Document 2q9zb9M9ERQgpkeymk3Y4bJop

Hilcorp Energy (formerly ConocoPhillips Company) Sunnyside Compressor Station Full Compliance Evaluation (FCE) On-Site Clean Air Act Evaluation Inspection Date: 6//27/2022 Inspection Report Date: 7/19/2022 EPA Representatives: Alexis North, Young Joo Kim, Colin Lecortz, Katelyn Bergl Company Representatives: Mitch Killough, Environmental Specialist Jake Work, Compression Lead Gary Horst, Emission Specialist Freddy Proctor, Foreman Clara Cardoza, Environmental Specialist Tribal Representatives: David Heermance, Meredith Breen, Andrew Switzer Inspection Report Prepared By: Inspection Report Reviewed By: Last CAA Inspection: Alexis North Scott Patefield May 14, 2018 Digitally signed by SCOTT SCOTT PATEFIELD PATEFIELD Date: 2022.09.23 06:58:03 -06'00' Applicable Rules: 40 C.F.R. Part 63, Subpart HH--National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities (MACT HH) 40 C.F.R. Part 63, Subpart ZZZZ--National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities (MACT ZZZZ) (area source) 40 C.F.R. Part 60, Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and on or Before September 18, 2015 (compressors) Tribal minor new source review (# SMNSR-SU-000032-2019.002) CAA Permit History: 1. September 26, 2006, operating permit the EPA issued to ConocoPhillips for the Sunnyside Compressor Station in accordance with the Title V Operating Permit Program at 40 CFR part 71 (Part 71). 2. February 4, 2010, Federal Compliance Agreement and Final Order (CAFO) between the EPA and ConocoPhillips. (Docket No.: CAA-08-2010-0007) 3. August 30, 2011, application from ConocoPhillips requesting a synthetic minor permit for the Sunnyside Compressor. This facility was formally owned and operated by ConocoPhillips but as of August 1, 2017, was purchased by Hilcorp. 1 General Source Information Parent Company Name: Facility Name: Facility Location: EPA Region: County, State: Reservation & Tribe: Responsible Official: SIC Code: ICIS Air ID: Hilcorp Energy Sunnyside Compressor Station Latitude 37.1194, Longitude -107.8372 8 La Plata County, Colorado Southern Ute Indian Tribe, Southern Ute Reservation Mitch Killough 1311 SU00000008067U0041 Areas of Concern x Engine #1 onsite measured catalyst pressure drop higher than documented baseline (3.5 inches of water baseline, 5.9 inches of water measured onsite). x Based on the data provided by Mr. Killough in a 9/1/22 email, it appears that Hilcorp is comparing monthly pressure drop readings to the pressure drop measured during the most recent quarterly tests, including from quarterly portable analyzer tests. Permit condition C.5.e specifically requires the actions in C.5.e.i - C.5.e.iii be taken "If the pressure drop reading exceeds 2 inches of water from the baseline pressure drop established during the most recent performance test", where testing is considered to be a performance test if it meets the requirements outlined in Permit condition C.4.d.(i-v). Quarterly portable analyzer tests do not meet these requirements, and the pressure drop measured during these tests is therefore not an appropriate value to be used in determining deviations of monthly pressure drop readings. x Hilcorp did not provide a description of corrective actions taken to address Inlet Catalyst Temperature Alarms pursuant to this permit x When looking at the Inlet Catalyst Temperature Alarms submitted via email to EPA by Hilcorp on 9/1/2022, the low temperature alarms reading -13F began consistently on 5/4/2021. Engine 3 alarmed 146 times over 126 days before the issue was resolved. The documentation supplied by Hilcorp shows staff was not alerted to the alarms until 8/4/2021, three months after the issue began. x At the