the operating combustor/flare. [R307-401-8]
II.B.1.c NEW The owner/operator shall not produce more than 3,000 barrels (1 barrel = 42 gallons) of condensate per rolling 12-month period. [R307-401-8] II.B.1.c.1 NEW The owner/operator shall:
A. Determine production with process flow meters and/or sales records B. Record production on a daily basis C. Use the production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep the production records for all periods the plant is in operation. [R307-401-8] II.B.1.d The owner/operator shall load the tanker trucks on site by the use of submerged loading. [R307-401] II.B.1.e NEW The owner/operator shall keep the storage tank thief hatches closed and latched except during tank unloading or other maintenance activities. [R307-401] II.B.1.e.1 NEW The owner/operator shall inspect the thief hatches at least once every six (6) months to ensure the thief hatches are closed, latched and the associated gaskets, if any, are in good working condition. [R307-401-8]

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II.B.1.e.2 NEW The owner/operator shall keep records of thief hatch inspections which shall include the date of the inspection and the status of the thief hatches. [R307-401-8] II.B.2 NEW Stack Testing Requirements
II.B.2.a NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.a.1 NEW Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8]
II.B.2.a.2 NEW Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] II.B.2.a.3 NEW Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8]
II.B.2.a.4 NEW Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] II.B.2.a.5 NEW Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] II.B.2.b NEW Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] II.B.2.b.1 NEW Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] II.B.2.b.2 NEW NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]

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II.B.2.b.3 NEW CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.3 Engine Requirements II.B.3.a NEW The owner/operator shall not emit more than the following rates and concentrations from EACH Caterpillar 3516 Natural Gas Compressor Engine: Pollutant lb/hr ppmdv NOx 2.79 76.6 CO 2.79 125.7 Concentration (ppmdv) is corrected to 15% oxygen, dry basis. [R307-401-8] II.B.3.a.1 NEW Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8]
II.B.3.a.2 NEW Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] II.B.3.a.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit within two (2) years after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] II.B.3.b NEW The owner/operator shall replace the reciprocating compressor rod packing before the compressor has operated for 26,000 hours or 36-months, whichever comes first. The owner/operator shall continuously monitor the hours of operation upon initial startup of the reciprocating compressor or the date of the most recent rod packing replacement, whichever is later. [40 CFR 60 Subpart OOOO]

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN102530014-18 dated April 6, 2018 Incorporates Additional Information dated April 3, 2024 Incorporates Additional Information dated July 22, 2024
REVIEWER COMMENTS 1. Comment regarding Reduction in Air Pollutants: UGC Midstream has requested the replacement of one (1) 72 hp natural gas-fired engine with one (1) 40.2 hp natural gas-fired microturbine. The engine and the microturbine are assumed to operate 8,760 hours annually with the same source of natural gas fuel. The equipment replacement results in a reduction of 0.96 tpy of NOx, 0.03 tpy of VOCs, 0.81 tpy of CO, 1.15 lbs per year of SO2, 0.01 tpy of PM10/2.5, and 0.03 tpy of HAPs. R307-401-12 applies to owners or operators of a stationary source of air pollutants that reduce or eliminate air pollutants. The change must not increase the potential to emit of any air pollutant or cause emissions of any new air pollutant. The proposed changes have resulted in a total reduction in site-wide PTE. Therefore, this amendment qualifies as a Reduction in Air Pollutants. In addition to updating the equipment list to the permit, the 2018 AO has been updated to reflect current DAQ language and formatting standards. The 2018 AO was issued to "Red Rock Gathering Company, LLC". In 2020, the owner/operator was changed to "UGC Midstream LTC, LLC". See Letter DAQE-GN102530015-20 for details. In 2015, the DAQ approved a Replacement-In-Kind to replace the Condensate Storage Tanks (400-bbl) with smaller capacity tanks (300-bbl). This update was not included in the 2018 AO and has been added as a part of this Reduction in Air Pollutants. [Last updated August 22, 2024] 2. Comment regarding Emission Estimates: Emissions were estimated from the following sources: The emissions estimated for the generator engine used manufactures data for NOx, CO, and VOC's. The Natural Gas Standby Emission Factors for NOx, CO, and VOC's are 6.9, 34.5, and 2.0 g/HP-hr, respectively. The PM10, PM2.5 and SO2 emissions estimates for the existing generator used AP-42 Table 3.2-3 and gas consumption data. Existing generator emissions for CO2e emissions were estimated by using emission factors from 40 CFR 98 Subpart C Table C-2. Emissions for the replacement microturbine were calculated based on the uncontrolled emission factors from manufacturer data, AP-42 Table 3.1-2a, AP-42 Table 3.1-3, 40 CFR 98 Subpart C Table C-2. The manufacturer emission factors for the C30 Natural gas Microturbine for NOx, CO, and VOC's are 0.22, 0.60, and 0.078 g/HP-hr, respectively. [Last updated May 30, 2024] 3. Comment regarding Engine NSPS & MACT Applicability: 40 CFR 60 NSPS Subpart JJJJ applies to owners and operators of stationary SI ICE that commence construction after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1, 2008, for engines with a maximum engine power less than 500 hp. The generator engine at this facility was manufactured in 2007 and installed at the site in 2008. Therefore, NSPS Subpart JJJJ does not apply to this facility.

