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Home My WebLink AboutDAQ-2025-0020021 DAQC-CI103200001-25 Site ID 10320 (B1) MEMORANDUM TO: FILE – KERN RIVER GAS TRANSMISSION COMPANY – Fillmore Compressor Station THROUGH: Rik Ombach, Minor Source Oil and Gas Section Manager FROM: Kyle Greenberg, Environmental Scientist DATE: April 2, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, Synthetic Minor, Millard County INSPECTION DATE: March 17, 2025 SOURCE LOCATION: -112.503807067871 38.8472518920898 Millard County, UT 84644 DIRECTIONS: West of Meadow in Millard County Lat Long: 38.84949925, -112.503854 SOURCE CONTACTS: Denise Kohtala: Denise.Kohtala@kernrivergas.com OPERATING STATUS: Operating PROCESS DESCRIPTION: At this pipeline station, natural gas is first warmed by a natural gas-fired glycol boiler and then put into a transfer pipe. The heated natural gas fuels two (2) turbine engines that drive compressors that pressurize the remaining gas back into the pipeline for delivery to the next compressor station. APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN103200020-24, dated March 11, 2024 NSPS (Part 60) -GG : Standards of Performance for Stationary Gas Turbines, MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, SOURCE EVALUATION: Name of Permittee: Permitted Location: Kern River Gas Transmission Company - Fillmore Compressor Station 2755 East Cottonwood Parkway, Suite 300 -112.503807067871, 38.8472518920898 Salt Lake City, UT 84121 Millard County, UT 84644 SIC Code: 4923: (Natural Gas Transmission & Distribution) 4 ' - ) - " 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] 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 five (5) 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: In Compliance. No limits set in this AO have been exceeded. No unapproved modifications were observed during the time of inspection. The source provided all records requested, see attached hour log of the emergency generator. The site was well kept and appeared to be operated in a manner consistent with good air pollution control practice for minimizing emissions. The source reported that there were no breakdowns that resulted in excess of emissions in the past 24 months. The source submitted an emissions inventory for 2023. Section II: SPECIAL PROVISIONS II.A The approved installations shall consist of the following equipment: II.A.1 Compressor Station II.A.2 Two (2) Natural Gas Turbine Compressors Power: 15,000 hp Control: SoLoNOx Burners Site Rated Power: 12,298 hp-site rated @ 59 degrees Fahrenheit Stack Height: 46 feet from the ground II.A.3 One (1) Emergency Backup Generator Fuel Type: Natural Gas Capacity: 7.73 MMBTU/hr Power: 1072 hp-ISO rated Site Rated Power: 818 hp-site rated 3 II.A.4 One (1) Building Heater Capacity: 3.85 MMBTU/hr II.A.5 One (1) Emergency Flare Status: In Compliance. During the time of inspection, there were two Solar Mars 100-15000 Turbines, SN: OHG22-M9214 and SN: OHA24-M4804. There was one 818 hp emergency generator. One building heater (boiler) rated at 3.05 MMBTU/hr. The emergency flare is a transportable candle stick flare, the flare is kept at Kern River Gas Transmission’s office building, and is transported to site when emergency flaring is required. II.B Requirements and Limitations II.B.1 Compressor Station II.B.1.a The owner/operator shall not operate the emergency generator for more than 300 hours of operation (excluding maintenance) per rolling 12-month period. [R307-401-8] II.B.1.a.1 The owner/operator shall: A. Determine hours of operation by the examination of operational records B. Record hours of operation on a monthly basis C. Use the hours of operation data to calculate a new rolling 12-month total