time of this inspection report, EPA was unable to locate the 2021 emission inventory report. Compliance Assistance 2018 Findings: x If ASTM D6348 is going to be used for performance testing, the performance test protocol should be revised to assure that ASTM D6348-03 is used rather than ASTM D6348-12. x Based on the information provided, it's not clear whether all appropriate actions have been taken when engine pre-catalyst temperature falls below 405F; x It appears that a performance test was not conducted within 90 calendar days after engine #2 was rebuilt in 3/2017. x When Hilcorp initially purchased Sunnyside they were late in submitting performance test results and failed to notify EPA of upcoming testing. This issue has since been resolved. x Annual deviation reports indicate that the pressure drop across engine catalysts haven't always met permit requirements. It's not clear whether all appropriate actions have been taken when this has occurred. As of the date of this report the pressure drop data had not been provided to the EPA. x The annual NSPS OOOO report was not submitted in 2018. x Based on a review of the pressure drop data provided by Ms. Deal on 812118, pressure drop readings exceeded the baseline pressure drop established during the most recent performance test (see Table 5, below) by 2 inches of water for engine C-13405/1 in 5/2016, 7/2016 through 9/2016, 11/2016 and 11/2017 through 5/2018;/or engine C-10664/2 no data was provided/or 12/2016; for C-115../2/1.from 2 11/2017 through 4/2018, and no data was provided for 1/2018; and for C-11100/8 in 12/2016, 12/2017, and 1/2018. Additionally, no performance test data are available/or engine C-10788/1 to compare the pressure drop readings that occurred from 1/2018 through 5/2018, and/or engine C-11542/1 for the pressure drop readings that occurred from 5/2016 through 8/2016. x When monthly pressure drop readings exceeded the baseline pressure drop, it doesn't appear that any of the requirements contained in permit condition C. 5. (g) were fulfilled Onsite Inspection Details EPA et al. arrived onsite at 1:35 pm. Hilcorp staff walked inspection team through compressor station inlet (from roughly 50 wells), separations, compression, dehydration and plant outlet into Harvest Midstream gas plant. Sunnyside processes roughly 8-9 MCF per day of raw coalbed methane using three engines and a dehydration unit. EPA noted the following onsite engine performance observations: Engine ID Engine #1 Engine #2 Engine #3 Engine Serial Number C-10664/2 C-11542/1 C-10788/1 Catalyst Pressure Drop (inches of water) 5.9 3.7 2.5 Inlet Catalyst Temperature (F) 640 706 714 Engine RPM 1006 999 1030 Hilcorp trucks out water removed from the gas at a rate of about 2 truckloads per week. CAA Synthetic Minor Permit # SMNSR-SU-000032-2019.002 (Effective 10/8/2020) Section I. Conditional Permit to Construct C. Requirements for Engines I. Construction and Operational Limits: Engine Requirements E001 (C-11100/8) E002 (C-10664/2) E003 (C-13405/1) 1. Op limits (a) 4-stroke lean burn 4SLB 4SLB 4SLB (b) Fired w/ natural gas NG fired NG fired NG fired (c) 1,330 hp max 1,330 HP 1,330 HP 1,330 HP 2. Emission limits NOx 5.28 lb/hr* Last tested 2018 Passed Passed CO 1.27 lb/hr* Last tested 2018 Passed Passed CH20 0.10 lb/hr* Last tested 2018 Passed Passed 3. Control & Ops (a) Install catalyst Installed Installed Installed (b)-(c) monitor catalyst Installed- temps Installed- temps Installed- temps temp between 450- good good good 1350F* (d) catalyst pressure drop See Appendix A See Appendix A See Appendix A w/in +/- 2 inches of water *See Appendix A for actual test results, catalyst exhaust temps and pressure drop. E004 (C-11542/1) 4SLB