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HomeMy WebLinkAboutDAQ-2024-0104511 DAQC-961-24 Site ID 11532 (B1) MEMORANDUM TO: FILE – DOMINION ENERGY – Kastler Station THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Jeremiah Marsigli, Environmental Scientist DATE: September 24, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Major, Daggett County, FRS ID# UT0000004900900001 INSPECTION DATE: August 28, 2024 SOURCE LOCATION: Kastler/Marushack Compressor Station, Clay Basin, Daggett County. From Main Street in Vernal, travel north approximately 34.5 miles on Highway 191 to where it splits into 191 and 44. Take a right, staying on 191 towards Dutch John and the dam. Continue from the split for 17.4 miles toward Rock Springs, Wyoming. Travel southeast on the road marked with a Clay Basin/Brown’s Park sign approximately 0.5 miles and over the Wyoming border. Travel 11.812 miles on this road that includes paved and unpaved sections to the left split in the road to the plant which is 1.9 miles away. The entrance gate is on the north side of the fenced property. MAILING ADDRESS: Dominion Energy Questar Pipeline, LLC 1140 West 200 South P.O. Box 45360 Salt Lake City, UT 84145-0360 SOURCE CONTACTS: Scott Bassett, Environmental and Safety Coordinator: 801-324-3820 Dani Baldwin, Environmental Specialist III: C: 801-201-0595, O: 801-324-3062 Troy Gale, Operations Supervisor: 307-352-7457 Tracy Richmond, Operations Supervisor: 307-352-7807 OPERATING STATUS: ICE-1 (Marushack)– units 6 and 7 operating ICE-3 (Kastler) – units 1-2 operating 0 3 2 PROCESS DESCRIPTION: Natural gas arrives at the Kastler Compressor Station via pipeline from several well sites in the area. Natural gas powered turbine-driven and NG fired reciprocating compressors are used to compress the gas from the pipeline into several underground storage wells during the summer months when natural gas usage is low. During high usage months, the natural gas is pumped from the wells through dehydration units. These units remove water from the gas stream by bubbling the gas through ethylene glycol, which chemically pulls the water molecules from the gas. The water is later removed from the ethylene glycol by heating the liquid with a natural gas burner that forces the water to evaporate from the solution. The gas, which is now free of water, is then compressed as needed for entry into the main gas line for shipment to the consumer. Emergency generators, which are powered by natural gas turbine engines, are used at the facility on a standby basis when electrical service is interrupted. A natural gas fired boiler is also used on site for heating purposes and to provide hot water and steam at the facility. To control emissions, Dominion Energy is using NG fuel and limits the operating hours on turbines and generators. APPLICABLE REGULATIONS: Title V operating permit 900001005, revised October 31, 2023 SOURCE INSPECTION EVALUATION: SECTION I: GENERAL PROVISIONS I.A Federal Enforcement. All terms and conditions in this permit, including those provisions designed to limit the potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990 (CAA) except those terms and conditions that are specifically designated as "State Requirements." (R307-415-6b) Status: This is not an inspection item. I.B Permitted Activity(ies). Except as provided in R307-415-7b(1), the permittee may not operate except in compliance with this permit. (See also Provision I.E, Application Shield) Status: In Compliance. The source appeared to be operating in compliance with the conditions of this permit. See each condition below for more specific details. I.C Duty to Comply. I.C.1 The permittee must comply with all conditions of the operating permit. Any permit noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of 3 the following: enforcement action; permit termination; revocation and reissuance; modification; or denial of a permit renewal application. (R307-415-6a(6)(a)) I.C.2 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. (R307-415-6a(6)(b)) I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director copies of records required to be kept by this permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e)) I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance shall not stay any permit condition, except as provided under R307-415-7f(1) for minor permit modifications. (R307-415-6a(6)(c)) Status: In Compliance. The source appeared to be operating in compliance with the conditions of this permit. See each condition below for more specific details. I.D Permit Expiration and Renewal. I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under "Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2)) I.D.2 Application for renewal of this permit is due on or before the date shown under "Enforceable Dates and Timelines" at the front of this permit. An application may be submitted early for any reason. (R307-415-5a(1)(c)) I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for processing, but shall not be considered a timely application and shall not relieve the permittee of any enforcement actions resulting from submitting a late application. (R307-415-5a(5)) I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted consistent with R307-415-7b (see also Provision I.E, Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2)) Status: This permit has not expired. I.E Application Shield. If the permittee submits a timely and complete application for renewal, the permittee's failure to have an operating permit will not be a violation of R307-415, until the Director takes final action on the permit renewal application. In such case, the terms and conditions of this permit shall remain in force until permit renewal or denial. This protection shall cease to apply if, subsequent to the completeness determination required pursuant to 4 R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing by the Director any additional information identified as being needed to process the application. (R307-415-7b(2)) Status: This permit expires September 26, 2027. Application for renewal is due by March 26, 2027. I.F Severability. In the event of a challenge to any portion of this permit, or if any portion of this permit is held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5)) Status: This is not an inspection item. I.G Permit Fee. I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9. (R307-415-6a(7)) I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a)) Status: In Compliance. Permit fees have been paid as invoiced. I.H No Property Rights. This permit does not convey any property rights of any sort, or any exclusive privilege. (R307-415-6a(6)(d)) Status: This is not an inspection item. I.I Revision Exception. No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are provided for in this permit. (R307-415-6a(8)) Status: This is not an inspection item. I.J Inspection and Entry. I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Director or an authorized representative to perform any of the following: I.J.1.a Enter upon the permittee's premises where the source is located or emissions related activity is conducted, or where records are kept under the conditions of this permit. (R307-415-6c(2)(a)) I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit. (R307-415-6c(2)(b)) 5 I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practice, or operation regulated or required under this permit. (R307-415-6c(2)(c)) I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with this permit or applicable requirements. (R307-415-6c(2)(d)) I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e)) Status: In Compliance. Entry was allowed during this inspection. Records were provided as requested. I.K Certification. Any application form, report, or compliance certification submitted pursuant to this permit shall contain certification as to its truth, accuracy, and completeness, by a responsible official as defined in R307-415-3. