HomeMy WebLinkAboutDAQ-2024-0109731
DAQC-CI117930001-24
Site ID 11793 (B1)
MEMORANDUM
TO: FILE – SAVAGE SERVICES CORPORATION – Savage Energy Terminal
THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager
FROM: Kyle Greenberg, Environmental Scientist
DATE: September 25, 2024
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Carbon County
INSPECTION DATE: August 27, 2024
SOURCE LOCATION: 2025 East 5000 South
Price, UT 84501
SOURCE CONTACTS: Butch Hansen, Operations Manager: 435-749-2458
LuAnn Koch, Coordinator: 435-637-5664 records
OPERATING STATUS: Operating
PROCESS DESCRIPTION: Coal transfer station. Coal, crushed to 6" minus size and
screened at various coal mines in Carbon and Emery Counties, is
transported in 40-ton haul trucks to this site. The haul trucks
dump the coal into one of the underground hoppers where it is
taken by conveyor to the concrete stacking tubes which stack the
coal into stockpiles. The coal is then recovered from the
stockpiles by underground reclaim systems. Finally, the coal is
either loaded into haul trucks for delivery to area power plants or
into a 10,000-ton load out silo. The coal silo is used to load
railcars for domestic and over-seas deliveries. Coal with high ash
content is washed in the on-site wash plant that consists of a
fully enclosed crusher and screen. This process and equipment
are operated by a contracting company. The company has also
transloaded crude oil and M-I WATE into rail cars.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN117930013-24, dated
July 3, 2024
40 CFR Part 60 Subpart Y
RO
RO
2
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
Savage Services Corporation
Savage Energy Terminal
901 West Legacy Center Way 2025 East 5000 South
Midvale, UT 84047 Price, UT 84501
SIC Code: ORA-01422: exact fetch returns more than requested number of rows
Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
Status: Out of Compliance. The source is out of compliance with Condition I.3; an
exceedance of the rolling 12-month transloading throughput limit of M-I WATE (barite)
was observed during the time of inspection. Records were made available upon request.
During the time of inspection, all equipment appeared to be well maintained and operated
in a manner consistent with good air pollution control. Savage Services Corporation stated
that there were no known breakdowns that have caused excess emissions and a 2023
emissions inventory has been submitted.
3
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 Savage Energy Terminal (Price)
II.A.2 Four (4) Coal Truck Unloading Facilities
Control: Enclosed receiving hoppers equipped with water sprays
II.A.3 Five (5) Stacking Tubes
With associated coal stockpiles
II.A.4 Two (2) Radial Stackers
Control: Covered
II.A.5 One (1) Sampling Crusher
Capacity: 2 tph
Control: Enclosed in the building
II.A.6 Two (2) Underpile Reclaim Systems
II.A.7 One (1) Underground Reclaim
II.A.8 One (1) Wash Plant
With associated conveyor
II.A.9 One (1) Radial Conveyor
36" X 100' Radial stock conveyor
Control: Covered
II.A.10 One (1) Belt Conveyor
36" X 150' conveyor to load out belt
Control: Covered
II.A.11 One (1) Silo
Capacity: 10,000 tons
Control: Enclosed extendable chute for railcar loading
II.A.12 Three (3) Diesel Fuel Tanks
Capacity: Less than 42,000 gallons each
II.A.13 Three (3) Storage Tanks
Capacity: One (1) 10,000 gal; Two (2) 20,000 gal
Contents: Antifreeze
-Listed for informational purposes only-
II.A.14 One (1) Gasoline Fuel Dispensing Station
Gravity Fed
Capacity: 500 gallons
MACT Applicability: Subpart CCCCCC
4
II.A.15 Four (4) Oil Transloading Racks
Rating: 260 bbl/hr
II.A.16 Four (4) Condensate Collectors
Capacity: 5 gal (each)
II.A.17 Four (4) Vapor Capture Systems
Activated-Carbon (55 gal each)
II.A.18 One (1) Emergency Generator
Rating: 350 hp
Fuel: Diesel
MACT Applicability: Subpart ZZZZ
II.A.19 One (1) Boiler
Capacity: 10.5 MMBtu/hr
Fuel: Natural Gas
NSPS Applicability: Subpart Dc
II.A.20 Haul Roads
Control: Water sprayed and chemically treated
II.A.21 Mobile Loading Conveyors
*Listed for informational purposes
II.A.22 Magnesium Hydroxide/M-I WATE Transloading
One (1) electric blower (for information only) and (1) baghouse
Status: In Compliance. No unapproved equipment was noted during the time of inspection.