NG fired 1,330 HP Passed Passed Passed Installed Installed- temps good See Appendix A 4. Performance Testing 3 (a) NOx, CO, CH2O testing per Part 63 (CH2O) and Part 60 (NOx and CO) (i) within 90 days of startup of new engine, (ii) every 12 months for CH2O, (iii) 90 days of catalyst replacement or (iv) engine rebuild. Observation: In an email exchange between EPA (Katelyn Bergl) and Hilcorp (Mitch Killough), see Appendix C, the following engine rebuild/replacement activities were noted for each engine: x E001 (C-11100/8)- Per engine testing, this engine was removed from service sometime in late 2018. x E002 (C-10664/2)- Like-kind engine swap occurred in May 2018. Engine with serial No. C-13405 was replaced with C-10664. Cost of engine re-build did not exceed the 50% threshold when comparing the cost of the re-build to the cost of an entirely new engine. x E003 (C-13405/1, now C-10788)- Like-kind engine swap occurred in 2017. Engine with serial No. C13405 was swapped out with serial No. C-10788 in June 2017. Per the 7/3/2018 EPA inspection report date, Sunnyside Skid #3 is shown to have an engine re-build date of 6/25/2017, but is shown to be 6/23/2017 on a tag pulled from the unit. In addition, an email from Hilcorp's Jennifer Deal (5/30/2018) shows the rebuild date to be 6/7/2017. This table reflects a 6/23/2017 start-up date. Cost of engine rebuild did not exceed the 50% threshold when comparing the cost of the re-build to the cost of an entirely new engine. x E004 (C-11542/1)- No engine re-builds or replacements noted in Hilcorp records since March 2017. 5. Monitoring Requirements (a) and (b) monitoring exhaust temp of each engine at the catalyst inlet. Observation: Upon request, Hilcorp provided records of catalyst temperature alarms Appendix C, Item 5. A spot check of alarms and the Hilcorp work orders (Appendix C) demonstrated not every alarm results in a work order. Per Hilcorp, when an alarm is triggered, Hilcorp personnel are alerted to diagnose the issue immediately. Hilcorp did not provide a description of corrective actions taken pursuant to this permit (c), (d) and (g) is pressure differential drop across the catalyst monitoring. Observation: Upon request, Hilcorp provided all differential pressure drop monitoring in Appendix C, Item 6. Based on the data provided by Mr. Killough in a 9/1/22 email, it appears that Hilcorp is comparing monthly pressure drop readings to the pressure drop measured during the most recent quarterly tests, including from quarterly portable analyzer tests. Permit condition C.5.e specifically requires the actions in C.5.e.i - C.5.e.iii be taken "If the pressure drop reading exceeds 2 inches of water from the baseline pressure drop established during the most recent performance test", where testing is considered to be a performance test if it meets the requirements outlined in Permit condition C.4.d.(i-v). Quarterly portable analyzer tests do not meet these requirements, and the pressure drop measured during these tests is therefore not an appropriate value to be used in determining deviations of monthly pressure drop readings. (e) Quarterly NOx and CO using portable analyzer, see Appendix A. (h) thru (k) is portable analyzer protocol approved July 12, 2016. 