HomeMy WebLinkAboutDAQ-2024-0048571
DAQC-CI126560001-24
Site ID 12656 (B1)
MEMORANDUM
TO: FILE – PRICE RIVER ENERGY, LLC – Gordon Creek Compressor Facility
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Kyle Greenberg, Environmental Scientist
DATE: January 11, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Carbon County
INSPECTION DATE: July 24, 2023
SOURCE LOCATION: SE/4 Sec. 32 T13S R8E
Price, UT 84501
DIRECTIONS: 12 miles west of Helper, UT. 2 miles south of Helper on 191,
take Consumer Road west for 9 miles. Then turn left on Benches
Road and take that southwest for 2 miles, site will be on the
right-hand side.
SOURCE CONTACTS: Thomas Muchard, Owner
t.muchard@priceriverenergy.com
713-907-8257
OPERATING STATUS: Operating
PROCESS DESCRIPTION: Price River extracts and processes natural gas in the Gordon
Creek Field. The gas is sent to the compressor station, where the
station processes natural gas as it travels along the gas pipeline.
The facility removes condensation from the gas product and
pressurizes the gas, allowing it to reach its final destination.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN126560008-22, dated January
21, 2022; 40 CFR Part 60 Subpart JJJJ
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Price River Energy, LLC - Gordon Creek
Compressor Facility
950 Echo Lane, Suite 200 SE/4 Sec. 32 T13S R8E
Houston, TX 77024 Price, UT 84501
SIC Code: 1311: (Crude Petroleum & Natural Gas)
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Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of the new 637 hp compressor
engine to the Director within 18 months from the date of this AO. This AO may become invalid
if construction is not commenced within 18 months from the date of this AO or if construction is
discontinued for 18 months or more. To ensure proper credit when notifying the Director, send
the documentation to the Director, attn.: NSR Section. [R307-401-18]
Status: Out of Compliance with Condition I.5. The source has been unresponsive in
scheduling a stack test for the engines on-site and is not operating in a manner consistent
with good air pollution control maintenance. There have been no known breakdowns that
have caused excess emissions. An emissions inventory has not been required to date.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Gordon Creek Compressor Facility
II.A.2 One (1) 637 hp Compressor Engine (New)
Fuel: Natural Gas
Type: 4 Stroke, Lean Burn
Manufacturing Date: November 30, 2006
Control: Oxidation Catalyst
Applicable MACT: Subpart ZZZZ
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II.A.3 One (1) Generator Engine
Fuel: Natural Gas
Type: 4 Stroke, Lean Burn
Rating: 350 kW
Control: Selective Catalytic Reduction
Applicable NSPS: Subpart JJJJ
Applicable MACT: Subpart ZZZZ
II.A.4
II.A.5
One (1) Backup Generator
Engine Fuel: Diesel Size: 547 hp
Applicable NSPS: Subpart IIII
Applicable MACT: Subpart ZZZZ
Two (2) Storage Tanks
Capacity: 400 barrels (each)
Contents: Condensate and waste water containing lube oil
II.A.6 One (1) Produced Water Tank
Capacity: 400 barrels
II.A.7 One (1) Glycol Dehydration Unit
Rated Capacity: 16 MMscf/day
Status: The above listed equipment is accurate. The 637 hp Compressor’s Serial # is
6ZMO2826 and was rebuilt February 19, 2016. The 350 kW Generator’s Serial # is
5283700164 and has a manufacture date of June 2009. The Emergency Generator’s
Serial # is 16501001332 and was manufactured November 2011.
II.B Requirements and Limitations
II.B.1 Site Wide Requirements
II.B.1.a Unless otherwise specified in this AO, the owner/operator shall not allow visible emissions from
any stationary point or fugitive emission source on site to exceed 10 percent opacity.
[R307-401-8]
II.B.1.a.1 Unless otherwise specified in this AO, opacity observations of emissions from stationary sources
shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-201-3]
Status: In Compliance. No visible emissions were observed during the time of inspection.
