Document OzaJVvz1nJmzqp6R0NBr60pLe
MPLX - Walker Hollow Compressor Station Full Compliance Evaluation (FCE) On-Site Inspection
Inspection Date:
September 18, 2024
Inspection Report Date:
December 3, 2024
EPA Representatives:
Colin LeCortz, Environmental Scientist, US EPA Region 8 Mike Stovern, Environmental Scientist, US EPA Region 8 Chris Andrade, Environmental Scientist, US EPA Region 8 James Floyd, US EPA Region 8
Tribal Representatives:
Lonnie Favel Alverna Nelson
Company Representatives:
Joshua Hirschi AJ Thompson Jared Holmes Bill Allen Joe Lopez Chris Calvert David VanLeuben
Inspection Report Prepared By:
Chris Andrade, Environmental Scientist, US EPA Region 8
Inspection Report Reviewed By: Last Inspection:
Scott Patefield, Manager, Air & Toxics Enforcement Branch
US EPA Region 8 September 2, 2021
Digitally signed by SCOTT
SCOTT PATEFIELD PATEFIELD
Date: 2024.12.03 17:09:32 -07'00'
Operating Status:
Operational
Applicable Requirements:
Title V 40 CFR Part 60, Subpart KKKK: Standards of Performance for Stationary Combustion Turbines (NSPS KKKK) 40 CFR Part 60, Subpart OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced after September 18, 2015 (NSPS OOOOa) 40 CFR Part 60, Subpart OOOOb: Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022 (NSPS OOOOb) 40 CFR Part 63, Subpart HH: National Emissions Standards for Hazardous Pollutants from Oil and Natural Gas Production Facilities (MACT HH)
1
Permit Number: V-UO-000979-2017.00 Replaces Permit No.: N/A (initial permit)
Issue Date: June 12, 2018 Effective Date: July 12, 2018 Expiration Date: July 12, 2023
Facility Information and Emission Unit Identification
Parent Company Name: Mailing Address: Facility Contact:
Facility Operator & Name: Facility Location: County, State: Reservation: Tribe: Responsible Official: SIC Code: ICIS ID: Other CAA Permits:
Marathon Petroleum Corporation (MPLX) 200 East Hardin Street, Findlay, Ohio 45840 Josh Hirschi, Environmental Engineer (435) 781-7489 MPLX - Walker Hollow Compressor Station Latitude 40.1851, Longitude -109.3040 Uintah, Utah Uintah and Ouray Indian Reservation Ute Indian Tribe Darren Snow, Northwest Region Director 1311 - Crude Petroleum and Natural Gas 49-047-01025 There are no other CAA permits for this facility.
Enforcement History Questar Gas Management Company, a predecessor of Andeavor and MPLX, entered into a Consent Decree with the United States (Case No. 2:08-CV-00167-TS-PMW) on July 3, 2012, to resolve alleged violations of several MACT ZZZZ and MACT HH requirements at the Coyote Wash, Chapita, Island, Wonsits Valley, and River Bend Compressor Stations. The Consent Decree was terminated on June 4, 2014 (see Appendix C) and does not apply to the Walker Hollow Compressor Station.
Inspection Findings/Areas of Concern No areas of concern are noted at this time.
Compliance Assistance No compliance assistance was provided as a result of this full compliance evaluation.
Description of Operations Walker Hollow receives a comingled liquid stream containing natural gas, condensate, and water from the field via pipeline and enters the facility first at an onsite slug catcher. The slug catcher dumps at a controlled rate to a 3-phase separator, which operates at 30 pounds per square inch gauge (psig). Flash gas generated from the separator is recovered in one of four Arial Model JGP/1 electrically-driven flash gas reciprocating compressors (emissions units C-103, C-104, C-203, and C-204) and recycled back to the inlet slug catcher. The stream in the separator is divided into both a natural gas and a liquids phase.
2
Natural gas that exits the separator flows to four (4) compressors, which compress the gas before it enters either of the triethylene glycol (TEG) dehydration units (emissions units SK-101, SK-121, and SK-201). The emissions for the TEG dehydration units are routed to a Vapor Recovery Unit (VRU), which sends the recovered vapors back to the 3-phase separator. The compressors are powered by a Solar Turbines Mars 100 turbines (emissions units GT-101 and GT-121) and Solar Turbines Titan 130 turbines (GT-201 and GT-221). There are four 1st Stage compressors (C-101, C-121, C-201, and C-221) and four 2nd stage compressors (C-102, C-122, C-202, and C-222) associated with the turbines. The turbines are fueled with dehydrated natural gas from the facility. The natural gas enters the dehydration units and is bubbled up through lean TEG in a process vessel called a contactor. During this process, water vapor is removed from the gas to a concentration determined by a sales contract of 7 pounds per million standard cubic foot (lb/MMscf). The pipeline-quality natural gas then exits the contactor, is metered and then routed off site. The rich TEG exits the contactor and is regenerated using heat in a vessel called a reboiler. A natural gas-fired heater heats the TEG to a set temperature that boils impurities out of the TEG. The vapors from the reboiler are routed to the emissions control device, an open flare (FL-101). A backup flare (FL-201) is present for when the VRU is not operating. The regenerated lean TEG is circulated back to the contactor.
Condensate (liquid) exiting the separator is pumped from Walker Hollow via four (4) condensate pumps. Produced water exiting the separator is routed to four (4) 500-barrel (bbl) produced water atmospheric storage tanks at the facility. Liquids containing benzene, toluene, ethylbenzene, and xylenes (BTEX) from dehydration towers SK-101, SK-121 and SK-201 are collected in a BTEX condenser and are also pumped to these four (4) tanks. Once adequate volumes are accumulated in the storage tanks, the produced water is trucked off location for further processing or treatment.
General Inspection Observations and Commentary On September 18, 2024 at 2:45 PM, EPA representatives Colin LeCortz, Mike Stoven, Chris Andrade, and James Floyd and Ute Tribe Air Program representatives Lonnie Favel and Alverna Nelson met with MPLX representatives Joshua Hirschi, AJ Thompson, Jared Holmes, Bill Allen, Joe Lopez, Chris Calvert, and David VanLeuben at the Walker Hollow Compressor station in Vernal, Utah. An opening conference was conducted, during which EPA inspectors presented credentials. A safety orientation was also completed, and EPA inspectors informed MPLX representatives that the site would be surveyed using a forward looking infrared (FLIR) camera for which a hot work permit was generated and signed by all personnel on site.
The Walker Hollow Compressor Station was not operated from November 2016 until January 27, 2022, when the turbine and other associated equipment were briefly restarted. The facility resumed operations on March 25, 2022.
Since the previous inspection in 2018, turbine GT-101 has been replaced and three new turbines have been added (GT-121, GT-201, and GT 221). There is also two additional dehydration towers (SK-121 and SK-201), two compressors (C-203 and C-204), four 1st stage compressors (C-101, C-121, C-201, and C-221), four 2nd stage compressors (C-102, C-122, C-202, and C-222), and four produced water and BTEX storage tanks (TK101, TK-102, TK-201, and TK-202) that are new since the previous inspection.
The facility has online power and, according to MPLX representatives, the facility operates on instrument air powered pneumatic devices. During the inspection Units GT-101 and GT-221 were operating while units GT121 and GT-201 were off. Condensate generated at the facility is trucked off-site to Koda.
Emissions from the manway at the bottom of the dehydration tower were detected by the FLIR. The emissions were coming from the natural gas side of the tower. Video MOV_3576 was recorded by Mr. Stovern. An email was sent on November 20, 2024 to Mr. Hirshi from MPLX. A response was received on November 26, 2024 stating that the leak was repaired on September 21, 2024 and verified with an OGI camera on September 23, 2024.
