HomeMy WebLinkAboutDAQ-2025-000847
DAQE-AN102640008-25
{{$d1 }}
Robert Havalda
Mid-America Pipeline Company
1100 Louisiana Street
PO Box 4234
Houston, TX 77210-4234
rmhavalda@eprod.com
Dear Mr. Havalda:
Re: Approval Order: Administrative Amendment to Approval Order DAQE-AN102640004-07 for a
10-Year Review and Permit Updates
Project Number: N102640008
The attached Approval Order (AO) is issued pursuant to the Division of Air Quality conducting a 10-year
administrative review of this source and its respective AO. Mid-America Pipeline Company must comply
with the requirements of this AO, all applicable state requirements (R307), and Federal Standards.
The project engineer for this action is Lucia Mason, who can be contacted at (385) 707-7669 or
lbmason@utah.gov. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter.
Sincerely,
{{$s }}
Bryce C. Bird
Director
BCB:LM:jg
cc: Southeastern Utah District Health Department
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
February 12, 2025
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
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APPROVAL ORDER
DAQE-AN102640008-25
Administrative Amendment to Approval Order
DAQE-AN102640004-07 for a 10-Year Review
and Permit Updates
Prepared By
Lucia Mason, Engineer
(385) 707-7669
lbmason@utah.gov
Issued to
Mid-America Pipeline Company - Moab Station
Issued On
{{$d2 }}
Issued By
{{$s }}
Bryce C. Bird
Director
Division of Air Quality
February 12, 2025
TABLE OF CONTENTS
TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 4
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 5
PERMIT HISTORY ..................................................................................................................... 8
ACRONYMS ................................................................................................................................. 9
DAQE-AN102640008-25
Page 3
GENERAL INFORMATION
CONTACT/LOCATION INFORMATION
Owner Name Source Name
Mid-America Pipeline Company Mid-America Pipeline Company - Moab Station
Mailing Address Physical Address
1100 Louisiana Street PO Box 4234 1.1 miles south of the intersection of Highway 191 and Old Airport Road on Highway 191
Houston, TX 77210-4234 Moab, UT
Source Contact UTM Coordinates
Name: Robert Havalda 634,688 m Easting
Phone: (713) 381-6698 4,259,300 m Northing
Email: rmhavalda@eprod.com Datum NAD83
UTM Zone 12
SIC code 4619 (Pipelines, NEC)
SOURCE INFORMATION
General Description
Mid-America Pipeline Company (MAPCO) operates a turbine natural gas liquids pumping station near
Moab, Grand County. Equipment onsite includes two (2) natural gas turbine compressor engines, one (1)
storage tank, and one (1) flare.
NSR Classification
10-Year Review
Source Classification
Located in Attainment Area
San Juan County
Airs Source Size: SM
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), GG: Standards of Performance for Stationary Gas Turbines
NSPS (Part 60), KKKK: Standards of Performance for Stationary Combustion Turbines
Title V (Part 70) Area Source
DAQE-AN102640008-25
Page 4
Project Description
This project is an administrative amendment for a 10-year review of MAPCO's Moab Station and the
associated AO. The 10-year review includes updates to permit conditions, format, and state and federal
rule applicability.
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 12873.00
Carbon Monoxide 0 74.69
Nitrogen Oxides 0 45.07
Particulate Matter - PM10 0 0.81
Particulate Matter - PM2.5 0 0.81
Sulfur Dioxide 0 0.42
Volatile Organic Compounds 0 14.55
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 260
Change (TPY) Total (TPY)
Total HAPs 0 0.13
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 five-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]
DAQE-AN102640008-25
Page 5
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]
SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT II.A.1 Moab Station
II.A.2 One (1) 1,040 hp Turbine Compressor Engine Site Rating: 1,040 hp (12.98 MMBtu/hr) Fuel: Natural Gas NSPS Subpart GG II.A.3 One (1) 1,389 hp Turbine Compressor Engine Site Rating: 1,389 hp (13.49 MMBtu/hr) Fuel: Natural Gas NSPS Subpart KKKK
II.A.4 One (1) Storage Tank Service: Methanol Capacity: 500 gallons II.A.5 One (1) Flare
SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-wide Requirements: II.B.1.a The owner/operator shall not exceed the following opacity limits: A. The flare - no visible emissions B. All other points - 10% opacity. [R307-401-8]
DAQE-AN102640008-25
Page 6
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 natural gas and natural gas liquids as fuel in the turbine pumping engines and the flare. The composition of the fuel shall be tested according to the schedule
specified in 40 CFR 60 Subpart KKKK. [R307-401-8]
II.B.2 Stack Testing Requirements II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from the
1,040 hp Turbine Compressor Engine Exhaust Stack: Pollutant lb/hr ppmdv
NOx 7.57 109.81 CO 6.14 146.32
Concentration (ppmdv) is corrected to 15% oxygen, dry basis.
