Document np456xJJJwRK7Kzp5njNxbE78

Operated by MPLX1 Wonsits Valley Compressor Station Full Compliance Evaluation (FCE) On-Site Inspection Inspection Date: September 17, 2024 Inspection Report Date: October 8, 2024 EPA Representatives: Environmental Scientist, US EPA Region 8 , Environmental Scientist, US EPA Region 8 US EPA Region 8 , US EPA Region 8 Tribal Representatives: Company Representatives: Inspection Report Prepared By: Inspection Report Reviewed By: Last Inspection: Operating Status: Applicable Requirements: , Physical Scientist, US EPA Region 8 June 23, 2022 Operating Title V 40 CFR Part 60, Subpart JJJJ: Standards of Performance for New Stationary Sources (NSPS JJJJ) 40 CFR Part 63, Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (MACT ZZZZ) 40 CFR Part 63, Subpart HH: National Emissions Standards for Hazardous Pollutants from Oil and Natural Gas Production Facilities (MACT HH) 40 CFR Part 71: Federal Operating Permit Programs Consent Decree Case No. 2:08-CV-00167-TS-PMW Civil Action No. 2:23cv252 Permit Number: V-UO-000005-2018.03 Replaces Permit No.: V-UO-000005-2018.01B Issue Date: March 30, 2023 Effective Date: November 22, 2021 1 Wonsits Valley Compressor station is owned by Andeavor Field Services, LLC and operated by MPLX according to information in permit V-UO-000005-2018.01. 1 Expiration Date: September 16, 2025 Facility Information and Emission Unit Identification Parent Company Name: Mailing Address: Facility Contact: MPLX 1801 California Street, Suite 1200, Denver, Colorado 80202 , Environmental Engineer Facility Operator & Name: Facility Location: County, State: Reservation: Tribe: Responsible Official: SIC Code: AFS ID: Other CAA Permits: MPLX, LP Wonsits Valley Compressor Station (Wonsits) Latitude 40.140792, Longitude -109.494322 Uintah, Utah Uintah and Ouray Indian Reservation Ute Indian Tribe , Vice President, Mid-Continent Gathering and Processing 1311 Crude Petroleum and Natural Gas 49-047-00103 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); however, several requirements survive termination of the decree. (See Section V of this report.) The EPA issued a Notice of Violation (NOV) to MPLX LP on November 22, 2019, which included alleged violations of NSPS JJJJ, MACT HH and MACT ZZZZ at Wonsits Valley for: (1) Failure to conduct performance tests of a secondary control device, enclosed combustor C-2, during periods when the primary control device, flare FL-1 at a major source of HAPs, in violation of the MACT HH testing requirements for applicable control device requirements specified in 63.771(d) or 63.771(f), and the requirements for initial performance testing of enclosed combustion devices at 63.772(e). Additionally, Paragraph II.D.2. of the previous Title V operating permit, permit number V-UO-000005-2000.00, for the Wonsits Valley requires that each control device required to comply with MACT HH shall comply with the monitoring requirements as specified in 63.773(b) or 63.773(d). (2) Failure to continuously operate a control device during operation of a dehydrator at Wonsits Valley. (3) Failure to conduct performance tests after catalyst replacement on Engine C207, in violation of the MACT ZZZZ testing requirements at 40 C.F.R. 63.6640(b), the MACT ZZZZ emissions limitations and operating limitations at 40 C.F.R. 63.6600(b), and the requirements of Paragraphs III.C.2 and III.E.2 of the previous Title V permit for Wonsits Valley, V-UO-000005-2000.00; (4) Failure to timely submit MACT ZZZZ performance test results for Engines C202, C203, C204, C206 and C207, in violation of the reporting requirements at 63.7(g)(1); (5) Failure to timely submit NSPS JJJJ performance test results for Engines C202, C203, C204, C206 and C207, in violation of the reporting requirements at 40 C.F.R. 60.4245(d); and (6) Emitting VOC in excess of 1.0 g/hp-hr from Engine C207, in violation of the NSPS JJJJ emission limits set forth for Engine C207 as specified in 40 C.F.R. 60.4233(f)(4) and (e) and Paragraph 2 IV.C.1 of the previous Title V permit for Wonsits Valley, Permit Number V-UO-000005-2000.00. Additionally, failure to conduct a performance test on Engine C207 according to the requirements of 40 C.F.R. 60.4244(c) and 60.8(f) because the test was concluded after the first test run. MPLX entered into a Consent Decree with the United States (See Civil Action No. 2:23cv252, not attached) effective July 21, 2023, to resolve alleged violations of MACT ZZZZ at the Wonsits Valley Compressor Station. The Consent Decree includes alleged violations of both MACT ZZZZ and separate regulations at multiple compressor stations and gas plants. MPLX was ordered to pay civil penalties totaling $2,000,000 plus interest, as follows: (i) $1,558,100 to the United States; (ii) $325,200 to the State of North Dakota; (iii) $116,700 to the State of Wyoming. See Section V of this report for provisions of the Civil Action that were evaluated for compliance during the inspection. There are no additional finalized enforcement actions at the time of the inspection. Inspection Findings/Areas of Concern 1. combustion of emissions being routed to a control device. 2. Where possible, EPA advised MPLX to route emissions to a control device or vapor balance during maintenance. MPLX was cleaning out the dehydration unit condensable tank and EPA viewed emissions via FLIR. There are no requirements to control emissions during maintenance in MACT HH but where possible MPLX should minimize emissions. Compliance Assistance , is being provided to MPLX upon finalization. Description of Operations Wonsits Valley gathers natural gas, natural gas condensate and produced water from surrounding well sites via a gathering pipeline system. The comingled stream enters the station and is routed to a slug catcher where the liquids and natural gas are separated. From the slug catcher, the liquids are routed to a 3-phase separator, where the natural gas, condensate and produced water are separated. The condensate is routed to the station discharge and then off site to a gas plant. The produced water is temporarily stored in the slop tank (emissions unit T-1 in Table 2 below) and the emissions are controlled with the combustor unit (emissions unit C-1 in