6. Recordkeeping d. Records shall be kept of all temperature measurements required in this permit, as well as a description of any corrective actions taken pursuant to this permit. Observations: At this time, only temperature deviations have been provided to the EPA. Complete temperature measurement data or a description of corrective actions taken pursuant to this permit have not been provided at this time. 4 Observation: As reported by Hilcorp in the CY2021 Deviation report, engine E003 "temperature sensing device was not operating properly" between 6/24/2021 and 9/28/2021. When looking at the Inlet Catalyst Temperature Alarms submitted via email to EPA by Hilcorp on 9/1/2022, the low temperature alarms reading 13F began consistently on 5/4/2021. Engine 3 alarmed 146 times over 126 days before the issue was resolved. The documentation supplied by Hilcorp shows staff was not alerted to the alarms until 8/4/2021, three months after the issue began. e. Records shall be kept of all pressure drop measurements required in this permit, as well as a description of any corrective actions taken pursuant to this permit. Observations: Pressure drop measurement data was provided upon request. Since 2018, there appear to have been several deviations of pressure drop data from the established baseline, as well as missing monthly data points. A description of corrective actions taken following deviations was not provided. E. Requirements for Leak Detection and Repair (LDAR) 1. The Permittee shall implement a LDAR monitoring program for detecting emissions of volatile organic compound (VOC) emissions due to leaking equipment. Observations: Hilcorp (and formerly ConocoPhillips) submits semiannual and annual reports of the LDAR monitoring that occurs at the facility. 2. The Permittee shall develop a written LDAR protocol that, at a minimum, specifies the following: (a) The use of an infrared camera for the detection of VOC leaks; (b) The technical procedures for monitoring with the infrared camera; (c) A schedule for conducting semiannual monitoring; (d) Monitoring of "equipment" per the approved LDAR protocol; (e) A definition of when a "leak" is detected; (f) A repair schedule for leaking equipment (including delay of repair); and (g) A recordkeeping format. Observations: The LDAR protocol was submitted to EPA on 7/31/12. 4. LDAR protocols that have already been approved by the EPA may be used in lieu of new protocols unless the EPA determines it is necessary to require the submittal and approval of a new LDAR protocol. 5. The Permittee may submit a revised LDAR protocol at any time for EPA approval. The existing LDAR protocol will remain in effect until a revised LDAR protocol is approved by the EPA. Observations: The LDAR protocol was submitted to EPA on 7/31/12. EPA or company is unable to find a copy of EPA's approval. However, the 7/31/12 letter submitting the Argenta and Sunnyside Compressor Station LDAR protocol indicates the protocol submitted on 7/31/12 was the same at the Ute LDAR CDP LDAR protocol which was approved in a 5/24/12 email from EPA. 6. In the event that the EPA determines that the LDAR monitoring program is not meeting its intended goals, the Permittee shall submit a revised LDAR protocol upon request by the EPA. Observations: EPA has not determined that the LDAR monitoring program is not meeting its intended goals. 5 7. Leak detection monitoring shall commence upon approval of the LDAR protocol by the EPA. Observations: The LDAR protocol was submitted to EPA on 7/31/12. Based on LDAR reports submitted, LDAR monitoring is being conducted. 8. LDAR monitoring shall be conducted at least semi-annually in accordance with an approved LDAR protocol and shall be conducted a minimum of 5 calendar months apart. Observations: Hilcorp submits semiannual and annual reports of the LDAR monitoring that is conducted. EPA reviews the reports as they are received. 9. The Permittee shall notify the EPA in writing at least 30 calendar days prior to any LDAR monitoring conducted. If monitoring cannot be performed on the scheduled date, the Permittee shall notify EPA at least 1 week prior to the scheduled date and reschedule the monitoring to satisfy the monitoring frequency requirements. Observations: Hilcorp submits notices of LDAR monitoring to be conducted 30 calendar days beforehand. 