Document ky3makv0wdayxbpy7xMeyDD0

Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 08/03/2023 Air CAA, Texas SIP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: Enlink Midstream Lake Arlington Compressor Station 6900 Rosedale St. Fort Worth, Texas, 76102 415 Private Road 3502 Bridgeport, Texas, 76426 Tarrant County 469-308-6204 Daria Underwood Environmental Engineer Daria.underwood@enlink.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: 110041481973 PBR 106.352(l), RN105227763 TX0000004843901700 211111 SIC: N/A Personnel participating in inspection: Benjamin Donaldson EPA Region 6 Aimee Boss EPA Region 6 Uma Lad EPA Region 6 Daria Underwood Enlink Midstream Shane Tribe Enlink Midstream Travis Burke Enlink Midstream Cherry Purvis Enlink Midstream Robert Carey Enlink Midstream Environmental Engineer Physical Scientist Physical Scientist Environmental Engineer Environmental Manager Emissions Manager Operations Foreman Operator EPA Lead Inspector Signature/Date Benjamin Donaldson Benjamin Donaldson Digitally signed by Benjamin Donaldson Date: 2023.12.01 12:05:21 -06'00' Date Supervisor Signature/Date JAMES LEATHERS Date: 2023.12.01 12:15:26 -06'00' Digitally signed by JAMES LEATHERS James Leathers Date 6ENFORM-019-R8.2 (02/12/2020) 1 Enlink Midstream / Lake Arlington Compressor Station Inspection Date 08/03/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTION I, Benjamin Donaldson, and the other EPA Region 6 inspectors Aimee Boss, and Uma Lad ("We", "Us") arrived at Enlink Midstream's ("Enlink") Lake Arlington Compressor Station (the "Facility", the "Site", or the "Terminal") at 8:18 AM on August 3, 2023 for an announced inspection (see photo DSCN0676.JPG and DSCN0677.JPG in the Photograph log, Appendix 1). We met with Enlink representatives, Daria Underwood, Environmental Engineer; Shane Tribe, Environmental Manager; Travis Burke, Emissions Manager; Cherry Purvis, Operation Forman; and Robert Carey, Pipeline Operator. Aimee Boss presented her credentials to Shane Tribe and Daria Underwood and informed them that this was an EPA inspection to determine compliance with the Facility's permit and the Clean Air Act ("CAA"). The scope of the inspection is a partial compliance evaluation (PCE) and includes evaluation of the compliance with permits, the Texas State Implementation Plan (SIP), and federal CAA regulations. The Texas Commission on Environmental Quality (TCEQ) was notified and invited but did not participate in the inspection. FACILITY DESCRIPTION Enlink owns and operates the Facility which is a natural gas compressor station. The site operates with personnel on-site approximately 2-3 hours a day. Natural gas is received through an inlet pipeline from Diversified Energy Company LP and Sage Natural Resources. The gas is then moved through a knockout tank to remove moisture. The moisture removed is stored on-site in four process water storage tanks (TANK-1, TANK-2, TANK-3, TANK-4) and is removed every Thursday via truck. After the knockout process, the gas is moved through one of two compressors (COMP-8 and COMP-9). The compressors run in parallel and are identical three-stage, 7,000 horsepower, electric start natural gas compressors. After compression, the gas is moved through glycol dehydration units (GS-02 and GS-03) to remove any remaining moisture. Each dehydration unit is equipped with a condenser, which captures liquid that is then sent to the process water storage tanks. The gas is then transported off-site via pipeline. Dehydrator flash vessel emissions are routed to the reboilers (H-02 and H-03) for fuel to heat the glycol. Section II - OBSERVATIONS We participated in a safety briefing and received an overview of the site from Mr. Burke. He informed us that three gas compressors (COMP-2, COMP-3, and COMP-4) were recently taken out of service and removed from the Facility. Mr. Burke also informed us that another compressor (COMP-7) and the Lift Compressor (COMP-11) had also been decommissioned earlier that year but were still on site. After the site overview, we began the field portion of the inspection and utilized a FLIR Systems GF320 Optical Gas Imaging Camera (OGIC) for observations. We walked to the inlet pipeline where it connects to the knockout tank. From the knockout tank, we followed the process water line to the process water tanks. Mr. Carey informed us the tanks share a common header and vent to atmosphere. We observed 2 Enlink Midstream / Lake Arlington Compressor Station Inspection Date 08/03/2023 the process water tanks' pressure relief valves (PRVs) with the OGIC and observed emissions from the TANK-3 PRV, (see MOV_0038 and MOV_0039 in Video log, Appendix 2) and TANK-4 PRV, (see MOV_0040 in Appendix 2, AOC 1). Mr. Burke explained that the tanks had been emptied before EPA's arrival on-site and the emissions were associated with flashing at the time of the inspection. We continued from the process water tanks to a compressor (COMP-9). We observed emissions from COMP-9 near the pocket valve with the OGIC (see MOV_0041 in Appendix 2, AOC 2). We then moved to another compressor (COMP-8). We observed emissions from COMP-8 from the compression chamber