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (R307-415-5d) Status: In Compliance. All application forms, reports, or compliance certifications submitted pursuant to this permit in the past year appear to have contained certification as to its truth, accuracy, and completeness by a responsible individual as defined in R307-415-3. I.L Compliance Certification. I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices. This certification shall be submitted no later than the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that date each year following until this permit expires. The certification shall include all the following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5)) I.L.1.a The identification of each term or condition of this permit that is the basis of the certification; I.L.1.b The identification of the methods or other means used by the permittee for determining the compliance status with each term and condition during the certification period. Such methods and other means shall include, at a minimum, the monitoring and related recordkeeping and reporting requirements 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 Act, which prohibits knowingly making a false certification or omitting material information; I.L.1.c The status of compliance with the terms and conditions of the permit for the period covered by the certification, including whether compliance during the period was continuous or intermittent. The certification shall be based on the method or means designated in Provision I.L.1.b. The certification shall identify each deviation and 6 take it into account in the compliance certification. The certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 occurred; and I.L.1.d Such other facts as the Director may require to determine the compliance status. I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the following address or to such other address as may be required by the Director: (R307-415-6c(5)(d)) Environmental Protection Agency, Region VIII Office of Enforcement, Compliance and Environmental Justice (mail code 8ENF) 1595 Wynkoop Street Denver, CO 80202-1129 Status: In Compliance. The last certification was received by DAQ on January 23, 2024. This report was reviewed under separate cover and found to meet the requirements of this condition. I.M Permit Shield. I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable requirements as of the date of this permit, provided that: I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or (R307-415-6f(1)(a)) I.M.1.b Those requirements not applicable to the source are specifically identified and listed in this permit. (R307-415-6f(1)(b)) I.M.2 Nothing in this permit shall alter or affect any of the following: I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a)) I.M.2.b The liability of the owner or operator of the source for any violation of applicable requirements under Utah Code Ann. Section 19-2-107(2)(a)(xiii) and Section 19-2-110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)) I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a). (R307-415-6f(3)(c)) I.M.2.d The ability of the Director to obtain information from the source under Utah Code Ann. Section 19-2-120, and the ability of the EPA to obtain information from the source under the CAA Section 114. (R307-415-6f(3)(d)) Status: This is not an inspection item. I.N Emergency Provision. 7 I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error. (R307-415-6g(1)) I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology-based emission limitations if the affirmative defense is demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that: I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency. (R307-415-6g(3)(a)) I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b)) I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in this permit. (R307-415-6g(3)(c)) I.N.2.d The permittee submitted notice of the emergency to the Director within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirement of Provision I.S.2.c below. (R307-415-6g(3)(d)) I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. (R307-415-6g(4)) I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any other section of this permit. (R307-415-6g(5)) Status: In Compliance. No emergency events were reported or recorded during the 12-month period preceding this inspection. I.O Operational Flexibility. Operational flexibility is governed by R307-415-7d(1). Status: This is not an inspection item. I.P Off-permit Changes. Off-permit changes are governed by R307-415-7d(2). Status: This is not an inspection item. I.Q Administrative Permit Amendments. 8 Administrative permit amendments are governed by R307-415-7e. Status: This is not an inspection item. I.R Permit Modifications. Permit modifications are governed by R307-415-7f. Status: This is not an inspection item. I.S Records and Reporting. I.S.1 Records. I.S.1.a The records of all required monitoring data and support information shall be retained by the permittee for a period of at least five years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records, all original strip-charts or appropriate recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. (R307-415-6a(3)(b)(ii)) I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record the following information, where applicable: (R307-415-6a(3)(b)(i)) I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement. I.S.1.b.2 The date analyses were performed. I.S.1.b.3 The company or entity that performed the analyses. I.S.1.b.4 The analytical techniques or methods used. I.S.1.b.5 The results of such analyses. I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement. I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special Provisions. I.S.2 Reports. I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more frequently if specified in Section II. All instances of deviation from permit requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i)) I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i) 9 I.S.2.c The Director shall be notified promptly of any deviations from permit requirements including those attributable to upset conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventative measures taken. Prompt, as used in this condition, shall be defined as written notification within the number of days shown under "Enforceable Dates and Timelines" at the front of this permit. Deviations from permit requirements due to breakdowns shall be reported in accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii)) I.S.3 Notification Addresses. I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Director are to be sent to the following address or to such other address as may be required by the Director: Utah Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114-4820 Phone: 801-536-4000 I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to the EPA should be sent to one of the following addresses or to such other address as may be required by the Director: For annual compliance certifications: Environmental Protection Agency, Region VIII Office of Enforcement, Compliance and Environmental Justice (mail code 8ENF) 1595 Wynkoop Street Denver, CO 80202-1129 For reports, notifications, or other correspondence related to permit modifications, applications, etc.: Environmental Protection Agency, Region VIII Air Permitting and Monitoring Branch (mail code 8ARD-PM) 1595 Wynkoop Street Denver, CO 80202-1129 Phone: 303-312-7015 Status: In Compliance. Records are kept as required. Monitoring reports have been submitted every six months. No deviations have been recorded or reported. I.T Reopening for Cause. I.T.1 A permit shall be reopened and revised under any of the following circumstances: I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit term of three or more years. No such reopening is required if the effective date of the requirement is later than the date on which this permit is due to 10 expire, unless the terms and conditions of this permit have been extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a)) I.T.1.b The Director or EPA determines that this permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of this permit. (R307-415-7g(1)(c)) I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure compliance with applicable requirements. (R307-415-7g(1)(d)) I.T.1.d Additional applicable requirements are to become effective before the renewal date of this permit and are in conflict with existing permit conditions. (R307-415-7g(1)(e)) I.T.2 Additional requirements, including excess emissions requirements, become applicable to a Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated into this permit. (R307-415-7g(1)(b)) I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. (R307-415-7g(2)) Status: This is not an inspection item. I.U Inventory Requirements. An emission inventory shall be submitted in accordance with the procedures of R307-150, Emission Inventories. (R307-150) Status: In Compliance. Emission inventories have been submitted as required. I.V Title IV and Other, More Stringent Requirements Where an applicable requirement is more stringent than an applicable requirement of regulations promulgated under Title IV of the Act, Acid Deposition Control, both provisions shall be incorporated into this permit. (R307-415-6a(1)(b)) Status: This is not an inspection item. SECTION II: SPECIAL PROVISIONS II.A Emission Unit(s) Permitted to Discharge Air Contaminants. (R307-415-4(3)(a) and R307-415-4(4)) II.A.1 Permitted Source Source-wide 11 II.A.2 ICE-1: Turbines for Gas Compression Three pipeline quality natural gas-fired turbines rated at 5,152 Hp each. Turbines are used to compress gas and each turbine is equipped with low NOx burners. II.A.3 ICE-2: Turbines for Backup Power Two pipeline quality natural gas-fired turbines rated at 800 kW each. Turbines used to generate backup power only. II.A.4 ICE-3: Internal Combustion Engines Five pipeline quality natural gas-fired four-stroke lean burn (4SLB) reciprocating internal combustion engines (ICE) rated at 2,600 Hp each. These reciprocating ICEs are used to compress gas. II.A.5 ICE-4: Internal Combustion Engine - Controlled One pipeline quality natural gas-fired four-stroke rich burn (4SRB) reciprocating internal combustion engine (ICE) rated at 1,680 Hp. The engine is equipped with three-way non-selective catalytic reduction and is used to compress gas. II.A.6 EC-1: Hot Water Boilers Pipeline quality natural gas-fired hot water boilers rated at no more than 9 MMBtu/hr combined. No unit- specific applicable requirements. II.A.7 EC-2: Miscellaneous Heating Units Pipeline-quality natural gas-fired heating units rated at no more than 9 MMBtu/hr combined. II.A.8 TNK-1: Condensate Tanks Three condensate tanks, 16,800 gallons each. No unit-specific applicable requirements. II.A.9 TNK-2: Underground Gasoline Storage Tank One 12,000-gallon underground gasoline storage tank. II.A.10 TNK-3: Diesel Tank One 940-gallon diesel storage tank. No unit-specific applicable requirements. II.A.11 TNK 4: Triethylene Glycol Tanks Two triethylene glycol storage tanks, 15,000 gallons combined. No unit-specific applicable requirements. II.A.12 TNK-5: Ambitrol Tanks Two 3,178-gallon ethylene glycol storage tanks. No unit-specific applicable requirements. II.A.13 TNK-6: Reflux Produced Water Tanks Two produced water storage tanks, 5,000 gallons combined. No unit-specific applicable requirements. II.A.14 TNK-7: Waste Water Tank One 2,520-gallon waste water storage tank. II.A.15 TNK-8: Waste Oil Tanks Three waste oil storage tanks, no more than 22,000 gallons combined. No unit-specific applicable requirements. II.A.16 TNK-9: Propane Refrigerant Make-up Tanks Four propane tanks, 1,000 gallons each. No unit-specific applicable requirements. 12 II.A.17 TNK-10: Oil Tanks One 2,500-gallon and one 5,000-gallon oil storage tank. No unit-specific applicable requirements. II.A.18 TNK-11: Lube Oil Tanks Two lube oil storage tanks, 5,000 gallons combined. No unit-specific applicable requirements. II.A.19 TNK-12: Dew Point Plant Slop Tanks Two process waste storage tanks, 5,000 gallons combined. No unit-specific applicable requirements. II.A.20 TNK-13: Pressurized Condensate Tanks Two 45,000 gallon each pressurized condensate tanks associated with the loading rack in the Clay Basin Dew Point process unit. No unit-specific applicable requirements. II.A.21 TNK-14: Oil Expansion Tank One 6,900-gallon expansion tank for heat transfer oil associated with EC-3. No unit-specific applicable requirements. II.A.22 MISC-1: Venting of Natural Gas Fourteen vents for methane and ethane. No unit-specific applicable requirements. II.A.23 MISC-2: Miscellaneous Parts Cleaner Parts washer using mineral spirits. No unit-specific applicable requirements. II.A.24 MISC-3: Emergency Flare Vent pipe to remove any vapors that may be present in the DPP building and process piping during upset conditions. Controlled by an elevated flare. II.A.25 CBDP-1: Clay Basin Dew Point Process Unit CBDP-1 includes miscellaneous process stream equipment and fugitive emissions including pumps, compressors, pressure relief devices, open-ended valves and lines, valves, flanges and other connectors that are in VOC or wet gas service. Includes equipment in CBDP-2, CBDP-3, CBDP-4, EC-3, and TNK-13. II.A.26 CBDP-2: Liquid Hydrocarbon Loading Rack One liquid hydrocarbon loading rack controlled using a vapor balancing system. No unit-specific applicable requirements. II.A.27 CBDP-3: Ethylene Glycol Regenerator One rich/lean exchanger, one flash tank, and one still. A flare controls the reflux vent stream from the ethylene glycol regenerator. II.A.28 CBDP-4: JT Processing Skids Three JT processing skids, with a 3-phase separator and stabilizer tower, remove liquid hydrocarbons from the natural gas stream and lower the cricondentherm dew point of the gas. II.A.29 EC-3: Hot Oil Heater One pipeline quality natural gas-fired heater rated at 3.0 MMBtu/hr, used for heat transfer in the CBDP process unit. No unit-specific applicable requirements. II.A.30 NESHAP SI RICE: Reciprocating IC Engines Existing spark ignition (SI) reciprocating internal combustion engines (RICE) that commenced 13 construction or reconstruction before June 12, 2006. These units are subject to 40 CFR 63 Subpart ZZZZ and meet the criteria for remote defined in 40 CFR 63.6675. The unit includes the engines listed under unit ICE-3. Status: In Compliance. No unapproved equipment was observed onsite. II.B Requirements and Limitations The following emission limitations, standards, and operational limitations apply to the permitted facility as indicated: II.B.1 Conditions on permitted source (Source-wide). II.B.1.a Condition: Unless otherwise specified in this permit, at all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and operate any permitted plant equipment, 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. [Origin: DAQE-AN115320012-21]. [40 CFR 60.11(d), R307-401-8] II.B.1.a.1 Monitoring: Records required for this permit condition will serve as monitoring. II.B.1.a.2 Recordkeeping: Permittee shall document activities performed to assure proper operation and maintenance. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Dominion Energy’s Kastler Station appeared to be properly maintained and operated in a manner consistent with good air pollution control practice for minimizing emissions. The source uses work order software named ACTS to track and record maintenance activities. II.B.1.b Condition: Visible emissions shall be no greater than 10 percent opacity from all natural gas-fired emission units. [Origin: DAQE-AN115320012-21]. [R307-201-3, R307-401-8] II.B.1.b.1 Monitoring: Records required for this permit condition will serve as monitoring. 14 II.B.1.b.2 Recordkeeping: In lieu of monitoring via visible emission observations, the permittee shall keep one of the following sets of records for each affected emission unit, as applicable: (1) Documentation that the emission unit can only burn pipeline quality natural gas; (2) Documentation that the fuels other than pipeline quality natural gas cannot be supplied to the emission unit without modification of the fuel supply system; or (3) Fuel bills or fuel meter readings that demonstrate only pipeline quality natural gas are combusted in the emission unit. The permittee shall keep a log which includes the location and description of each affected emission unit. For each affected emission unit, the log shall include the type of records that will be used in lieu of monitoring via visible emission observations. If fuel bills or fuel meter readings will be used in lieu of monitoring via visible emission observations, the permittee shall review fuel bills or fuel meter readings once per quarter and record in the log the types of fuel combusted. The records and log required by this condition shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.b.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. The site was designed to operate on natural gas only. II.B.1.c Condition: 1) General requirements for prevention of emissions and use of good air pollution control practices. (a) All condensate, and intermediate hydrocarbon liquids collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize emission of VOCs to the atmosphere to the extent reasonably practicable. (b) At all times, including periods of start-up, shutdown, and malfunction, the installation and air pollution control equipment shall be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. (c) Determination of whether or not 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, infrared camera images, opacity observations, review of operating and maintenance procedures, and inspection of the source. 