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Home My WebLink AboutDAQ-2024-0112041 DAQC-CI147880001-24 Site ID 14788 (B1) MEMORANDUM TO: FILE – WEXPRO COMPANY – Clay Basin Compressor Station THROUGH: Rik Ombach, Minor Source Compliance Oil and Gas Section Manager FROM: Stephen Foulger, Environmental Scientist DATE: October 11, 2024 SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Daggett County INSPECTION DATE: September 18, 2024 SOURCE LOCATION: 40.993821 -109.215888 Daggett County, UT DIRECTIONS: NWSW SEC 16 T3N, R24E Daggett County, UT SOURCE CONTACTS: Adam Plonsky, Manager Environmental Phone: 307-371-0966 Email: adam.r.plonsky@dominionenergy.com OPERATING STATUS: Operating. PROCESS DESCRIPTION: The Clay Basin compressor station receives natural gas from offsite via flowlines. The station operates compressor engines, (1) natural gas-fired compressor engine, (1) natural gas dehydrator, (1) combustor, (2) tanks, (1) pump, and (1) tank heater. Gas processed by the facility is transferred to pipelines for public or private consumption. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN147880007-23, dated November 23, 2022 SOURCE EVALUATION: Name of Permittee: Permitted Location: Wexpro Company - Clay Basin Compressor Station 915 North Eldridge Parkway Suite 1100 40.993821 -109.215888 Houston, TX 77079 Daggett County, UT SIC Code: 1311: (Crude Petroleum & Natural Gas) 2 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] Status: In Compliance. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In Compliance. No limits set in the AO were found exceeded at the time of inspection. I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] Status: In Compliance. All modifications were addressed in an approved AO. I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon request, and the records shall include the two-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of two (2) years. [R307-401-8] Status: In Compliance. Records required to be kept by the AO were requested and were observed at the time of inspection. I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4] Status: In Compliance. Good air pollution control practices found in use at the time of inspection. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In Compliance. No breakdowns were reported at the time of inspection. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In Compliance. Source found properly reported in the most recent Emissions Inventory. I.8 The owner/operator shall submit documentation of the status of construction or modification 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. All modifications found properly permitted. 3 Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1Clay Basin Compressor Station II.A.2 ICE-1 One (1) Internal Combustion Compressor Engine - new Fuel: natural gas Site rating: 1,480 hp Control device: NSCR Manufactured: 2022 NSPS Subpart JJJJ MACT Subpart ZZZZ II.A.3 DEHY-1 One (1) Glycol Dehydration Unit with Reboiler Fuel: Natural gas Capacity: 6 MMscfd II.A.4 COMB-1 One (1) Combustor Stack Height: 13' approximately from ground II.A.5 T-1 One (1) Tank Size: 400 bbl II.A.6 T-2 One (1) Tank Size: 300 bbl II.A.7 H-1 One (1) Line Heater Manufacturer: Maloney-Crawford Capacity: 0.75 MMBtu/hr II.A.8 PUMP-1 One (1) Pneumatic Pump Manufacturer: Husky 1040 II.B Requirements and Limitations II.B.1 Site Wide Requirements. II.B.1.a All exhaust air from the natural gas dehydration units shall be routed to the vent gas combustor. [R307-401-8] Status: In Compliance. Emissions found properly routed to the combustor at the time of inspection. 4 II.B.1.b Visible emissions from any stationary point or fugitive emission source associated with the source or with the control facilities shall not exceed 10% opacity. [R307-401] Status: In Compliance. No visible emissions were observed at the time of inspection. II.B.1.b.1 Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. Records reviewed at the time of inspection showed that opacity observations are conducted properly. II.B.2 Compressor Engine Condition II.B.2.a The owner/operator shall not emit more than the following rates from the Source: (1,480 hp Compressor Engine) Pollutant lb/hr gr/hp-hr NOx 3.30 1.0 CO 2.30 0.7 VOC 1.00 0.3. [R307-401-8] Status: In Compliance. II.B.2.a.1 Compliance Demonstration To demonstrate compliance with the emission limitations above, the owner/operator shall perform stack testing on the emissions unit according to the stack testing conditions contained in this AO. [R307-165-2, R307-401-8] Status: In Compliance. Records show stack testing was performed. II.B.2.a.2 Initial Test The owner/operator shall conduct an initial stack test on the emission unit within 180 days after startup of the emission unit. [R307-165-2] Status: Not Observed. II.B.2.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within one year after the date of the most recent stack test of the emission unit. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] Status: In Compliance. These records were reviewed and found compliant at the time of inspection. II.B.3 Stack Testing Requirements II.B.3.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.a.1 Notification At least 30 days prior to conducting a stack test, the owner/operator shall submit a source test protocol to the Director. The source test protocol shall include the items contained in R307-165-3. If directed by the Director, the owner/operator shall attend a pretest conference. [R307-165-3, R307-401-8] Status: Not Observed. Stack tests reviewed at the time of inspection. 5 II.B.3.a.2 Testing & Test Conditions The owner/operator shall conduct testing according to the approved source test protocol and according to the test conditions contained in R307-165-4. [R307-165-4, R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.a.3 Access The owner/operator shall provide Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access to the test location. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.a.4 Reporting No later than 60 days after completing a stack test, the owner/operator shall submit a written report of the results from the stack testing to the Director. The report shall include validated results and supporting information. [R307-165-5, R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.a.5 Possible Rejection of Test Results The Director may reject stack testing results if the test did not follow the approved source test protocol or for a reason specified in R307-165-6. [R307-165-6, R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.b Test Methods When performing stack testing, the owner/operator shall use the appropriate EPA-approved test methods as acceptable to the Director. Acceptable test methods for pollutants are listed below. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.b.1 Standard Conditions A. Temperature - 68 degrees Fahrenheit (293 K) B. Pressure - 29.92 in Hg (101.3 kPa) C. Averaging Time - As specified in the applicable test method. [40 CFR 60 Subpart A, 40 CFR 63 Subpart A, R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.b.2 NOx 40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.b.3 VOC 40 CFR 60, Appendix A, Method 18; Method 25; Method 25A; 40 CFR 63, Appendix A, Method 320; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. II.B.3.b.4 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] Status: In Compliance. Stack tests reviewed at the time of inspection. 6 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 Wexpro Company - Clay Basin Compressor Station. Criteria Pollutant PTE tons/yr Actuals tons/yr Carbon Monoxide 10.24 .04 Nitrogen Oxides 14.70 .05 Particulate Matter - PM10 1.13 0 Particulate Matter - PM2.5 1.13 0 Sulfur Oxides 0.04 0 Volatile Organic Compounds 10.55 7.23 Status: In Compliance. Source found properly reported in the most recent Emissions Inventory. PREVIOUS ENFORCEMENT ACTIONS: No previous enforcement action has been found taken in the last 5 years. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN147880007-23, dated November 23, 2022, the overall status is: In Compliance. Source was found compliant at the time of inspection. ATTACHMENTS: None.