3
EPA and Ute Tribe representatives met with MPLX representatives for a brief closing conference. A confidential business information (CBI) warning was presented to MPLX representatives, and no CBI was claimed. EPA and tribal staff departed the facility at 4:00 PM. Emails to request relevant compliance-related information and records were sent to Mr. Hirshi on October 1,2024, October 29, 2024, and November 20, 2024. Mr. Hirshi provided the requested information to EPA via email on October 12, 2024, November 7, 2024, and November 26, 2024 respectively.
4
Potential to Emit (PTE) Pursuant to 40 CFR 52.21, potential to emit (PTE) is defined as the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation, or the effect it would have on emissions, is federally enforceable.
See Table 1, below, for facility-wide and emission unit-specific potential to emit data included in the Statement of Basis for Permit No. V-UO-000979-2017.00 for the Walker Hollow Compressor Station. The PTE totals below include reductions from legally and practically enforceable requirements set forth in the Title V permit. Table 1 also contains the total PTE for all insignificant emissions units. The 2024 inspection identified three new engines, two new dehydrators, two new compressors, and four storage tanks on site. Updated PTE calculations will come with the next updated Title V Permit.
Table 1: Potential to Emit in Tons Per Year (tpy) MPLX Walker Hollow Compressor Station
Emission Unit Id.
NOx
GT-101
40.3
SK-101
-
EL
-
Insignificant
Emission
0.03
Units
TOTAL
40.3
Regulated Air Pollutants (tpy)
CO
VOC
PM10
SO2
25.1
2.7
2.7
0.09
-
87.7
-
-
-
2.74
-
-
0.38
0.56
0.03
-
25.4
93.7
2.7
0.1
Total HAP 0.4 3.63 0.01
0.9
4.9
NOx = oxides of nitrogen; CO = carbon monoxide; VOC = volatile organic compounds; PM10 = particulate matter 10 m in diameter; SO2 = sulfur dioxide; HAP = hazardous air pollutants "Units in existing permit, see below on additional equipment included in the new permit application"
5
Permit Number V-UO-000979-2017.00 Requirements and Compliance Status Inspector notes discussing compliance status will follow each relevant permit requirement in bold blue font.
I. Facility Emission Points and Unit-Specific Information
Emission Unit ID
GT-101** GT-121**
GT-201** GT-221**
SK-101
SK-121**
SK-201**
Table 2: Source Emission Points
Description
91.7 MMBtu/h*, natural gas-fired turbine Solar Turbines Mars 100
Serial Number: OHJ23-M4538 Installed: April 23, 2024 Serial Number: OHG22-M7701 Installed: June 28, 2023
132.4 MMBtu/h*, natural gas-fired turbine Solar Turbines Titan 130-23502S
Serial Number: 1274L Serial Number: 1313L
Installed: Dec 17, 2023 Installed: Jan 5, 2024
65 MMscfd* Dehydration Unit TEG Regenerator and Flash Separator Vents
Serial Number: N/A
Installed: 10/10/2016
80 MMscfd* Dehydration Unit TEG Regenerator and Flash Separator Vents
Serial Number: N/A
Installed: 7/1/2023
200 MMscfd* Dehydration Unit
TEG Regenerator and Flash Separator Vents, Vapor Recovery Unit,
Backup Enclosed Combustor.
C-103 C-104
C-203** C-204**
C-101 C-121**
C-102 C-122**
C-201** C-221**
C-202** C-222**
Serial Number: N/A
Installed: 12/16/2023
Arial Model JGP/1 Electrically-driven Reciprocating Compressor
Emissions are fugitive emissions leaks from the rod packing.
Serial Number: N/A
Installed: 10/10/2016
Serial Number: N/A
Installed: 10/10/2016
Arial Model JGP/1 Electrically-driven Reciprocating Compressor
Emissions are fugitive emissions leaks from the rod packing.
Serial Number: N/A
Installed: 12/16/2023
Serial Number: N/A
Installed: 12/16/2023
Solar C51LL Dry Seal Centrifugal Compressor
Emissions are fugitive emissions leaks from the dry seal
Serial Number: G5110200
Installed: 2/15/2016
Serial Number: G5110201
Installed: 3/1/2023
Solar C336 Dry Seal Centrifugal Compressor
Emissions are fugitive emissions leaks from the dry seal
Serial Number: G2620007
Installed: 2/15/2016
Serial Number: G2620008
Installed: 3/1/2023
Solar C61 Dry Seal Centrifugal Compressor
Emissions are fugitive emissions leaks from the dry seal
Serial Number: G6110179 Serial Number: G6110184
Installed: 8/31/2023 Installed: 1/5/2024
Solar C51 Dry Seal Centrifugal Compressor Emissions are fugitive emissions leaks from the dry seal
Control Equipment
None
None
John Zink Low-Pressure Flare (FL-101), Vapor Recovery Unit, Backup Flare for Recovery Unit Zeeco AFDS-4/20-40 BTEX (FL-201) John Zink Low-Pressure Flare (FL-101), Vapor Recovery Unit, Backup Flare for Recovery Unit Zeeco AFDS-4/20-40 BTEX (FL-201) John Zink Low-Pressure Flare (FL-101), Vapor Recovery Unit, Backup Flare for Recovery Unit Zeeco AFDS-4/20-40 BTEX (FL-201)
None
None
None
None
None
6
Serial Number: G5110323 Serial Number: G5110322
Installed: 8/31/2023 Installed: 1/5/2024
500 bbl. produced water and BTEX liquids atmospheric storage
TK-101** TK-102** TK-201** TK-202**
tank.
Serial Number: N/A Serial Number: N/A Serial Number: N/A
Installed: 10/10/2016 Installed: 10/10/2016 Installed: 12/16/2023
Cimarron AB100 Enclosed Combustor (ECD-201)
Serial Number: N/A
Installed: 12/16/2023
Fugitive Equipment Leaks
EL
None
Serial Number: N/A
Installed: N/A
* MMBtu/h = million British thermal units per hour; MMscfd = million standard cubic feet per day
** New emission units identified during the inspection that were not installed in the initial Title V permit
7
Equipment
GT-101* Solar Turbine Mars 100
GT-121* Solar Turbine Mars 100
GT-201* Solar Turbine Titan 130
GT-221* Solar Turbine Titan 130
SK-101 65 MMscfd Dehydration Unit
SK-121* 80 MMscfd Dehydration Unit
SK-201* 200 MMscfd Dehydration Unit
Table 3: Requirements for Emission Units
Applicable Requirements
Limitations
Monitoring
Method
Interval
25a ppm NOx at 15% oxygen (O2) or 54 ng/J
of useful output
Performance test
Annual
NSPS KKKK
NSPS KKKK MACT HH MACT HH MACT HH
110 ng SO2/J (0.90 lb SO2/MWh) gross output
OR
Fuel total potential sulfur emissions 26
ng SO2/J (0.060 lb SO2/MMBtu)b
Performance test
25a ppm NOx at 15% oxygen (O2) or 54 ng/J
of useful output
Performance test
110 ng SO2/J (0.90 lb SO2/MWh) gross output
OR
Fuel total potential sulfur emissions 26
ng SO2/J (0.060 lb SO2/MMBtu)b
Performance test
Flare reducing VOC emissions by 95% or more
Presence of pilot light
No visible emissions
Flare reducing VOC emissions by 95% or more
Presence of pilot light
No visible emissions
Flare reducing VOC emissions by 95% or more
Presence of pilot light
No visible emissions
Annual Annual Annual Continuous Continuous Continuous
8
Equipment
C-103, C-104 Arial Model JGP/1 Electricallydriven Reciprocating Compressor
C-203*, C-204* Arial Model JGP/1 Electricallydriven Reciprocating Compressor
C-102*, C-122* Solar C336 Dry Seal Centrifugal Compressor
C-201*, C-221* Solar C61 Dry Seal Centrifugal Compressor
C-202*, C-222* Solar C51 Dry Seal Centrifugal Compressor
Applicable Requirements
NSPS OOOOa NSPS OOOOb
NSPS OOOOb
NSPS OOOOb
NSPS OOOOb
Limitations
Reduce GHG and VOC emissions
Monitoring
Method
Interval
Replace rod packing
Every 26,000 hours of operation
Reduce GHG and VOC emissions
Volumetric flow rate measurements
Every 8,760 hours of operation
Reduce GHG and VOC emissions
Volumetric flow rate measurements
Every 8,760 hours of operation
Reduce GHG and VOC emissions
Volumetric flow rate measurements
Every 8,760 hours of operation
Reduce GHG and VOC emissions
Volumetric flow rate measurements
Every 8,760 hours of operation
Collection of Fugitive Emissions Components (EL)
NSPS OOOOb
Reduce GHG and VOC emissions
Monitoring surveys
Initial and Quarterly
a Although the Title V permit for Walker Hollow states that the NOx limit for GT-101 is 15 ppm at 15% O2, it is actually 25 ppm at 15% O2 per Table 1 to 40 C.F.R. Part 60, Subpart KKKK. (See Section III.C., below, for details.) b Per the information provided by MPLX in its Title V permit application, it is choosing to comply with the MACT KKKK SO2 requirements using the fuel total sulfur content rather than the SO2 stack emissions limit. * New emission units identified during the inspection that were not installed in the initial Title V permit
9
II. Compliance Schedule for Walker Hollow
Walker Hollow commenced operations on October 10, 2016. Andeavor promptly ceased compression related activities onsite after initial commencement of operations at the facility due to low natural gas prices. Walker Hollow was operational for less than 14 days and was mothballed at the time of the initial permit issuance. No emission units have operated since November 9, 2016, until March 25, 2022, when operations were resumed.