2) General requirements for air pollution control equipment. (a) All air pollution control equipment shall be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable and consistent with technological limitations and good engineering and maintenance practices. (b) In addition, all such air pollution control equipment shall be adequately designed and sized to achieve the control efficiency rates established in rules or in approval orders issued under R307- 401 and to handle reasonably foreseeable fluctuations in emissions of VOCs during normal operations. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. [Origin: R307-501-4]. [R307-501-4] 15 II.B.1.c.1 Monitoring: Records required for this permit condition will serve as monitoring. II.B.1.c.2 Recordkeeping: The permittee shall keep manufacturer specifications or equivalent on file and shall document activities performed to assure proper operation and maintenance. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.c.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Equipment design is evaluated during the approval and permitting processes. Equipment appeared to be maintained and operated in a manner consistent with good air pollution control practices. II.B.1.d Condition: A Risk Management Plan (RMP) developed in accordance with 40 CFR Part 68 shall be submitted to the United States Environmental Protection Agency not later than the applicable date in 40 CFR 68. [Origin: 40 CFR 68]. [40 CFR 68] II.B.1.d.1 Monitoring: Records required for this permit condition will serve as monitoring. II.B.1.d.2 Recordkeeping: A copy of the Risk Management Plan shall be available to the Director upon request. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.d.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. The most recently updated RMP was submitted to US EPA on August 15, 2023. II.B.1.e Condition: If materials that may create fugitive dust are deposited on a public or private paved road, the permittee shall clean the road promptly. [Origin: R307-205-6]. [R307-205-6(2)] II.B.1.e.1 Monitoring: Records required for this permit condition will serve as monitoring. 16 II.B.1.e.2 Recordkeeping: Records demonstrating compliance with this condition shall be maintained in accordance with Provision I.S.1 of this permit. II.B.1.e.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Most operational areas of this site are paved, including sections exiting the plant. The surrounding roads are gravel and dirt. Tracking materials from the site and depositing on these roads is negligent to non-existent, and likely would not alter the characteristics of these roads in the event material was deposited outside the plant areas. II.B.2 Conditions on Turbines for Gas Compression (ICE-1). II.B.2.a Condition: Sulfur content of any fuel burned shall be no greater than 0.8% by weight. [Origin: 40 CFR 60 Subpart GG]. [40 CFR 60.333(b)] II.B.2.a.1 Monitoring: The permittee shall demonstrate that any fuel burned meets the definition of natural gas in 40 CFR 60.331(u). To make the required demonstration, the permittee shall use the gas quality characteristics in a current, valid tariff sheet (Federal Energy Regulatory Commission (FERC) gas tariff) specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or less. [40 CFR 60.334(h)(3)(i)]. Records required for this permit condition will also serve as monitoring. II.B.2.a.2 Recordkeeping: The total sulfur limit in the FERC gas tariff shall be recorded and converted to percent sulfur by weight to determine the sulfur content. Records demonstrating compliance with this condition shall be maintained in accordance with Provision I.S.1 of this permit. II.B.2.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Only pipeline quality natural gas is burned. II.B.2.b Condition: Combined hours of operation shall be no greater than 24,120 hours per rolling 12-month period. [Origin: DAQE-AN115320012-21]. [R307-401-8] 17 II.B.2.b.1 Monitoring: An hour meter shall be used to continuously monitor the hours of operation for the affected equipment. Readings shall be taken monthly to determine the total operating hours for that month. Compliance with the limitation shall be determined on a rolling 12-month total. Each month, a new 12-month total shall be calculated using data from the previous 12 months. II.B.2.b.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.2.b.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. During the 12-month period ending July 31, 2024, 11,373 combined hours of operation were recorded for the three ICE-1 engines. II.B.2.c Condition: Emissions of NOx shall be no greater than 7.43 lb/hr and 0.0042% by volume (15% O2, dry) for each turbine. [Origin: DAQE-AN115320012-21]. [40 CFR 60 Subpart GG, R307-401-8] II.B.2.c.1 Monitoring: Stack testing shall be performed as specified here: (a) Frequency. Each unit shall be tested every five years, based on the date of the latest stack test. (b) Notification. At least 30 days before the test, the source shall notify the Director of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Director. (c) Sample Point The emission sample points shall be selected following Method 20 or Method 1 in accordance with 40 CFR 60.335(a)(4) and (5). (d) Methods (1) 40 CFR 60, Appendix A, Method 20; ASTM D6522-00; or 40 CFR 60, Appendix A, Method 7E and either 40 CFR 60, Appendix A Method 3 or 3A, to determine NOx and diluent concentration; (2) 40 CFR 60, Appendix A, Method 19 may be used to determine the volumetric flow rate based on the fuel flow determined by fuel gas meter and exhaust O2 concentration. (3) Fuel-bound nitrogen content factor F shall be 0; (e) Calculations. The nitrogen oxides emission rate (NOx) shall be computed for each run using the following equation: NOx=(NOxo) (Pr/Po)0.5 e19(Ho-0.00633) (288°K/Ta)1.53 where: NOx = emission rate of NOx at 15% O2 and ISO standard ambient conditions, volume percent. NOxo = observed NOx concentration, ppm by volume. 18 Pr = reference combustor inlet absolute pressure at 101.3 kilopascals ambient pressure, mm Hg. Po = observed combustor inlet absolute pressure at test, mm Hg. Ho = observed humidity of ambient air, g H2O/g air. e = transcendental constant, 2.718. Ta = ambient temperature, °K. To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director to give the results in the specified units of the emission limitation. (f) Production Rate During Testing. The operational rate during all compliance testing shall be no less than 90% of the maximum rate achieved in the previous three (3) years. II.B.2.c.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.2.c.3 Reporting: Results of required stack testing shall be submitted to the Director within 60 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit shall use the most recent test results as a basis for stating compliance status for this limitation. Status: In Compliance. NOx emissions from the ICE-1 Units #6 and #7 gas turbines was tested September 7-8, 2021. ICE-1 Unit #8 was last tested on April 24, 2023. DAQ calculated results of those tests were as follows: Unit# DAQ Result Limit #6 Turbine 0.76 lb/hr 7.43 lb/hr 0.0006% vol 0.0042% vol #7 Turbine 0.70 lb/hr 7.43 lb/hr #8 Turbine 0.65 lb/hr* 7.43 lb/hr *at max load II.B.2.d Condition: Emissions of CO shall be no greater than 5.38 lb/hr and 50 ppmdv (15% O2, dry) for each turbine. [DAQE-AN115320012-21]. [R307-401-8] II.B.2.d.1 Monitoring: Stack testing shall be performed as specified here: (a) Frequency. Test every five years (based on the date of the latest stack test) using 40 CFR 60, Appendix A, Method 10, 10A, or 10B or every two years with a portable testing monitor. If 19 a portable testing monitor is to be used, a correlation must be established during the initial test between the portable testing monitor and the reference method test. Subsequently, the portable testing monitor results shall be correlated with the results of the periodic reference method test at least once every five years. (b) Notification. At least 30 days before the test, the source shall notify the Director of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Director. (c) The emission sample point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1. (d) Methods to be used: (1) To determine stack volumetric flow rate - 40 CFR 60, Method 19 based on the fuel flow determined by fuel gas meter and exhaust O2 concentration. (2) To test for CO emissions - 40 CFR 60, Appendix A, Method 10, 10A, 10B, or other EPA-approved testing method acceptable to the Director. A portable testing monitor may be used in lieu of the reference test method provided the requirements of (a) are met. If the requirements of (a) are not met, the reference test method must be used for subsequent tests. (e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors to give the results in the specified units of the emission limitation. (f) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. II.B.2.d.