using data from the previous 12 months. [R307-401-8] II.B.1.b The owner/operator shall ensure that visible emissions from the turbine compressors, the heater, and the backup generator do not exceed 10% opacity. [R307-401-8] II.B.1.b.1 Opacity observations of emission from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In Compliance. The source provided the hour log for the emergency generator. The previous 24 months have been reviewed and the emergency generator has not been used for more than 300 hours. The highest rolling 12-month use was 67.3 hours. This is also in compliance with the emergency generator requirements of 40 CFR Part 63 Subpart ZZZZ. See the attached hour log record. The emergency generator was not operating during the time of inspection and visible emission opacities were not able to be determined during the time of inspection. II.B.2 Stack Testing II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from the following sources: Source: Natural Gas Turbine Compressors Pollutant lb/hr NOx 9.29 (each) CO 10.18 (each). [R307-401-8] II.B.2.a.1 Test Frequency The owner/operator shall conduct a stack test on the emission unit within 5 years 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] 4 II.B.2.a.2 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] II.B.2.a.3 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] II.B.2.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] II.B.2.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] II.B.2.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] II.B.2.b.1 NOx 40 CFR 60, Appendix A, Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.b.2 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. Solar Mars 100-15000 Turbine; Unit 1 SN: OHG22-M9214 was tested on November 29, 2022, and Solar Mars 100-15000; Unit 2 SN: OHA24-M4804 was tested on July 9, 2024. Both units were in compliance with their emission limits during the time of testing and are in compliance with testing every five years. See stack test review memos DAQC-163-23 and DAQC-043-25 II.B.3 Fuel II.B.3.a The owner/operator shall use only pipeline quality natural gas in the turbines, heater, and emergency generator. [R307-401-8] Status: In Compliance. Only pipeline quality natural gas is used to fuel the equipment on site. Section III: APPLICABLE FEDERAL REQUIREMENTS In addition to the requirements of this AO, all applicable provisions of the following federal programs have been found to apply to this installation. This AO in no way releases the owner or operator from any liability for compliance with all other applicable federal, state, and local regulations including UAC R307. NSPS (Part 60) -GG : Standards of Performance for Stationary Gas Turbines Status: In Compliance. See stack test review memos DAQC-163-23 and DAQC-043-25. 5 MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Status: In Compliance. The emergency generator has not operated more than 100 hours on a rolling 12-month schedule for the past 24 months. See attached record. 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 Kern River Gas Transmission Company - Fillmore Compressor Station. A comparison of the estimated total potential emissions (PTE) on AO: DAQE-AN103200020-24, dated March 11, 2024, is provided. PTE are supplied for supplemental purposes only. Criteria Pollutant PTE tons/yr Actuals tons/yr Carbon Monoxide 94.20 10.860 Nitrogen Oxides 85.16 30.998 Particulate Matter - PM10 5.53 4.363 Sulfur Dioxide 2.79 0.156 Volatile Organic Compounds 28.63 3.312 Hazardous Air Pollutant PTE lbs/yr Actuals lbs/yr Formaldehyde (CAS #50000) 1200 0.471 Toluene (CAS #108883) 220 Xylenes (Isomers And Mixture) (CAS #1330207) 100 PREVIOUS ENFORCEMENT ACTIONS: None. COMPLIANCE STATUS & RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN103200020-24, dated March 11, 2024, the overall status is: In Compliance. There was no audio, visible, or olfactory leaks or emissions observed during the time of inspection. The facility appeared to be well kept and operated in a manner consistent with good air pollution control practices. The compressors and the emergency generator are operated in compliance with their limits. It is recommended that the Fillmore Compressor Station be found in compliance with the conditions of the AO during the time of inspection. HPV STATUS: Not Applicable. RECOMMENDATION FOR NEXT INSPECTION: Call ahead to ensure that there will be someone on site to grant access through the locked gate. 6 NSR RECOMMENDATIONS: Change the emergency generator 12-month rolling operating hour limit to 100 hours, to be consistent with the hour limits in 40 CFR Part 63 Subpart ZZZZ. ATTACHMENTS: Emergency Generator Log Hour Records Rolling 12 Month Tot 35.5 100.0 Hours for Maintenance and Testing Month Year Month Meter Beginning Meter Ending Month Total Use 12 Month Rolling Total Reason for Use & Comments Emergency Use hours Emergency Use Reason/Comments Other, Non- Emergency Use Hours Other, Non-Emergency Reason/Comments Initials of Technician 50.0 Hours for Non-Emergency use 1 2023 Jan-23 3750.60 3755.50 4.9 67.3 Weekly Exercise, power outage 2.4 Power Outage 1/10 RW 1/31/2023 2 2023 Feb-23 3755.50 3757.50 2 67.2 Weekly Exercise 0 RW 2/28/20233 2023 Mar-23 3757.50 3760.40 2.9 66.8 Weekly Exercise, ATS Testing 0 0.4 ATS Testing RW 3/30/2023 4 2023 Apr-23 3760.40 3762.50 2.1 57.4 Weekly Exercise, power outage 0.1 RW 4/26/2023 5 2023 May-23 3762.50 3768.40 5.9 56.3 Weekly Exercise, power outage 3.4 Power Outage 5/27 RW 5/31/2023 6 2023 Jun-23 3768.40 3770.40 2 55.8 Weekly Exercise 0 RW 6/28/2023 7 2023 Jul-23 3770.40 3772.40 2 52.4 Weekly Exercise 0 RW 7/19/20238 2023 Aug-23 3772.40 3776.00 3.6 53.5 Weekly Exercise, Gen. Maint. Load Test 1.1 Gen Main, Load Test RW 8/31/2023 9 2023 Sep-23 3776.00 3795.90 19.9 71.4 Weekly Exercise, New Transformer work 3.9 Power Outage 9/1 14 New Station Transformer Work RW 9/29/2023 10 2023 Oct-23 3795.90 3801.00 5.1 70.9 Weekly Exercise,Aux Gen Troubleshoot,repair 2.4 Power Outage 10/9 0.7 Aux Gen Troubleshoot/repair RW 10/31/2023 11 2023 Nov-23 3801.00 3807.80 6.8 61.7 Weekly Exercise, power outage 4.3 Power Outage 11/8,11/29 RW 11/30/202312 2023 Dec-23 3807.80 3809.80 2 59.2 Weekly Exercise 0 RW 12/28/2023 1 2024 Jan-24 3809.80 3812.30 2.5 56.8 Weekly Exercise 0 RW 1/31/2024 2 2024 Feb-24 3812.30 3814.30 2 56.8 Weekly Exercise 0 RW 2/28/2024 3 2024 Mar-24 3814.30 3816.10 1.8 55.7 Weekly Exercise 0 0.3 ATS Annual Test RW 3/21/2024 4 2024 Apr-24 3816.10 3819.00 2.9 56.5 Weekly Exercise 0.9 power outage 3/23/2024 RW 4/26/2024 5 2024 May-24 3819.00 3822.90 3.9 54.5 Weekly Exercise, Gen. Maint. Load Test 0 1.4 Gen Main, Load Test RW 5/31/2024 6 2024 Jun-24 3822.90 3834.60 11.7 64.2 Weekly Exercise, Power Outage 6/17-6/28 9.7 power outage 0 RW 6/28/2024 7 2024 Jul-24 3834.60 3837.00 2.4 64.6 Weekly Exercise 0 0 RW 7/31/2024 8 2024 Aug-24 3837.00 3839.30 2.3 63.3 Weekly Exercise, Power Outage 8/25 0.3 Power Outage RW 8/30/20249 2024 Sep-24 3839.30 3841.30 2 45.4 Weekly Exercise 0 0 RW 9/25/2024 10 2024 Oct-24 3841.30 3845.00 3.7 44 Weekly Exercise 1.2 Power Outage 10/17 0 RW 10/30/2024 11 2024 Nov-24 3845.00 3847.00 2.0 39.2 Weekly Exercise 0 0 RW 11/27/2024 12 2024 Dec-24 3847.00 3849.20 2.2 39.4 Weekly Exercise 0.2 Power Outage 12/15 0 RW 12/20/2024 1 2025 Jan-25 3849.20 3851.60 2.4 39.3 Weekly Exercise 0 0 RW 1/28/2025 2 2025 Feb-25 3851.60 #REF! Fillmore Compressor Station - Generator Hours