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 Page 10
40 CFR 60 NSPS Subpart KKKK applies to stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBtu per hour, based on the higher heating value of the fuel, which commenced construction, modification, or reconstruction after February 18, 2005. The source has one (1) turbine on site that has a heat rate of 0.43 MMBtu per hour. The heat rate of the turbine is less than the applicability threshold of 10 MMBtu per hour. This subpart does not apply to the source. 40 CFR 60 NSPS Subpart OOOO applies to owners and operators of onshore affected facilities as listed in the subpart for which construction, modification, or reconstruction commence after August 23, 2011, and on or before September 18, 2015. The list of affected facilities includes each reciprocating compressor affected facility. The source has four (4) compressors that are subject to this subpart. 40 CFR 60 NSPS Subpart OOOOb applies to owners and operators of onshore affected facilities as listed in the subpart for which construction, modification, or reconstruction commence after December 6, 2022. A turbine is defined as a centrifugal compressor in Subpart OOOOb. The source has one (1) turbine that is subject to this subpart. 40 CFR 63 MACT Subpart YYYY applies to owners and operators of stationary combustion turbines located at major sources of HAP emissions. The Westwater Compressor Station is not a major source of HAP emissions. Therefore, the source is not subject to this subpart. 40 CFR 63 MACT Subpart ZZZZ applies to owners and operators of stationary RICE at a major or area source of HAP emissions. Since this source will have a stationary RICE at an area source of HAP emissions, MACT Subpart ZZZZ will apply to this facility. A new or reconstructed stationary RICE located at an area source must meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting the requirements of 40 CFR part 60 subpart JJJJ. No further requirements apply for such engines under MACT Subpart ZZZZ. [Last updated August 22, 2024] 4. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following: 1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source; however, the facility is subject to 40 CFR 60 NSPS Subpart JJJJ, 40 CFR 60 NSPS Subpart OOOO, 40 CFR 60 NSPS Subpart OOOOb, and 40 CFR 63 MACT Subpart ZZZZ regulations. However, Title V does not apply because NSPS Subpart JJJJ, NSPS Subpart OOOO, NSPS Subpart OOOOb, and MACT Subpart ZZZZ each exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. No such reason exists. Therefore, Title V does not apply to this facility. [Last updated August 22, 2024]

Engineer Review N102530016: UGC Midstream LDT, LLC- Westwater Compressor Station August 22, 2024 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 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
Katie Andersen <[e-mail]>
Compliance Review of Administrative Amendment 10253
25 messages
Katie Andersen <[e-mail]>Thu, May 30, 2024 at 12:38 PM
To: Chad Gilgen <[e-mail]>
Hello Chad,
Administrative Amendment for site 10253 is ready for Compliance Review. Please let me know what updates should be made to the permit.
Cheers,
Katie Andersen
Google File
-

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Draft 5 RN102530016.rtf
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Chad Gilgen <[e-mail]>Wed, Jun 5, 2024 at 2:45 PM
To: Rik Ombach <[e-mail]>, Katie Andersen <[e-mail]>
Hi Katie,
This source is classified as an oil & gas source and is regulated through Rik Ombach's group. I am forwarding this one onto Rik.
Thanks,
Chad
Chad Gilgen | Manager | Minor Source Compliance
385-306-6500 (cell)
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Draft 5 RN102530016.rtf1541K
Rik Ombach <[e-mail]>Wed, Jun 5, 2024 at 2:48 PM
To: Kyle Greenberg <[e-mail]>, Katie Andersen <[e-mail]>
Kyle:
Can you take a look at this and let Katie know if you have any concerns?
