DAQ-2024-004630

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1251 Lumpkin Rd, Houston, TX 77043-4101- [phone]
December 12,2023
Sent via Federal Express
Bryce Bird, Director
Utah Division of Air Quality
P.O. Box '144820
195 North 1950 West
Salt Lake City, Utah 84116-3100
Environmental Protection Agency, Region Vlll
Office of Enforcement, Compliance and
Environmental Justice (mail code SENG-AT)
1595 Wynkoop Street
Denver, CO80202-1129
Re: 40 CFR Part 60, Subpart OOOO, Annual Report
July 01, 2022 through June 30,2023
Wapiti Operating, LLC, Sage Brush Flats Compressor Station, Carbon County, Utah
Title V Operating Permit: #500101002, lssued June 14, 2019
Dear Mr. Bird and EPA Region Vlll,
ln accordance with Title 40 of the Code of Federal Regulations, Part 60, Subpart OOOO
(NSPS OOOO), enclosed is an annual report for the period of July 01, 2022 through June 30, 2023.
The report is for three reciprocating compressors powered by engines ENG01, ENG02, and ENG03.
There is no a) gas well, b) centrifugal compressor (w/ wet seals), c) pneumatic controller (>6 scf/hr),
d) storage vessel (16 tpy), e) natural gas process unit, or other NSPS OOOO affected facility at Wapiti
Operating, LLC's Sage Brush Compressor Station.
lf you have any questions or need additional information, please contact me at [phone] or
[e-mail].
Sincerely,
. ! "- r,.r_
Clyde ffhodes
Environmental Specialist
B-2-12929
General lnformation
560.5420(b)(1)(i)
s60.5420(b)(1)(ii0
560.5a20@)(1)(iv)
40 CFR Part 60. Subpart OOOO Annual Report
lncludinq Cer.tification of Truth, Accuracv. and Completeness
July 01, 2022lhrough June 30,2023
The company name and address of the affected facility.
WapitiOperatinq, LLC
Saqe Brush Flat Compressor Station
-30 miles South of Mvton
Remote Location in Carbon County, UT
Lat: 39.73611'N Lon: -110.11292"W
An identification of each affected facility included in the annual report.
Three Bl reciprocatinq compressors powered bv enoines ENG01, ENG02, and
ENGO3.
Beginning and ending dates of the reporting period.
Beqin: Julv 01, 2022 and End: June 30, 2023.
A certification by a certifying official of truth, accuracy, and completeness.
See Below.
s60.5420(b)(1)(i0
Reportinq for Reciprocating Compressors
560.5420(b)(4)(il Cumulative number of hours of operation or the number of months since initial
staftup, since October 15,2012, or since the previous reciprocating compressor
rod packing replacement, whichever is later.
Compressor lD:ENGOl ENG02 ENGO3
Date of Last Packing Change 09t30t21 09t27t21 09t29t21
Hours of Operation w/ Current Packing 12,767 6,640 19,049
Threshold Hours or Months Later of 26,000 Hours or 36 Months
s60.5420(b) (4)(ii)Records of deviations specified in paragraph (c)(3)(iii) of this section that
occurred during the reporting period.
Goinq fon/vard, submission of this NSPS OOOO Report will coincide with
submission of the Title V Annual Compliance Certification due on or before
March 01 of each calendar vear.
Certificate of Truth. Accuracv. and Completeness
ln accordance with Operating Permit provision l.K, UAC R307-415-5d, and 40CFRS60.5420(bX1)(iv), to
the bestof myknowledge, and based on information and belief formed afterreasonable inquiry, lcertify
that the statements and information in this document are true, accurate, and complete.
esident & CEO
Dae'/L-->cc Z-'L3
.10 CFR Part 60 Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas
Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23,
2011, and on or Before September 18,2015
$ 60.5365 Am I subject to this subpart?
You are subject to the applicable provisions of this subpart if you are the owner or operator olone or
more of the onshore affected tacilities listed in paragraphs (a) through (g) of this section that is locared
within the Cmde Oil and Natural Gas Production source category, as defined in g 60.5430 tbr which yoLr
commence constntction, modification, or reconstruction zrfter August23,20l l. and on or befbre
September 18, 2015.
(c) Each reciprocating compressor affected facility, rvhich is a single reciprocating compressor. A
reciprocating compressor located at a well site, or an adjacent r.vell site and sewicing more than one
well site, is not an affected f'acility under this sLrbpart.
$ 60.5385 What standards apply to reciprocating compressor affected facilities?
You must comply with the standards in paragraphs (a) through (d) of this section tbr each reciprocating
compressor affected facility.
(a) You must replace the reciprocating compressor rod packing according to either paragraph (aX l) or
(2) of this section or you must comply with paragraph (a)(3) of this sectiorr.
(1) Before the compressor has operated for 26,000 hours. The number of hours of operation must be
continuously monitored beginning upon initial startup of your reciprocating compressor affected
facility, or October [5, 2012, or the date of tlie most recent reciprocating compressor rod packing
replacement. whichever is later.
(2) Prior to 36 months from the date of the most recent rod packing replacement, or 36 months tiom
the date of starrup for a new reciprocating compressor for which the rod packing has not yet been
replaced.