The Permittee is subject to NSPS KKKK, NSPS OOOOa, NSPS OOOOb, and MACT HH requirements. Further details regarding the compliance schedules can be found below.
OBSERVATION: According to information submitted by MPLX, "On January 27, 2022, the turbine and other associated equipment were briefly restarted after being shut down since late 2016, and were periodically operated for testing, maintenance, and recommissioning until normal operations resumed on March 25th, 2022. It has been operational since March 25th, 2022".
The facility was operational at the time of the inspection.
III. Standards of Performance for Stationary Gas Turbines - 40 CFR Part 60, Subpart KKKK (NSPS KKKK)
A. Applicability [40 CFR 60.4305]
40 CFR part 60, subpart KKKK (NSPS KKKK) applies to turbine emissions units GT-101, GT-121, GT-201, and GT-221.
OBSERVATION: Since turbines GT-101, GT-121, GT-201, and GT-221 have heat inputs at peak loads 10 MMBtu/h and commenced construction, modification, or reconstruction after February 18, 2005, they are subject to NSPS KKKK.
B. General Provisions [40 CFR 60.1-19]
1. The General Provisions at 40 CFR part 60, subpart A apply. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 60, subpart A.
2. All reports required under 40 CFR part 60, subpart A shall be sent to the EPA at the following address as listed in 60.4:
Director, Air and Toxics Technical Enforcement Program, 8ENF-AT Office of Enforcement, Compliance and Environmental Justice 1595 Wynkoop Street, Denver, Colorado 80202-1129
OBSERVATION: Dates of the construction notification date, construction commencement dates, start-up notifications, and start-up dates for the turbines can be found in the table below. Pursuant to 40 CFR 60.7(a)(1), the notification for construction has been submitted within the required 30-day timeframe for the start of construction. Pursuant to 40 CFR 60.7(a)(3), a notification of the actual date of initial startup of the turbines was submitted to EPA within the required 15-day from of start-up.
10
Construction Notification Date Construction Commencement Start-up Notification Start-up Date
GT-101 4/26/2024
4/23/2024
4/26/2024 4/26/2024
GT-121 3/1/2023
3/1/2023
7/5/2023 6/28/2023
GT-201 9/28/2023
8/31/2023
12/28/2023 12/17/2023
GT-221 1/18/2024
1/5/2024
4/17/2024 4/10/2024
C. NOx Requirements [40 CFR 60.4320 and NSPS KKKK Table 1]
The Permittee shall meet the emission standard of 15 ppm NOx at 15% oxygen (O2) or 54 nanograms per Joule (ng/J) of useful output.
OBSERVATION: Since turbines GT-101, GT-121, GT-201, and GT-221 are new natural gas-fired turbines, with a combustion turbine heat inputs at peak loads of > 50 MMBtu/h and 850 MMBtu/h, per Table 1 to Subpart KKKK, they must meet a NOx emission standard of 25 ppm at 15% O2 or 54 ng/J of useful output (1.2 lb/MWh). Therefore, the emission limits for the turbines listed in this permit requirement (15 ppm NOx at 15% O2 or 54 ng/J of useful output) are incorrect.
D. SO2 Requirements [40 CFR 60.4330]
The Permittee shall comply with one of the following requirements:
1. The turbine shall not discharge any gases which contain SO2 in excess of 110 ng/J (0.90 lb/MWh) gross output [40 CFR 60.4330(a)(1)];
2. The turbine shall not burn any fuel which contains total potential sulfur emissions in excess of 26 ng SO2/J (0.060 lb SO2/MMBtu) heat input. If the turbine simultaneously fires multiple fuels, each fuel shall meet this requirement [40 CFR 60.4330(a)(2)]; or
3. If the turbine burns at least 50 percent biogas on a calendar month basis, as determined based on total heat input, the Permittee shall not cause to be discharged into the atmosphere from the affected source any gases that contain SO2 in excess of 65 ng SO2/J (0.15 lb SO2/MMBtu) heat input. [40 CFR 60.4330(a)(3)]
OBSERVATIONS: Turbines GT-101, GT-121, GT-201, and GT-221 do not burn biogas, so the requirements at 60.4330(a)(3) do not apply. GT-101, GT-121, GT-201, and GT-221 must comply with the SO2 emission limits at 60.4330(a)(1) and (2). Per the information submitted by MPLX in the Title V permit application for Walker Hollow Compressor Station, it is choosing to comply with the MACT KKKK SO2 requirements using the fuel total sulfur content at 60.4330(a)(2) rather than the SO2 stack emissions limit at 60.4330(a)(1).
E. General Compliance Requirements [40 CFR 60.4333]
The Permittee shall operate and maintain the turbine and air pollution control and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during startup, shutdown and malfunction.
11
F. Monitoring and Reporting Requirements
The Permittee shall comply with the following monitoring, recordkeeping and reporting requirements:
1. Demonstrate continuous compliance for NOx as specified in 60.4335 and 60.4355 if using water or steam injection.
2. Demonstrate continuous compliance for NOx as specified in 60.4340 and 60.4355 if not using water or steam injection.
3. Demonstrate continuous compliance for NOx as specified in 60.4345 and 60.4350 if using continuous emissions monitoring systems (CEMS).
OBSERVATION: Since turbines GT-101, GT-121, GT-201, and GT-221 do not use water or steam injection to control NOX emissions, pursuant to 60.4340(a), annual performance tests must be conducted to demonstrate continuous compliance with NOX emission limits. As an alternative to testing, CEMS may be installed, calibrated, maintained, and operated (see 60.4340(b)). CEMS are not installed at the facility; therefore, annual NOX performance testing on turbines GT-101, GT-121, GT-201, and GT-221 is required. Pursuant to 60.4355, during the performance test, acceptable values, and ranges of continuously monitored operating parameters that are indicative of the unit's NOX formation characteristics must be established, and a parameter monitoring plan must be developed and kept onsite.
4. Determine the total sulfur content of the turbine's combustion fuel as specified in 60.4360 and 60.4370 unless exempted from monitoring the total sulfur content of the fuel as provided in 60.4365.
OBSERVATION: Pursuant to 60.4360, the total sulfur content of fuel being fired into turbines GT-101, GT-121, GT-201, and GT-221 must be determined using the total sulfur methods described in 60.4415. According to 60.4370(c), the monitoring frequency of fuel total sulfur content may be conducted according to custom schedules, which require 30 days of consecutive sampling.