Thanks,
Rik
[Quoted text hidden]
--
8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…1/6
Rik Ombach
Manager | Oil and Gas Compliance
P: [phone]
airquality.utah.gov

[Quoted text hidden]
Draft 5 RN102530016.rtf
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Kyle Greenberg <[e-mail]>Thu, Jun 6, 2024 at 1:06 PMTo: Katie Andersen <[e-mail]>
Cc: Rik Ombach <[e-mail]>
Hi Katie,
I had a chance to review this from a compliance viewpoint. Attached is the document with the comments.
Thanks,
Kyle
--
Kyle Greenberg
Environmental Scientist | Minor Source Compliance
P: [phone]
airquality.utah.gov
[Quoted text hidden]
RN102530016 Compliance Review.rtf
1550K
Katie Andersen <[e-mail]>Mon, Jun 10, 2024 at 10:28 AM
To: Kyle Greenberg <[e-mail]>
Kyle,
Thank you for reviewing it. Would you have a minute to discuss your comments this week? I have some questions and would like to discuss the
applicability of some of the subparts that you brought up.
Cheers,
Katie
[Quoted text hidden]
--
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Mon, Jun 10, 2024 at 10:39 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
Yup no problem. How about sometime this Wednesday, in the afternoon?
Thanks,
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Jun 10, 2024 at 10:41 AM
To: Kyle Greenberg <[e-mail]>
That would be perfect. Does 3pm work for you?
Cheers,
Katie
[Quoted text hidden]
8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…2/6
Kyle Greenberg <[e-mail]>Mon, Jun 10, 2024 at 10:48 AM
To: Katie Andersen <[e-mail]>
Perfect!
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jun 12, 2024 at 4:27 PM
To: Kyle Greenberg <[e-mail]>
Kyle,
I have a question that may be pretty dumb.
What is the difference between a Compression Ignition ICE and a Spark Ignition ICE? Since the engines at the source are compressor engines, does that
mean they should be subject to Subpart IIII instead of Subpart JJJJ?
Cheers,
Katie
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Wed, Jun 12, 2024 at 4:43 PMTo: Katie Andersen <[e-mail]>
Hi Katie
No worries, the wording on these subparts are confusing. These compressor engines for this source are Spark Ignition ICE, because it is a spark
ignition fuel and engines that are used to power the compressors.
Subpart IIII applies to diesel engines. They call diesel engines Compression ignition because it doesn't use a spark to ignite the diesel fuel. It's just the
high compression in the engine cylinder that causes the diesel fuel to ignite, but since Diesel engines (Compression ignition) is not used to power these
compressors, Subpart IIII is not applicable here.
Thanks,
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 10, 2024 at 3:47 PM
To: Kyle Greenberg <[e-mail]>
Kyle,
I reached out to the source a month ago and haven't heard back even though I've followed up with them. I decided to just add the stack test and other
requirements to the permit like you mentioned in your review comments. I was trying to figure out the math and ended up down a rabbit hole.
I found that in 2013 the source added the engines to their site. In all of the AOs before 2013 there is different equipment listed. Since 2013, the only
changes to the equipment on site have been dealing with updating the engine that is now a microturbine with this most recent AO modification. In the 2013
AO, there was an engineering review comment that says " The engines at this facility were manufactured before January 1, 2008 therefore, NSPS Subpart
JJJJ will not apply to this facility."
Since the engines were manufactured before January 1, 2008, Subpart JJJJ doesn't apply to the source. Knowing that, I don't believe I should make the
changes to the permit that you suggested since they were about being Subpart JJJJ compliant.
Please let me know your thoughts and what direction I should go with this.
Cheers,
Katie Andersen
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Thu, Jul 11, 2024 at 11:26 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
If the engines were manufactured before January 1, 2008; we need to look into when they were installed. According to 40 CFR 60.4236(b) in subpart JJJJ
the source can not install engines greater than 500 hp that do not meet JJJJ after July 1, 2009.