(3) Collect the emissions tiom the rod packing using a rod packing emissions collection system
which operates under negative pressure and route the rod packing emissions to a process throu-eh a
closed vent system that mccts thc requirements of $ 60.54 I I (a).
(b) You must demonstrate initial compliance with standards that apply to reciprocating compressor
aff-ected facilities as required by $ 60.5410.
(c) You must demonstrate continuous compliance with standards that apply to reciprocatint
compressor aftbcted tacilities as required by $ 60.5a15.
(d) You must perfonn the required notification, recordkeeping, and reporting as required by $ 60.5a20.
$ 60.5410 How do I demonstrate initial compliance rvith the standards for my gas well affected
facility, my centrifugal compressor affected facility, my reciprocating compressor affected
facility, my pneumatic controller affected facility, my storage vessel affected facility, and my
equipment leaks and sweetening unit at'l'ected lacilities at onshore natural gas processing plants l
(c) To achieve initial compliance with the standards fbr each reciprocatins compressor attectetl tacility
you must comply w'ith paragraphs (c)( l) through (4) of this section.
( I ) tf courplying with $ 60.5385(aX I ) or (2), during the initial compliance period, yoLr must
continuously monitor the number of hours of operation or track the number of months since the last
rod packing rcplaccmcnt.
(3) You must submit tlic initial annual rcport fbr yoLrr rcciprocating compressor as recluired in $
60.5420(b).
(4) You must maintain the records as specit-red in $ 60.5420(c)(3) fbr each reciprocating corllpressor
atl'ected f'acility.
$ 60.5415 How do I demonstrate continuous compliance with the standards for my gas well
affected facilitv, my centrifugal compressor affected facility, my stationary reciprocating
compressor affected facility, my pneumatic controller affected facility, my storage vessel affected
facilit_v, and my affected facilities at onshore natural gas processing plants?
(c) For each reciprocating compressor aftbcted f'acility cornplying with $ 60.538-5(a)( I ) or (2), you
must demonstrate continuous compliance according to paragraphs (c)( I ) through (3) of this section.
( I ) You must continuously monitor the number of hours of operation fbr each reciprocating
compressoraff'ected facility ortrack the numberof months since initial startup, orOctober 15,2012,
or the date of the most recent reciprocating compressor rod packing replacement, whichever is [ater.
(2) You must submit the annual report as required in $ 60.5420(b) and maintain records as required
in $ 60.5420(c)(3).
(3) You must replace the reciprocating compressor rod packing befbre the total number of hours of
operation reaches 26,000 hours or the number of rnonths since the most recent rod packing
replacement reaches 36 months.
$ 60.5420 What are my notification, reporting, and recordkeeping requirements?
(b) Reporting requirements. You must submit annual repofts containing the information specified in
paragraphs (b)( I ) through (6) of this section to the Administrator and perfonnance test reports as
specified in paragraph (b)(7) or (8) of this section. The initial annual report is due no later than 90 days
after the end of the initial compliance period as determined according to $ 60.5410. Subsequent annual
reports are due no later than same date each year as the initial annual report. If you o\,vn or operate
more than one affected facility, you may submit one report for multiple affected facilities provided the
report contains all of the infonlation required as specit-red in paragraphs (bXl)through (6) of this
section. Annual reports may coincide with title V reports as long as all the required elements of the
annual report are included. You may arrange with the Administrator a common schedule on which
reports required by this part may be submitted as long as the schedule does not extend the reporting
period.
( I ) The general information specified in paragraphs (bX I )(i) through (iv) of this section.
(i) The company name and address of the affected facility.
(ii) An identification of each aftected thcility being included in the annual report.
(iii) Beginning and ending dates of the reporting periocl.
(iv) A certification by a certifying official of tmth. accrrracy. and completeness. This certitlcation
shallstate that, based on infbnnation and belief tbnned afier reasonable inquiry, the statenlents and
intbrmation in the document are truc, accuratc, and complctc.
(4) For each reciprocating compressor affectcd facility. thc inlonnation spccified in paragraphs
(bX4Xi) through (ii) of this section.
(i) The cumulative number of hours of operation or the number of months since initial startup,
since October 15,2012, or since the previous reciprocating compressor rod packing replacement.
whichever is later.
(ii) Records of deviations specified in paragraph (cX3)(iii) of this section that occurrcd dr"rring the
reporting period.
(c) Recordkeeping requirements. You must maintain the records identified as specitied in $ 60.7(t) and
in paragraphs (cXl) through (14) of this section. All records required by this subpart must be
maintained either onsite or at the nearest local treld otllce tbr at least -5 years.
(3) For each reciprocatin-q compressors aft'ected tacility, you must maintain the records in paragraphs
(c)(3Xi) through (iii) of this section.
(i) Records of the cumulative number of hours of operation or number of months since initial
startup or October | 5. 2012, or the previous replacement of the reciprocating compressor rod
packing, whichever is later.
(ii) Records of the date and time of each reciprocating compressor rod packing replacement, or
date of installation of a rod packing emissions collection system and closed vent system as
specified in $ 60.5385(aX3)
(iii) Records of deviations in cases r,vhere the reciprocating compressor was not operated in
compliance with the requirements specified in $ 60.5385.