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Home My WebLink AboutDAQ-2024-0110011 DAQC-CI106250001-24 Site ID 10625 (B1) MEMORANDUM TO: FILE – GREEN NATURAL VENTURES – Four Corners Compressor Station THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: October 10, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, San Juan County INSPECTION DATE: September 20, 2024 SOURCE LOCATION: 18 miles east of Alkali Canyon Blanding, UT 84511 DIRECTIONS: Directions from Blanding: From the AmeriGas propane store located on the south end of town on Highway 191, turn left, east onto East Browns Canyon Drive. Turn right (south) at the stop sign about 1 mile from Highway 191. Travel southeast on this unpaved road for about 13.8 miles, passing through three canyons, until a four-way intersection near a large tank making a right turn (south) onto CR 222. Follow this road for approximately 3.9 miles and turn left onto the compressor station access road. The compressor station is visible from the turn off. Site located 19.1 miles from Blanding. The last few miles of this unpaved road can wash out during rain. A high clearance vehicle may be required during bad weather. SOURCE CONTACTS: Scott Nowak klapham@gng-partners.com OPERATING STATUS: Operating. PROCESS DESCRIPTION: Green Natural Ventures operates a compressor station at this site. Natural gas is drawn from a pipeline into a header. The natural gas is routed through a compressor to increase the pressure and then pass through a pressurized relief valve back into the pipeline. The pipeline feeds producing oil wells' equipment on nearby Indian Reservations. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN106250004-22, dated August 8, 2022 2 SOURCE EVALUATION: Name of Permittee: Permitted Location: Four Corners Pipeline, LLC Four Corners Compressor Station 500 Dallas Street, 16th Floor 18 miles east of Alkali Canyon Houston, TX 77002 Blanding, UT 84511 SIC Code: 1311: (Crude Petroleum & Natural Gas) Section I: GENERAL PROVISIONS I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 The owner/operator shall submit documentation of the status of installation of the 440 hp compressor engine to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months from the date of this AO or if construction is discontinued for 18 months or more. To ensure proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18] Status: In Compliance. In compliance with all conditions of Section I. Emission inventories, referenced in condition 1.7, are not currently requested from this source by the Inventory Section. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Four Corners Pipeline LLC, Four Corners Compressor Station II.A.2 One CS RICE-1 Natural gas fired IC engine Capacity: 1,232 hp Controls: Catalytic Converter II.A.3 One CS RICE-2 (New) Natural gas fired IC engine Capacity: 440 hp Manufacture Date: 1999 II.A.4 One TEG Dehy Capacity: 0.125 mmbtu/hr II.A.5 One Emergency Flare II.A.6 Two Condensate Storage Tanks II.A.7 Misc. Storage Tanks Status: In Compliance. There is a Waukesha F18GL 440 hp compressor engine and a 1,232 hp Waukesha L7042 compressor engine on-site. There is also one TEG Dehydrator (shut-in for the past 4 years), one emergency flare, two condensate tanks (300bbl and 400bbl), and miscellaneous storage tanks (methanol, corrosion inhibitor) on-site. II.B Requirements and Limitations II.B.1 Site Wide Requirement II.B.1.a Unless otherwise specified in this AO, visible emissions from the following emission points shall not exceed the following values: A. All natural gas/propane operated equipment and tanks - 10% opacity B. All other points - 20% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall use only natural gas as a fuel in the engines and dehydration unit. [R307-401-8] 4 II.B.1.c II.B.2 II.B.2.a II.B.2.a.1 II.B.2.a.2 II.B.2.a.3 II.B.2.a.4 The flare shall be used during upset or emergency conditions only. The flare system has been exempted from the requirements of 40 CFR 60.18. [R307-401-8] Status: In Compliance. Green Natural Ventures records reviewed by Ken Lapham do not show the visible emission opacity limits being exceeded. The compressor engines and dehydration unit (shut-in for the past four years) are all fueled by natural gas and the flare is only used during upset or emergency conditions. Compressor Engine Requirements The owner/operator shall not emit more than the following rates and concentrations from the indicated emissions unit(s): CE-01, 1,232 hp Compressor Engine Pollutant gram/hp-hr lb/hr NOx 2.0 5.43 CO 2.0 5.43 CE-02, 440 hp Compressor Engine (New) Pollutant gram/hp-hr