40 CFR 60.4236(b):
After July 1, 2009, owners and operators may not install stationary SI ICE with a maximum engine power of greater than or equal to 500 HP that do not
meet the applicable requirements in § 60.4233, except that lean burn engines with a maximum engine power greater than or equal to 500 HP and less than
1,350 HP that do not meet the applicable requirements in § 60.4233 may not be installed after January 1, 2010
https://www.ecfr.gov/current/title-40/part-60/subpart-JJJJ#p-60.4236(b)
Thanks,Kyle
8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…3/6
[Quoted text hidden]
Katie Andersen <[e-mail]>Mon, Jul 22, 2024 at 11:23 AM
To: Kyle Greenberg <[e-mail]>
Kyle,
I've heard back from the source. They supplied the following information about the engines:
Horsepower Make Model Serial Number Manufacture Date Fuel Date of Installation
1340 Caterpillar G3516 WPT00216 2/5/2007 Natural Gas 2008
1340 Caterpillar G3516 WPT00215 2/2/2007 Natural Gas 2008
1340 Caterpillar G3516 WPT00209 1/2/2007 Natural Gas 2008
655 White Superior 8G825 19834 9/9/1969 Natural Gas 1978
With the installation dates being before July 1, 2009, does Subpart JJJJ not apply?
Cheers,
Katie Andersen
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Jul 31, 2024 at 9:13 AM
To: Kyle Greenberg <[e-mail]>
Hi Kyle,
I've worked through your comments and hopefully I addressed them. Here is the updated ER. Please let me know if there are any issues.
Cheers,
Katie Andersen
[Quoted text hidden]
Draft 6 RN102530016.rtf
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Katie Andersen <[e-mail]>Wed, Aug 7, 2024 at 10:34 AM
To: Kyle Greenberg <[e-mail]>
Hi Kyle,
Have you had a chance to look over this updated ER?
Cheers,
Katie
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Wed, Aug 7, 2024 at 11:50 AM
To: Katie Andersen <[e-mail]>
Hi Katie,
Everything looks good from a compliance aspect. Thanks for having the source look into the installation dates.
Thanks,
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Aug 7, 2024 at 11:53 AM
To: Kyle Greenberg <[e-mail]>
Kyle,
Thank you so much for your help! I really appreciate it.
Would you be able to sign off on the ER in the WAL or should I send a message to Chad about signing off on it?
Cheers,
Katie
8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…4/6
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Wed, Aug 7, 2024 at 12:31 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
I think there might have been something I missed. With the tanks needing to be controlled by the flare, does that mean the condensate throughput for the
site is greater than 2,000 bbl of condensate per rolling 12-months? If that is the case I think the source needs to have an LDAR requirement according
to R307-509. Sorry I missed this till now.
Thanks,
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Wed, Aug 7, 2024 at 1:47 PM
To: Kyle Greenberg <[e-mail]>
Kyle,
I was looking into this and had a few questions that I asked Alan about. He helped me realize that the source is not a well site, just a compressor station.
Because of that, R307-509 does not apply to it. I also dug into 40 CFR 60 Subpart OOOOa to see if the source should have LDAR requirements under that
subpart. I found that the compressors were added to the site in 2013. Since then, the only things to change have been the generator engine (it has been
replaced 2 times as administrative amendments for reduction in air pollutants) and the storage tanks (there was a Replacement in Kind in 2015 to take the
tanks from 400 bbl to 300 bbl but keep the same throughput. I will update this in the current ER). I believe that Subpart OOOOa does not apply to the site
since the compressors were constructed in 2013 and have not been modified since.
What are your thoughts?
Cheers,
Katie
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Wed, Aug 7, 2024 at 2:18 PM
To: Katie Andersen <[e-mail]>
Hi Katie,
That all sounds good for LDAR sorry about my misinterpretation/confusion of the well site and 40 CFR 60.5397a.
Would these compressors fall under Subpart OOOO then? If that is the case it does look like there is a condition to replace the Compressor rod packing
every 26,000 hour or 36-months to be compliant with OOOO. https://www.ecfr.gov/current/title-40/section-60.5385 Sorry for being a pain on this one, but I
figure being more thorough is better than not.
Thanks,
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Aug 8, 2024 at 11:41 AM
To: Kyle Greenberg <[e-mail]>
Kyle,
It's all good. I appreciate how thorough you are!
I think these compressors do fall under Subpart OOOO. What is the best way to include the condition in the permit? Should I say that the owner/operator
shall comply with 40 CFR 60 Subpart OOOO? Or should I list it out that the owner/operator shall replace the reciprocating compressor rod packing before
the compressor has operated 26,000 hours or 36-months?
Cheers,
Katie
[Quoted text hidden]
Katie Andersen <[e-mail]>Thu, Aug 8, 2024 at 11:58 AMTo: Kyle Greenberg <[e-mail]>
Kyle,
Sorry for the back to back emails. I figured I would draft it out and let you see it. Here is the updated ER.