II.B.2 Compressor Engine Requirements
II.B.2.a The owner/operator shall use only natural gas as fuel in the Compressor Engine. [R307-401-8]
II.B.2.b The owner/operator shall install oxidation catalysts on the 637 HP compressor engine. All
exhaust emissions from the compressor engine shall be routed through the oxidation catalysts
prior to being released to the atmosphere. [R307-401-8]
II.B.2.c The owner/operator shall not emit more than the following rates from the 637-hp Compressor
Engine:
Pollutant lb/hr
NOx 2.81
CO 2.38
VOC 0.63. [R307-401-8]
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II.B.2.c.1 Compliance Demonstration
To demonstrate compliance with the emission limitations above, the owner/operator shall
perform stack testing on the emissions unit according to the stack testing conditions contained in
this AO. [R307-165-2, R307-401-8]
II.B.2.c.2 Initial Test
The owner/operator shall conduct an initial stack test on the emission unit within 180 days after
startup of the emission unit. [R307-165-2]
II.B.2.c.3 Test Frequency
The owner/operator shall conduct a stack test on the emission unit within 5 years after the date of
the most recent stack test of the emission unit. The Director may require the owner/operator to
perform a stack test at any time. [R307-165-2, R307-401-8]
Status: Out of Compliance. An initial Stack Test was not conducted on the compressor
engine. A Compliance Advisory (DAQC-787-23) has been issued.
II.B.3 Stack Testing Requirements
II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the
following conditions. [R307-401-8]
II.B.3.a.1 Notification
At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test
protocol to the Director. The source test protocol shall include the items contained in
R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference.
[R307-165-3, R307-401-8]
II.B.3.a.2 Testing & Test Conditions
The owner/operator shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8]
II.B.3.a.3 Access
The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or
Mine Safety and Health Administration (MSHA)-approved access to the test location.
[R307-401-8]
II.B.3.a.4 Reporting
No later than 60 days after completing a stack test, the owner/operator shall submit a written
report of the results from the stack testing to the Director. The report shall include validated
results and supporting information. [R307-165-5, R307-401-8]
II.B.3.a.5 Possible Rejection of Test Results
The Director may reject stack testing results if the test did not follow the approved source test
protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8]
II.B.3.b Test Methods
When performing stack testing, the owner/operator shall use the appropriate EPA-approved test
methods as acceptable to the Director. Acceptable test methods for pollutants are listed below.
[R307-401-8]
II.B.3.b.1 Standard Conditions
A. Temperature - 68 degrees Fahrenheit (293 K)
B. Pressure - 29.92 in Hg (101.3 kPa)
C. Averaging Time - As specified in the applicable test method
[40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8]
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II.B.3.b.2 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]
II.B.3.b.3 VOC
40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A,
Method 320; or other EPA-approved testing method as acceptable to the Director.
[R307-401-8]
II.B.3.b.4 CO
40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the
Director. [R307-401-8]
Status: Unable to be determined. Initial and subsequent stack tests have not been
submitted for the engines onsite. The condition’s status will be determined once stack tests
have been submitted to the DAQ.
II.B.4 Generator Engine Requirements
II.B.4.a The owner/operator shall not operate the emergency engine on site for more than 100 hours per
rolling 12-month period during non-emergency situations. There is no time limit on the use of
the engines during emergencies. [R307-401-8]
Status: In Compliance. The emergency generator has not exceeded 100 hours per rolling
12-months for the last 24 months.
II.B.4.b To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of the backup generator shall be kept in a log and shall include the
following:
a. The date the engine was used
b. The duration of operation in hours
c. The reason for emergency engine usage. [R307-401-8]
Status: In Compliance.
II.B.4.c The owner/operator shall use only natural gas as a fuel source in the 350 kW (II.A.3) Generator
Engine. [R307-401-8]
Status: In Compliance.