There was one radial stacker onsite and the emergency generator and boiler have
been removed from site.
II.B Requirements and Limitations
II.B.1 Site-Wide Requirements
II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:
A. All crushers - 15% opacity
B. All screens - 10% opacity
C. All conveyor transfer points - 10% opacity
D. All diesel engines - 20% opacity
E. Conveyor drop points - 10% opacity
F. Silo - 10% opacity
5
G. All baghouses - 10% opacity
H. All other points - 20% opacity
[R307-401-8]
II.B.1.b Opacity observations of emissions from stationary sources shall be conducted while in operation
in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. During the time of inspection, no visible emissions were observed
in exceedance of the applicable opacity limits. All coal material onsite appeared to be
properly controlled with water to keep the dust within limits. The diesel engine is no longer
onsite.
II.B.2 Coal Transloading Requirements
II.B.2.a The owner/operator shall not exceed the following:
A. 7,000,000 tons of total coal throughput per rolling 12-month period
B 1,000,000 tons of coal processed (crushed and screened) per rolling 12-month period
[R307-401-8]
II.B.2.a.1 The owner/operator shall:
A. Determine the coal throughput with truck scales
B. Determine the coal processed (crushed and screened) by supervisor monitoring of
an operations log
C. Record the coal throughput and coal processed (crushed and screened) each day
D. Calculate a new rolling 12-month total by the 20th day of each month using data
from the previous 12 months
E. Keep all the records for all periods when the plant is in operation
[R307-401-8]
Status: In Compliance. The coal throughput limits have not been exceeded during a rolling
12-month. Throughput records were reviewed since January of 2023, see attached records.
II.B.3 Coal Transfer and Crushing Requirements
II.B.3.a The owner/operator shall enclose the following transfer points:
A. Each conveyor transfer or drop point
B. Reclaim conveyor from the primary coal stockpile to the stacking tube
6
C. All wash plants with associated screens, crushers, and conveyors
[R307-401]
II.B.3.b The owner/operator shall cover all above-ground conveyors. All reclaim points for the primary
coal storage shall be beneath the stockpile. [R307-401]
II.B.3.c The owner/operator shall operate water sprays and/or chemical treatment to control fugitive dust
emissions from storage piles. Water sprays and/or chemical treatment shall operate as necessary
to prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401]
II.B.3.c.1 Records of water or chemical treatment shall be kept for all periods when the plant is in
operation. [R307-401-8]
II.B.3.d The owner/operator shall install and operate water sprays or chemical dust suppression sprays at
the following points to control fugitive emissions:
A. All crushers
B. All screens
The sprays shall operate as necessary to prevent visible emissions from exceeding the opacity
limits listed in this AO. [R307-401-8]
II.B.3.e The owner/operator shall control the disturbed or stripped areas at all times (24 hours per day
every day) for the duration of the project/operation until the area is reclaimed. Areas disturbed
during construction of the facility and not subjected to repeated disturbance shall be revegetated.
Repeatedly disturbed areas shall be chemically treated or water sprayed as necessary to prevent
visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8]
II.B.3.f In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New Source
Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart Y, 40 CFR 60.250
to 60.254 (Standards of Performance for Coal Preparation Plants) apply to this installation. The
owner/operator must operate in accordance with the most current version of 40 CFR 60
applicable to this source. The following emission points are subject to Subpart Y:
A. All crushers (above ground)
B. All screens (above ground)
C. All conveyors (above ground)
D. Storage silo stack.
[40 CFR 60 Subpart Y]
Status: In Compliance. All required equipment with transfer points is enclosed. All
crushers, screens, disturbed or stripped area, storage silo stack, and haul roads appeared to
be treated with water sprayed to prevent visible emissions from exceeding the applicable
opacity limits.