Cheers,
Katie
[Quoted text hidden]
Draft 7 RN102530016.rtf
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8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…5/6
Katie Andersen <[e-mail]>Tue, Aug 20, 2024 at 2:25 PMTo: Kyle Greenberg <[e-mail]>
Hi Kyle,
I haven't heard back, and want to make sure this project doesn't fall through the cracks.
Have you had a chance to review the updated ER?
Cheers, Katie Andersen
[Quoted text hidden]
Kyle Greenberg <[e-mail]>Tue, Aug 20, 2024 at 2:32 PM
To: Katie Andersen <[e-mail]>
Hi Kate,
Sorry for the late reply. Everything looks great from a compliance viewpoint.
Thanks!
Kyle
[Quoted text hidden]
Katie Andersen <[e-mail]>Tue, Aug 20, 2024 at 2:59 PM
To: Kyle Greenberg <[e-mail]>
Kyle,
Thank you! Will you let Rik know to sign off on the project in the WAL? Or change the compliance sign off to yourself?
Cheers,
Katie Andersen
[Quoted text hidden]
8/20/24, 3:03 PM State of Utah Mail - Compliance Review of Administrative Amendment 10253
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r-8860571125544731642&simpl=msg-a:r-66706456743439…6/6
6/12/24, 1:49 PM State of Utah Mail - DAQ Reduction in Air Pollutants Westwater Natural Gas Compressor Station
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r3425246839882295101&simpl=msg-a:r-64620226315113…1/2
Katie Andersen <[e-mail]>
DAQ Reduction in Air Pollutants Westwater Natural Gas Compressor Station
2 messages
Katie Andersen <[e-mail]>Mon, Jun 10, 2024 at 10:36 AM
To: Taryn Weiner <[e-mail]>
Cc: Christine Bodell <[e-mail]>
Hello Taryn,
I want to give you an update about the status of your Reduction in Air Pollutants for the Westwater Natural Gas
Compressor Station.
The Reduction in Air Pollutants is currently in the process of internal review.
An internal review comment brought to my attention that the dehydrator is likely subject to 40 CFR 63 MACT Subpart HH.
The AO will be updated accordingly to reflect the requirements outlined in this Subpart. Can you please verify that the unit
is subject to this subpart?
Cheers,
Katie Andersen
--

Katie Andersen
Engineering Technician I | Minor NSR Section
M: [phone]
airquality.utah.gov
Taryn Weiner <[e-mail]>Wed, Jun 12, 2024 at 12:54 PM
To: Katie Andersen <[e-mail]>
Cc: Christine Bodell <[e-mail]>
Good aernoon Kae,

The Dehy at West Water is would subject to MACT HH as an area source. Based on the 2023 triennial EI, the 2023
annual throughput was 626 mmcf, which is an average daily throughput of 48,573 m3/day. This would qualify the unit
for the exempon of requirements of paragraph (d). I’ve added the secon from MACT HH with the exempon.
Please let me know if you have any quesons.

6/12/24, 1:49 PM State of Utah Mail - DAQ Reduction in Air Pollutants Westwater Natural Gas Compressor Station
https://mail.google.com/mail/u/0/?ik=0900585596&view=pt&search=all&permthid=thread-a:r3425246839882295101&simpl=msg-a:r-64620226315113…2/2
(2) For area sources, the affected source includes each triethylene glycol (TEG) dehydration unit located at a
facility that meets the criteria specified in paragraph (a) of this section.

The facility meets the “criteria specified in paragraph (a)”. However, there is a provision that exempts it from
requirements, except for recordkeeping, per https://www.ecfr.gov/current/title-40/part-63/subpart-HH#p-63.764(e):
(e) Exemptions.
(1) The owner or operator of an area source is exempt from the requirements of paragraph (d) of this
section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of
the determination of these criteria must be maintained as required in § 63.774(d)(1).
(i) The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85
thousand standard cubic meters per day, as determined by the procedures specified in §
63.772(b)(1) of this subpart; or
(ii) The actual average emissions of benzene from the glycol dehydration unit process vent to the
atmosphere are less than 0.90 megagram per year, as determined by the procedures specified
in § 63.772(b)(2) of this subpart.

Taryn Weiner
Manager, Air and Sustainability
[e-mail]
Phone: [phone]

From: Kae Andersen <[e-mail]>
Sent: Monday, June 10, 2024 10:37 AM
To: Taryn Weiner <[e-mail]>
Cc: Chrisne Bodell <[e-mail]>
Subject: DAQ Reducon in Air Pollutants Westwater Natural Gas Compressor Staon

WARNING - EXTERNAL SENDER - This message came from outside of your organization. Be cautious when opening
attachments and do not provide your user ID or password.