lb/hr NOx 2.0 1.94 CO 1.3 1.26. [R307-401-8] Standard Conditions & Emission Limit Parameters A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Concentration (ppmdv) - 3% oxygen, dry basis D. Averaging Time - As specified in the applicable test method. [R307-401-8] Initial Test The owner/operator shall conduct an initial emission test on CE-02 within 180 days after startup. [R307-165-2] Test Frequency The owner/operator shall conduct subsequent emission tests for the following emissions units according to the following schedule. The owner/operator must complete subsequent emission tests within the indicated time after the date of the most recent emission test. Compressor Engine CE-01: three months Compressor Engine CE-02: twelve months The Director may require the owner/operator to perform an emission test at any time. [R307-165-2] Notification At least 30 days prior to conducting an emission test, the owner/operator shall submit a source 5 II.B.2.a.5 II.B.2.a.6 II.B.2.b II.B.2.c II.B.2.c.1 test protocol to the Director. The source test protocol shall include: A. The date, time, and place of the proposed test B. The proposed test methodologies C. The stack to be tested D. The procedures to be used E. Any deviation from an EPA-approved test method F. Explanation of any deviation from an EPA-approved test method If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3] NOx 40 CFR 60, Appendix A, Method 7; Method 7E; portable monitor or other EPA-approved testing method as acceptable to the Director. [R307-401-8] CO 40 CFR 60, Appendix A, Method 10; portable monitor or other EPA-approved testing method as acceptable to the Director. [R307-401-8] If tested with a portable monitor, all engines which are operative shall be tested as indicated above for the concentrations of CO and NOx in the exhaust stack using an exhaust gas analyzer. The engines which exceed the above limitation shall be adjusted or other maintenance performed within 72 hours, or the engine shall be removed from service if possible. These gas analyzer readings shall be recorded and maintained in a logbook. The logbook shall be made available to the Director or Director’s representative upon request. It shall contain at least the records from the most recent two years of operation. The analyzer to be used to obtain the required readings shall be subject to the approval of the Director. [R307-401] The owner/operator shall not operate an engine for more than 12 hours per rolling 12-month total with the catalyst removed for washing or replacement. [R307-401] Records of operation of an engine without the catalyst shall be kept for all periods when the owner/operator facility is in operation. The records of operation of an engine without the catalyst shall be kept on a daily basis. [R307-401] Status: Out of Compliance. This inspection found a failure to conduct/submit an initial emission test on CE-02 and a failure to conduct/submit quarterly subsequent emission tests for CE-01 which may be a violation of Condition II.B.2.a.2 and Condition II.B.2.a.3. A compliance advisory has been issued to address this. 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. Not Applicable. 6 AREA SOURCE RULES EVALUATION: The following Area Source Rules were evaluated during this inspection: EMISSION INVENTORY: The emissions listed below are an estimate of the total potential emissions (PTE) from Green Natural Ventures – Four Corners Compressor Station on the Approval Order (AO) DAQE-AN106250004-22, dated August 8, 2022. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr CO2 Equivalent 1906.00 Carbon Monoxide 31.34 Nitrogen Oxides 34.27 Particulate Matter - PM10 3.36 Particulate Matter - PM2.5 3.36 Sulfur Oxides 0.01 Volatile Organic Compounds 52.86 Hazardous Air Pollutant PTE lbs/yr Generic HAPs (CAS #GHAPS) 22640 PREVIOUS ENFORCEMENT ACTIONS: - Notice of Violation (DAQC-1408-21) - December 5, 2021 - Warning Letter (DAQC-260-23) - March 9, 2023 - Compliance Advisory (DAQC-456-23) - May 5, 2023 - No Further Action (DAQC-004-24) - January 5, 2024 - Compliance Advisory (DAQC-953-24) - September 25, 2024 COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN106250004-22, dated August 8, 2022: Out of Compliance. A Compliance Advisory has been issued (DAQC 953-24) for not conducting an initial emission test on CE-02 and a failure to conduct/submit quarterly subsequent emission tests for CE-01. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Check that stack tests have been conducted and are up to date for the two compressor engines on-site. NSR RECOMMENDATIONS: None. ATTACHMENTS: None.