7
II.B.4 Petroleum Products Transloading Requirements
II.B.4.a The owner/operator shall not conduct any liquid petroleum product transloading
operations after January 1, 2026. [R307-401-8]
II.B.4.b The owner/operator shall not transload more than 4,380,000 barrels of all petroleum products
combined per rolling 12-month period. [R307-401-8]
II.B.4.b.1 The owner/operator shall:
A. Determine the petroleum products throughput with truck scales
B. Record the throughput of petroleum products each day
C. Calculate a new 12-month total by the 20th day of each month using data from
the previous 12 months
D. Keep the petroleum products throughput records for all periods when the facility is in
operation.
[R307-401-8]
II.B.4.c The owner/operator shall not transload any petroleum products with a true vapor pressure greater
than 2.0 psia. [R307-401-8]
II.B.4.c.1 The owner/operator shall keep and maintain records of true vapor pressures of all petroleum
products transloaded on site. The records shall be kept for all periods when the facility is in
operation. [R307-401-8]
Status: In Compliance. This site has not transloaded crude oil since 2018, where 158,990
BBLs was transloaded.
II.B.5 Vapor Balance and Carbon Capture Requirements
II.B.5.a During rail car loading of petroleum products, the owner/operator shall rout vapors from the
pressure balance lines to the vapor capture systems equipped with carbon capture barrels prior to
venting to the atmosphere. [R307-401-8]
II.B.5.b The owner/operator shall maintain the carbon canisters per the manufacture specifications and
replace the carbon canisters using the colorimetric breakthrough detector in accordance with the
manufacturer's recommendations. [R307-401-8]
II.B.5.b.1
Records of each carbon canister replacement shall be kept on site for all times the plant is in
operation. Canister replacement records shall record the date of replacement and the reason, and
shall be kept in an operations log maintained by the operator. [R307-401-8]
Status: In Compliance. Records were observed onsite showing that the carbon canisters
were maintained and replaced as needed when crude oil was transloaded through the
facility in 2018. The vapor capture system routed these emissions to the carbon canisters.
8
II.B.6
II.B.6.a
II.B.6.a.1
II.B.6.b
Magnesium Hydroxide and M-I WATE Transloading Requirements
The owner/operator shall not transload more than the following:
A. 12,000 tons of magnesium hydroxide per rolling 12-month period.
B. 18,000 tons of M-I WATE per rolling 12-month period.
The owner/operator shall:
A. Determine the amount of magnesium hydroxide and M-I WATE transloaded with truck
scales.
B. Record the amount of magnesium hydroxide and M-I WATE transloaded each day.
C. Calculate a new 12-month total by the 20th day of each month using data from the
previous 12 months.
D. Keep all records when the plant is in operation.
The owner/operator shall use a baghouse to control air streams from the magnesium hydroxide
and M-I WATE transloading operations. All air streams from these processes shall vent to the
baghouse before being vented to the atmosphere.
Status: Out of Compliance. Records reviewed revealed the following rolling 12-month
throughput of M-I WATE (barite) to exceed the 18,000-ton limit:
March 2023 - February 2024: 18,301.87 tons
April 2023 - March 2024: 18,876.06 tons
May 2023 - April 2024: 18,977.56 tons
June 2023 - May 2024: 20,063.05 tons
July 2023 - June 2024: 19,487.13 tons
August 2023 - July 2024: 20,080.13 tons
September 2023 - August 2024: 19,586.90 tons
Magnesium hydroxide is currently not transloaded through this facility.
II.B.7 Haul Road Requirements
II.B.7.a The owner/operator shall prevent visible fugitive dust emissions from haul-road traffic and
mobile equipment in operational areas from exceeding 20% opacity. [R307-205]
II.B.7.a.1 Visible emissions determinations for fugitive sources shall use procedures similar to Method 9.