[Quoted text hidden]
Westwater Compressor StationGenerator ReplacementTable 1 - Summary
Existing Replacement Change in Emissions Notes
NOX 1.04 0.09 -0.96
VOC (Total HC)0.06 0.03 -0.03
CO 1.04 0.23 -0.81
SO2 0.00 0.01 0.00 See Note 1.
PM10/PM2.5 0.03 0.01 -0.01
Formaldehyde 0.03 0.00 -0.03
Acetaldehyde 0.00 0.00 0.00
Acrolein 0.00 0.00 0.00
Benzene 0.00 0.00 0.00
CO2e 337.87 221.97 -115.89
Notes:
Pollutant Controlled Emissions (tpy)
(1) The SO2 emission factors for engines and for turbines are from different sections of AP-42
and are based on different assumed fuel sulfur contents. However, both factors assume that all
sulfur in the fuel is converted to SO2. Therefore, since the microturbine will utilize less fuel, the
SO2 emissions will be reduced since the fuel characteristics will remain the same.
Date printed: 10/23/2024 Page 1 of
0.6 lbs/10^6 scf Emission Factor from AP-42 Table 1.4-2
0.00058824 lbs/MMBtu Unit conversion
Sulfur:
lbs/hr lbs/yr tpy
Generator 0.66 0.0003876 3.348864 0.00167443
Turbine 0.43 0.00025471 2.20065882 0.00110033 -0.0005741
See Note 1 on Turbine (Replacement) Sheet. Turbine Heat Rate is conservative
8760 hr/year
The sulfur emissions were estimated using AP-42 Table 1.4-2 (Natural Gas Combustion)
since both sources will use the same fuel source.
Heat Rate
MMBtu/hr
Date printed: 10/23/2024 Page 2 of
tpy change
Date printed: 10/23/2024 Page 3 of
Utah Gas Corporation - Westwater Compressor StationGenerator ReplacementTable 2 - Existing Generator Emission Calculations
Source Description GeneratorEquipment Usage Power Generation
Equipment Make CumminsEquipment Model GM Vortec 5.0Configuration4SRB
Fuel Type Field Gas
Horsepower 72 hpFuel Consumption 646 scf/hr
Heat Rate 0.66 MMBtu/hr
Emission Controls Oxidation Catalyst
Control Source ofEfficiencyEmission Factor
EF Units %EF Units (lb/hr)(tpy)(lb/hr)(tpy)
NOx 6.90 g/hp-hr 78.3%1.50 g/hp-hr 1.10 4.80 0.24 1.04 Manufacturer DataVOC (Total HC)2.00 g/hp-hr 96.0%0.08 g/hp-hr 0.32 1.39 0.01 0.06 Manufacturer Data
CO 34.50 g/hp-hr 95.7%1.50 g/hp-hr 5.48 23.99 0.24 1.04 Manufacturer Data
SO2 5.88E-04 lb/mmBtu NA ----0.00039 0.00170 0.00 0.00 AP42 Table 3.2-3. See Note 1.
PM10/PM2.5 9.50E-03 lb/mmBtu NA ----0.01 0.03 0.01 0.03 AP42 Table 3.2-3
Formaldehyde 2.05E-02 lb/mmBtu 50.0%1.03E-02 lb/mmBtu 0.01 0.06 0.01 0.03 AP42 Table 3.2-3
Acetaldehyde 2.79E-03 lb/mmBtu 50.0%1.40E-03 lb/mmBtu 0.00 0.01 0.00 0.00 AP42 Table 3.2-3Acrolein2.63E-03 lb/mmBtu 50.0%1.32E-03 lb/mmBtu 0.00 0.01 0.00 0.00 AP42 Table 3.2-3Benzene1.58E-03 lb/mmBtu 50.0%7.90E-04 lb/mmBtu 0.00 0.00 0.00 0.00 AP42 Table 3.2-3CO253.06 kg/mmBtu NA ----77.06 337.51 77.06 337.51 40 CFR 98 Subpart C Table C-2
CH4 0.001 kg/mmBtu NA ----0.00 0.01 0.00 0.01 40 CFR 98 Subpart C Table C-2N2O0.0001 kg/mmBtu NA ----0.00 0.00 0.00 0.00 40 CFR 98 Subpart C Table C-2CO2e----------77.14 337.87 77.14 337.87 40 CFR 98
Notes:(1) Based on 100% conversion of fuel sulfur to SO2. Assumes sulfur content in natural gas of 2,000 gr/mmscf.