[R307-401-8]
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]
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]
II.B.2.a.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five (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] II.B.2.b The owner/operator shall not emit more than the following rates and concentrations from the
1,389 hp turbine exhaust stack:
Pollutant lb/hr ppmdv
NOx 6.00 100.00
CO 4.38 120.00
Concentration (ppmdv) is corrected to 15% oxygen, dry basis.
[R307-401-8]
II.B.2.b.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]
II.B.2.b.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]
DAQE-AN102640008-25
Page 7
II.B.2.b.3 Test Frequency The owner/operator shall conduct a stack test on the emission unit according to NSPS Subpart KKKK for NOx and within five (5) years after the date of the most recent stack test for CO 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] II.B.2.c The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.c.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]
II.B.2.c.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]
II.B.2.c.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]
II.B.2.c.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.c.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.c.6 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.d 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]
II.B.2.d.1 NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as
acceptable to the Director. [R307-401-8]
II.B.2.d.2 CO 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
DAQE-AN102640008-25
Page 8
PERMIT HISTORY
This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN102640004-07 dated January 5, 2007
DAQE-AN102640008-25
Page 9
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
DAQE-
RN102640008 January 27, 2025 Robert Havalda
Mid-America Pipeline Company 1100 Louisiana Street PO Box 4234
Houston, TX 772104234 rmhavalda@eprod.com
Dear Robert Havalda, Re: Engineer Review - Administrative Amendment to Approval Order DAQE-AN102640004-07 for a 10-Year Review and Permit Updates Project Number: N102640008 The DAQ requests a company representative review and sign the attached Engineer Review (ER). This ER identifies all applicable elements of the New Source Review (NSR) permitting program. Mid-America Pipeline Company should complete this review within 10 business days of receipt. Mid-America Pipeline Company should contact Lucia Mason at (385) 707-7669 if there are questions or
concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Lucia Mason at lbmason@utah.gov the signed cover letter. Upon receipt of the signed cover letter, the DAQ will prepare an Approval Order (AO) for signature by the DAQ Director. If Mid-America Pipeline Company does not respond to this letter within 10 business days, the project will move forward without source concurrence. If Mid-America Pipeline Company has concerns that
cannot be resolved and the project becomes stagnant, the DAQ Director may issue an Order prohibiting construction. Approval Signature _____________________________________________________________ (Signature & Date)
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978
www.deq.utah.gov
Printed on 100% recycled paper
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 1
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Project Number N102640008 Owner Name Mid-America Pipeline Company Mailing Address 1100 Louisiana Street
PO Box 4234 Houston, TX, 772104234
Source Name Mid-America Pipeline Company- Moab Station Source Location 1.1 miles south of the intersection of Highway 191 and Old Airport Road on Highway 191
Moab, UT UTM Projection 634,688 m Easting, 4,259,300 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 4619 (Pipelines, NEC) Source Contact Robert Havalda Phone Number (713) 381-6698 Email rmhavalda@eprod.com
Billing Contact Brenda Mendez Phone Number (713) 381-6595 Email bjmendez@eprod.com
Project Engineer Lucia Mason, Engineer Phone Number (385) 707-7669
Email lbmason@utah.gov Notice of Intent (NOI) Submitted December 5, 2024 Date of Accepted Application December 31, 2024
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 2
SOURCE DESCRIPTION General Description
Mid-America Pipeline Company (MAPCO) operates a turbine natural gas liquids pumping station near Moab, Grand County. Equipment onsite includes two (2) natural gas turbine compressor engines, one (1) storage tanks, and one (1) flare.
NSR Classification: 10 Year Review Source Classification Located in Attainment Area San Juan County Airs Source Size: SM Applicable Federal Standards NSPS (Part 60), A: General Provisions
NSPS (Part 60), GG: Standards of Performance for Stationary Gas Turbines NSPS (Part 60), KKKK: Standards of Performance for Stationary Combustion Turbines Title V (Part 70) Area Source
Project Proposal Administrative Amendment to Approval Order DAQE-AN102640004-07 for a 10-Year Review
and Permit Updates Project Description This project is an administrative amendment for a 10-year review of MAPCO's Moab Station and the associated AO. The 10-year includes updates to permit conditions, format, and state and federal rule applicability.
EMISSION IMPACT ANALYSIS This is a 10-year review. There are no changes to equipment or emissions at this time. Therefore, modeling is
not required. [Last updated December 31, 2024]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 3
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY) CO2 Equivalent 0 12873.00 Carbon Monoxide 0 74.69
Nitrogen Oxides 0 45.07
Particulate Matter - PM10 0 0.81
Particulate Matter - PM2.5 0 0.81
Sulfur Dioxide 0 0.42
Volatile Organic Compounds 0 14.55 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Generic HAPs (CAS #GHAPS) 0 260
Change (TPY) Total (TPY)
Total HAPs 0 0.13
Note: Change in emissions indicates the difference between previous AO and proposed modification.