Table 2 below). Liquids from T-1 are gravity fed offsite. The natural gas exits the slug catcher and 3-phase separator as mentioned in the first paragraph, where it is routed to an inlet scrubber; condensate and produced water that are removed during this process are also routed to T-1. The natural gas is then compressed from field pressure to approximately 1,200 pounds per square inch gauge (psig) from five reciprocating internal combustion engines (RICE) that are also located onsite. The compressed natural gas enters the dehydration unit, emissions unit D-1, and is bubbled up through lean triethylene glycol (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. The pipeline quality natural gas then exits the contactor, is metered and then routed off site. Natural gas used to fuel equipment at Wonsits Valley is pulled from the discharge after the dehydrator where it is filtered and separated. The rich TEG exits the contactor, is depressurized in a TEG flash tank, and is regenerated using heat in a vessel known as a reboiler (emissions unit R-1 in Table 2 below). The rich TEG is heated in R-1 to a set temperature The description of operations provided here is a modified excerpt from the process description provided by MPLX in its September 28, 2022 Title V permit V-UO-000005-2018.03. 3 C207a 99 754 (East) 651 (West) 1.8 (East) 2.0 (West) 2.1 (East) 1.4 (West) a Unit C207 is a dual-stack engine. East = East Stack (also referred to as the Left Bank); West = West Stack (also referred to as the Right Bank) EPA and MPLX representative met for a closing conference. A confidential business information (CBI) warning was presented to MPLX representatives, and no CBI was claimed. During the on-site closing conference, EPA inspectors discussed emissions from the truck loadout from maintenance and cleaning of the dehydration unit. EPA inspectors also discussed a potential antifreeze odor near C-206. In a response provided September 24, 2024, MPLX representatives stated that a mechanic inspected the engine and found that there was a very slow drip from the jacket water pump and that C- t has been scheduled to be repaired. EPA staff departed the facility at 1:53 PM. An email to request relevant compliance-related information and records was sent to MPLX representatives prior to the onsite inspection and MPLX provided the requested information to EPA via email on September 24, 2024 and September 30, 2024. 5 Table 23: Potential to Emit in Tons Per Year (tpy) MPLX Wonsits Valley Compressor Station Table 2 Potential-to-Emit Without Legally and Practicably Enforceable Controls Regulated Air Pollutants (tpy) NOX* CO* VOC* PM* SO2* CH2O * Total HAPs * CO2* CH4* (as CO2e) C202 32.89 82.22 35.72 1.12 0.07 8.55 10.59 13,139 6.20 N2O* (as CO2e) 7.39 CO2e* 13,153 C203 32.89 82.22 35.72 1.12 0.07 8.55 10.59 13,139 6.20 7.39 13,152 C204 32.89 82.22 35.72 1.12 0.07 8.55 10.59 13,139 6.20 7.39 13,152 C206 38.91 65.85 21.91 1.00 0.06 5.29 7.11 11,713 5.52 65.83 11,784 C207 43.97 109.94 46.87 1.50 0.09 11.43 14.16 17,498 8.25 19.83 17,516 D-1 - - 393.23 - - - 213.43 - - - - R-1 0.39 0.33 0.02 0.03 0.00 - 0.01 511.97 0.24 0.29 513 T-1 - - 13.12 - - - 0.55 - - - - T-2 - - 1.12 - - - 0.07 - - - T-9 EL - - 4.79 - - - 0.38 - - - - FL-1 0.02 0.02 0.00 0.00 0.00 - - - - - - C-1 0.01 0.005 - - - - - - - - - C-2 0.05 0.03 0.00 0.00 0.00 - 0.00 - - - Removed LO - - 1.57 - - - - - - - - ES - - 0.22 - - - 0.01 - - - - CB - - 10.05 - - - 0.49 - - - - ESD - - 0.067 - - - 0.003 - - - - PG - - 10.17 - - - 0.01 - - - - TOTAL 182.0 422.84 610.30 5.89 0.36 42.37 267.99 69,139.97 32.61 2 108.12 69,270 *NOX = nitrogen oxide; CO = carbon monoxide; VOC = volatile organic compound; PM = particulate matter; SO2 = sulfur dioxide; CH2O = formaldehyde; HAP = hazardous air pollutant; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = equivalent CO2. Table 3 Potential-to-Emit With Legally and Practicably Enforceable Controls Regulated Air Pollutants (tpy) NOX CO VOC PM SO2 CH2O Total CO2 HAPs C202 C203 C204 C206 C207 D-1 32.9 32.9 17.9 a 1.1 0.1 1.64 2.7 13,139 32.9 32.9 17.9 a 1.1 0.1 1.64 2.7 13,139 32.9 32.9 17.9 a 1.1 0.1 1.64 2.7 13,139 38.9 29.9 11.0 a 1.0 0.1 2.69 3.6 11,713 44.0 44.0 23.4b 1.5 0.1 2.20 3.6 17,498 - - 15.3 c - - - 6.12 - CH4 (as CO2e) 6.20 6.20 6.20 5.52 8.25 - N2O (as CO2e) 7.39 7.39 7.39 65.83 9.83 - CO2e 13,153 13,153 13,153 11,784 17,516 - 3 Note: C-2 has been removed from the facility in April 2022. It remains in this table because it operated during the time between the previous inspection which was on March 12, 2019. 7 Regulated Air Pollutants (tpy) R-1 0.39 0.33 0.02 0.03 0.00 - 0.01 511.97 0.24 0.29 513 T-1 - - 0.7 - - - 0.03 - T-2 - - - - - - - T-9 EL - - 4.8 - - - 0.4 - - - - - - - - - - FL-1 0.7 0.02 - - - - - - - - - C-1 0.4 0.1 - - - - - - C-2 0.05 0.03 0.00 0.00 0.00 0.00 Removed LO - - 1.57 - - - - - - - - - - - ES - - 0.22 - - - 0.01 0.05 32.04 - 32 CB - - 10.0 - - - 0.5 - - - - ESD - - 0.07 - - - 0.003 0.02 9.61 - 10 GP - - 10.57 - - - 0.51 2.37 1,515.69 - 1,518 PG - - 1.26 - - - 0.06 0.28 180.44 - 181 TOTAL 183.14 173.08 132.61 5.83 0.5 9.81 22.94 69,143 1770.39 98.12 71,013 a. Based on the enforceable emission limit of 1.0 g/hp-hr limit in the Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ). b. Based on the enforceable emission limit of 0.7 g/hp-hr limit in NSPS JJJJ. c. Based on the enforceable requirement of a 95% reduction of VOC emissions in National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities. 