10. The Permittee shall maintain a record of all EPA approved LDAR protocols. 11. The Permittee shall maintain a record of the results of all LDAR monitoring and any necessary equipment repairs due to VOC leaks. Observations: Hilcorp (formerly ConocoPhillips) submits semiannually and annually the results of all LDAR monitoring. The LDAR reports identifies what and when inspections occurred, weather, findings and repairs in a large table and then individual reports on each finding. G. Requirements for Reporting 1. Annual Emissions Reports Reports summarizing actual emissions and submitted to the Region 8 Air Permitting group. Report Date Year NOx* CO* VOC* PM* SO2* CH2O* Benzene Not Rcvd 2021 3/9/21 2020 69.27 17.28 10.84 1.55 2.3 1.32 0.23 3/1/20 2019 69.59 17.36 10.84 1.55 2.31 1.32 0.23 *NOx = nitrogen oxide; CO = carbon monoxide; VOC = volatile organic compound; PM = particulate matter; SO2 = sulfur dioxide; CH2O = formaldehyde 4. Deviation reports are due 30 days after discovery. Observation: Hilcorp submits deviation reports when necessary. ADDITIONAL CAA REQUIREMENTS NSPS OOOO (Compressor Engines) Compressor engines pre-date NSPS OOOO applicability. MACT HH Hilcorp Sunnyside is exempt from MACT HH emissions limitations due to their actual average emissions of 6 benzene are less than 0.9 megagrams per year. MACT ZZZZ Hilcorp Sunnyside is subject to area source, remote engine work practices outlined in MACT ZZZZ- Table 2d (see below): Emissions 8. For each Non-emergency, non-black start 4SLB and 4SRB remote stationary RICE >500 HP You must meet the following requirement, except during periods of startup: a. Change oil and filter every 2,160 hours of operation or annually, whichever comes first;6 b. Inspect spark plugs every 2,160 hours of operation or annually, whichever comes first, and replace as necessary; and c. Inspect all hoses and belts every 2,160 hours of operation or annually, whichever comes first, and replace as necessary Observation: Hilcorp has indicated that the engines at Sunnyside are considered remote designated engines in accordance with NESHAP ZZZZ practices. Laurie Ostrand's 2018 inspection verified the remote status and the implementation of a compliant engine maintenance program. 7 Appendix A: Sunnyside Engine Test Reports Permit Limit Permit Limit Test Results Facility Name Unit ID Serial # Date Test Notice Rcvd Date Test Report Rcvd Quarte r CO lb/hr CH2O lb/hr NOX lb/hr Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside Sunnyside E003 E004 E002 E003 E004 E002 E002 E003 E004 E003 E004 E002 E002 E003 E004 E002 E003 E004 E002 E003 E004 E003 E004 E002 C-10664/2 2/1/2022 5/2/2022 Q1 C-11542/1 2/1/2022 5/2/2022 Q1 C-10788/1 2/1/2022 5/2/2022 Q1 C-10664/2 10/15/202 12/29/202 Q4 1 1 C-11542/1 10/15/202 12/29/202 Q4 1 1 C-10788/1 10/15/202 12/29/202 Q4 1 1 C-10788/1 7/15/2021 11/23/202 Q3 1 C-10664/2 7/15/2021 11/23/202 Q3 1 C-11542/1 7/15/2021 11/23/202 Q3 1 C-10664/2 6/4/2021 Q2 C-11542/1 6/4/2021 Q2 C-10788/1 6/4/2021 Q2 C-10788/1 1/13/2021 3/31/2021 Q1 C-10664/2 1/13/2021 3/31/2021 Q1 C-11542/1 1/13/2021 3/31/2021 Q1 C-10788/1 10/5/2020 1/15/2021 Q4 C-10664/2 10/5/2020 1/15/2021 Q4 C-11542/1 10/5/2020 1/15/2021 Q4 C-10788/1 9/24/2020 Q3 C-10664/2 9/24/2020 Q3 C-11542/1 9/24/2020 Q3 C-10664/2 4/7/2020 6/16/2020 Q2 C-11542/1 4/7/2020 6/16/2020 Q2 C-10788/1 4/7/2020 6/16/2020 Q2 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 0.10 5.28 1.27 0.10 5.28 1.27 0.10 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 1.27 5.28 2.70 0.22 5.50 1.27 0.10 5.28 1.27 0.10 