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HomeMy WebLinkAboutDAQ-2024-0073611 DAQC-CI130090001-24 Site ID 13009 (B1) MEMORANDUM TO: FILE – MONARCH NATURAL GAS, LLC – Gate Canyon Natural Gas Compressor Station THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Paul Bushman, Environmental Scientist DATE: March 27, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Carbon County INSPECTION DATE: March 20, 2024 SOURCE LOCATION: Remote location Carbon County, UT DIRECTIONS: Near Nine Mile Canyon SOURCE CONTACTS: Glen Hicks, Environmental Contact O: 832-280-5072, C: 724-263-6199 ghicks@mngllc.com OPERATING STATUS: Temporarily down due to low natural gas prices. PROCESS DESCRIPTION: Natural gas is routed into the facility via pipeline. The gas is then sent through a dehydration unit before being compressed and routed back into the pipeline. Liquids recovered from the gas are stored in a 300 bbl condensate tank and a 100 bbl water tank. Emissions from the storage tanks and vapor collection system are routed to a flare. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN130090005-11, dated December 6, 2011 NSPS (Part 60) JJJJ : Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, MACT (Part 63) – HH: National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Monarch Natural Gas, LLC- Gate Canyon Natural Gas Compressor Station 5613 DTC Parkway, Suite 200 Remote location Greenwood Village, CO 80111 Carbon County, UT SIC Code: 1311: (Crude Petroleum & Natural Gas) 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] Status: In Compliance. No limits appear to have been exceeded. 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] Status: In Compliance. No modifications to the equipment or processes were observed during the inspection. 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] Status: In Compliance. Records are kept as required and were made available to be reviewed upon request. 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] Status: In Compliance. The equipment appeared to be maintained and operated in a manner consistent with good air pollution control practices. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns have been reported. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. An emissions inventory was submitted for the 2020 operating year. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Gate Canyon Compressor Station Natural gas compressor station II.A.2 Compressor Engine (E-2) One (1) compressor engine Capacity: 290 hp Fuel: natural gas Attached equipment: catalytic converter II.A.3 Natural Gas Dehydrator One (1) natural gas dehydration unit Solvent: triethylene glycol Attached equipment: 1,000,000 Btu/hr boiler and vapor collection system Fuel: natural gas II.A.4 Storage Tanks (T-1, T-2, T-3) Three (3) vertical, fixed-roof storage tanks Capacity: 12,600 gallons each Service: natural gas condensates Attached equipment: tank heaters rated at 125,000 Btu/hr each Fuel: natural gas II.A.5 Flare Device One (1) flare device Fuel: natural gas or vapor collection system gas II.A.6 Vapor Collection System With attached BTEX condenser and flare device II.A.7 Fugitives from condensate loading Truck loading Status: In Compliance. The compressor engine is an Ajax 360LE with SN: 83235. The dehydrator is a 250 kBtu/hr unit, and there is a 250 kBtu/hr line heater that is used seasonally. There is one unheated 300 bbl condensate tank, and one unheated 100 bbl water storage tank. The flare is a TCI 2000. II.B Requirements and Limitations II.B.1 The Gate Canyon Natural Gas Compressor Station shall be subject to the following. II.B.1.a Visible emissions from any stationary point or fugitive emission source associated with the plant operations or with the control facilities shall not exceed 10% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. No visible emissions were observed from any point during the inspection. II.B.1.b The following limit shall not be exceeded: 1,686,300 gallons of natural gas condensates throughput per rolling 12-month period. [R307-401-8] 4 II.B.1.b.1 A new 12-month total shall be calculated on a monthly basis by summing the monthly totals for the previous consecutive 12-months. Monthly calculations shall be made no later than 20 days after the end of each month. Records of condensate throughput shall be kept for all periods when the plant is in operation. Condensate throughput shall be determined by examination of company and/or customer billing records. The records of condensate throughput shall be kept on a daily basis. [R307-401-8] Status: In Compliance. Records reviewed show condensate throughput to be below the 1,686,300 gallon limit. II.B.1.c All exhaust air from the vapor collection system shall be routed through, and combusted within the flare device before being vented to the atmosphere. [R307-401-8] Status: In Compliance. 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. NSPS (Part 60) JJJJ : Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Status: In Compliance. The Ajax 360LE is required to submit an initial performance, but is not required to perform any subsequent performance tests unless the engine is rebuilt or undergoes major repair or maintenance. The initial performance test was conducted on June 30, 2009. A copy of the test can be found in DAQC-1365-21. MACT (Part 63) – HH: National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities Status: In Compliance. This subpart is applicable to the Gate Canyon Compressor station due to the use of triethylene glycol (TEG) as the scrubbing liquor in the dehydrator. Due to the throughput capacity and low concentrations of benzene, there are no emissions standards or compliance standards that apply. MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. Adhering to NSPS JJJJ requirements satisfies MACT ZZZZ. AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: Oil and Gas Industry: General Provisions [R307-501] Status: In Compliance. Monarch performs monthly flare inspections where the flare's pilot light function is verified, and that the flare is operating with no visible emissions. See attached records. 5 Oil and Gas Industry: Pneumatic Controllers. [R307-502] Status: In Compliance. The source does not use any continuous bleed pneumatic controllers at this compressor station. Oil and Gas Industry: Flares. [R307-503] Status: In Compliance. The flare onsite is equipped with an operational auto-igniter. Oil and Gas Industry: Tank Truck Loading [R307-504] Status: In Compliance. The source is equipped to load trucks through bottom filling. EMISSION INVENTORY: Listed before are the Actual Emissions Inventory provided from Monarch Natural Gas, LLC Gate Canyon Natural Gas Compressor Station. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN130090005-11, dated December 6, 2011, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr CO2 Equivalent 1884.00 N/A Carbon Monoxide 15.30 0.6961 Nitrogen Oxides 8.30 5.444 Particulate Matter - PM10 0.20 0.0857 Particulate Matter - PM2.5 0.20 0.0857 Sulfur Oxides 0.18 0.0010 Volatile Organic Compounds 21.10 6.8343 PREVIOUS ENFORCEMENT ACTIONS: No enforcement actions within the past five years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN130090005-11, dated December 6, 2011: In compliance at the time of inspection. The facility appears to be well maintained and operated. Required records were current and made available after the inspection via email. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Inspect at the typical inspection frequency for this type of source. ATTACHMENTS: Applicable supporting documentation included. Date Suction PSI Discharge PSI Flow MCF Fuel, Gas MCF Fuel Gas PSI Down Hours Dehy Hrs Ran Yesterday MCF Questar MCF Difference of Questar and Meter Total Comments Feet Inches BBLS Feet Inches BBLS BBLS Bom 0 0 0 1 72 615 699 43 18 0 24 381 330 51 4 0 80 3 2 36 116 2 73 600 338 42 18 0 24 473 420 53 4 0 80 3 2 36 116 3 72 605 669 43 18 0 24 473 420 53 4 0 80 3 2 36 116 4 72 604 570 43 18 0 24 385 356 29 4 0 80 3 7 41 121 5 72 616 135 37 18 0 24 325 354 (29)4 0 80 3 7 41 121 6 72 611 254 44 18 0 24 425 379 46 4 0 80 3 7 41 121 7 76 623 515 41 18 0 24 408 359 49 4 0 80 3 7 41 121 8 79 633 642 45 18 0 24 410 360 50 4 0 80 3 7 41 121 9 80 609 367 45 18 0 24 409 356 53 4 0 80 3 7 41 121 10 79 680 550 44 18 0 24 419 376 43 4 0 80 3 7 41 121 11 80 643 162 43 18 0 24 446 394 52 4 0 80 3 7 41 121 12 80 615 505 44 18 0 24 408 354 54 4 0 80 3 7 41 121 13 80 568 181 45 18 0 24 388 335 53 4 0 80 3 7 41 121 14 80 607 326 44 18 0 24 392 343 49 4 0 80 3 7 41 121 15 80 621 137 43 18 0 24 409 360 49 4 0 80 3 7 41 121 dominion site was down 16 80 613 222 43 18 0 24 396 351 45 4 0 80 3 7 41 121 17 80 608 547 44 18 0 24 469 416 53 4 0 80 3 7 41 121 18 80 597 200 44 18 0 24 433 381 52 4 0 80 3 7 41 121 19 80 604 243 44 18 0 24 284 230 54 4 0 80 3 7 41 121 20 80 632 439 45 18 0 24 242 191 51 4 0 80 3 7 41 121 21 80 622 0 45 18 0 24 221 151 70 4 0 80 3 7 41 121 22 80 605 239 45 18 0 24 221 159 62 4 0 80 3 7 41 121 23 81 594 280 43 18 0 24 226 164 62 4 0 80 3 7 41 121 24 81 588 347 44 18 0 24 243 189 54 4 0 80 3 7 41 121 25 81 591 622 44 18 0 24 377 332 45 4 0 80 3 7 41 121 26 80 587 0 44 18 0 24 384 337 47 4 0 80 3 7 41 121 27 81 601 569 44 18 0 24 418 371 47 4 0 80 3 7 41 121 28 80 607 608 42 18 0 24 428 376 52 4 0 80 3 7 41 121 29 80 604 484 43 18 0 24 399 355 44 4 0 80 3 7 41 121 30 80 602 445 43 18 0 24 399 346 53 4 0 80 3 7 41 121 31 82 570 120 43 18 0 24 393 345 48 4 0 80 3 7 41 121 Totals and Averages 78 609 368 1,346 18 0 744 11,684 10,190 1,494 300 bbl tank 100 bbl tank Gate Canyon Compressor Site January-00 COMPRESSOR STATISTICS Pig Tank Sump Tank LB RB I I E E #1 #1 #2 #2 #3 #3 Current Kill Setting Suc.Dish.#4 #4 P1 90 25/130 T1 181 #5 #5 P2 260 75/350 T2 218 #6 #6 P3 620 100/750 T3 #7 #7 P4 T4 #8 #8 P5 T5 #9 #9 P6 T6 #10 #10 Eop.RPM Overspeed 440 #11 #11 Cop.#12 #12 Tawp.#13 #13 Ejwp.16 #14 #14 Eot.#15 #15 Cot.#16 #16 Ejwt 127 Tawt. 61 Eng. Man. Psi/Hg. R Eng. Man. Psi/Hg. L Engine Hours: Volume: Coalescer Diff Oil Filter Diff. Process Diff. #1 513 #2 532 #3 Diff.Pressure drop #4 #5 #6 0.5 0 #7 #8 #9 #10 #11 #12 #13 #14 #15 #16 FIELD SERVICE ORDER DATE: change air filters, change spark plugs, grease cooler, do panel check, check belts. rebuild injection pump, install new coils and repair wires to the coils. 313 Kill Setting COUNTY/STATE: Engine Timing Unit number TECH NAME: Lease name:Gate Canyon 2/10/2023 Duchesne/Utah 321 327 Al Kettle 20 16 65037 Frick Information Eng. Exhaust Tempature Fuel Psi O2 Setting Eng. Thrust Comp. Thrust Coupl. Alignment CommentsQuantity Received Quantity Used Part Number Part Description Warehouse Work Description: Technician Last Diff status date 12/7/2018 Catalyst FIELD SERVICE ORDER Emplyee Signature Catalyst Serial's/ CommentCatalyst Status 0.50 LB RB I I E E #1 #1 #2 #2 #3 #3 Current Kill Setting Suc.Dish.#4 #4 P1 75 25/130 T1 204 #5 #5 P2 250 75/350 T2 244 #6 #6 P3 640 100/750 T3 #7 #7 P4 T4 #8 #8 P5 T5 #9 #9 P6 T6 #10 #10 Eop.RPM Overspeed 440 #11 #11 Cop.#12 #12 Tawp.#13 #13 Ejwp.16 #14 #14 Eot.#15 #15 Cot.