GT-121 was tested over the period of 7/5/2024 to 8/7/2024 using the Gas Processor's Association (GPA) Standard 2377 method. The results of the test were submitted to the EPA on August 28, 2024, and demonstrate compliance with the emission limits for sulfur dioxide as specified in 40 CFR 60.4330(a)(2).
GT-201 was tested over the period of 1/15/2024 to 2/14/2024 using the Gas Processor's Association (GPA) Standard 2377 method. The results of the test were submitted to the EPA on February 15, 2024, and demonstrate compliance with the emission limits for sulfur dioxide as specified in 40 CFR 60.4330(a)(2).
GT-101 and GT-221 were tested over the period of 6/12/2024 to 7/11/2024 using the Gas Processor's Association (GPA) Standard 2377 method. The results of the test were submitted to the EPA on July 29, 2024, and demonstrate compliance with the emission limits for sulfur dioxide as specified in 40 CFR 60.4330(a)(2).
5. Submit reports for excess emissions and monitor downtime for NOx and SO2 as specified in, 60.4375(a), 60.4380, and 60.4385.
6. Submit reports of the results of each performance tests as specified in 60.4375(b).
12
7. All reports required under 60.7(c) shall be postmarked by the 30th day following the end of each 6month period. (60.4395)
OBSERVATION: The table below details the dates of installation for the turbines, the dates of the tests, the dates of the reports, the average NOx emissions and the emissions limits for GT-101, GT-121, GT201, and GT-221. See the submitted performance test results submitted within 30 days of the test taking place. The results show the NOx emissions as less than 75% of the emission limit, which allows for testing to take place once every 2 years instead of every 6 months.
Turbine
GT-101 GT-121 GT-201 GT-221
Equipment Installation Date 4/26/2024 6/28/2023 12/17/2023 4/10/2024
Date of Test
6/3/2024 8/30/2023 2/21/2024 6/4/2024
Date of Test Report
7/29/2024 10/27/2023 3/26/2024 7/29/2024
Average NOx Emissions
5.21 4.87 4.44 6.40
Emission Limit
25 25 25 25
G. Performance Test Requirements [40 CFR 60.4340(a) and 60.4400]
1. The Permittee shall conduct an initial performance test for NOx emissions, according to 60.8. Subsequent NOx performance tests shall be conducted on an annual basis and no more than 14 calendar months following the previous performance test. As specified in 60.4340(a), if the Permittee is not using water or steam injection to control NOx emissions, and if the NOx emission result from the performance tests is less than or equal to 75 percent of the NOx emission limit for the turbine, the Permittee may reduce the frequency of subsequent performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the results of any subsequent performance test exceed 75 percent of the NOx emission limit for the turbine, the Permittee must resume annual performance tests.
2. The Permittee shall comply with the following requirements for each performance test for NOx emissions:
(a) Measure NOx by using the methodologies in 60.4400(a),
(b) The Permittee shall conduct each performance test according to 60.4400(b),
(c) If a NOx-diluent CEMS is installed, the Permittee shall perform the initial performance test as specified in 60.4405; and
(d) If choosing to continuously monitor parameters, the Permittee shall establish a valid parameter range as specified in 60.4410.
3. The Permittee shall conduct an initial performance test for SO2 emissions, as specified in 60.8 and 60.4415. Subsequent SO2 performance tests shall be conducted on an annual basis and no more than 14 calendar months following the previous performance test.
4. The Permittee shall conduct each performance test for SO2 according to 60.4415(a)(1) - (3).
OBSERVATION: All the requirements above appear to be met in the submitted performance test results
13
and were conducted in the methodologies outlined in EPA 40 CFR 60(A) Methods 1, 3A, 7E and Subpart KKKK. The table below details the dates of installation for the turbines, the dates of the tests, the dates of the reports, the average NOx emissions, and the emissions limits for GT-101, GT-121, GT-201, and GT221. The results show the NOx emissions as less than 75% of the emission limit, which allows for testing to take place once every 2 years instead of every 6 months.
Turbine
GT-101 GT-121 GT-201 GT-221
Equipment Installation Date 4/26/2024 6/28/2023 12/17/2023 4/10/2024
Date of Test
6/3/2024 8/30/2023 2/21/2024 6/4/2024
Date of Test Report
7/29/2024 8/27/2023 3/26/2024 7/29/2024
Average NOx Emissions
5.21 4.87 4.44 6.40
Emission Limit
25 25 25 25
IV. Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 - 40 CFR Part 60, Subpart OOOOa (NSPS OOOOa)
A. Applicability [40 CFR 60.5365a(c) and (j)]
40 CFR part 60, Subpart OOOOa (NSPS OOOOa) applies to the reciprocating compressor on emissions units C-103 and C-104, and the collection of fugitive emissions components, as defined at 60.5430a.
OBSERVATION: Since the two Arial electrically driven reciprocating compressors (C-103 and C-104) commenced construction, modification, or reconstruction after September 18, 2015, they are considered affected facilities under NSPS OOOOa, pursuant to 60.5365a(c). Since the facility is subject to OOOOb requirements, the collection of fugitive emissions components at the Walker Hollow Compressor Station is considered an affected facility under NSPS OOOOb, pursuant to 60.5365b(i).
B. General Compliance Requirements [40 CFR 60.5370a]
At all times, including during startup, shutdown and malfunction, the Permittee shall maintain and operate the reciprocating compressors and collection of fugitive emission components, air pollution control and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the EPA which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
C. GHG and VOC Emissions Standards for Reciprocating Compressor Affected Facilities [40 CFR 60.5385a]
The Permittee shall comply with the following standards for each reciprocating compressor affected facility:
1. Replace the reciprocating compressor rod packing according to 60.5385a(a).
OBSERVATION: Pursuant to 60.5385a(a), the reciprocating compressor rod packing must (1) be replaced on or before the compressor has operated for 26,000 hours; (2) be replaced prior to 36 months from the date of the most recent rod packing replacement or from the date of startup for a new compressor; or (3) collect the methane and VOC emissions from the rod packing and route emissions to a process through a closed vent system that operates under negative pressure. According to the
14
information submitted by the source in its Title V permit application for Walker Hollow, it elects to comply with 60.5385a(a)(1) by replacing the rod packing no later than every 26,000 hours of operation.
OBSERVATION: As of October 1, 2024, the run time hours of compressor C-103 and C-104 are 1,668 hours and 18,211 hours respectively. There have been no rod packing replacements since they still have some time before reaching 26,000 hours.
2. Demonstrate initial compliance with standards that apply to the reciprocating compressor affected facilities as required by 60.5410a(c).
3. Demonstrate continuous compliance with standards that apply to reciprocating compressor affected facilities as required by 60.5415a(c).
OBSERVATION: appears to have continuously monitored the number of hours of operation of C-103 and C-104 and has submitted the initial annual report as required by 60.5410a(c)(1) and (3) and 60.5415a(c)(1) through (3).
4. Perform reporting requirements as specified by 60.5420a(b)(1) and (4) and the recordkeeping as required by 60.5420a(c)(3), (6) through (9), and (17), as applicable.
OBSERVATION: The initial NSPS OOOOa Annual Report for Walker Hollow was submitted by the source on October 27, 2017 (within 90 days of the end of the initial compliance period), as required by 60.5420a(b). The report appeared to contain all of the general information required pursuant to 60.5420a(b)(1) and the information for reciprocating compressor affected facilities at 60.5420a(b)(4).
Pursuant to 60.5420a(c)(3), the source keeps records of the cumulative hours of operation, dates and times of rod packing replacements, and records of deviations on each reciprocating compressor. According to the information provided by the source, no deviations have occurred on C-103 or C-104, and the rod packing on each unit has not been replaced, to date. The recordkeeping requirements at 60.5420a(c)(6), (7), (9), and (17) do not apply because the reciprocating compressors at Walker Hollow have neither a cover nor a closed vent system. The requirement at 60.5420a(c)(8) does not apply because the reciprocating compressors are not subject to the bypass requirements of 60.5416a(a)(4).