8 Permit Number V-UO-000005-2018.01 Requirements and Compliance Status Inspector notes discussing compliance status will follow each relevant permit requirement in bold blue font. A. Facility Emission Points Table 4 - Emission Units and Emission Generator Activities Unit I.D. C202 C203 C204 Description Caterpillar G3612LE Compressor Engine; 3,406 hp*, 4SLB* RICE*, Natural Gas-Fired Serial No. 1YG00023 Installed: 9/2007 Manufactured: 10/21/2001 Reconstructed: 9/2007 Serial No. 1YG00022 Installed: 9/2007 Manufactured: 10/10/1991 Reconstructed:9/2007 Serial No. 1YG00034 Installed: 9/2007 Manufactured: 5/12/1993 Reconstructed: 9/2007 EPA inspectors noted the serial numbers and engine information during the onsite inspection. C202 was recorded with a serial number of 1YG00143 and a mfg date of May 1998. MPLX confirmed a like kind replacement submitted in April 2023 during a phone call 10/8/2024 and subsequent email. C203 was recorded with a serial number of 1YG00023 and a mfg date was unreadable. This was originally C202 but during the like kind replacement for C202, this engine replaced C203 which was confirmed by MPLX during a phone call 10/8/2024 and subsequent email. C204 was recorded with a serial number of 1YG00142 and a mfg date of May 1998. A like kind replacement occurred December 2022, which was confirmed by MPLX during a phone call 10/8/2024 and subsequent email. Control Equipment Selective Catalytic Oxidation C206 C207 Waukesha 12V-AT27GL Compressor Engine; 3,100 hp, 4SLB RICE, Natural Gas-Fired Serial No. C-13271/2 Installed: 3/2001 Manufactured: 12/7/2000 Reconstructed: 6/2007 EPA inspectors confirmed the serial numbers and engine information matched C206 as permitted during the onsite inspection. Caterpillar G3616LE Compressor Engine; 4,554 hp, 4SLB RICE, Natural Gas-Fired Serial No. BLB00215 Installed: 6/2008 Manufactured: 12/5/1993 Reconstructed: 1/2014 EPA inspectors confirmed the serial numbers and engine information matched C206 as permitted during the onsite inspection. Selective Catalytic Oxidation Selective Catalytic Oxidation 9 1. The Facility is subject to the requirements of 40 CFR part 60, subpart A General Provisions as specified in Table 3 of Subpart JJJJ. 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 60.19: Branch Chief, Air and Toxics Enforcement Branch, 8ENF-AT Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 8 1595 Wynkoop Street Denver, Colorado 80202-1129 Reports may be submitted on electronic media where applicable through the Compliance and Emissions Reporting Data Interface (CEDRI). B. Emission Standards [40 CFR 60.4233 (f)(4) and Table 1, 60.4234] 1. The Permittee shall comply with the emissions standards for non-emergency, spark ignition (SI) internal combustion engines (ICE) greater than 1,350 hp that are modified or reconstructed after June 12, 2006 for C202, C203, C204, C206 and C207 as specified in 60.4233(f)(4) and Table 1 to Subpart JJJJ. 2. The Permittee must operate and maintain the stationary SI ICE subject to the emission standards as required in 60.4233 over the entire life of the engine as specified in 60.4234. OBSERVATION: Pursuant to 60.4233(f)(4) and NSPS JJJJ Table 1, engines C202, C203, C204, C206, and C207 utilize oxidation catalysts for emissions control in order to meet the following emission standards for non-emergency, natural gas SI engines greater than 500 hp: Engines C202, C203, C204, and C206 (manufacture date on or after July 1, 2007) NOx = 2.0 g/hp-hr CO = 4.0 g/hp-hr VOC = 1.0 g/hp-hr Engine C207 (manufacture date on or after July 1, 2010) NOx = 1.0 g/hp-hr CO = 2.0 g/hp-hr VOC = 0.7 g/hp-hr Performance tests results since the last inspection indicates compliance with the NSPS JJJJ emission standards. See Table 6 below. C. Compliance Requirements [40 CFR 60.4243 (c)] The Permittee, as the owner and operator of stationary SI ICE that must comply with the emission standards specified in Section II.C. of this permit, shall demonstrate compliance according to one of the methods specified in paragraphs 1 or 2 of this section as applicable: 1. Purchasing an engine certified according to the procedures specified in Subpart JJJJ for the same model year and demonstrating compliance according to one of the methods specified in paragraphs 1. (a) or (b) of this section: (a) If the Permittee operates and maintains the certified stationary SI ICE and control device 12 according to the emission-related written instructions, the Permittee shall keep records of conducted maintenance to demonstrate compliance, but no performance testing is required. The Permittee shall also meet requirements as specified in 40 CFR 1068 subparts A through D, as applicable. If the Permittee adjusts engine settings , the stationary SI ICE will not be considered out of compliance; or (b) If the Permittee does not operate and maintain the certified stationary SI ICE and control device according to the manufactures emission-related written instructions, the engine will be considered a non-certified engine and the Permittee shall demonstrate compliance according to 60.4243(a)(2)(i) through(iii) as appropriate; or 2. Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in Section II.C. of this permit and according to the test methods and other procedures specified in 60.4244, and according to the following: As an owner or operator of a stationary SI ICE greater than 500 hp, the Permittee shall keep a maintenance plan and records of conducted maintenance and shall, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the Permittee shall conduct an initial performance test and conduct subsequent performance testing every 8,760 hours or for 3 years, whichever comes first, to demonstrate compliance. Note to Permittee: The initial performance testing has been satisfied for the engines currently operating at this facility. The requirements for initial performance testing are retained in this permit in the case of new construction, installation or modification of an affected source under this subpart. OBSERVATION: Pursuant to 60.4243(b)(2)(ii), MPLX is required to keep a maintenance plan and records of conducted maintenance on C202, C203, C204, C206, and C207, and to operate the engines in a manner consistent with good air pollution control practices. MPLX provided maintenance records for C202, C203, C204, C206, and C207 to EPA upon request. Documents indicate that maintenance is scheduled to be conducted at regularly scheduled intervals of at least 720 operating hours. MPLX also provided maintenance reports separately for 2000, 2500, 4,000, 10,000, 16,000 and 50,000 operating hour intervals all of which include more thorough engine maintenance than solely visual inspection, including oil analysis, wiring, electrical, lubricant, valve clearance, torque specs and cylinder/bearing checks. Additionally, an initial performance test must be conducted on each engine, with subsequent testing every 8,760 hours or three years, whichever