The normal requirement for observations to be made at 15-second intervals over a six-minute
period, however, shall not apply. Six points, distributed along the length of the haul road or in the
operational area, shall be chosen by the Director or the Director's representative. An opacity
reading shall be made at each point when a vehicle passes the selected points. Opacity readings
shall be made at a point not less than one half the vehicle length behind the vehicle and not less
than one half the height of the vehicle. The accumulated six readings shall be averaged for the
compliance value. [R307-205]
II.B.7.b The owner/operator shall water flush or broom sweep the paved haul roads as necessary to
prevent visible emissions from exceeding the opacity limits listed in this AO. [R307-401-8]
II.B.7.b.1 Records of water flushing and/or sweeping shall be kept for all periods when the plant is in
operation. The records shall include the following items:
9
A. Date of water flushing and/or sweeping
B. Number of sweeping and quantity of water used
C. Rainfall received, if any, and approximate amount
D. Time of day water flushing and/or sweeping were made
E. Records of temperature if the temperature is below freezing.
[R307-401-8]
II.B.7.c The owner/operator shall water spray or chemically treat all unpaved roads and other unpaved
operational areas that are used by mobile equipment to control fugitive dust. Water spray and
chemical treatment shall be of sufficient frequency and quantity to prevent visible emissions
from exceeding the opacity limits in this AO unless it is below freezing (32 degrees F).
[R307-401-8]
II.B.7.c.1 Records of water or chemical treatment shall be kept for all periods when the plant is in
operation. The records shall include the following items:
A. Date of treatment
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature is below freezing
[R307-401-8]
Status: In Compliance. During the time of inspection all haul roads appeared to be
properly watered. No visible emissions were observed during the time of inspection. See
attached haul road watering records.
II.B.8 Emergency Generator Engine Requirements
II.B.8.a The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the emergency engine. [R307-401-8]
II.B.8.a.1 The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.8.b The owner/operator shall not operate the emergency generator engine on site for more than 100
hours per calendar year for maintenance checks and readiness testing. The emergency generator
engine on site may be operated for up to 50 hours per calendrer year in non-emergency
situations. Any operation in non-emergency situations shall be counted as part of the 100 hours
per calendar year for maintenance and testing. There is no time limit on the use of the engine
during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8]
10
II.B.8.b.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of the emergency engine shall be kept in a log and shall include the
following:
A. The date the emergency engine was used
B. The duration of operation in hours
C. The reason for the emergency engine usage
[40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.8.b.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for the emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8]
II.B.8.b.3 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the ULSD
requirements. [R307-401-8]
Status: Not Applicable. The emergency diesel generator engine is no longer onsite.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs
have been found to apply to this installation. This AO in no way releases the owner or operator from any
liability for compliance with all other applicable federal, state, and local regulations including
UAC R307.
40 CFR Part 60 Subpart Y:
Status: In Compliance. Records reviewed onsite show that Method 22 is conducted daily and if
visible emissions are determined, Savage Energy Terminal has a policy to attempt to fix the source
of the visible emissions and conduct a Method 9 observation that same day. This is in compliance
with this subpart requiring a Method 9 to be conducted within 45 days if visible emissions are
observed. Savage Energy Terminal stated that monthly visible observations of process and control
equipment are conducted and that Method 9 is conducted at least once every 5 years. No visible
emissions exceeding applicable limits were observed during the time of inspection.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from Savage Services Corporation – Savage
Energy Terminal. A comparison of the estimated total potential emissions (PTE) on AO:
DAQE-AN117930013-24, dated July 3, 2024, is provided. PTE are supplied for supplemental purposes
only.
11
Criteria Pollutant PTE tons/yr Actuals tons/yr
CO2 Equivalent 6305.00
Carbon Monoxide 3.88 .00001
Nitrogen Oxides 7.07 .00001
Particulate Matter - PM10 45.30 22.68
Particulate Matter - PM2.5 5.70 12 3.