D. GHG and VOC Standards for the Collection of Fugitive Emissions Components [40 CFR 60.5397a]
The Permittee shall reduce GHG (in the form of a limitation on emissions of methane), and VOC emissions by complying with the requirements in 60.5397a(a)-(j).
OBSERVATION: Per 60.5397a(b)-(d), an emissions monitoring plan is required; a copy of the emissions monitoring plan was provided to EPA upon request and appears to include the required elements. The emissions monitoring plan states that a site map and observation path for each site subject to NSPS OOOOa will be created as required by 60.5397a(d)(1)-(2). 60.5397a(f)(2) requires the initial monitoring survey of the collection of fugitive emissions components at a compressor station to be conducted within 60 days of the startup of production or by June 3, 2017, whichever is later. The initial monitoring survey was conducted on the collection of fugitive emissions components at Walker Hollow Compressor Station on October 4, 2017. According to information provided by the source in its Initial NSPS OOOOa Annual Report, the initial monitoring was conducted after June 3, 2017, due to the judicial stay that was in effect for NSPS OOOOa. Per the annual OOOOa reports component monitoring surveys occurred 2019 through 2023. No fugitive emissions components at the Walker Hollow Compressor Station have been
15
identified by the source as difficult-to-monitor or unsafe-to-monitor; therefore, the requirements of 60.5397a(g)(3) - (4) do not currently apply.
Per 60.5397a(g)(2), a monitoring survey must be conducted at least quarterly after the initial survey. According to the information provided to EPA by the source, fugitive emissions monitoring surveys were also conducted quarterly from 2019 through 2023. Results of the quarterly monitoring surveys were included in NSPS OOOOa Annual Reports.
E. Initial Compliance Requirements for Reciprocating Compressor and Fugitive Emission Components Affected Facilities [40 CFR 60.5410a(c) and (j)]
1. The Permittee shall achieve initial compliance for each reciprocating compressor affected facility by complying with 60.5410a(c)(1) - (4).
OBSERVATION: Pursuant to 60.5410a(c)(1) - (4), initial compliance for C-103 and C-104 shall be demonstrated by tracking the number of hours of operation, maintaining records, and submitting the Initial NSPS OOOOa Annual Report. See Section IV.C, above, for a discussion of these items.
2. The Permittee shall achieve initial compliance with the fugitive emission standards for each collection of fugitive emissions components by complying with 60.5410a(j)(1) - (5).
OBSERVATION: Pursuant to 60.5410a(j)(1) - (5), initial compliance for the collection of fugitive emissions components shall be demonstrated by developing a fugitive emission monitoring plan, conducting an initial monitoring survey and making repairs as required by 60.5397a(h), maintaining records, and submitting the Initial NSPS OOOOa Annual Report. See Section IV.D, above, for a discussion of these items.
F. Continuous Compliance Requirements for Reciprocating Compressor and Fugitive Emissions Components Affected Facilities [40 CFR 60.5415a]
1. The Permittee shall demonstrate continuous compliance for the reciprocating compressor according to 60.5415a(c).
OBSERVATION: As discussed in Section IV.C, above, the source continuously monitors the number of hours of operation for C-103 and C-104. NSPS OOOOa Annual Reports were submitted for 2019 through 2023.
2. The Permittee shall demonstrate continuous compliance for each collection of fugitive emission components according to 60.5415a(h).
OBSERVATION: As discussed in Section IV.D, above, the source conducted periodic monitoring surveys each calendar quarter since the initial survey in October 2017. NSPS OOOOa Annual Reports were submitted for 2019-2023, which included results of the initial and quarterly surveys conducted.
G. Reporting and Recordkeeping Requirements [40 CFR 60.5420a(b) and (c)]
1. The Permittee shall submit annual reports for reciprocating compressors affected facilities containing the information specified in 60.5420a(b)(1), (4), (7), (9), and (11).
2. The Permittee shall maintain all records identified as specified in 60.7(f) and in 60.5420a(c)(3), (69), and (15). 16
OBSERVATION: Based on the information available, the source appears to have submitted annual reports and maintained records as required.
V. Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022 (NSPS OOOOb) Reciprocating Compressors
A. Applicability [40 CFR 60.5365b(c) and (i)]
40 CFR part 60, Subpart OOOOb (NSPS OOOOb) applies to the reciprocating compressors on emissions units C-203 and C-204, and the collection of fugitive emissions components, as defined at 60.5430b.
OBSERVATION: Since the two Arial electrically-driven reciprocating compressors (C-203 and C-204) commenced construction, modification, or reconstruction after December 6, 2022, they are considered affected facilities under NSPS OOOOb, pursuant to 60.5365b(c).
OBSERVATION: The collection of fugitive emissions components at the Walker Hollow Compressor Station is considered an affected facility under NSPS OOOOb, pursuant to 60.5365b(i).
B. General Compliance Requirements [40 CFR 60.5370b]
At all times, including during startup, shutdown and malfunction, the Permittee shall maintain and operate the reciprocating compressors and collection of fugitive emission components, air pollution control and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the EPA which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
C. GHG and VOC Emissions Standards for Reciprocating Compressor Affected Facilities [40 CFR 60.5385b]
The Permittee shall comply with the following standards for each reciprocating compressor affected facility:
1. Measure the volumetric flow rate of each cylinder according to 60.5385b(a).
OBSERVATION: The facility contact states that rod packing vent volumetric flow rates will be measured once every 8,760 hours of operation or 8,760 after hours of operation from May 7, 2024, whichever is later, according to 60.5385b. As of November 7, 2024 the units have not reached a run time of 8,760 hours yet.
2. Demonstrate initial compliance with standards that apply to the reciprocating compressor affected facilities as required by 60.5410b(e).
3. Demonstrate continuous compliance with standards that apply to reciprocating compressor affected facilities as required by 60.5415b(g).
OBSERVATION: The facility contact states that rod packing vent volumetric flow rates will be measured once every 8,760 hours of operation or 8,760 after hours of operation from May 7, 2024, whichever is later, and must have a flow rate of less than 2scfm per cylinder, according to 60.5385b. As of November 7, 2024 the units have not reached a run time of 8,760 hours yet.
17
4. Perform reporting requirements as specified by 60.5420b(b)(1), (6), and (11) through (13) as applicable, and the recordkeeping as required by 60.5420b(c)(5) and (8) through (13), as applicable.
OBSERVATION: The initial NSPS OOOOb Annual Report for reciprocating compressors C-203 and C204 at Walker Hollow are required to be submitted within 8,760 hours of operation after May 7, 2024 or on or before 8,760 hours of operation after startup, whichever date is later. At the time of this inspection report compressors C-203 and C-204 have not reached 8,760 hours of operation.
Pursuant to 60.5420b(c)(5), the source keeps records of the cumulative hours of operation since startup or previous volumetric flow rate measurement, the method used and results of volumetric flow rate, records for flow meters, dates and times of rod packing replacements, and records of deviations on each reciprocating compressor. According to the information provided by the source, no deviations have occurred on C-203 or C-204, and the rod packing on each unit has not been replaced, to date.
D. GHG and VOC Standards for the Collection of Fugitive Emissions Components [40 CFR 60.5397b]
The Permittee shall reduce GHG (in the form of a limitation on emissions of methane), and VOC emissions by complying with the requirements in 60.5397b.
OBSERVATION: Per 60.5397b(b)-(d), an emissions monitoring plan is required; a copy of the emissions monitoring plan for OOOOa, which includes equipment subject to OOOOb, was provided to EPA upon request and appears to include the required elements. The emissions monitoring plan states that a site map and observation path for each site subject to NSPS OOOOa will be created as required by 60.5397b(d)(1)-(2). 60.5397b(f)(2) requires the initial monitoring survey of the collection of fugitive emissions components at a compressor station to be conducted within 90 days of the startup of production or by June 6, 2024, whichever is later. The Facility contact has indicated that "The next OOOOb compliance report will be submitted covering operations during 2024", as of November 18, 2024 the EPA has not received a report of the initial monitoring survey.