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 4
Review of BACT for New/Modified Emission Units 1. BACT review regarding 10-Year Review
This is a 10-year review. There are no changes to equipment or emissions at this time. Therefore, a BACT analysis is not required. [Last updated December 31, 2024]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the AO. (New or Modified conditions are indicated as “New” in the Outline Label):
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 Executive Secretary or Executive Secretary'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]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 5
SECTION II: PERMITTED EQUIPMENT The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.A THE APPROVED EQUIPMENT
II.A.1 Natural Gas Pumping Station
II.A.2 One (1) 1,040 hp Turbine Compressor Engine Site Rating: 1,040 hp (12.98 MMBtu/hr) Fuel: Natural Gas NSPS Subpart GG
II.A.3 One (1) 1,389 hp Turbine Compressor Engine Site Rating: 1,389 hp (13.49 MMBtu/hr)
Fuel: Natural Gas NSPS Subpart KKKK
II.A.4 One (1) Storage Tank
Service: Methanol Capacity: 500 gallons
II.A.5 One (1) Flare
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 6
SECTION II: SPECIAL PROVISIONS The intent is to issue an air quality AO authorizing the project with the following recommended conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label): II.B REQUIREMENTS AND LIMITATIONS
II.B.1 NEW Site-wide Requirements:
II.B.1.a NEW The owner/operator shall not exceed the following opacity limits: A. The flare- no visible emissions
B. All other points- 10% opacity
[R307-401-8]
II.B.1.a.1 NEW 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 NEW The owner/operator shall use natural gas and natural gas liquids as fuel in the turbine pumping engines and the flare. The composition of the fuel shall be tested according to the schedule
specified in 40 CFR 60 Subpart KKKK. [R307-401-8] II.B.2 NEW Stack Testing Requirements
II.B.2.a NEW The owner/operator shall not emit more than the following rates and concentrations from the 1,040 hp Turbine Compressor Engine Exhaust Stack:
Pollutant lb/hr ppmdv
NOx 7.57 109.81 CO 6.14 146.32 Concentration (ppmdv) is corrected to 15% oxygen, dry basis. [R307-401-8] II.B.2.a.1 NEW 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]
II.B.2.a.2 NEW 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]
II.B.2.a.3 NEW 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]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 7
II.B.2.b NEW The owner/operator shall not emit more than the following rates and concentrations from the 1,389 hp turbine exhaust stack: Pollutant lb/hr ppmdv NOx 6.00 100.00 CO 4.38 120.00
Concentration (ppmdv) is corrected to 15% oxygen, dry basis.
[R307-401-8]
II.B.2.b.1 NEW 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]
II.B.2.b.2 NEW 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]
II.B.2.b.3 NEW Test Frequency The owner/operator shall conduct a stack test on the emission unit according to NSPS Subpart KKKK for NOx and within 5 years after the date of the most recent stack test for CO 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]
II.B.2.c NEW The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8]
II.B.2.c.1 NEW 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.c.2
NEW
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.c.3
NEW
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]
II.B.2.c.4 NEW 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]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 8
II.B.2.c.5 NEW 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.c.6 NEW 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.d NEW 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]
II.B.2.d.1
NEW
NOx
40 CFR 60, Appendix A, Method 7; Method 7E; or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
II.B.2.d.2 NEW CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 9
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Supersedes AO DAQE-AN102640004-07 dated January 5, 2007
REVIEWER COMMENTS
1. Comment regarding 10-Year Review:
This is a 10-year review. The language and formatting of this AO have been updated to reflect the style of modern permits. PTE values and the approved equipment list have been moved to respective new sections. The source is not modifying and/or installing any equipment.
PM2.5 and CO2e emissions were not included in AO DAQE-AN102640004-07 and have been added
to the Summary of Emissions table. PM2.5 emissions were conservatively estimated to be equivalent to PM10 emissions (0.81 tpy). CO2e emission calculations were based on the two (2) natural gas turbine compressor engines with heat inputs of 12.98 MMBtu/hr and 13.49 MMBtu/hr respectively operating 8,760 hours per year. CO2e emissions were calculated using emission factors sourced from AP-42 Table 3.1-2a and global warming potentials from 40 CFR Table A-1 to Subpart A of Part 98. The onsite flare was not included in CO2e emissions because it's rating was not recorded in 2007
AO. The source should include details about the flare in their next permit update so that CO2e emissions from the flare can be added to the total on record. [Last updated January 27, 2025]
2. Comment regarding Federal Standard Applicability: 40 CFR 60 Subpart KKKK: Standards of Performance for Stationary Combustion Turbines. NSPS Subpart KKKK applies to stationary combustion turbines with a heat input at peak load equal or greater than 10 MMBtu/hr (based on the lower heating value of the fuel fired) that commenced construction after February 18, 2005. The 1,389 hp (13,486,857 Btu/hr) turbine compressor engine was installed as part of a 2007 modification (AO DAQE-AN 102640004-07), triggering NSPS
Subpart KKKK. 40 CFR 60 Subpart GG: Standards of Performance for Stationary Gas Turbines. Subpart GG applies to all stationary gas turbines with a heat input at peak load equal to or greater than 10 MMBtu/hr (based on the lower heating value of the fuel fired). The facility operates two stationary
gas turbines with heat inputs greater than 10MMBtu/hr. However, the 1,389 hp turbine is subject to NSPS Subpart KKKK which exempts it from NSPS Subpart GG. Therefore, only the 1,040 hp turbine compressor engine is subject to NSPS Subpart GG.