comes first. See Table 6, below, for NSPS JJJJ performance tests conducted at the Wonsits Valley Compressor Station from 2022 to present. D. Testing Requirements [40 CFR 60.4244 (a)-(f)] The Permittee shall comply with the performance testing requirements for the non-emergency, SI ICE greater than 1,350 hp as specified in 60.4244 (a)-(f) for emissions units C202, C203, C204, C206 and C207. OBSERVATION: Pursuant to 60.4243(c) and (b)(2)(ii), engines C202, C203, C204, C206, and C207 must conduct performance tests every 8,760 hours of operation or 3 years, whichever comes first. Results of NSPS JJJJ performance tests are displayed in Table 6, below. According to 60.4244(b), if an engine is non-operational, it does not need to be started up for testing; however, the performance test must be conducted immediately upon startup. Tests on all engines appear to have been conducted in accordance with the test methods required by NSPS Subpart JJJJ (40 CFR 60.4244), that is to conduct subsequent performance testing every 8,760 13 40 CFR part 63, subpart HH applies to the 100 MMscfd TEG dehydrator identified as D-1, and control device FL-1 in Table 2 of this permit. 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 hazardous air pollutants (HAP). OBSERVATION: The glycol dehydrator meets the definition of large glycol dehydration unit at 63.761. Per Paragraph 158 of the federal consent decree (Case No. 2:08-CV-00167-TS-PMV), the Wonsits Valley Compressor Station is considered a major source of HAP under MACT HH. Enclosed combustor, C-2, was removed in April 2022. B. General Standards [40 CFR 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. All reports required under 40 CFR part 63, subpart A shall be sent to the EPA at the following address as listed in 63.13: Branch Chief, Air and Toxics Enforcement Branch, 8ENF-AT Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 8 1595 Wynkoop Street Denver, Colorado 80202-1129 Reports may be submitted on electronic media where applicable through CEDRI. 3. The Permittee shall comply with the following requirements for the large glycol dehydrator at a major source as specified in 63.764(c): (a) The control requirements for glycol dehydrator 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. 4. 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: The glycol dehydrator (D-1) at Wonsits Valley is controlled by a flare (F-1). Control device downtime is reported by MPLX in its Semi-Annual Periodic MACT HH Reports. (See Table 7) C. Glycol Dehydration Unit Process Vent Standards [40 CFR 63.765(b)] The Permittee shall comply with the control equipment requirements as follows: 15 1. Except as specified in 63.765(c), the Permittee shall comply with the applicable requirements for large glycol dehydration unit process vents at major sources of HAP specified in 63.765(b)(1) and (2): (a) For each large glycol dehydration process vent, the Permittee shall control air emissions by either paragraph (b)(1)(i) or (ii) of 63.765. (i) The Permittee shall connect the process vent to a control device or combination of control devices through a closed-vent system, the closed-vent system shall be designed and operated in accordance with the requirements of 63.771(c). The closed-vent system shall be designed and operated in accordance with the requirements of 63.771(d); or (ii) The permittee shall connect the process vent to a control device or combination of control devices through a closed-vent system and the outlet benzene emissions from the control device(s) shall be reduced to a level less than 0.90 megagrams per year. The closed-vent system shall be designed and operated in accordance with the requirements of 63.771(c). The control device shall be designed and operated in accordance with the requirements of 63.771(d), except that the performance levels specified in 63.771(d)(1)(i) and (ii) do not apply; and (b) One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with paragraph (b)(1) of 63.765. OBSERVATION: The dehydration unit at Wonsits Valley Compressor Station is considered a large dehydration unit, and therefore the requirements in 40 CFR 63.771(d) apply. According to information from previous inspection reports, flash gas from the dehydration unit is routed back into the process and used as fuel for the reboiler. Any flash gas from the dehydration unit that cannot be used by the reboiler burner is routed to a John Zink air-assisted flare with a 8% hydrocarbon emission reduction, however MPLX may only use 95% as their enforceable limit through MACT HH. Per 40 CFR 63.771(d)(1)(iii), the flare 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. The flares operating parameters were reviewed while onsite and during records review. While onsite, MPLX noted that the current flare shut-off temperature of based on pilot/combustion zone (thermocouple is located on the pilot which is enveloped by the combustion of vapors when emissions are routed to the flare) is 300F. The flare and dehydration unit were not operating during the inspection. Pursuant to 40 CFR 63.771(e)(1)(i) and (e)(2), no performance test on the flare is required. Records for 63.11(b) were reviewed and MPLX included sufficient information, btu content and flare tip velocity, to determine compliance during the previous inspection. A safety device, as described in 40 CFR 63.771(c)(3), that allows emissions to vent directly to the atmosphere was observed in the place of C-2, removed. MPLX representatives informed EPA Inspectors that the safety device is only if the flare, FL-1, is not operating. During the previous inspection in 2022, MPLX representatives stated that the dehydration unit will automatically shut in in the flare is not operating and the safety device allows the remaining gases in the closed vent system to vent to atmosphere if necessary during shut-in. D. Control Equipment Requirements [40 CFR 63.771(b)-(d)] 1. For each cover, the Permittee shall comply with the cover requirements specified in 63.771(b). 2. The Permittee shall comply with the closed-vent system requirements specified in 63.771(c). 