with the OGIC (see MOV-0042, Appendix 2, AOC 3). After the compressors, we went to the glycol dehydration units (GS-02 and GS-03). Mr. Carey explained the dehydration units work in parallel and are identical. He showed us that each dehydration unit has its own reboiler and that the reboilers use gas from the process for heat. Each component of this system was observed with the OGIC. Emissions were observed from GS-02 at the reboiler stack (see MOV_0043 in Appendix 2, AOC 4) and from GS-03 at the reboiler stack (see MOV_0044 in Appendix 2, AOC 5). From the dehydration units, we moved on to view the slop oil tanks. We climbed to the top via a common walkway and used the OGIC for observation and no emissions were observed. After the slop oil tanks, we viewed the coalescers and finished our site tour at 9:35 AM. Following the site tour, Mr. Carey explained some of the maintenance procedures. Blowdowns are done at the Facility for maintenance purposes based on a preventative maintenance (PM) schedule. The PM schedule is based on the number of hours components are run. The Facility has a total site shutdown twice a year for emergency safety device testing but there are typically no upstream or downstream reasons for site shutdowns. Section III - AREAS OF CONCERN 1) Emissions observed from the PRV's on Tank-3 and Tank-4 with the OGIC. During the closing conference, Mr. Burke stated that tanks were off-loaded prior to the on-site observation and the emissions were associated with flashing. 2) Emissions observed at Compressor-9 near the pocket valve with the OGIC. Compressor-9 is not listed in the Facility emissions summary in the Facility's permit. 3) Emissions observed at Compressor-8 near the compression chamber observed with the OGIC. Compressor-8 is not listed in the Facility emissions summary in the Facility's permit. 4) Emissions observed at the reboiler stack for the Glycol Dehydrator-02 with the OGIC. During the closing conference, Mr. Burke noted that possible emissions observed could be due to heat. 5) Emissions observed at the reboiler stack for the Glycol Dehydrator-03 with the OGIC. During the closing conference, Mr. Burke noted that possible emissions observed could be due to heat. 3 Enlink Midstream / Lake Arlington Compressor Station Inspection Date 08/03/2023 EPA Region 6 inspectors Benjamin Donaldson, Aimee Boss, and Uma Lad conducted a closing conference for the inspection at Enlink Midstream's Lake Arlington Compressor Station at 9:48 AM on August 3, 2023. During the closing conference, the inspectors reviewed the five Areas of Concern noted during the inspection. Section IV - FOLLOW UP On August 9, 2023, I requested follow-up information regarding when the compressors were taken out of service. On August 18, 2023, the Facility provided a response via email. The Facility clarified that COMP-2, COMP-3, and COMP-4 were taken out of service on May 17, 2023, June 20, 2023, and June 29, 2023 respectively. Their removal from the site was also completed on July 14, 2023. COMP-11 was also shown to be taken out of service on June 26, 2023. Section V - LIST OF APPENDICES Appendix 1 - Photograph Log - 2 Photos 08/03/23 Appendix 2 - Video Log - 6 FLIR videos taken 08/03/23 4 Enlink Midstream / Lake Arlington Compressor Station Inspection Date 08/03/2023 Appendix 1 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Enlink Lake Arlington Compressor Station City: Ft. Worth County/Parish: Tarrant State: TX Photo File Name: DSCN0676.JPG Date of Photo: 08/03/2023 Time of Photo: 8:18 Photographer: Uma Lad Description: Sign at the Facility turn in with relevant information UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Enlink Lake Arlington Compressor Station City: Ft. Worth County/Parish: Tarrant State: TX Photo File Name: DSCN0677.JPG Date of Photo: 08/03/2023 Time of Photo: 8:19 Photographer: Uma Lad Description: Sign at the Facility gate entrance with relevant information Enlink Midstream / Lake Arlington Compressor Station Inspection Date 08/03/2023 Appendix 2 Video Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Location: Enlink Midstream / Lake Arlington Compressor Station City: Ft. Worth County/Parish: Tarrant State: TX Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0038.mp4 08/03/2023 8:41 am Uma Lad TANK-3 Appendix 2 Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0039.mp4 08/03/2023 8:44 am Uma Lad TANK-3 Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_0040.mp4 08/03/2023 8:46 am Uma Lad TANK-4 Video File Name: MOV_0041.mp4 Date of Video: Time of Video: Videographer: Description: 08/03/2023 8:56 am Uma Lad COMP-9 Page 1 of 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Location: Enlink Midstream / Lake Arlington Compressor Station City: Ft. Worth County/Parish: Tarrant State: TX Video File Name: MOV_0042.mp4 Date of Video: Time of Video: Videographer: Description: 08/03/2023 9:05 am Uma Lad COMP-8 Video File Name: MOV_0043.mp4 Date of Video: Time of Video: Videographer: Description: 08/03/2023 9:15 am Uma Lad GS-02 Video File Name: MOV_0044.mp4 Date of Video: Time of Video: Videographer: Description: 08/03/2023 9:17 am Uma Lad GS-03 Appendix 2 Page 2 of 2