40 CRF 63 Subpart YYYY: National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines. MACT Subpart YYYY applies to all stationary combustion turbine located at a major source of HAP emissions. There are two stationary combustion turbines at the facility. However, the facility is not a major source of HAP emissions. Thus, MACT Subpart
YYYY does not apply.
[Last updated January 16, 2025]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 10
3. Comment regarding Title V Applicability: Title V of the 1990 Clean Air Act (Title V) applies to the following:
1. Any major source 2. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources; 3. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous
Air Pollutants. 4. Any Title IV affected source. This facility is not a major source and is not a Title IV source. However, the facility is subject to 40 CFR 60 Subpart GG and 40 CFR 60 Subpar KKKK. Due to operational constraints in the AO, this
source is a synthetic minor. Therefore, the source is subject to the Title V program but is not currently required to obtain an operating permit. [Last updated January 13, 2025]
Engineer Review N102640008: Mid-America Pipeline Company- Moab Station January 27, 2025 Page 11
ACRONYMS The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations AO Approval Order BACT Best Available Control Technology
CAA Clean Air Act CAAA Clean Air Act Amendments CDS Classification Data System (used by EPA to classify sources by size/type) CEM Continuous emissions monitor CEMS Continuous emissions monitoring system CFR Code of Federal Regulations CMS Continuous monitoring system CO Carbon monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1 COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality DAQE This is a document tracking code for internal UDAQ use EPA Environmental Protection Agency
FDCP Fugitive dust control plan GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i) GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s) ITA Intent to Approve LB/HR Pounds per hour
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units
NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent NOx Oxides of nitrogen NSPS New Source Performance Standard NSR New Source Review PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size PSD Prevention of Significant Deterioration PTE Potential to Emit
R307 Rules Series 307 R307-401 Rules Series 307 - Section 401 SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act Title V Title V of the Clean Air Act TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds
GAS TURBINES
Rating 1040
Rating 12.98
Hours of Operation 8760
Greenhouse Gas Pollutant
Emission Factor
(lb/MMBtu)
Global Warming
Potential
CO2 110 1
Methane 0.0086 28
N2O 0.003 265
CO2e
Source AP-42Table 3.1-2a
Table A-1 to Subpart A
of Part 98
1389 hp
13.49 MMBtu/hr
8760 Hours/year
Emissions, 1,040 hp
engine (tpy)
Emissions, 1,389 hp
engine (tpy)
6254 6499
0 1
0 0
6313 6561
TOTAL CO2e 12873
DAQE-953-99
December 7, 1999
H. Lee Bauerle
Sr. Environmental Specialist
Williams-Mid America Pipeline Company
295 Chipeta Way
Salt Lake City, Utah 84158
Dear Mr. Bauerle:
Re: Modification to Approval Order (DAQE-0986-93), for Addition of a Turbine Compressor at the
Moab Station, Grand County, CDS, B, ATT, NSPS, Title V
The attached document is an Approval Order for the above-referenced project.
Future correspondence on this Approval Order should include the engineer's name as well as the DAQE
number as shown on the upper right-hand corner of this letter. Please direct any technical questions you
may have on this project to Mr. Tad Anderson. He may be reached at (801) 536-4456.
Sincerely,
Ursula Kramer, Executive Secretary
Utah Air Quality Board
LRM:TDA:aj
cc:
Southeastern Utah District Health Department
Mike Owens, EPA Region VIII
State of Utah DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
Michael O. Leavitt 150 North 1950 West
Governor P.O. Box 144820
Dianne R. Nielson, Ph.D. Salt Lake City, Utah 84114-4820
Executive Director (801) 536-4000 Voice
Ursula Kramer (801) 536-4099 Fax
Director (801) 536-4414 T.D.D.
Web: www.deq.state.ut.us
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
MODIFICATION TO APPROVAL ORDER (DAQE-0986-93),
FOR ADDITION OF A TURBINE COMPRESSOR AT THE
MOAB STATION
Prepared By: Tad Anderson, Engineer
(801) 536-4456
APPROVAL NUMBER
DAQE-953-99
Date: December 7, 1999
Source Contact
Mid-America Pipeline Company
H. Lee Bauerle
(801) 584-6999
Ursula Kramer
Executive Secretary
Utah Air Quality Board
Abstract
Williams-Mid America Pipeline Company (MAPCO) has submitted a Notice Of Intent (NOI) to modify
their current Approval Order (AO) DAQE-0986-93 for the Moab Station in San Juan County, Utah.