5.28 1.27 0.10 5.28 1.27 0.10 5.28 1.27 0.10 5.28 1.27 5.28 1.27 5.28 1.27 5.28 8 Test Date 3/7/2022 3/7/2022 3/7/2022 11/16/2021 11/16/2021 11/16/2021 8/23/2021 8/23/2021 8/23/2021 5/5/2021 5/5/2021 5/5/2021 2/16/2021 2/16/2021 2/16/2021 11/10/2020 11/10/2020 11/10/2020 8/6/2020 8/6/2020 8/6/2020 4/28/2020 4/28/2020 4/28/2020 CO (lb/hr) 0.18 0.31 0.11 0.11 0.11 0.24 0.39 0.09 0.05 0.07 0.3 0.13 0.08 0.06 0.24 0 0.21 0.22 0.04 0.09 0.22 0.19 0.39 0.22 CH2O NOx (lb/hr) (lb/hr) 0.68 0.65 0.54 0.47 0.34 0.043 0.06 1.41 0.01 2.57 0.04 1.75 0.074 0.68 0.58 0.45 0.56 0.48 0.01 0.86 0.92 0.05 1.72 0.04 2.47 0.05 3.39 1.38 0.82 0.73 Avg. Catalyst Temp. (F) 682 708 709 685 705 721 738 671 731 636 714 722 700 677 694 706 686 702 738 709 730 691 701 706 Avg. 3 (inche s H2O) 3.5 3.5 3.8 2.1 Averag e Load 65% 57% 62% 38% 2 33% 6.7 37% 3.8 82% 3.5 86% 3.5 82% 3.4 65% 3.5 58% 3.8 60% 3.8 66% 3.4 70% 3.5 60% 3.8 61% 3.4 61% 3.5 66% 3.8 82% 1.93 77% 2.67 77% 3.4 54% 3.5 52% 3.8 49% Sunnyside E003 C-10664/2 2/5/2020 4/7/2020 Q1 1.27 Sunnyside E004 C-11542/1 2/5/2020 4/7/2020 Q1 1.27 Sunnyside E002 C-10788/1 2/5/2020 4/7/2020 Q1 1.27 Sunnyside E002 C-10788/1 6/18/2019 8/27/2019 1.27 0.1 Sunnyside E003 C-10664/2 6/18/2019 8/27/2019 1.27 0.1 Sunnyside E004 C-11542/1 6/18/2019 8/27/2019 1.27 0.1 Sunnyside E003 C-10664/2 4/23/2019 5/21/2019 1.27 Sunnyside E004 C-11542/1 4/23/2019 5/21/2019 1.27 Sunnyside E002 C-10788/1 4/23/2019 5/21/2019 1.27 Sunnyside E003 C-10664/2 4/23/2019 1.27 Sunnyside E004 C-11542/1 4/23/2019 1.27 Sunnyside E002 C-10788/1 4/23/2019 1.27 Sunnyside E003 C-10664/2 11/1/2018 1/8/2019 1.27 Sunnyside E004 C-11542/1 11/1/2018 1/8/2019 1.27 Sunnyside E002 C-10788/1 11/1/2018 1/8/2019 1.27 Sunnyside E004 C-11542/1 8/10/2018 10/9/2018 1.27 0.1 Sunnyside Sunnyside Sunnyside Sunnyside E002 E001 E001 (Swing) E004 C-10788/1 C-11100/8 C-10664/2 8/10/2018 8/10/2018 6/15/2018 10/9/2018 10/9/2018 9/19/2018 C-11542/1 7/12/2018 1.27 0.1 1.27 0.1 1.27 0.1 1.27 Sunnyside E001 C-11100/8 7/12/2018 1.27 Sunnyside E002 C-10664/2 7/12/2018 1.27 5.28 3/18/2020 0.17 0.98 718 3.8 50% 5.28 3/18/2020 0.34 0.51 697 3.5 53% 5.28 3/18/2020 0.18 0.62 718 3.8 50% 5.28 8/9/2019 0.03 0.024 2.29 752 2.97 89% 5.28 8/9/2019 0.06 0.03 1.64 705 8 89% 5.28 8/9/2019 0.16 0.052 2.79 715 6.5 74% 5.28 5/6/2019 0.04 1.71 724 pre 3.4 74% 5.28 5/6/2019 0.23 1.37 698 pre 2 71% 5.28 5/6/2019 0.07 1.35 634 pre 0.3 70% 5.28 3/6/2019 0.12 5.28 3/6/2019 0.5 1.35 637 pre; 681 2.9 60% post 1.76 712 pre; 656 3.2 60% post 5.28 3/19/2019 0.08 1.45 717 pre 3.7 65% 5.28 12/4/2018 0.41 0.79 626 pre; 675 NR 60% post 5.28 12/4/2018 0.55 1.62 688 pre; 592 NR 60% post 5.28 12/4/2018 0.13 0.5 693 pre; NR NR 60% post 5.28 9/6/2018 0.4 0.073 2.85 724 pre; 666 2.9 87% post 5.28 9/6/2018 0.43 0.073 2.11 736 pre; 721 3 86% post 5.28 9/6/2018 0.45 0.072 2.51 not reported 3.2 92% 5.28 8/7/2018 0.13 0.032 3.35 663 pre; 707 5.2 86% post 5.28 6/5/2018 0.35 1.55 713 pre; 656 5.6 60% post 5.28 6/5/2018 0.14 1.67 875 pre; NR 5.2 60% post 5.28 6/5/2018 0.36 0.84 703 pre; NR 3.7 60% post 9 Appendix B: Picture and IR MOVIE LOG Date 6/27/2022 6/27/2022 6/27/2022 File MOV_2971.mp4 MOV_2792.mp4 DSCN004.jpg Name Sunnyside CS Sunnyside CS Sunnyside CS Comment Small leak at inlet separator. Dehy vent stack. Sign photograph APPENDIX C: Hilcorp Response Table to EPA's Sunnyside Records Request 10 Table 1 (Hilcorp Response Table- Item 1) 11 Catalyst Replacement Example (Hilcorp Response Table- Item 3) 12 Example Catalyst Temp Monitoring Alarms (Hilcorp Response Table- Item 5) 13 Example Differential Pressure Monitoring (Hilcorp Response Table- Item 6) Example of Work Orders Showing Temp and/or DP Addressed (Hilcorp Response Table- Items 5 & 6) 14 15