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.2.d.3 Reporting: Results of required stack testing shall be submitted to the Director within 60 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit shall use the most recent test results as a basis for stating compliance status for this limitation. Status: In Compliance. CO emissions from the ICE-1 Units #6 and #7 gas turbines were tested September 7-8, 2021. ICE-1 Unit #8 was last tested on April 24, 2023. DAQ calculated results of those tests were as follows: Unit# DAQ Results Limit #6 Turbine 0.09 lbs/hr 5.38 lb/hr #7 Turbine 0.27 lb/hr 5.38 lb/hr #8 Turbine 0.35 lb/hr 5.38 lb/hr II.B.3 Conditions on Turbines for Backup Power (ICE-2). 20 II.B.3.a Condition: Combined hours of operation shall be no greater than 400 hours per rolling 12-month period. [Origin: DAQE-AN115320012-21]. [R307-401-8] II.B.3.a.1 Monitoring: An hour meter shall be used to continuously monitor the hours of operation for the affected equipment. Readings shall be taken monthly to determine the total operating hours for that month. Compliance with the limitation shall be determined on a rolling 12-month total. Each month, a new 12-month total shall be calculated using data from the previous 12 months. II.B.3.a.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.3.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. During the 12-month period ending July 31, 2024, 46 combined hours of operation were recorded for the two ICE-2 engines. II.B.3.b Condition: Emissions of NOx shall be no greater than 3.80 lb/hr and 76.4 ppmdv (15% O2, dry) for each generator. [Origin: DAQE-AN115320012-21]. [R307-401-8] II.B.3.b.1 Monitoring: Stack testing shall be performed as specified here: (a) Frequency. Test every five years (based on the date of the latest stack test) using 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E or every two years with a portable testing monitor. If a portable testing monitor is to be used, a correlation must be established during the initial test between the portable testing monitor and the reference method test. Subsequently, the portable testing monitor results shall be correlated with the results of the periodic reference method test at least once every five years. (b) Notification. At least 30 days before the test, the source shall notify the Director of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Director. (c) The emission sample point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1. (d) Methods to be used: (1) To determine stack volumetric flow rate - 40 CFR 60, Method 19 based on the fuel flow determined by fuel gas meter and exhaust O2 concentration. (2) To test for NOx emissions - 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing method acceptable to the Director. A portable testing monitor may be used in lieu of the reference test method provided the requirements of 21 (a) are met. If the requirements of (a) are not met, the reference test method must be used for subsequent tests. (e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors to give the results in the specified units of the emission limitation. (f) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. II.B.3.b.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.3.b.3 Reporting: Results of required stack testing shall be submitted to the Director within 60 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit shall use the most recent test results as a basis for stating compliance status for this limitation. Status: In Compliance. Stack testing was scheduled for July 20, 2023. Test results were submitted to DAQ and audited in DAQC-1244-23. DAQ calculated results of those tests were as follows: Unit# Emissions Limit Unit #1 0.24 lb/hr 3.8 lb/hr 42.4 ppmdv 76.4 ppmdv Unit #2 0.27 lb/hr 3.8 lb/hr 48.5 ppmdv 76.4 ppmdv II.B.3.c Condition: Sulfur content of any fuel burned shall be no greater than 0.8% by weight. [Origin: 40 CFR 60 Subpart GG]. [40 CFR 60.333(b)] II.B.3.c.1 Monitoring: The permittee shall demonstrate that any fuel burned meets the definition of natural gas in 40 CFR 60.331(u). To make the required demonstration, the permittee shall use the gas quality characteristics in a current, valid tariff sheet (FERC gas tariff) specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or less. [40 CFR 60.334(h)(3)(i)] Records required for this permit condition will also serve as monitoring. II.B.3.c.2 Recordkeeping: The total sulfur limit in the FERC gas tariff shall be recorded and converted to percent sulfur by weight to determine the sulfur content. Records demonstrating compliance with this condition shall be maintained in accordance with Provision I.S.1 of this permit. 22 II.B.3.c.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Only pipeline quality natural gas is burned. II.B.4 Conditions on Internal Combustion Engine - Controlled (ICE-4). II.B.4.a Condition: Emissions of NOx shall be no greater than 3.70 lb/hr. [Origin: DAQE-AN115320012-21]. [R307-401-8] II.B.4.a.1 Monitoring: I. Stack testing shall be performed as specified below: (a) Testing Frequency: Test every 2200 hours of operation or every five years (based on the date of the latest stack test), whichever comes first, using 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E. Additionally, if an excursion (as defined below) occurs, the unit shall be tested with a portable testing monitor upon restart. The portable testing monitor results shall be correlated with the results of the periodic reference method test at least once every five years. If testing is triggered by operating hours, the permittee shall perform the test within 90 days after reaching 2200 hours of operation. (b) Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. Notification shall not be required for post-excursion testing using the portable testing monitor. (c) Methods (1) Sample Location: The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) approved access shall be provided to the test location (2) Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2 or 40 CFR 60, Appendix A, Method 19 based on the fuel flow determined by fuel gas meter and exhaust gas O2 concentration. (3) Oxides of Nitrogen (NOx): 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA-approved testing method acceptable to the Director must be used for the initial test. After performing the initial test, a portable NOx monitor may be used in lieu of Method 7, 7A, 7B, 7C, 7D or 7E provided the requirements of I(a) are met. If the requirements of I(a) are not met, Method 7, 7A, 7B, 7C, 7D or 7E must be used for subsequent tests. (d) Calculations: To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. (e) Production Rate During Testing: The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. II. Monitor CAM Indicator #1 (Pressure drop across catalyst) in accordance with 40 CFR 64.7(c) when unit is operating. 23 (a) Measurement approach: Measure pressure drop across catalyst beds using a differential pressure gauge. (b) Indicator range: An excursion is defined as a pressure drop of two (2) inches of water or greater beyond the baseline value as determined in the most recent test, based on the measurement at the time of inspection. If an excursion occurs, corrective action will be taken in accordance with 40 CFR 64.7(d)(1). (c) Performance criteria: (1) Data representativeness: Pressure drop is measured at catalyst inlet and outlet during engine operation. (2) Verification of operational status: Pressure gauge is functioning correctly. (3) QA/QC practices and criteria: Pressure gauge shall be calibrated and pressure taps checked for plugging when gauge malfunction is evident during daily check. (4) Monitoring frequency: Differential pressure shall be continuously measured and inspected monthly to determine if a pressure drop excursion has occurred. (5) Data collection: Each monthly reading shall be documented by the observer. III. Monitor CAM Indicator #2 (Temperature of exhaust entering catalyst) in accordance with 40 CFR 64.7(c) when unit is operating. (a) Measurement approach: Temperature of gas flowing from the engine to the catalyst is measured using a thermocouple mounted in the gas stream. (b) Indicator range: An excursion is defined as a temperature outside the catalyst operating range of 750-1250 degrees F (399-676 degrees C), as read at the time of inspection. If an excursion occurs, corrective action will be taken in accordance with 40 CFR 64.7(d)(1). (c) Performance criteria: (1) Data representativeness: Temperature is measured at the