Sample Calculationsg/hp-hr Emission Factor:(34.50 g/hp-hr CO) x ((100% - 96%)/100%) x (72 hp) / (453.59 g/lb) x ( hr/yr) / (2000 lb/ton) = 1.04 tpy COlb/mmBtu Emission Factor:(0.00279 lb/mmBtu Acetaldehyde) x (0.66 mmBtu/hr) x ( hr/yr) / (2000 lb/ton) = 0.00 tpy Acetaldehyde
kg/mmBtu Emission Factor:(0.001 kg/mmBtu CH4) x (0.66 mmBtu/hr) x ( hr/yr) x (2.204 lb/kg) / (2000 lb/ton) = 0.01 tpy CH4
2000 gr/mmscf
4.40924884 lb/mmscf453.592 grains in a pound
0.004322793 lb/MMBtu
4.32E-03 lb/MMBtu Exerpt from AP-42 Section 3.1 Background Document Stationary Gas Turbines page 31
Pollutant Uncontrolled Emission Controlled Emission Estimated EmissionsFactorFactorUncontrolledControlled
Date printed: 10/23/2024 Page 4 of
Utah Gas Corporation - Westwater Compressor StationGenerator ReplacementTable 3 - Replacement Microturbine Emission Calculations
Source Description MicroturbineEquipment Usage Power Generation
Equipment Make CapstoneEquipment Model C30 NGFuel Type Natural Gas
Horsepower 40.2 hp
Heat Rate(1)0.43 MMBtu/hr 0.43Emission Controls None 303100
433000
Control Source of
Efficiency Emission Factor
EF Units %EF Units (lb/hr)(tpy)(lb/hr)(tpy)NOx 0.22 g/hp-hr NA ----0.02 0.09 0.02 0.09 Manufacturer Data
VOC (Total HC)0.078 g/hp-hr NA ----0.01 0.03 0.01 0.03 Manufacturer Data
CO 0.60 g/hp-hr NA ----0.05 0.23 0.05 0.23 Manufacturer DataSO20.0034 lb/mmBtu NA ----0.00 0.01 0.00 0.01 AP42 Table 3.1-2a. See Note 2.
PM10/PM2.5 0.01 lb/mmBtu NA ----0.00 0.01 0.00 0.01 AP42 Table 3.1-2a
Formaldehyde 0.00 lb/mmBtu NA ----0.00 0.00 0.00 0.00 AP42 Table 3.1-3Acetaldehyde0.00 lb/mmBtu NA ----0.00 0.00 0.00 0.00 AP42 Table 3.1-3
Acrolein 0.00 lb/mmBtu NA ----0.00 0.00 0.00 0.00 AP42 Table 3.1-3
Benzene 0.00 lb/mmBtu NA ----0.00 0.00 0.00 0.00 AP42 Table 3.1-3CO2571.22 g/hp-hr NA ----50.62 221.74 50.62 221.74 Manufacturer DataCH40.001 kg/mmBtu NA ----0.00 0.00 0.00 0.00 40 CFR 98 Subpart C Table C-2N2O0.0001 kg/mmBtu NA ----0.00 0.00 0.00 0.00 40 CFR 98 Subpart C Table C-2
CO2e ----------50.68 221.97 50.68 221.97 40 CFR 98
Notes
(2) All sulfur in the fuel is assumed to be converted to SO2. S = percent sulfur in fuel. Since S is not available, use 3.4 E-03 lb/MMBtu for natural gas turbines.
Sample Calculations
g/hp-hr Emission Factor:(0.60 g/hp-hr CO) x ((100% - NA)/100%) x (40.2 hp) / (453.59 g/lb) x ( hr/yr) / (2000 lb/ton) = 0.23 tpy COlb/mmBtu Emission Factor:(0.00004 lb/mmBtu Acetaldehyde) x (0.43 mmBtu/hr) x ( hr/yr) / (2000 lb/ton) = 0.00 tpy Acetaldehydekg/mmBtu Emission Factor:(0.001 kg/mmBtu CH4) x (0.43 mmBtu/hr) x ( hr/yr) x (2.204 lb/kg) / (2000 lb/ton) = 0.00 tpy CH4
Controlled
(1) Maximum fuel consumption for a fully loaded, high pressure unit. Since the unit is standalone and the site elevation is 5,058 feet, actual maximum fuel consumption is
303,100 BTU/hr.