The air pollution emitting equipment at this site currently consists of one Solar Saturn turbine
compressor T-1302 and an emergency flare. MAPCO proposes to install another turbine compressor
(Solar Saturn 1302) at this site. The new natural gas turbine has a low NOX burner which meets the
state’s Best Available Control Technology (BACT) for this process. The total air pollutant emissions
for the entire Moab Station are estimated to be: PM10 = 3.02 tpy; SOX = 0.14 tpy; NOX = 87.03 tpy;
CO = 77.82 tpy; VOC = 3.69 tpy, and HAPs = 0.19 tpy.
San Juan County is an attainment area for all criteria pollutants. This site is subject to the
requirement of New Source Performance Standards (NSPS) under 40 CFR Part 60 Subpart GG
(Stationary Gas Turbines). Because this source is an NSPS source, this also falls under the 40 CFR
Part 70 CAA Title V regulations. No modeling was required since the increase in emissions is below
the current threshold established in DAQ’s modeling guidelines. Because there is an increase in
emissions associated with this modification, a 30-day public comment period was required.
The above-referenced project has been evaluated and found to be consistent with the requirements of the
Utah Administrative Code Rule 307 (UAC R307) and the Utah Air Conservation Act. A 30-day public
comment period was held and all comments received were evaluated. The conditions of this AO reflect
any changes to the proposed conditions which resulted from the evaluation of the comments received.
This air quality AO authorizes the project with the following conditions and failure to comply with any of
the conditions may constitute a violation of this order:
General Conditions:
1. This Approval Order (AO) applies to the following company:
Facility Location Corporate Office Location
Moab Natural Gas Pump Station Williams-Mid America Pipeline Company
8 miles south of Moab 295 Chipeta Way
San Juan County, Utah Salt Lake City, Utah 84158
Phone (801)584-6135
Fax (801)584-7760
The equipment listed below in this AO shall be operated at the following location:
PLANT LOCATION:
8 miles south of Moab
Universal Transverse Mercator (UTM) Coordinate System:
4,259.1 kilometers Northing; 634.7 kilometers Easting; Zone 12
2. Definitions of terms, abbreviations, and references used in this AO conform to those used
in the Utah Administrative Code Rule 307 (UAC R307), and Series 40 of the Code of
Federal Regulations (40 CFR). These definitions take precedence unless specifically
defined otherwise herein.
3. Williams-Mid America Pipeline Company shall install and operate the new Solar Saturn
T-1302 turbine compressor and shall operate the Moab Natural Gas Compressor Station
DAQE-953-99
Page 3
according to the terms and conditions of this AO as requested in the Notice of Intent
dated September 21, 1999.
4. This AO shall replace all sections which address Moab Station in the AO dated
November 5, 1993 (DAQE-0986-93).
5. The approved installations shall consist of the following equipment or equivalent*:
A. Two (2) Turbine Compressors
Manufacturer: Solar Saturn*
Model: T-1302
Capacity: 1,040 Horsepower
B. Flare (emergencies and maintenance only)
* Equivalency shall be determined by the executive secretary.
Any future changes or modifications to the equipment and processes approved by this
AO that could affect the emissions covered by this AO must be approved in accordance
with R307-401-1, UAC.
6. The executive secretary shall be notified in writing upon start-up of the new turbine
compressor, as an initial compliance inspection is required. Eighteen months from the
date of this AO the executive secretary shall be notified in writing of the status of
construction/installation if construction/installation is not completed. At that
time the executive secretary shall require documentation of the continuous construction/
installation of the operation and may revoke the AO in accordance with R307-401-11,
UAC. If construction is complete and operation has commenced a notice is not required
on the status of the construction/installation.
Limitations and Tests Procedures
7. Emissions to the atmosphere at all times from the indicated emission points shall not
exceed the following rates and concentrations:
A. New Turbine Compressor, T-1302
Pollutant lb/hr
NOx ................. ........................................ ........................................ 7.57
CO ................... ........................................ ........................................ 6.14
B. Old Turbine Compressor, T-1302
Pollutant lb/hr
NOx ................. ........................................ ........................................ 4.33
CO ................... ........................................ ...................................... 18.35
8. Stack testing to show compliance with the emission limitations stated in the above
condition shall be performed as specified below:
DAQE-953-99
Page 4
A. Testing Test
Emissions Point Pollutant Status Frequency
New Turbine Compressor CO ......................... ** ..................... #
NOx ........................ ** ..................... #
Old Turbine Compressor CO ......................... * ....................... #
NOx ........................ * ....................... #
B. Testing Status (To be applied above)
.
* The initial testing has already been performed.
** Initial compliance testing using method 20 and 10 is required on the new
turbine compressor at site elevation. The initial test date shall be
performed as soon as possible and in no case later than 180 days after the
start up of a new emission source, an existing source without an AO, or
the granting of an AO to an existing emission source that has not had an
initial compliance test performed. If an existing source is modified, a
compliance test is required on the modified emission point.