16 OBSERVATION: No leaks were detected from the closed vent system during the FLIR survey conducted by EPA inspectors. See the notes above that the unit was shut down for maintenance and that emissions seen were due to maintenance and cleaning. 3. For the control device, FL-1, the Permittee shall comply with the applicable control device requirements to reduce HAP emissions as specified in 63.771(d). OBSERVATION: As mentioned above, C-2 was removed in April 2022. FL-1 complies with the control device requirements to reduce HAP emissions per 63.771(d) by complying with the requirements of 63.11(b). A review of the 63.11(b) records provided by MPLX show that FL-1 complies with these requirements during the previous inspection. E. Test Methods, Compliance Procedures and Compliance Determination Requirements [40 CFR 63.772 (b)-(c), and (e)-(f)] The Permittee shall determine compliance with the requirements of 40 CFR part 63, subpart HH using the applicable test methods and compliance procedures for large glycol dehydration units specified in 63.772. 1. The Permittee shall determine the glycol dehydration unit flowrate, benzene emissions or BTEX emissions as specified in 63.772(b). 2. The Permittee shall comply with the test procedures for no detectable emissions in accordance with Method 21, 40 CFR part 60, appendix A, as specified in 63.772(c). 3. The Permittee shall comply with the test procedures for control device performance for FL-1 and C-2 as specified in 63.772(e). 3. The Permittee shall comply with the compliance demonstration for control device performance requirements for FL-1 as specified in 63.772(f). OBSERVATION: As mentioned above, C-2 was removed in April 2022. FL-1 complies with the control device requirements to reduce HAP emissions per 63.771(d) by complying with the requirements of 63.11(b). A review of the 63.11(b) records provided by MPLX show that FL-1 complies with these requirements during the previous 2022 inspection. F. Inspection and Monitoring Requirements [40 CFR 63.773 (c) and (d)] 1. For each closed-vent system or cover required by 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). 2. For the control device, FL-1, required by 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(d). OBSERVATION: The inspection and monitoring requirements specified in 63.773(c) require an initial inspection to demonstrate that the closed-vent system operates with no detectable emissions. The initial inspection was conducted more than five years ago and so is not applicable to this compliance evaluation. Annual visual inspections for defects of the closed-vent and cover and annual Method 21 inspections on the closed-vent system are also required. Results of annual inspections were submitted with the MACT HH Semi-Annual Periodic Reports since the previous inspection are shown in Table 7 below. MPLX representatives utilize a SCADA system to comply with additional monitoring parameters of the control device provided in the MACT HH semiannual reports. MPLX also maintains a system that 17 records if the dehydration unit was operating without controls and reports these items as well. 40 CFR 63.773(d)(1)(iii) requires a CPMS performance evaluation at least once every 12 months. MPLX provided information in MACT HH semiannual reports indicating that CPMS performance evaluations were conducted annually. G. 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), (e) and (g). 3. Except as specified in 63.774(c), 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. The Permittee shall keep records of the requirements of 63.774(e) when using a flare to comply with 63.771(d). 6. 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 malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. OBSERVATION: According to MPLX representatives, the facility logs and maintains records through a SCADA system, and records are stored at a central location at the MPLX facility located in Vernal, Utah. Records of malfunctions and corrective actions were submitted with periodic reports. H. 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. 3. 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 Initial Notification required by 63.775(b) and the Notification of Compliance Status required by 63.775(d) were submitted prior to the last full compliance evaluation. The facility 18 of HAP. These engines are subject to emissions limitations in MACT ZZZZ Table 2a (#2) and operating limitations in Table 2b (#1). B. General Provisions [40 CFR 63.6665] 1. The General Provisions at 40 CFR part 63, subpart A apply as specified in Table 8 of 40 CFR part 63, subpart ZZZZ. Notwithstanding conditions in this permit, the Permittee shall comply with all applicable requirements of 40 CFR part 63, subpart A. 2. All reports required under 40 CFR part 63, subpart A shall be sent to the EPA at the following address as listed in 63.13: Branch Chief, Air and Toxics Enforcement Branch, 8ENF-AT Enforcement and Compliance Assurance Division U.S. Environmental Protection Agency, Region 8 1595 Wynkoop Street Denver, Colorado 80202-1129 Reports may be submitted on electronic media where applicable through CEDRI. C. Emission and Operating Limitations [40 CFR 63.6600and 63.6605] 1. The Permittee shall comply with the emissions limitations and operating limitations for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, specified in 63.6600(b) for engines C202, C203, C204, C206 and C207. 2. The Permittee shall demonstrate compliance with general requirements for engines C202, C203, C204, C206 and C207 according to 63.6605. 