Pollutant Uncontrolled Emission Controlled Emission Estimated Emissions
Factor Factor Uncontrolled
Date printed: 10/23/2024 Page 5 of
Emissions estimates using AP-42 Table 1.4-2 (Natural Gas Combustion)
Heat Rate MMBtu/hr 0.66
lb/10^6 scf
Pollutant Emission Factor lbs/MMBtu lbs/hr lbs/yr
CO2 120000 117.6470588 77.64706 670870.6
Lead 0.0005 4.90196E-07 3.24E-07 0.002795
N2O Uncontrolled 2.2 0.002156863 0.001424 12.29929
N2O Control 0.64 0.000627451 0.000414 3.577976
PM Total 7.6 0.00745098 0.004918 42.48847
PM cond 5.7 0.005588235 0.003688 31.86635
PM filter 1.9 0.001862745 0.001229 10.62212
SO2 0.6 0.000588235 0.000388 3.354353
TOC 11 0.010784314 0.007118 61.49647
Methane 2.3 0.002254902 0.001488 12.85835
VOC 5.5 0.005392157 0.003559 30.74824
Engine
0.43
Difference
tpy lbs/hr lbs/yr tpy tpy
335.4353 50.58824 437082.4 218.5412 -116.894
1.4E-06 2.11E-07 0.001821 9.11E-07 -4.9E-07
0.00615 0.000927 8.013176 0.004007 -0.00214
0.001789 0.00027 2.331106 0.001166 -0.00062
0.021244 0.003204 27.68188 0.013841 -0.0074
0.015933 0.002403 20.76141 0.010381 -0.00555
0.005311 0.000801 6.920471 0.00346 -0.00185
0.001677 0.000253 2.185412 0.001093 -0.00058
0.030748 0.004637 40.06588 0.020033 -0.01072
0.006429 0.00097 8.377412 0.004189 -0.00224
0.015374 0.002319 20.03294 0.010016 -0.00536
Micro Turbine
Meter N RelativeDensity HeatingValue CO2 N2 C1 C2 C3 IC4 NC4 IC5 NC5January 01, 2023 09:00:00102270.6267 1075.18 D 1.3031 1.1251 ######4.6326 1.4323 0.2775 0.3319 0.1228 0.0808
February 01, 2023 09:00:00
10227 0.6267 1075.18 D 1.3031 1.1251 ######4.6326 1.4323 0.2775 0.3319 0.1228 0.0808
March 01, 2023 09:00:00102270.6267 1075.18 D 1.3031 1.1251 ######4.6326 1.4323 0.2775 0.3319 0.1228 0.0808
April 01, 2023 09:00:00102270.6328 1087.57 D 1.3322 0.9082 ######4.9032 1.5389 0.3426 0.3761 0.1585 0.1080
May 01, 2023 09:00:00
10227 0.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
June 01, 2023 09:00:00102270.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
July 01, 2023 09:00:00
10227 0.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
August 01, 2023 09:00:00
10227 0.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
September 01, 2023 09:00:00102270.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
October 01, 2023 09:00:00
10227 0.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
November 01, 2023 09:00:00
10227 0.6337 1089.43 D 1.3365 0.8759 ######4.9435 1.5550 0.3524 0.3827 0.1639 0.1121
December 01, 2023 09:00:00102270.6318 1092.82 D 1.1324 0.8056 ######4.9087 1.5956 0.3514 0.4107 0.1713 0.1129
January 01, 2024 09:00:00
10227 0.6290 1097.99 D 0.8207 0.6982 ######4.8555 1.6576 0.3499 0.4534 0.1827 0.1142
February 01, 2024 09:00:00102270.6290 1097.99 D 0.8207 0.6982 ######4.8555 1.6576 0.3499 0.4534 0.1827 0.1142
March 01, 2024 09:00:00102270.6353 1082.17 D 1.2590 1.5712 ######4.7664 1.5114 0.3227 0.3770 0.1634 0.1261
April 01, 2024 09:00:00
10227 0.6363 1079.52 D 1.3326 1.7178 ######4.7514 1.4868 0.3181 0.3642 0.1602 0.1281
*** End of Report ***
FLOWC © Quorum Software. All Rights Reserved.Print Date: 04/19/2024 15:37 Page 1
Neo C6 C7 C8 C9 C10 H2S H2O Other
0.1944 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.1944 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.1944 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2517 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2603 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2457 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2233 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2233 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.2951 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
0.3072 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000