inlet to the catalyst beds using a thermocouple. The thermocouple shall have a minimum accuracy of +/- 4 degrees F at typical catalyst temperatures. (2) Verification of operational status: No control system alarms or shutdowns have occurred. (3) QA/QC practices and criteria: Thermocouple is replaced when a malfunction is detected. (4) Monitoring frequency: Catalyst inlet temperature shall be measured continuously and inspected daily to determine if a temperature excursion has occurred. (5) Data collection: Each daily reading shall be documented by the observer. IV. During the stack test required in I. above, the permittee shall acquire new test data to evaluate or update the ranges and excursion levels for the two indicators. Any resultant changes to the monitoring shall be addressed in accordance with 40 CFR 64.7(e). II.B.4.a.2 Recordkeeping: Results of all monitoring shall be maintained as described in Provision I.S.1 of this permit. In addition, the permittee shall maintain a file of the occurrence and duration of any excursion, corrective actions taken, and any other supporting information required to be maintained under 40 CFR 64 (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions). Instead of paper records, the permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b)). 24 II.B.4.a.3 Reporting: I) Results of required stack testing shall be submitted to the Director within 60 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit shall use the most recent test results as a basis for stating compliance status for this limitation. II) In addition to the reporting requirements described in Provision I.S.2 of this permit, the monitoring report required by Provision I.S.2.a shall include, at a minimum, the following information, as applicable: (a) Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken. (40 CFR 64.9(a)(2)(i)) Status: In Compliance. ICE-4 was replaced in March 2023 and is now subject to Subpart JJJJ. Initial stack testing was performed July 18, 2023. Test results were submitted to DAQ and audited in DAQC-937-23. DAQ calculated results of those tests were as follows: Unit# Emissions (NOX) Limit ICE-4 0.1 lb/hr 3.70 lb/hr 2.2 ppmdv 82 ppmdv 0.0 g/bhp-hr 1.0 g/bhp-hr CAM is being conducted as required with each indicator being monitored and recorded. Daily log sheets were provided and showed temperature checks. Pressure drop has been monitored and recorded monthly. No excursions to the ranges listed above were logged in the records reviewed. Alarms are set to notify operators in the event an excursion is being approached. II.B.4.b Condition: Emissions of CO shall be no greater than 3.70 lb/hr. [Origin: DAQE-AN115320012-21]. [R307-401-8] II.B.4.b.1 Monitoring: Stack testing shall be performed as specified below: (a) Testing Frequency: Test every five years (based on the date of the latest stack test) using 40 CFR 60, Appendix A, Method 10 or every two years with a portable testing monitor. If portable testing monitor is to be used, a correlation must be established during the initial test between the portable testing monitor and Method 10. Subsequently, the portable testing monitor results shall be correlated with the results of the periodic reference method test at least once every five years. (b) Notification: The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. (c) Methods (1) Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A, Method 1, or other methods as approved by the Director. An Occupational Safety and Health Administration (OSHA) approved access shall be provided to the test location. (2) Volumetric Flow Rate 25 40 CFR 60, Appendix A, Method 2 or 40 CFR 60, Appendix A, Method 19 based on the fuel flow determined by fuel gas meter and exhaust gas O2 concentration. (3) Carbon Monoxide (CO) 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method acceptable to the Director must be used for the initial test. After performing the initial test, a portable CO monitor may be used in lieu of Method 10 provided the requirements of (a) are met. If the requirements of (a) are not met, Method 10 must be used for subsequent tests. (d) Calculations To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. (e) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. II.B.4.b.2 Recordkeeping: Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.4.b.3 Reporting: Results of required stack testing shall be submitted to the Director within 60 days of completion of the testing. The submittal shall clearly identify results and indicate compliance status. The annual compliance certification required by Provision L in Section I of this permit shall use the most recent test results as a basis for stating compliance status for this limitation. Status: In Compliance. Stack testing was scheduled for July 18-20, 2023. Test results were submitted to DAQ and audited in DAQC-937-23. DAQ calculated results of those tests were as follows: Unit# Emissions (CO) Limit ICE-4 1.4 lb/hr 3.70 lb/hr 38 ppmdv 270 ppmdv 0.4 g/bhp-hr 2.0 g/bhp-hr II.B.5 Conditions on Underground Gasoline Storage Tank (TNK-2) II.B.5.a Condition: The permittee shall not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following: i) Minimize gasoline spills; ii) Clean up spills as expeditiously as practicable; iii) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; iv) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators. At all times, the permittee shall operate and maintain any affected emission unit, including associated air 26 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 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 source. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [Origin: 40 CFR 63 Subpart CCCCCC]. [40 CFR 63.11111(b), 40 CFR 63.11115, 40 CFR 63.11116, 40 CFR 63.11130] II.B.5.a.1 Monitoring: Records required for this permit condition will serve as monitoring. Additionally, the permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]. II.B.5.a.2 Recordkeeping: The permittee shall keep records demonstrating monthly throughput is less than the 10,000-gallon threshold level. Records shall be available within 24 hours of a request by the Director to document gasoline throughput in the affected emission unit. [40 CFR 63.11111(e), 40 CFR 63.11116(b)] The permittee shall keep records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. Records shall be kept of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.11115(b), 40 CFR 63.11125(d)] The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130] Documentation shall be kept that demonstrates compliance with this provision. Records shall be maintained in accordance with Provision I.S.1. of this permit. II.B.5.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Items i) through iv) were implemented. Monthly throughput is tracked and recorded. Throughput records were provided, with no throughput greater than 10,000 gallons per month. II.B.6 Conditions on Emergency Flare (MISC-3) II.B.6.a Condition: 1. The permittee shall conduct a leak detection inspection for each new or modified fugitive emission component installed or modified as part of the project (MISC-3, Emergency Flare). Each individual 27 inspection shall encompass valve(s), flange(s) or other connection, pump(s), compressor(s), pressure relief device(s) or other vent(s), process drain(s), open-ended valve(s), pump seal(s), compressor seal(s), and access door seal(s) or other seal containing or contacting a process stream with hydrocarbons that is associated with the approved emission unit. Leak detection inspections shall be conducted at least once every 12 months after the initial leak detection inspection. 