Per 60.5397a(g)(1)(iv), a monitoring survey must be conducted at bimonthly after the initial survey. The Facility contact has indicated that "The next OOOOb compliance report will be submitted covering operations during 2024", as of November 18, 2024 the EPA has not received a report of continuous monitoring surveys being performed
E. Initial Compliance Requirements for Reciprocating Compressor and Fugitive Emission Components Affected Facilities [40 CFR 60.5410b(e) and (k)]
1. The Permittee shall achieve initial compliance for each reciprocating compressor affected facility by complying with 60.5410b(e)(1) - (7).
OBSERVATION: Pursuant to 60.5410a(c)(1) - (4), initial compliance for C-203 and C-204 shall be demonstrated by tracking the number of hours of operation, volumetric flow rates, maintaining records, and submitting the Initial NSPS OOOOb Annual Report. See Section IV.C, above, for a discussion of these items.
2. The Permittee shall achieve initial compliance with the fugitive emission standards for each collection of fugitive emissions components by complying with 60.5410b(k)(1) - (5).
OBSERVATION: Pursuant to 60.5410b(k)(1) - (5), initial compliance for the collection of fugitive 18
emissions components shall be demonstrated by developing a fugitive emissions monitoring plan, conducting an initial monitoring survey, and making repairs as required by 60.5397b(h), maintaining records, and submitting the Initial NSPS OOOOb Annual Report. See Section IV.D, above, for a discussion of these items.
F. Continuous Compliance Requirements for Reciprocating Compressor and Fugitive Emissions Components Affected Facilities [40 CFR 60.5415b]
1. The Permittee shall demonstrate continuous compliance for the reciprocating compressor according to 60.5415b(g).
OBSERVATION: As discussed in Section IV.C, above, the source continuously monitors the number of hours of operation for C-203 and C-204.
2. The Permittee shall demonstrate continuous compliance for each collection of fugitive emission components according to 60.5415b(l).
OBSERVATION: As discussed in Section IV.D, above, the source has not yet submitted the biweekly monitoring surveys and has indicated that they would be included in the 2024 annual report.
G. Reporting and Recordkeeping Requirements [40 CFR 60.5420b(b) and (c)]
1. The Permittee shall submit annual reports for reciprocating compressors affected facilities containing the information specified in 60.5420b(b)(6).
2. The Permittee shall maintain all records identified as specified in 60.7(f) and in 60.5420b(c)(5).
OBSERVATION: Subpart OOOOb went into effect in 2024 thus no annual reports have yet been submitted.
VI. Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022 (NSPS OOOOb) Centrifugal Compressors
B. Applicability [40 CFR 60.5365b(c) and (i)]
40 CFR part 60, Subpart OOOOb (NSPS OOOOb) applies to the dry seal centrifugal compressors on emissions units C-121, C-122, C-201, C-202, C-221, and C-222, and the collection of fugitive emissions components, as defined at 60.5430b.
OBSERVATION: Since the six dry seal centrifugal compressors (C-121, C-122, C-201, C-202, C-221, and C-222) commenced construction, modification, or reconstruction after December 6, 2022, they are considered affected facilities under NSPS OOOOb, pursuant to 60.5365b(b).
OBSERVATION: The collection of fugitive emissions components at the Walker Hollow Compressor Station is considered an affected facility under NSPS OOOOb, pursuant to 60.5365b(i).
B. General Compliance Requirements [40 CFR 60.5370b]
19
At all times, including during startup, shutdown and malfunction, the Permittee shall maintain and operate the reciprocating compressors and collection of fugitive emission components, air pollution control and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the EPA which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
C. GHG and VOC Emissions Standards for Centrifugal Compressor Affected Facilities [40 CFR 60.5380b]
The Permittee shall comply with the following standards for each reciprocating compressor affected facility:
1. Measure the volumetric flow rate of each cylinder according to 60.5380b(a).
OBSERVATION: The facility contact states volumetric flow rates will be measured once every 8,760 hours of operation, or after 8,760 hours of operation from May 7, 2024, whichever is later according to 60.5380b. As of November 7, 2024, the units have not reached a run time of 8,760 hours yet.
2. Demonstrate initial compliance with standards that apply to the reciprocating compressor affected facilities as required by 60.5410b(d).
3. Demonstrate continuous compliance with standards that apply to reciprocating compressor affected facilities as required by 60.5415b(d).
OBSERVATION: The facility contact states volumetric flow rates will be measured once every 8,760 hours of operation or after 8,760 hours of operation from May 7, 2024, and must have a flow rate of less than 10scfm per seal according to 60.5385b. As of November 7, 2024, the units have not reached a run time of 8,760 hours yet.
4. Perform reporting requirements as specified by 60.5420b(b)(1), (6), and (11) through (13) as applicable, and the recordkeeping as required by 60.5420b(c)(5) and (8) through (13), as applicable.
OBSERVATION: The initial NSPS OOOOb Annual Report for dry seal centrifugal compressors C-203 and C-204 at Walker Hollow are required to be submitted within 8,760 hours of operation after May 7, 2024, or on or before 8,760 hours of operation after startup, whichever date is later. At the time of this inspection report compressors the centrifugal compressors have not reached 8,760 hours of operation.
Pursuant to 60.5420b(c)(4), the source keeps records of the cumulative hours of operation since startup or previous volumetric flow rate measurement, the method used and results of volumetric flow rate, records for flow meters, and records of deviations on each centrifugal compressor. According to the information provided by the source, no deviations have occurred on centrifugal compressors, to date.
D. GHG and VOC Standards for the Collection of Fugitive Emissions Components [40 CFR 60.5397b]
The Permittee shall reduce GHG (in the form of a limitation on emissions of methane), and VOC emissions by complying with the requirements in 60.5397b.
OBSERVATION: Per 60.5397b(b)-(d), an emissions monitoring plan is required; a copy of the emissions monitoring plan for OOOOa, which includes equipment subject to OOOOb, was provided to
20
EPA upon request and appears to include the required elements. The emissions monitoring plan states that a site map and observation path for each site subject to NSPS OOOOa will be created as required by 60.5397b(d)(1)-(2). 60.5397b(f)(2) requires the initial monitoring survey of the collection of fugitive emissions components at a compressor station to be conducted within 90 days of the startup of production or by June 6, 2024, whichever is later. The Facility contact has indicated that "The next OOOOb compliance report will be submitted covering operations during 2024", as of November 18, 2024, the EPA has not received a report of the initial monitoring survey.
Per 60.5397a(g)(1)(iv), a monitoring survey must be conducted at bimonthly after the initial survey. The Facility contact has indicated that "The next OOOOb compliance report will be submitted covering operations during 2024", as of November 18, 2024, the EPA has not received a report of continuous monitoring surveys being performed.
E. Initial Compliance Requirements for Centrifugal Compressor and Fugitive Emission Components Affected Facilities [40 CFR 60.5410b(d) and (k)]
1. The Permittee shall achieve initial compliance for each reciprocating compressor affected facility by complying with 60.5410b(d)(6) - (8).
OBSERVATION: Pursuant to 60.5410b(d)(6) - (8), initial compliance for the centrifugal compressors shall be demonstrated by tracking the number of hours of operation, volumetric flow rates, maintaining records, and submitting the Initial NSPS OOOOb Annual Report. See Section IV.C, above, for a discussion of these items.
2. The Permittee shall achieve initial compliance with the fugitive emission standards for each collection of fugitive emissions components by complying with 60.5410b(k)(1) - (5).
OBSERVATION: Pursuant to 60.5410b(k)(1) - (5), initial compliance for the collection of fugitive emissions components shall be demonstrated by developing a fugitive emissions monitoring plan, conducting an initial monitoring survey and making repairs as required by 60.5397b(h), maintaining records, and submitting the Initial NSPS OOOOb Annual Report. See Section IV.D, above, for a discussion of these items.