#16 #16 Ejwt 125 Tawt. 80 Eng. Man. Psi/Hg. R Eng. Man. Psi/Hg. L Engine Hours: Volume: Coalescer Diff Oil Filter Diff. Process Diff. #1 560 #2 500 #3 Diff.Pressure drop #4 #5 #6 0.5 0 #7 #8 #9 #10 #11 #12 #13 #14 #15 #16 FIELD SERVICE ORDER Emplyee Signature Catalyst Serial's/ CommentCatalyst Status 0.50 Technician Last Diff status date 12/7/2018 Catalyst Work Description: CommentsQuantity Received Quantity Used Part Number Part Description Warehouse Al Kettle 20 16 67051 Frick Information Eng. Exhaust Tempature Fuel Psi O2 Setting Eng. Thrust Comp. Thrust Coupl. Alignment FIELD SERVICE ORDER DATE: change air filters, change spark plugs, grease cooler, do panel check, check belts. 308 Kill Setting COUNTY/STATE: Engine Timing Unit number TECH NAME: Lease name:Gate Canyon 5/5/2023 Duchesne/Utah 321 327 LB RB I I E E #1 #1 #2 #2 #3 #3 Current Kill Setting Suc.Dish.#4 #4 P1 75 25/130 T1 235 #5 #5 P2 250 75/350 T2 283 #6 #6 P3 610 100/750 T3 #7 #7 P4 T4 #8 #8 P5 T5 #9 #9 P6 T6 #10 #10 Eop.RPM Overspeed 440 #11 #11 Cop.#12 #12 Tawp.#13 #13 Ejwp.16 #14 #14 Eot.#15 #15 Cot.#16 #16 Ejwt 133 Tawt. 101 Eng. Man. Psi/Hg. R Eng. Man. Psi/Hg. L Engine Hours: Volume: Coalescer Diff Oil Filter Diff. Process Diff. #1 517 #2 474 #3 Diff.Pressure drop #4 #5 #6 0.5 0 #7 #8 #9 #10 #11 #12 #13 #14 #15 #16 FIELD SERVICE ORDER Emplyee Signature Catalyst Serial's/ CommentCatalyst Status 0.50 Technician Last Diff status date 12/7/2018 Catalyst Work Description: CommentsQuantity Received Quantity Used Part Number Part Description Warehouse Al Kettle 20 16 68965 Frick Information Eng. Exhaust Tempature Fuel Psi O2 Setting Eng. Thrust Comp. Thrust Coupl. Alignment FIELD SERVICE ORDER DATE: change air filters, change spark plugs, grease cooler, do panel check, check belts. 306 Kill Setting COUNTY/STATE: Engine Timing Unit number TECH NAME: Lease name:Gate Canyon 7/24/2023 Duchesne/Utah 321 327 LB RB I I E E #1 #1 #2 #2 #3 #3 Current Kill Setting Suc.Dish.#4 #4 P1 75 25/130 T1 245 #5 #5 P2 250 75/350 T2 272 #6 #6 P3 630 100/750 T3 #7 #7 P4 T4 #8 #8 P5 T5 #9 #9 P6 T6 #10 #10 Eop.RPM Overspeed 440 #11 #11 Cop.#12 #12 Tawp.#13 #13 Ejwp.16 #14 #14 Eot.#15 #15 Cot.#16 #16 Ejwt 133 Tawt. 85 Eng. Man. Psi/Hg. R Eng. Man. Psi/Hg. L Engine Hours: Volume: Coalescer Diff Oil Filter Diff. Process Diff. #1 576 #2 476 #3 Diff.Pressure drop #4 #5 #6 0.5 0 #7 #8 #9 #10 #11 #12 #13 #14 #15 #16 FIELD SERVICE ORDER Emplyee Signature Catalyst Serial's/ CommentCatalyst Status 0.50 Technician Last Diff status date 12/7/2018 Catalyst Work Description: CommentsQuantity Received Quantity Used Part Number Part Description Warehouse Al Kettle 20 16 70039 Frick Information Eng. Exhaust Tempature Fuel Psi O2 Setting Eng. Thrust Comp. Thrust Coupl. Alignment FIELD SERVICE ORDER DATE: change air filters, change spark plugs, grease cooler, do panel check, check belts. clean pre cumbustion chamber check valves 313 Kill Setting COUNTY/STATE: Engine Timing Unit number TECH NAME: Lease name:Gate Canyon 9/7/2023 Duchesne/Utah 321 327 LB RB I I E E #1 #1 #2 #2 #3 #3 Current Kill Setting Suc.Dish.#4 #4 P1 85 25/130 T1 225 #5 #5 P2 290 75/350 T2 262 #6 #6 P3 680 100/750 T3 #7 #7 P4 T4 #8 #8 P5 T5 #9 #9 P6 T6 #10 #10 Eop.RPM Overspeed 440 #11 #11 Cop.#12 #12 Tawp.#13 #13 Ejwp.16 #14 #14 Eot.#15 #15 Cot.#16 #16 Ejwt 131 Tawt. 85 Eng. Man. Psi/Hg. R Eng. Man. Psi/Hg. L Engine Hours: Volume: Coalescer Diff Oil Filter Diff. Process Diff. #1 580 #2 563 #3 Diff.Pressure drop #4 #5 #6 0.5 0 #7 #8 #9 #10 #11 #12 #13 #14 #15 #16 FIELD SERVICE ORDER DATE: change air filters, change spark plugs, grease cooler, do panel check, check belts. rebuil injector #1 308 Kill Setting COUNTY/STATE: Engine Timing Unit number TECH NAME: Lease name:Gate Canyon 11/6/2023 Duchesne/Utah 321 327 Al Kettle 20 16 71482 Frick Information Eng. Exhaust Tempature Fuel Psi O2 Setting Eng. Thrust Comp. Thrust Coupl. Alignment CommentsQuantity Received Quantity Used Part Number Part Description Warehouse Work Description: Technician Last Diff status date 12/7/2018 Catalyst FIELD SERVICE ORDER Emplyee Signature Catalyst Serial's/ CommentCatalyst Status 0.50