3. Pursuant to 63.6600, compliance with the numerical emissions limitations for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions established in 40 CFR part 63, subpart ZZZZ for engines C202, C203, C204, C206 and C207, shall be based on the results of testing the average of three 1-hour runs using the testing requirements and procedures in 63.6620 and Table 4 to 40 CFR part 63, subpart ZZZZ. OBSERVATION: Pursuant to 40 C.F.R. 63.6600, engines C202, C203, C204, C206, and C207 must meet the emission limitations established in MACT ZZZZ by either (a) reducing carbon monoxide (CO) emissions by 93% or more or (b) limiting the concentration of formaldehyde (CH2O) in the exhaust to 14 ppmvd or less at 15% O2. The engines at the Wonsits Valley Compressor Station comply with MACT ZZZZ using the CO reduction limitation option. In accordance with Table 3 (#1) to MACT ZZZZ, compliance with reduction requirements is determined through semi-annual performance testing. See Table 8, below for results of MACT ZZZZ performance tests conducted at the Wonsits Valley Compressor Station since the previous inspection in 2022. Engines C202, C203, C204, C206, and C207 meet the continuous monitoring requirements of MACT ZZZZ Table 2b (#1) by (1) operating a continuous parametric monitoring system (CPMS) to ensure the catalyst inlet temperature is greater than or equal to 450F and less than or equal to 1350F, and (2) maintaining the pressure drop across the catalyst to within 2 inches of water of the pressure drop recorded during the performance test that established baseline operating parameters (at 100% load 10%). Per Table 6 (#1) of MACT ZZZZ, to demonstrate continuous compliance with CPMS requirements, MPLX must collect catalyst temperature, reduce the temperature data to 4-hour rolling averages, and ensure the 4-hour rolling averages are within the operating limitations for catalyst inlet temperature specified above. MPLX must also measure the pressure drop across the catalyst once per 20 month to demonstrate it is within the allowable range established during the performance test. In response to a request from EPA, MPLX provided catalyst temperature data and monthly pressure drop readings covering the period of July 1, 2022 through the date of inspection for engines C202, C203, C204, C206, and C207. EPA notes the rolling average listed temperatures in the compliant range and all monthly differential pressure readings reported were within 2 inches of the baseline differential pressure. At the time of the inspection, the catalyst inlet temperature and catalyst pressure differential for the operating engines were within the compliant range. D. Testing and Initial Compliance Requirements [40 CFR 63.6610, 63.6615, 63.6620, 63.6625, and 63.6630] 1. The Permittee shall conduct the initial performance tests and other compliance demonstrations requirements for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6610, for engines C202, C203, C204, C206 and C207. Note to Permittee: The initial performance testing has been satisfied for the engines currently operating at this facility. The requirements for initial performance testing are retained in this permit in the case of new construction, installation or modification of an affected source under this subpart. 2. The Permittee shall conduct subsequent performance tests for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6615, for engines C202, C203, C204, C206 and C207. 3. The Permittee shall use the performance tests and other procedures for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified 63.6620 for engines C202, C203, C204, C206 and C207. 4. The Permittee shall comply with the monitoring, installation, collection, operation and maintenance requirements for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6625, for engines C202, C203, C204, C206 and C207. OBSERVATION: Pursuant to 63.6625, EPA inspectors verified information from the CPMS while onsite for the inspection of Wonsits Valley. Additionally, operation and maintenance records were provided upon request. 5. The Permittee shall demonstrate initial compliance with the emission limitations, operating limitations and other requirements that apply to stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6630, for engines C202, C203, C204, C206 and C207. 6. As an alternative to the test methods specified in 40 CFR part 63, subpart ZZZZ, Table 4, Item 1.a.iii, the Permittee may use EPA Method 320 to measure CO at the inlet and the outlet of the control device. Note to Permittee: The initial compliance has been satisfied for the engines currently operating at this facility. The requirements for initial compliance are retained in this permit in the case of new construction, installation or modification of an affected source under this subpart. OBSERVATION: Pursuant to 63.6615, 63.6620 and Table 3 to MACT ZZZZ, semi-annual performance testing must be conducted on engines C202, C203, C204, C206, and C207, with the option of moving to annual testing after two consecutive successful semi-annual tests. MPLX 21 C207c BLB00215 11/7/2023 8/25/2023 11/20/2023 98.9% 93% C207c BLB00215 5/14/2024 3/4/2024 7/29/2024 98.9% 93% 97% 2.0 (East) 1.3 (West) 98% 1.9 (East) 1.5 (West) E. Continuous Compliance Requirements [40 CFR 63.6635 and 63.6640 (a)(e)] 1. The Permittee shall monitor and collect data to demonstrate continuous compliance for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6635, for engines C202, C203, C204, C206 and C207. 2. The Permittee shall demonstrate continuous compliance with the emission limitations, operating limitations, and other requirements for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions, as specified in 63.6640, for engines C202, C203, C204, C206 and C207. OBSERVATION: Pursuant to 63.6640(a) and MACT ZZZZ Table 6 (#1 & #4), MPLX shall (1) continuously collect inlet catalyst temperature data and reduce the data to 4-hour rolling averages and (2) measure the pressure drop across the catalyst once per month. Catalyst inlet temperature 4-hour rolling averages should be maintained within 450 - 1350F and differential pressure across the catalyst should be within 2 inches of water from the baseline established during the performance test (at 100% load). EPA observed the CPMS for engines C203, C204, C206 and C207 during its tour of the facility. (See Table 1 for engine parameters recorded during the inspection.) Catalyst inlet temperature and differential pressure across the catalyst were within the compliant range at the time of inspection. MPLX provided inlet catalyst temperature data and monthly pressure drop readings covering the period of July 1, 2022, through the date of inspection to EPA for review. EPA notes the rolling average listed temperatures in the compliant range. All monthly differential pressure readings reported were within 2 inches of the baseline differential pressure. MPLX data clearly indicated performance test dates corresponding with baseline pressure information. F. Notifications, Reports and Records [40 CFR 63.6645, 63.6650 and Table 7, 63.6655, and 63.6660] 1. The Permittee shall submit notifications as specified for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions in 63.6645 for engines C202, C203, C204, C206 and C207. 