# Test every two years (or sooner if requested by executive secretary)
using portable testing monitors or every five years using Method 20 and
10. If the source is suspected to be in violations with the emission limits
stated in the permit, testing may be required.
Sample Location
As described in Method 20 and 10
Volumetric Flow Rate
As described in Method 20 and 10
C. Notification
The applicant shall provide a notification to the executive secretary of any test
required by this AO at least 45 days before the test. A pretest conference shall
be held if directed by the executive secretary. It shall be held at least 30 days
before the test and include representation from the owner/operator, the tester, and
the executive secretary. The emission point shall be designed to conform to the
requirements of 40 CFR 60, Appendix A, Method 20, 10, and Occupational
Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.
Calculations
To determine mass emission rates (lbs/hr), 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
executive secretary to give the results in the specified units of the emission
limitation. The calculations shall also be performed as described in Method 20
and 10.
DAQE-953-99
Page 5
D. New Source Operation
For a new source/emission point, the production rate during all compliance
testing shall be no less than 90% of the production rate listed in this AO. If the
maximum AO allowable production rate has not been achieved at the time of the
test, the following procedure shall be followed:
1) Testing shall be at no less than 90% of the production rate achieved to
date.
2) If the test is passed, the new maximum allowable production rate shall be
110% of the tested achieved rate, but not more than the maximum
allowable production rate. This new allowable maximum production
rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when
necessary. Testing at no less than 90% of the higher rate shall be
conducted. A new maximum production rate (110% of the new rate)
will then be allowed if the test is successful. This process may be
repeated until the maximum AO production rate is achieved.
9. Visible emissions from any stationary point or fugitive emission source associated with
the source or with the control facilities shall not exceed 10% opacity (typical opacity
limit for natural gas combustion sources). Opacity observations of emissions from
stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A,
Method 9. Visible emissions from mobile sources and intermittent sources shall use
procedures similar to Method 9, but the requirement for observations to be made at
15-second intervals over a thirty-minute period.
Fuels
10. The owner/operator shall use only pipeline quality natural gas as a fuel in the turbines.
If any other fuel is to be used, an AO shall be required in accordance with R307-401,
UACR.
Records & Miscellaneous
11. In addition to the requirements of this AO, all provisions of 40 CFR 60, New Source
Performance Standards (NSPS)1 Subparts A and GG, 40 CFR 60.1 to 60.18 and 40 CFR
60.330 to 60.335 (Standards of Performance for Stationary Gas Turbines) apply to this
installation. A copy of the latest 40 CFR 60 Subparts A (section 60.8) and Subparts
(section 60.330), dated July 1, 1993, is attached to this document as Appendix A.
However, to be in compliance, this facility must operate in accordance with the most
current version of 40 CFR 60 applicable to this source.
1 NSPS = New Source Performance Standards.
DAQE-953-99
Page 6
12. The owner/operator shall comply with R307-150, UAC. This rule addresses emission
inventory reporting requirements. Each owner or operator of a stationary source subject
to this rule shall maintain for a period of four years from the due date of each emission
statement, a copy of the emission statement submitted to the Division of Air Quality and
records indicating how the information submitted in the emission statement was
determined, including any calculations, data, measurements, and estimates used. These
records shall be made available to the executive secretary or executive secretary’s
representative upon request and the records shall include the two-year period prior to the
date of the request.
The full text of R307-150 Emission Inventories is included as Appendix B. However, to
be in compliance, this facility must operate in accordance with the most current version
of R307-150 or the applicable section(s), if renumbered.
13. The owner/operator shall keep on record the fuel analysis to determine sulfur
concentration. Fuel analysis must be preformed every six months and must be recorded
and filed to determine compliance with § 60.333 (a). Nitrogen monitoring can be
waived for pipeline quality natural gas, since there is no fuel-bound nitrogen and since
the free nitrogen does not contribute appreciably to NOX emissions [USEPA Memo,
August 14, 1987].
14. All installations and facilities authorized by this AO shall be adequately and properly
maintained. All pollution control vendor-recommended equipment shall be installed,
maintained, and operated. Instructions from the vendor or established maintenance
practices that maximize pollution control shall be used. All maintenance performed on
equipment authorized by this AO shall be recorded, and the records shall be maintained
for a period of two years. All necessary equipment control and operating devices, such
as pressure gauges, amp meters, volt meters, flow-rate indicators, temperature gauges,
CEMS, etc., shall be installed and operated properly and easily accessible to compliance
inspectors. A copy of all the manufacturers' and company’s own subsequent operating
instructions for pollution control equipment and pollution emitting equipment shall be
kept on site. These instructions shall be available to all employees who operate the
equipment and shall be made available to compliance inspectors upon their request.
Maintenance records shall be made available to the executive secretary or executive
secretary’s representative upon request, and the records shall include the two-year period
prior to the date of the request.