2. The permittee is exempt from inspecting a valve, flange or other connection, pump or compressor, pressure relief device, process drain, open-ended valve, pump or compressor seal system degassing vent, accumulator vessel vent, agitator seal, or access door seal under any of the following circumstances: A. The contacting process stream only contains glycol, amine, methanol, or produced water. B. Monitoring could not occur without elevating the monitoring personnel more than six feet above a supported surface or without the assistance of a wheeled scissor-lift or hydraulic type scaffold. C. Monitoring could not occur without exposing monitoring personnel to an immediate danger as a consequence of completing monitoring. D. The item to be inspected is buried, insulated in a manner that prevents access to the components by a monitor probe, or obstructed by equipment or piping that prevents access to the components by a monitor probe. [Origin: DAQE-AN115320012-21]. [R307-401-8] II.B.6.a.1 Monitoring: A. Inspections shall be conducted in one of two ways: i. An analyzer that meets U.S. EPA Method 21, 40 CFR Part 60, Appendix A ii. An optical gas imaging instrument as defined in 40 CFR 60.18(g)(4) The optical gas imaging instrument shall meet requirements specified in 40 CFR 60.18(i)(3). Any emissions detected with an optical gas imaging instrument shall be considered a leak in need of repair unless the permittee evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60 and the analyzer reading is less than 500 ppmv. A reading of 500 ppmv or greater shall be considered a leak in need of repair. Emissions detected from tank gauging, load-out operations, venting of pneumatics, properly operating pressure relief valves, or other maintenance activities shall not be considered leaks. B. If a leak is detected at any time, the permittee shall attempt to repair the leak no later than 5 calendar days after detection. Repair of the leak shall be completed no later than 15 calendar days after detection, unless parts are unavailable or unless repair is technically infeasible without a shutdown. The permittee shall inspect the repaired leak no later than 15 calendar days after the leak was repaired to verify that it is no longer leaking. If replacement parts are unavailable, the replacement parts must be ordered no later than 5 calendar days after detection, and the leak must be repaired no later than 15 calendar days after receipt of the replacement parts. If repair is technically infeasible without a shutdown, the leak must be repaired by the end of the next shutdown. If a shutdown is required to repair a leak, the shutdown must occur no later than 6 months after the detection of the leak unless the permittee demonstrates that emissions generated from the shutdown are greater than the fugitive emissions likely to result from delay of repair. 28 II.B.6.a.2 Recordkeeping: Records of inspections and leak detection and repair shall include the following: A. The date of the inspection B. The name of the person conducting the inspection C. Any component not exempt under II.B.6.a that is not inspected and the reason it was not inspected D. The identification of any component that was determined to be leaking E. All records shall be maintained for optical gas imaging instrument as per 40 CFR 60.18(i)(4)(vi) F. The date of first attempt to repair the leaking component G. Any component with a delayed repair H. The reason for a delayed repair i. For Unavailable Parts: a) The date of ordering a replacement component b) The date the replacement component was received ii. For a Shutdown: a) The reason the repair is technically infeasible b) The date of the shutdown c) Emission estimates of the shutdown and the repair if the delay is longer than 6 months I. Corrective action taken J. The date corrective action was completed K. The date the component was verified to no longer be leaking L. The records of each component exempt under II.B.6.a: i. Type of component ii. Description of qualifying exemption Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.6.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. The Dew Point Process Unit has not operated for over two years. When operating, this process vents to flare. Pressure relief devices are hard piped directly to flare, with no vents or valves to monitor. A leak detection has been implemented. The most recent annual leak inspection was performed October 18, 2023. Records were provided. II.B.6.b Condition: Flares used to control emissions of volatile organic compounds shall be equipped with and operate an auto-igniter. [Origin: R307-503-4]. [R307-503-4] II.B.6.b.1 Monitoring: Records required for this permit condition will serve as monitoring. 29 II.B.6.b.2 Recordkeeping: The permittee shall maintain records demonstrating the date of installation and manufacturer specifications for each auto-igniter required under R307-503-4. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.6.b.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. The flare was installed in March 2015 and became operational in May 2015. An auto-igniter is installed, along with an alarm to notify operators if the flare flames out. The flare is operated continuously with supplemental gas. II.B.7 Conditions on Ethylene Glycol Regenerator (CBDP-3) II.B.7.a Condition: Flares used to control emissions of volatile organic compounds shall be equipped with and operate an auto-igniter. [Origin: R307-503-4]. [R307-503-4] II.B.7.a.1 Monitoring: Records required for this permit condition will serve as monitoring. II.B.7.a.2 Recordkeeping: The permittee shall maintain records demonstrating the date of installation and manufacturer specifications for each auto-igniter required under R307-503-4. Records shall be maintained in accordance with Provision I.S.1 of this permit. II.B.7.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. An auto-igniter was installed during the initial construction. On February 13, 2020, this flare was replaced with a new in-kind unit and an auto-igniter was included. II.B.8 Conditions on Reciprocating IC Engines (NESHAP SI RICE). II.B.8.a Condition: At all times the permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the permittee to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review of operation and 30 maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6605(b)] II.B.8.a.1 Monitoring: Records required for this permit condition will serve as monitoring. II.B.8.a.2 Recordkeeping: The permittee shall keep records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR 63.6605(b), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this permit. II.B.8.a.3 Reporting: There are no reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Dominion Energy’s Kastler Station appeared to be properly maintained and operated in a manner consistent with good air pollution control practice for minimizing emissions. The source uses work order software named ACTS to track and record maintenance activities. II.B.8.b Condition: For existing, 4SLB, 4SRB, non-emergency, non-black start remote RICE > 500 hp: (1) The permittee shall evaluate the status of their stationary RICE every 12 months. If the evaluation indicates that the stationary RICE no longer meets the definition of remote stationary RICE in 40 CFR 63.6675, the permittee shall comply with all of the requirements for existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP that are not remote stationary RICE within 1 year of the evaluation. (2) Except during periods of startup, the permittee shall: (a) Change oil and filter every 2,160 hours of operation or annually, whichever comes first; (b) Inspect spark plugs every 2,160 hours of operation or annually, whichever comes first, and replace as necessary; and (c) Inspect all hoses and belts every 2,160 hours of operation or annually, whichever comes first, and replace as necessary. During periods of startup the source shall minimize the engine's time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. (3) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6603(a), 40 CFR 63.6603(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d(11), 40 CFR 63 Subpart ZZZZ Table 2d(8), 40 CFR 63 Subpart ZZZZ Table 8] II.B.8.b.1 Monitoring: 31 The permittee shall demonstrate continuous compliance by operating and maintaining the stationary RICE according to the manufacturer's emission-related written operation and maintenance instructions or develop and follow the permittee's own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. [40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6] The permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement in accordance with 40 CFR 63.6625(j). The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]. II.B.8.b.2 Recordkeeping: The permittee shall keep records of the initial and annual evaluation of the remote status of each affected emission unit. [40 CFR 63.6603(f)] The permittee shall keep records that demonstrate continuous compliance with each applicable operating limitation [including, but not limited to, the manufacturer's emission-related operation and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d), 40 CFR 63 Subpart ZZZZ Table 6] Records of the maintenance conducted shall be kept in order to demonstrate that the permittee operated and maintained the affected emission unit and after-treatment control device (if any) according to their own maintenance plan. [40 CFR 63.6655(e)] The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665] Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this permit. II.B.8.b.3 Reporting: Each instance in which the permittee did not meet each emission limitation or operating limitation in Table 2d in 40 CFR 63 Subpart ZZZZ shall be reported according to the requirements in 40 CFR 63.6650. [40 CFR 63.6640(b)] The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also report each instance in which it did not meet the applicable requirements in Table 8. [40 CFR 63.6640(e)] There are no additional reporting requirements for this provision except those specified in Section I of this permit. Status: In Compliance. Non-resettable hour meters are installed and operation is tracked. A maintenance system is in place. Activities are tracked, with records provided showing dates of required maintenance listed in this condition. The permittee has evaluated and documented the remote stationary RICE status annually and provided this record. 