2. The Permittee shall submit reports as specified for stationary 4SLB RICE with a site rating of more than 500 brake hp located at a major source of HAP emissions in 63.6650 and Table 7 for engines C202, C203, C204, C206 and C207. 3. The Permittee shall keep records as specified in 63.6655 for engines C202, C203, C204, C206 and C207. 4. The Permittee shall keep the records in the format and for the duration as specified in 63.6660 for engines C202, C203, C204, C206 and C207. 23 OBSERVATION: The Consent Decree was terminated on June 14, 2014. (See Appendix C for a copy of the signed termination order.) However, based on Section XVII of the Consent Decree, Paragraphs 17, 19, 20 and 23 shall expressly survive the termination of the Consent Decree. OBSERVATION: Civil Action No. 2:23cv252 appears to have duplicative emission limits to Consent Decree Case No. 2:08-CV-00167-TS-PMVand therefore EPA only assessed compliance with those emission limitations during this compliance evaluation. B. Requirements for the Glycol Dehydrator [Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraphs 17] 1. Requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 17 (a) The flare installed pursuant to Paragraph 15 of the Consent Decree shall achieve a 95% by weight or greater reduction of volatile organic compound (VOC) emissions for the glycol dehydrator process vent stream at all times except during periods of time when the pilot flame at the flare is off, the Permittee shall automatically shut-down the glycol dehydrator (D-1) glycol pumps and re-light the flare pilot flame prior to restarting the glycol pumps. (b) Compliance with 40 CFR 63.11(b), and with the associated monitoring and recordkeeping required in 40 CFR 63.773(d)(3)(i)(C), 63.774(b) and 63.774(e) shall be sufficient to determine compliance with the 95% VOC reduction requirement of Paragraph 17 of the Consent Decree. OBSERVATION: See Section III for a discussion of MACT HH requirements for the glycol dehydrator at the Wonsits Valley Compressor Station. C. Requirements for the Condensate Storage Tank [Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraphs 19, 20] 1. Requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 19 (a) The Permittee shall, within 30 days of the Effective Date of the Consent Decree, connect the condensate storage tank, identified as T-1 in this permit, to an existing or new combustor at the facility. Note to Permittee: The EPA has determined that the requirements of Section V.C.1.a. of this permit have been satisfied. This section has been retained because the provision of the terminated CD was stated to live on in perpetuity. (b) The Permittee shall, within 60 days of the Effective Date of the Consent Decree, certify to the EPA that the design of the conveyance systems from the condensate storage tank to the combustor does not, under normal operating conditions, cause or contribute to a release of VOCs from the condensate storage tank through thief hatches or pressure relief valves. Note to Permittee: The EPA has determined that the requirements of Section V.C.1.b. of this permit have been satisfied. This section has been retained because the provision of the terminated CD was stated to live on in perpetuity. (c) The Permittee shall equip the combustor with thermocouples (or other heat sensing monitoring devices) to continuously monitor the presence of a pilot flame. 2. Requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 20 25 (a) The Permittee shall monitor and record the presence of a pilot flame with a continuous recording device, such as a chart recorder or similar device. OBSERVATION: Emissions from the condensate storage tank (Unit T-1) are routed to a Cimmaron combustor for control. The presence of a pilot flame is continuously monitored with a thermocouple. Records of thermocouple downtime information were provided to EPA upon request between July 1, , see Table 11 below for thermocouple records provided during for six month and annual reporting periods. D. Requirements for RICE [Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 23] 1. Requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 23 For RICE a site rating of 500 hp or greater operated at the facility, identified as engines C202, C203, C204, C206 and C207, the Permittee shall comply with the requirements specified below: (a) Emissions Control: (i) The Permittee has installed and is operating an oxidation catalyst control device on each lean burn RICE. The four existing lean burn RICE at Wonsits Valley, identified as C202, C203, C204 and C207, shall not exceed 1.0 gram per horsepower hour (g/hp-hr) for NOX (nitrogen oxides) and 1.0 g/hp-hr for CO (carbon monoxide) and C206 shall not exceed 1.3 g/hp-hr for NOX and 1.0 g/hp-hr for CO in this permit. OBSERVATION: The engines currently installed, are equipped with an AFR and NSCR control system. Results of semi-annual performance tests for NOX and CO conducted since the last full compliance evaluation are within the allowable limits. See Table 10, below. (b) Emissions Controls Maintenance: Any oxygen sensors in use shall be replaced within 2,000 hours of engine run time. OBSERVATION: According to information provided by MPLX in previous inspection reports, the engines are 4SLB and do not use oxygen sensors. (c) Performance Testing for NOX and CO: (i) Not later than 180 days after the Effective Date of the Consent Decree, the Permittee shall conduct initial performance tests for NOX and CO emissions, on each RICE, using the test protocol selected from the list in paragraph iv below. Note to Permittee: The EPA has determined that the requirements of Section V.D.1.c.i. of this permit have been satisfied. This section has been retained because the provision of the terminated CD was stated to live on in perpetuity. (ii) The Permittee shall retest each reciprocating internal combustion engine semi-annually using the test protocol developed from the test methods specified above. The Permittee shall submit to the EPA the test results for NOX and CO with the respective semiannual report required in Section VI.B.1. of this permit that corresponds with the reporting period within which the test was conducted. 