Sulfur Dioxide 0.28 .00001
Volatile Organic Compounds 70.23 .005
Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr
Benzene (Including Benzene From Gasoline) (CAS #71432) 580
Hexane (CAS #110543) 10120
Toluene (CAS #108883) 200
Xylenes (Isomers And Mixture) (CAS #1330207) 50
PREVIOUS ENFORCEMENT
ACTIONS: Compliance Advisory (DAQC-927-24) – September 17, 2024
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN117930013-24,
dated July 3, 2024, the overall status is: Out of Compliance. The
M-I WATE (barite) throughput limit has been exceeded. A
Compliance Advisory (DAQC-927-24) has been issued.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: None.
NSR RECOMMENDATIONS: Savage Energy Terminal is currently reviewing if operations can
operate within the M-I WATE limits or if a NOI will be
submitted to increase the M-I WATE limits in the AO.
ATTACHMENTS: Coal throughput records; M-I WATE (Barite) throughput
records; Haul Road Water log Records June 2024 - August 2024
r Tons Shipped 2023
January
February
March
April
May
June
July
August
September
October
November
December
Stockpiling 2023
January
February
March
April
May
June
July
August
September
October
November
December
Monthly Total Cumulative Total
96,578.40 96,578.40
112,795.60 209,374.00
200,509.90 409,883.90
120,832.70 530,716.60
100.759.56 631,476.16
112,502.30 743,978.46
106,929.40 850,907.86
145,730.70 996,638.56
109,148.84 1,105,787.40
166,860.95 1,272,648.35
229,190.10 1,501,838.45
160,684.64 1,662,523.09
Monthly Total YTD Owed
147,079.64
80,339.79
82,332.12
23,806.87
47,817.97
68,193.20
187,494.69
173,919.58
227,021.63
273,429.78
229,248.51
305,680.77 _____ _
$
Payments Due
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Payments Due
$
$
$
$
$
$
$
$
$
$
$
$
~
Tons Shipped 2024
January
February
March
April
May
June
July
August
September
October
November
December
Stockpiling 2024
January
February
March
April
May
June
July
August
September
October
November
December
Monthly Total Cumulative Total
76,172.70 76,172.70
200,438.88 276,611.58
87,877.48 364,489.06
97,077.87 461,566.93
57,231.60 518,798.53
171,822.40 690,620.93
690,620.93
690,620.93
690,620.93
690,620.93
690,620.93
690,620.93
Monthly Total YTD Owed
131,900.03
294,537.50
229,193.13
222,766.62
124,648.87
184,429.71
~
I
~
Shipper productName Month Sum of Tons Shipper productNaMonth transfer Order Id Sum of Tons Average Tons
Schlumberger Technology Corporation Barite March 650.02 Schlumberger Technology Corporation Barite March 650.02 32.50
April 1,409.36 April 1,409.36 28.19
May 1,107.34 May 1,107.34 29.93
June 2,750.62 June 2,750.62 30.23
July 1,679.41 July 1,679.41 27.99
August 2,277.41 August 2,277.41 27.44
September 1,250.45 September 1,250.45 29.77
October 1,496.37 October 1,496.37 29.93
November 1,329.37 November 1,329.37 29.54
December 1,569.42 December 1,569.42 29.61
Barite Total 15,519.76 Schlumberger Technology Corporation Total 15,519.76 29.23
Schlumberger Technology Corporation Total 15,519.76 Grand Total 15,519.76 29.23
Grand Total 15,519.76
Shipper productName Month Sum of Tons Shipper productNaMonth transfer Order Id Sum of Tons Average Tons
Schlumberger Technology Corporation Barite January 1,921.94 Schlumberger Technology Corporation Barite January 1,921.94 27.46
February 860.17 February 860.17 29.66
March 1,224.21 March 1,224.21 29.15
April 1,510.86 April 1,510.86 29.62
May 2,192.83 May 2,192.83 29.24
June 2,174.69 June 2,174.69 28.24
July 2,272.42 July 2,272.42 29.51
August 1,784.18 August 1,784.18 29.74
Barite Total 13,941.29 Schlumberger Technology Corporation Total 13,941.29 28.98
Schlumberger Technology Corporation Total 13,941.29 Grand Total 13,941.29 28.98
Grand Total 13,941.29