32 II.B.9 Conditions on Spark Ignition (SI) Internal Combustion Engines (ICE) (NSPS SI ICE). II.B.9.a Condition: (i) For stationary SI ICE with a maximum engine power greater than or equal to 75 KW (100 HP) (except gasoline and rich burn engines that use LPG), the permittee shall comply with the emission standards in Table 1 of 40 CFR 60 Subpart JJJJ. (40 CFR 60.4233(e)) (ii) The permittee shall comply with the provisions of 40 CFR 60.4236 as applicable. (40 CFR 60.4230(a)(6)) (iii) The permittee shall operate and maintain affected emission units that achieve the emission standards as required in this condition over the entire life of the engine. (40 CFR 60.4234) (iv) Stationary SI natural gas fired engines may be operated using propane for a maximum of 100 hours per year as an alternative fuel solely during emergency operations, but shall keep records of such use. (40 CFR 60.4243(e)) (v) The air-to-fuel ratio (AFR) controller, if used, shall be maintained and operated appropriately by the permittee in order to ensure proper operation of affected emission units and control device to minimize emissions at all times. (40 CFR 60.4243(g)) [Origin: 40 CFR 60 Subpart JJJJ]. [40 CFR 60.4230(a)(6), 40 CFR 60.4233(e), 40 CFR 60.4234, 40 CFR 60.4243, 40 CFR 63 Subpart ZZZZ] II.B.9.a.1 Monitoring: (a) For affected emission units subject to 40 CFR 60.4233(e), the permittee shall demonstrate compliance according to one of the methods specified in paragraphs (a)(1) and (2) of this section. (1) Purchasing an engine certified according to procedures specified in 40 CFR 60 Subpart JJJJ, for the same model year, engine class, and maximum engine power. In addition, the permittee shall meet one of the requirements specified in paragraphs (1)a) and b) of this section. a) If the permittee operates and maintains the certified stationary SI internal combustion engine and control device according to the manufacturer's 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 the requirements as specified in 40 CFR part 1068, subparts A through D, as they apply. If the permittee adjusts engine settings according to and consistent with the manufacturer's instructions, the affected emission unit will not be considered out of compliance. b) If the permittee does not operate and maintain the certified stationary SI internal combustion engine and control device according to the manufacturer's emission- related written instructions, the engine will be considered a non-certified engine, and the permittee shall demonstrate compliance according to (i) of this section. (i) If the affected emission unit is 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 within 1 year of engine startup and conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance. (2) Purchasing a non-certified engine and demonstrating compliance with the emission standards specified in 40 CFR 60.4233(e) and according to the requirements specified in 40 CFR 60.4244, as applicable, and according to paragraph (2)a) of this section. 33 a) If the affected emission unit is 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 3 years, whichever comes first, thereafter to demonstrate compliance. (40 CFR 60.4243(b)) (b) The permittee shall conduct performance tests in accordance with the procedures in 40 CFR 60.4244(a) through (f). (40 CFR 60.4244) (c) If propane is used for more than 100 hours per year in an engine that is not certified to the emission standards when using propane, the permittee shall conduct a performance test to demonstrate compliance with the emission standards of 40 CFR 60.4233. (40 CFR 60.4243(e)) Records required for this permit condition will also serve as monitoring. II.B.9.a.2 Recordkeeping: (a) The permittee shall keep records of the information in paragraphs (a)(1) through (4) of this section. (1) All notifications submitted to comply with this condition and all documentation supporting any notification. (2) Maintenance conducted on each affected emission unit. (3) If the affected emission unit is a certified engine, documentation from the manufacturer that the affected emission unit is certified to meet the emission standards and information as required in 40 CFR parts 1048, 1054, and 1060, as applicable. (4) If the affected emission unit is not a certified engine or is a certified engine operating in a non-certified manner and subject to section (a)(1)b) of monitoring, documentation that the engine meets the emission standards. (40 CFR 60.4245(a)) (b) The permittee shall keep records of the install date of each affected emission unit and the applicable requirements under 40 CFR 60 Subpart JJJJ for the respective model year engine. (c) Records of propane usage shall be kept in accordance with 40 CFR 60.4243(e). Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. II.B.9.a.3 Reporting: For affected emission units that are subject to performance testing, the permittee shall submit a copy of each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has been completed. (40 CFR 60.4245(d)) There are no additional reporting requirements for this provision except those specified in 40 CFR 60.4245 and Section I of this permit. Status: In Compliance. The emissions units list identifies applicable equipment as ICE-4. A non-resettable hour meter is installed and operation is tracked. A maintenance system is in place. Activities are tracked, with records provided showing dates of required maintenance listed in this condition. 34 Stack testing requirements of ICE-4 are outlined in Conditions under II.B.4 above. Propane is not used in this unit. II.C Emissions Trading (R307-415-6a(10)) Not applicable to this source. II.D Alternative Operating Scenarios. (R307-415-6a(9)) Not applicable to this source. SECTION III: PERMIT SHIELD The following requirements have been determined to be not applicable to this source in accordance with Provision I.M, Permit Shield: III.A. 40 CFR 63 Subpart R (National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)) This regulation is not applicable to the Permitted Source for the following reason(s): this source is not a major source of hazardous air pollutants and does not meet the definition for bulk gasoline terminal or pipeline breakout station in 40 CFR 63.421. [Last updated October 19, 2023] III.B. 40 CFR 63 Subpart H (National Emission Standards for Organic HAPs for Equipment Leaks) This regulation is not applicable to the Permitted Source for the following reason(s): this source has no equipment in organic hazardous air pollutants (OHAP) service. [Last updated October 19, 2023] III.C. 40 CFR 63 Subpart B (Requirements for Control Technology Determinations for Major Sources) This regulation is not applicable to the Permitted Source for the following reason(s): this source is not a major source of hazardous air pollutants. [Last updated October 19, 2023] III.D. 40 CFR 60.332(a) in 40 CFR 60 Subpart GG (Standards of Performance for Stationary Gas Turbines) This regulation is not applicable to the ICE-2: Turbines for Backup Power for the following reason(s): these gas turbines are used only for emergency power and are exempt from 40 CFR 60.332(a) per 40 CFR 60.332(g). [Last updated October 19, 2023] SECTION IV: ACID RAIN PROVISIONS This source is not subject to Title IV. This section is not applicable. 35 EMISSIONS INVENTORY: Taken from DAQ’s emissions inventory database for 2023: Pollutant Tons/year PM10 3.52 PM2.5 3.52 NOX 953.62 CO 36.06 VOC 21.94 SOX 0.35 PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: Dominion Energy’s Kastler Marushack Station should be considered in compliance with the Title V Operating Permit conditions evaluated during this inspection. HPV STATUS: Not applicable. COMPLIANCE ASSISTANCE: No RECOMMENDATION FOR NEXT INSPECTION: Inspect as usual. ATTACHMENT: VEO form