15. The owner/operator shall comply with R307-107, UAC. This rule addresses
unavoidable breakdown reporting requirements. Any breakdown lasting longer than two
hours shall be reported to the executive secretary within three hours of the breakdown if
reasonable, but in no case longer than 18 hours after the beginning of the breakdown.
During times other than normal office hours, breakdowns for any period longer than two
hours shall be initially reported to the Environmental Health Emergency Response
Coordinator. Within seven calendar days of the beginning of any breakdown lasting
longer than two hours, a written report shall be submitted to the executive secretary. The
owner/operator shall calculate/estimate the excess emissions (amount above AO limits)
whenever a breakdown occurs. The total of excess emissions per calendar year shall be
reported to the executive secretary with the inventory submittal, as directed by the
executive secretary. The owner or operator of an installation suffering an unavoidable
breakdown shall assure that emission limitations and visible emission limitations are
exceeded for only as short a period of time as reasonable. The owner or operator shall
take all reasonable measures which may include but
DAQE-953-99
Page 7
are not limited to the immediate curtailment of production, operations, or activities at all
installations of the source if necessary to limit the total aggregate emissions from the
source to no greater than the aggregate allowable emissions averaged over the periods
provided in the source's approval order.
All records referenced in this AO or in applicable NSPS, which are required to be kept by the
owner/operator, shall be made available to the executive secretary or executive secretary’s representative
upon request and shall include a period of two years ending with the date of the request. All records
shall be kept for a period of two years. A summary of those records that are required as part of this AO
is included herein. This summary shall be not considered to be an additional requirement, but shall be
considered as an informational source only. The condition that requires that these records to be kept as
part of the compliance with this AO is listed following the individual record. Examples of records to be
kept at this source shall include the following as applicable:
Test results (Condition number 8)
Emission inventory (Condition number 12)
Fuel analysis records (Condition number 13)
Maintenance records (Condition number 14)
Upset, breakdown episodes (Condition number 15)
Any future modifications to the equipment approved by this order must also be approved in accordance
with R307-401, UAC.
The executive secretary shall be notified in writing if the company is sold or changes its name. The
notification shall be submitted within 30 days of such action.
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.
A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting
the Division of Air Quality. The Utah Administrative Code R307 rules used by DAQ, the Notice of
Intent (NOI) guide, and other air quality documents and forms may also be obtained on the Internet at the
following web site: http://www.eq.state.ut.us/eqair/aq_home.htm
Annual emissions for the Moab Station are currently calculated at the following values:
Pollutant Tons/yr
A. PM10 ...................................................... 3.02
B. SO2 ........................................................ 0.14
C. NOx ...................................................... 87.03
D. CO ....................................................... 77.82
E. VOC ...................................................... 3.69
F. HAP’s .................................................... 0.19
These calculations are for the purposes of determining the applicability of Prevention of Significant
Deterioration, nonattainment area, and Title V source requirements of the UAC R307.
DAQE-953-99
Page 8
In accordance with the requirements of Title V of the 1990 Clean Air Act, actual emissions of regulated
pollutants maybe subject to operating permit fee except for the following:
A. CO
B. Any pollutant that is a regulated air pollutant solely because it is a Class I or II substance
subject to a standard promulgated or established by Title VI of the Act, Stratospheric Ozone
Protection
C. Any pollutant that is a regulated air pollutant solely because it is subject to a standard or
regulation under Section 112(r) of the Act, Prevention of Accidental Releases
D. Tail pipe emissions.
Regulated air pollutant in R307-15 means any of the following:
(1) Nitrogen oxides or any volatile organic compound;
(2) Any pollutant for which a national ambient air quality standard has been promulgated;
(3) Any pollutant that is subject to any standard promulgated under Section 111 of the Act,
Standards of Performance for New Stationary Sources;
(4) Any Class I or II substance subject to a standard promulgated under or established by Title VI
of the Act, Stratospheric Ozone Protection;
(5) Any pollutant subject to a standard promulgated under Section 112, Hazardous Air
Pollutants, or other requirements established under Section 112 of the Act, including Sections
112(g), (j), and (r) of the Act, including any of the following:
(i) Any pollutant subject to requirements under Section 112(j) of the Act, Equivalent
Emission Limitation by Permit. If the Administrator fails to promulgate a standard by
the date established pursuant to Section 112(e) of the Act, any pollutant for which a
subject source would be major shall be considered to be regulated on the date 18 months
after the applicable date established pursuant to Section 112(e) of the Act;
(ii) Any pollutant for which the requirements of Section 112(g)(2) of the Act (Construction,
Reconstruction and Modification) have been met, but only with respect to the individual
source subject to Section 112(g)(2) requirement.