F. Continuous Compliance Requirements for Reciprocating Compressor and Fugitive Emissions Components Affected Facilities [40 CFR 60.5415b]
1. The Permittee shall demonstrate continuous compliance for the reciprocating compressor according to 60.5415a(g).
OBSERVATION: As discussed in Section IV.C, above, the source continuously monitors the number of hours of operation for the centrifugal compressors.
2. The Permittee shall demonstrate continuous compliance for each collection of fugitive emission components according to 60.5415b(l).
OBSERVATION: As discussed in Section IV.D, above, the source has not yet submitted the biweekly monitoring surveys and has indicated that they would be included in the 2024 annual report.
G. Reporting and Recordkeeping Requirements [40 CFR 60.5420b(b) and (c)]
21
1. The Permittee shall submit annual reports for centrifugal compressors affected facilities containing the information specified in 60.5420b(b)(5)(vi).
2. The Permittee shall maintain all records identified as specified in 60.7(f) and in 60.5420b(c)(4) and (9).
OBSERVATION: Subpart OOOOb went into effect in 2024 thus no annual reports have yet been submitted.
VII. National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities - 40 CFR Part 63, Subpart HH (MACT HH)
A. Applicability [40 CFR 63.760(a)-(d)]
40 CFR part 63, subpart HH (MACT HH) applies to emissions units SK-101, SK-121, and SK-201. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart HH for affected sources located at a major source of HAP.
OBSERVATION: The glycol dehydrators (SK-101, SK-121, and SK-201) meets the definition of large glycol dehydration units at 40 C.F.R. 63.761. Not considering controls, Walker Hollow is a major source of HAP under MACT HH; therefore, the major source requirements apply.
B. General Standards [40 CFR part 63, subpart A and 63.764]
1. The General Provisions at 40 CFR part 63, subpart A apply as specified in Table 2 of 40 CFR part 63, subpart HH. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart A.
2. Except as specified in 63.764(e), the Permittee shall comply with the following requirements for the glycol dehydration unit:
(a) The control requirements for glycol dehydration unit process vents specified in 63.765;
(b) The monitoring requirements specified in 63.773; and
(c) The recordkeeping and reporting requirements specified in 63.774 and 63.775. 3. At all times, the Permittee shall operate and maintain any glycol dehydration unit, including associated
air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the EPA which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the unit.
OBSERVATION: A John Zink low-pressure flare (FL-101) is used as the control device for the glycol dehydrators (SK-101 and SK-121). A Zeeco Air-Assisted Flare (FL-201) is used as backup to the VRU. The pilot light in the flare is monitored by a thermocouple and the data is recorded by a SCADA system.
C. Glycol Dehydration Unit Process Vent Standards [40 CFR 63.765 and 63.771]
The Permittee shall comply with the control equipment requirements as follows:
22
1. Except as specified in 63.765(c), the Permittee shall comply with the applicable requirements for controlling air emissions specified in 63.765(b);
2. For each closed-vent system, the Permittee shall comply with the closed-vent system requirements specified in 63.771(c);
3. For each control device, the Permittee shall comply with the applicable control device requirements specified in 63.771(d) or 63.771(f); and
4. For each process modification made to comply with the glycol dehydration unit process vent standards at 63.765(c)(2), the Permittee shall comply with the process modification standards specified in 63.771(e).
OBSERVATION: The dehydration units at Walker Hollow Compressor Station are considered large dehydration units, so the requirements in 40 CFR 63.771(d) apply. Dehydration units SK-101 and SK121 use control devices rather than process modifications to comply with the MACT HH glycol dehydration units process vent standards, so they comply with the standards at 40 CFR 63.765(b) rather than 63.765(c)(2). Dehydration unit SK-201 uses a vapor recovery unit and thus complies with 63.765(c)(1).
As specified at 63.771(c), emissions from the dehydration units SK-101 and SK-121 are routed via a closed vent system (CVS) to flare FL-101. Dehydration unit SK-201 is controlled by a VRU and backup flare FL-201. According to information provided by the source during the inspection, the CVS contains a bypass device. Pursuant to 63.771(c)(3)(i), the source must either (A) install, calibrate, maintain, and operate a flow indicator at the inlet to the bypass device that is capable of taking periodic readings and sounding an alarm when the bypass device is open or (B) secure the bypass device valve in the nondiverting position using a car-seal or a lock-and-key type configuration. According to the information provided by the source, the facility complies with the requirements at 63.771(c)(3)(i)(A). The SCADA system continuously tracks the time during which the flare pilot is out and automatically shuts down production in the event the flare turning off.
Per 40 CFR 63.771(d)(1)(iii), the flares must be designed and operated in accordance with the requirements of 40 CFR 63.11(b). The presence of a pilot light in the flare is continuously monitored via thermocouple. No visible emissions from the flare were observed during the inspection. Per 40 CFR 63.771(e)(1)(i) and (e)(2), no performance test on the flare is required.
D. Test Methods, Compliance Procedures and Compliance Determination Requirements [40 CFR 63.772]
The Permittee shall determine compliance with the requirements of 40 CFR part 63, subpart HH using the applicable test methods and compliance procedures specified in 63.772.
OBSERVATION: Per 63.772(e)(1)(i), a flare does not require performance testing if it is designed and operated in accordance with 63.11(b). Pursuant to 63.772(e)(2), a compliance determination shall be conducted using Method 22 of 40 C.F.R. Part 60, Appendix A, for visible emissions. Method 22 readings were included in the Notification of Compliance Status Report as required by 63.772(e)(2).
E. Inspection and Monitoring Requirements [40 CFR 63.773]
23
1. For each closed-vent system or cover required for the Permittee to comply with 40 CFR part 63, subpart HH, the Permittee shall comply with the inspection and monitoring requirements specified in 63.773(c).
OBSERVATION: The inspection and monitoring requirements specified in 40 CFR 63.773(c) require an initial inspection according to the procedures of Method 21, 40 C.F.R. Part 60, Appendix A to demonstrate that the closed-vent system operates with no detectable emissions. According to information provided by the source, the CVS at Walker Hollow is considered permanently or semi-permanently sealed; therefore, the CVS inspection and monitoring requirements at 63.773(c)(2)(i) apply. Pursuant to 63.773(c)(2)(i)(A), an initial Method 21 inspection is required; the initial inspection was conducted on November 8, 2016, and results were included in the Notification of Compliance Status Report, as required by 63.772(c)(2)(i)(A). Annual visual inspections for defects on the closed-vent system are also required pursuant to 63.773(c)(2)(i)(B). According to the information provided by the source, annual visual inspections have been conducted at Walker Hollow since the dehydration unit restarted operation in 2022. No cover is installed to comply with 63.764; therefore, the inspections required by 63.773(c)(2)(iii) do not apply.
2. For each control device required for the Permittee to comply with 40 CFR part 63, subpart HH, the Permittee shall comply with the inspection and monitoring requirements as specified in 63.773(b) or 63.773(d).
OBSERVATION: The control device at the Walker Hollow Compressor Station that is used to comply with 40 CFR Part 63, Subpart HH was not tested under 40 CFR 63.772(h); therefore, the inspection and monitoring requirements at 40 CFR 63.773(b) do not apply. Per the requirements of 40 CFR 63.773(d), the continuous ignition of the pilot light in the flare is continuously monitored via thermocouple.
SK-201 uses a vapor recovery unit and complies with the requirements outlined in 63.771(d). F. Recordkeeping Requirements [40 CFR 63.774]
1. The recordkeeping provisions of 40 CFR part 63, subpart A, that apply and those that do not apply to the Permittee are listed in Table 2 of 40 CFR part 63, subpart HH.
2. The Permittee shall maintain the records specified in 63.774(b), (c), (d), (e), (g) and (h).
3. Except as specified in 63.774(c), 63.774(d) and 63.774(f), the Permittee shall maintain the records specified in 63.774(b).