26 C202 C202 C203 C203 C203 C203 C203 C204 C204 C204 C204 C204 C204 C206 C206 C206 C206 C206 C206 C207c C207c C207c C207c C207c 12/4/2023 8/25/2023 12/21/2023 0.29 1.0 5/14/2024 3/4/2024 5/30/2024 0.40 1.0 5/25/2022 3/24/2022 7/12/2022 0.61 1.0 11/30/2022 9/28/2022 1/6/2023 0.55 1.0 5/1/2023 3/1/2023 6/7/2023 0.51 1.0 11/6/2023 8/25/2023 11/20/2023 0.58 1.0 5/15/2024 3/4/2024 5/30/2024 0.82 1.0 5/25/2022 3/24/2022 7/12/2022 0.81 1.0 11/30/2022 9/28/2022 1/6/2023 0.53 1.0 1/10/2023 12/7/2022 3/1/2023 0.50 1.0 5/1/2023 3/1/2023 6/7/2023 0.40 1.0 11/7/2023 8/25/2023 11/20/2023 0.44 1.0 5/13/2024 3/4/2024 5/30/2024 0.71 1.0 5/26/2022 3/24/2022 7/12/2022 0.47 1.3 11/30/2022 9/28/2022 1/6/2023 0.41 1.3 1/10/2023 1/5/2023 3/1/2023 0.42 1.3 5/2/2023 3/1/2023 6/7/2023 0.73 1.3 11/8/2023 8/25/2023 11/20/2023 0.51 1.3 5/14/2024 3/4/2024 5/30/2024 0.75 1.3 5/24/2022 3/24/2022 7/12/2022 0.54 1.0 11/29/2022 9/28/2022 1/6/2023 5/3/2023 3/1/2023 6/7/2023 0.57 1 0.68 1.0 11/7/2023 8/25/2023 11/20/2023 0.68 1.0 5/14/2024 3/4/2024 5/30/2024 0.65 1.0 0.00 1.0 0.00 1.0 0.01 1.0 0.00 1.0 0.01 1.0 0.00 1.0 0.00 1.0 0.01 1.0 0.00 1.0 0.00 1.0 0.01 1.0 0.00 1.0 0.00 1.0 0.06 1.0 0.06 1.0 0.05 1.0 0.05 1.0 0.05 1.0 0.03 1.0 0.05 1.0 0.04 1 0.05 1.0 0.05 1.0 0.02 1.0 6.8 6.9 7 7.1 7.8 7.8 7.4 6.8 5.8 6.5 7.1 7.2 6.9 7.9 7.9 7.7 8.8 8.6 8.9 2.1 (East) 1.4 (West) 2.0 (East) 1.3 (West) 1.9 (East) 1.4 (West) 1.9 (East) 1.3 (West) 1.9 (East) 1.5 (West) 782 695 787 784 768 693 798 821 792 817 773 701 675 750 746 740 749 680 684 763 (East) 667 (West) 764 (East) 646 (West) 778 (East) 671 (West) 775 (East) 677 (West) 748 (East) 631 (West) 87.7% 88.0% 87.3% 86.0% 96.7% 93.7% 90.0% 79% 82% 87% 100% 92% 85% 77% 96% 93% 98% 93% 96% 92% 93% 89% 97% 98% OBSERVATION:As previously discussed, engine loads are monitored and recorded via a SCADA system. a b Test results indicate combined emissions from both East (Left) and West (Right) Bank stacks. c Test does not meet the requirements of MACT ZZZZ, as the test was stopped after only one test run due to VOC emission results indicating an exceedance of the NSPS JJJJ limits for Engine C207. VI. 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. A. Recordkeeping Requirements [40 CFR 71.6(a)(3)(ii)] The Permittee shall comply with the following generally applicable recordkeeping requirements: 1. If the Permittee determines that his or her stationary source that emits (or has the potential to emit, without considering controls) one or more HAPs is not subject to a relevant standard or other requirement established under 40 CFR part 63, the Permittee shall keep a record of the applicability determination on site at the source for a period of 5 years after the determination, or until the source changes its operations to become an affected source, whichever comes first. The record of the applicability determination shall include an analysis (or other information) that demonstrates why the Permittee believes the source is unaffected (e.g., because the source is an area source). [40 CFR 63.10(b)(3)] 28 1. Compliance with the Permit (a) The Permittee must comply with all conditions of this Part 71 permit. Any permit noncompliance constitutes a violation of the CAA and is grounds for enforcement action; (b) For permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. (c) It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (d) For the purpose of submitting compliance certifications in accordance with 71.6(c)(5) or establishing whether or not a person has violated or is in violation of any requirement of this permit, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. 2. Compliance Schedule [40 CFR 71.5(c)(8)(iii)] (a) For applicable requirements with which the source is in compliance, the source will continue to comply with such requirements. (b) For applicable requirements that will become effective during the permit term, the source shall meet such requirements on a timely basis. 3. 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 January 31st, and shall cover the same 12-month period as the two consecutive semi-annual monitoring reports. [Explanatory note: To help Part 71 Permittees meet reporting responsibilities, the EPA has developed a reporting form for annual compliance certifications. The form may be found on the EPA website at: https://www.epa.gov/title-v-operating-permits/epa-issued-operating-permits ] (b) The compliance certification shall be certified as to truth, accuracy, and completeness by a responsible official consistent with 40 CFR 71.5(d). (c) The certification shall include the following: (i) Identification of each permit term or condition that is the basis of the certification; (ii) The identification of the method(s) or other means used for determining the compliance status of each term and condition during the certification period, and whether such methods or other means provide continuous or intermittent data. Such methods and other means shall include, at a minimum, the methods and means required in this permit. If necessary, the Permittee also shall identify any other material information that must be included in the certification to comply with Section 113(c)(2) of the CAA, which prohibits knowingly making a false certification or omitting material information; 34 (iii) The status of compliance with each term and condition of the permit for the period covered by the certification based on the method or means designated in (ii) above. The certification shall identify each deviation and take it into account in the compliance certification; (iv) Such other facts as the EPA may require to determine the compliance status of the source; and (v) Whether compliance with each permit term was continuous or intermittent. OBSERVATION: Title V Annual Compliance Certifications (TVACCs) submitted since the previous full compliance evaluation are shown in Table 11. 35 APPENDIX A: Site Overview 36 APPENDIX C: Consent Decree Termination 38