II.B.4.d The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the emergency generator (II.A.4). [R307-401-8]
Status: In Compliance.
II.B.4.e Visible emissions from the diesel-fired backup generator shall not exceed 20% opacity at any
time. [R307-401-8]
Status: Unable to be determined during the time of inspection. The diesel-fired backup
generator was not operating during the time of inspection and has not operated in the past
two years.
II.B.4.f The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
Status: In Compliance.
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II.B.4.f.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]
Status: In Compliance.
II.B.5 Tank Requirements
II.B.5.a The owner/operator shall not produce more than 5,333 barrels (1 barrel = 42 gallons) of
condensate per rolling 12-month period. [R307-401-8]
Status: In Compliance. The source provided data that zero barrels of condensate was
produced in a rolling 12-month period.
II.B.5.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
of condensate production shall be kept for all periods when the plant is in operation. Condensate
produced shall be determined by company and/or customer billing records. The records of
condensate production shall be kept on a daily basis. [R307-401-8]
Status: In Compliance.
II.B.5.b The owner/operator shall keep the storage tank thief hatches closed and latched except during
tank unloading or other maintenance activities. [R307-401-8]
Status: Out of Compliance. The thief hatches were open during the time of inspection. The
OGI camera did not detect any VOCs emitting from the open thief hatches. A Compliance
Advisory (DAQC-787-23) has been issued.
II.B.5.b.1 The owner/operator shall inspect the thief hatches at least once every six months to ensure the
thief hatches are closed, latched, and the associated gaskets, if any, are in good working
condition. Records of thief hatch inspections shall include the date of the inspection and the
status of the thief hatches. [R307-401-8]
Status: Out of Compliance. The thief hatches are not inspected every six months and
records have not been kept. A Compliance Advisory (DAQC-787-23) has been issued.
II.B.5.c The owner/operator shall load condensate into the tanker trucks by the use of submerged loading.
[R307-401-8]
Status: Unable to be determined during the time of inspection. According to Price River
Energy the Gordon Creek Compressor Facility has not produced any condensate.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including UAC
R307.
40 CFR Part 60 Subpart JJJJ:
Out of Compliance with section 60.4243(b)(2)(i). An initial stack test has not been conducted on the
Waukesha H24GL generator engine SN:5283700164 within one year of the engine start up. A
Compliance Advisory (DAQC-787-23) has been issued.
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EMISSION INVENTORY:
The emissions listed below are an estimate of the total potential emissions (PTE) from Price River
Energy, LLC - Gordon Creek Compressor Facility on the Approval Order (AO)
DAQE-AN126560008-22, dated January 21, 2022. PTE are supplied for supplemental purposes only.
Criteria Pollutant PTE tons/yr
CO2 Equivalent 7037.00
Carbon Monoxide 13.55
Nitrogen Oxides 23.37
Particulate Matter - PM10 0.06
Particulate Matter - PM2.5 0.06
Sulfur Dioxide 0.08
Volatile Organic Compounds 5.35
Hazardous Air Pollutant PTE lbs/yr
Acetaldehyde (CAS #75070) 771
Acrolein (CAS #107028) 474
Formaldehyde (CAS #50000) 480
Generic HAPs (CAS #GHAPS) 184
Hexane (CAS #110543) 20
Methanol (CAS #67561) 230
PREVIOUS ENFORCEMENT
ACTIONS: - Notice of Violation (DAQC-080-18) March 16, 2018
- Compliance Advisory (DAQC-787-23) August 1, 2023
- ESA (DAQC-1360-23) December 22, 2023
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN126560008-22,
dated January 21, 2022: Out of Compliance with conditions I.5,
ll.B.2,c.2, II.B5.b, II.B5.b.1, and 40 CFR Part 60 Subpart JJJJ §
60.4243(b)(2)(i). A Compliance Advisory (DAQC-787-23) has
been issued.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Check for stack test results.
NSR RECOMMENDATIONS: N/A
ATTACHMENTS: N/A