4. If compliance with the benzene emission limit specified in 63.765(b)(1)(ii) is elected, the Permittee shall document, to the Administrator's satisfaction, the items in 63.774(c).
5. For glycol dehydration units operating at the source that meet the exemption criteria in 63.764(e)(1)(i) or 63.764(e)(1)(ii), the Permittee shall maintain records as specified in 63.774(d).
6. The Permittee shall keep records of the requirements of 63.774(e) when using a flare to comply with 63.771(d).
7. The Permittee shall maintain records, pursuant to 63.774(g), of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment. The Permittee shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with 63.764(j), including corrective actions to restore 24
malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation.
8. The Permittee shall keep records of the requirements of 63.774(h) when using a control device whose model is tested under 63.772(h) to comply with 63.771(d), (e)(3)(ii) and (f)(1).
9. The Permittee shall keep records, pursuant to 63.774(i), of the date the semi-annual maintenance inspection required under 63.773(b) is performed when using a control device whose model was tested under 63.772(h).
OBSERVATION: The facility logs and maintains records through a SCADA system, and records are stored at a central location.
G. Reporting Requirements [40 CFR 63.775]
1. The reporting provisions of subpart A of this part, that apply and those that do not apply to the Permittee are listed in Table 2 of this subpart.
2. The Permittee shall submit the information specified in 63.775(b).
3. The Permittee shall submit Notification of Compliance Status Reports as specified in 63.775(d).
4. The Permittee shall submit Periodic Reports as specified in 63.775(e).
5. The Permittee shall submit notifications of process changes as specified in 63.775(f).
6. The Permittee shall comply with any applicable electronic reporting provisions specified at 63.775(g).
OBSERVATION: The Notification of Compliance Status Report was submitted on March 29, 2017, which is within 180 days of the compliance date, as required by 63.775(d). The report appeared to include all required information.
Per 63.775(e)(1), the first semi-annual periodic report shall be submitted no later than 240 days after the date the Notification of Compliance Status Report is due and shall cover the 6-month period beginning on the date the Notification of Compliance Status is due. The source has submitted a semiannual MACT HH reports for the Walker Hollow Compressor Station since it began operating 2022. Flare information required pursuant to 63.775(e)(2)(x) appears to have been submitted. A certification of truth, accuracy, and completeness was submitted in the reports as required by 63.775(e)(2)(xiv).
During non-operation (i.e. prior to 2022) of the Walker Hollow Compressor Station, the EPA has agreed to accept a copy of the Annual Title V Form FEE in lieu of the semi-annual periodic MACT reports1; therefore, no additional MACT HH semi-annual reports have been received for the Walker Hollow Compressor Station since the initial report.
VIII. Facility-Wide Requirements [40 CFR 71.6(a)(1)]
Conditions in this section of this permit apply to all emissions units located at the source, including any units not specifically listed in Table 2 of the Facility Emission Points section of this permit.
1 This was approved in an email from Alexis North/EPA to Thomas Gibbons/Andeavor on June 6, 2018.
25
B. Reporting Requirements [40 CFR 71.6(a)(3)(iii)]
1. The Permittee shall submit to the EPA all reports of any required monitoring under this permit semiannually. The first report shall cover the period from the effective date of this permit through December 31, 2018. Thereafter, the report shall be submitted semi-annually, by April 1st and October 1st of each year. The report due on April 1st shall cover the 6-month period ending on the last day of December before the report is due. The report due on October 1st shall cover the 6-month period ending on the last day of June before the report is due. All instances of deviations from permit requirements shall be clearly identified in such reports. All required reports shall be certified by a responsible official consistent with the Submissions section of this permit.
OBSERVATION: The semi-annual (SIXMON) reports for the Walker Hollow Compressor Station were submitted for each reporting period from 2019 through 2024.
2. "Deviation" means any situation in which an emissions unit fails to meet a permit term or condition. A deviation is not always a violation. A deviation can be determined by observation or through review of data obtained from any testing, monitoring, or recordkeeping established in accordance with 71.6(a)(3)(i) and (a)(3)(ii). For a situation lasting more than 24 hours which constitutes a deviation, each 24-hour period is considered a separate deviation. Included in the meaning of deviation are any of the following:
(a) A situation where emissions exceed an emission limitation or standard;
(b) A situation where process or emissions control device parameter values indicate that an emission limitation or standard has not been met; or
(c) A situation in which observations or data collected demonstrate noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit.
3. The Permittee shall promptly report to the EPA deviations from permit requirements, including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows:
(a) Any definition of "prompt" or a specific time frame for reporting deviations provided in an underlying applicable requirement as identified in this permit.
(b) Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a HAP or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence. (ii) For emissions of any regulated air pollutant, excluding a HAP or a toxic air pollutant that continues for more than two (2) hours in excess of permit requirements, the report shall be made within 48 hours. (iii) For all other deviations from permit requirements, the report shall be submitted with the semi-annual monitoring report.
(c) If any of the conditions in (i) or (ii) of paragraph (b) above are met, the Permittee shall notify the EPA by telephone (1-800-227-6312), facsimile (303-312-6409), or by email to
26
r8airreportenforcement@epa.gov based on the timetables listed above. [Notification shall specify that this notification is a deviation report for a Part 71 permit]. A written notice, certified consistent with the Submissions section of this permit shall be submitted within ten working days of the occurrence. All deviations reported under this section shall also be identified in the 6month report required under Condition 1 in this section of this permit.
OBSERVATION: No deviations were reported in the Title V Annual Compliance Certification (TVACC) or SIXMON Reports received between 2019 and 2024.
IX. General Provisions
A. Annual Fee Payment [40 CFR 71.9]
1. The Permittee shall pay an annual permit fee in accordance with the procedures outlined below.
2. The Permittee shall pay the annual permit fee each year no later than April 1st. The fee shall cover the previous calendar year.
OBSERVATION: The source submitted the required FEE Calculation Worksheets to EPA for years it was operating including the 2022 through 2024 reporting years.
B. Annual Emissions Inventory [40 CFR 71.9(h)(1) and (2)]
1. The Permittee shall submit an annual emissions report of its actual emissions for both criteria pollutants and regulated HAPs for this source for the preceding calendar year for fee assessment purposes. The annual emissions report shall be certified by a responsible official and shall be submitted each year to the EPA by April 1st.
OBSERVATION: Annual emissions reports for the Walker Hollow Compressor Station were submitted for the 2019 through 2023 reporting years.
C. Compliance Requirements [40 CFR 71.6(a)(6), Section 113(a) and 113(e)(1) of the CAA, and 40 CFR 51.212, 52.12, 52.33, 60.11(g), 61.12]
1. Compliance Certifications [40 CFR 71.6(c)(5)]
(a) The Permittee shall submit to the EPA a certification of compliance with permit terms and conditions, including emission limitations, standards, or work practices annually by April 1st, and shall cover the same 12-month period as the two consecutive semi-annual monitoring reports.
OBSERVATION: The source submitted all Title V Annual Compliance Certification (TVACC) for the Walker Hollow Compressor Station for 2019 through 2023 reporting periods.
O. Off Permit Changes [40 CFR 71.6(a)(12) and 71.6(a)(3)(ii)]
The Permittee is allowed to make certain changes without a permit revision, provided that the following requirements are met, and that all records required by this section are kept for a period of 5 years.
OBSERVATION: Per the source, no off-permit changes have been conducted at the Walker Hollow Compressor Station.
27
28
APPENDIX A: Site Overview
TK-101, TK-121, TK-201, TK-221
C-103 C-104
SK-121
SK-101
GT-101
FL-101
FL-201
GT-121 GT-201 GT-221
C-203 C-204
SK-201
Figure 1: Walker Hollow Compressor Station Aerial View
29
Appendix B Photo and Video Log File Name
Mov_3576
Location SK-101
Description Emissions from the manway at the bottom of the tower.
30