Emissions of the following pollutants from all sources, including pre-November 29, 1969 sources, may be
subject to the operating permit fee. Both the fees rate and the class of pollutants are subject to change by
State, the federal agencies, or both. If the actual emissions are not known, then the operating permit fee
will be base on the following amounts:
Pollutant Tons/yr
A. PM10 ...................................................... 3.02
B. SO2 ........................................................ 0.14
C. NOx ...................................................... 87.03
D. VOC ...................................................... 3.69
E. HAP’s .................................................... 0.19
Approved By:
Ursula Kramer, Executive Secretary
Utah Air Quality Board
Lucia Mason <lbmason@utah.gov>
Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
12 messages
Lucia Mason <lbmason@utah.gov>Mon, Dec 16, 2024 at 1:54 PM
To: pwabbott@eprod.com
Hi Patrick,
The Division of Air Quality (DAQ) is making customary permit updates to the approval order (AO) for Mid-America Pipeline Company's Moab Pump Station (site
10264). Please provide the following updated contact information for the site:
Site: phone number, and email (if applicable)
Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email
Environmental contact: name, physical address, mailing address, phone number, fax number (if applicable) and email
Billing contact: (if different from environmental contact): name, physical address, phone number, fax number (if applicable) and email
Name on Approval Order: (if different from environmental contact): name, physical address, mailing address, phone number, fax number (if applicable)
and email
Feel free to reach out with any questions.
Thanks,
Lucia
Abbott, Patrick <pwabbott@eprod.com>Thu, Dec 19, 2024 at 2:25 PM
To: Lucia Mason <lbmason@utah.gov>
Cc: "Abbott, Patrick" <pwabbott@eprod.com>
Lucia,
Updated info below in blue:
Let me know if you need anything further.
Thanks,
1/16/25, 11:03 AM State of Utah Mail - Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2926572784282480233&simpl=msg-a:r-925593501570955897&simpl=msg-f:1818905584805939869&simpl=…1/5
Pat Abbott
Senior Environmental Scientist
Enterprise Products
744 Horizon Ct., Ste. 224
Grand Junction, CO 81506
pwabbott@eprod.com
Cell: 970.210.0052
Desk: 970.263.3016
From: Lucia Mason <lbmason@utah.gov>
Sent: Monday, December 16, 2024 1:55 PM
To: Abbott, Patrick <pwabbott@eprod.com>
Subject: [EXTERNAL] Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
[Use caution with links/attachments]
Hi Patrick,
The Division of Air Quality (DAQ) is making customary permit updates to the approval order (AO) for Mid-America Pipeline Company's Moab Pump Station (site
10264). Please provide the following updated contact information for the site:
· Site: phone number, and email (if applicable) N/A
· Company: physical address, billing address, mailing address, phone number, fax number (if applicable) and email Mid-America Pipeline Company,
LLC 1100 Louisiana Houston, TX 77002 P.O. Box 4234 Houston, TX 77210-4234 713-381-6595 environmental@eprod.com
· Environmental contact: name, physical address, mailing address, phone number, fax number (if applicable) and email Robert Havalda 1100
Louisiana Houston, TX 77002 P.O Box 4234 Houston, TX 77210-4234 Houston, TX 77210-4234 713-381-6698 rmhavalda@eprod.com
· Billing contact: (if different from environmental contact): name, physical address, phone number, fax number (if applicable) and email Brenda
Mendez 1100 Louisiana Houston, TX 77002 P.O. Box 4234 Houston, TX 77210-4234 713-381-6595 bjmendez@eprod.com
1/16/25, 11:03 AM State of Utah Mail - Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2926572784282480233&simpl=msg-a:r-925593501570955897&simpl=msg-f:1818905584805939869&simpl=…2/5
· Name on Approval Order: (if different from environmental contact): name, physical address, mailing address, phone number, fax number (if
applicable) and email Same as environmental contact
Feel free to reach out with any questions.
Thanks,
Lucia
This message (including any attachments) is confidential and intended for a specific individual and purpose. If you are not the intended recipient, please notify the
sender immediately and delete this message.
Lucia Mason <lbmason@utah.gov>Fri, Dec 20, 2024 at 6:13 AM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Thank you. I'll reach out if the DAQ needs additional information.
[Quoted text hidden]
Lucia Mason <lbmason@utah.gov>Tue, Dec 31, 2024 at 10:56 AM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Hi Patrick,
I have two follow up questions:
1. What is the best address for the facility? At the moment the address we have on file is "1.1 miles south-east of the intersection of Highway 191 and Old
Airport Road on Highway 191." I'm wondering if there is something more concise you like to use.
2. What is the manufacture date of the 1,389 hp turbine compressor engine? The date may impact the facility's federal subpart applicability.
Happy New Year's Eve!
Lucia
[Quoted text hidden]
Lucia Mason <lbmason@utah.gov>Fri, Jan 3, 2025 at 9:23 AM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Hi Patrick,
1/16/25, 11:03 AM State of Utah Mail - Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2926572784282480233&simpl=msg-a:r-925593501570955897&simpl=msg-f:1818905584805939869&simpl=…3/5
I forgot to ask in my previous email, what is the capacity of the flare in Equipment ID 8.D?
Best,
Lucia
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Abbott, Patrick <pwabbott@eprod.com>Mon, Jan 6, 2025 at 11:05 AM
To: Lucia Mason <lbmason@utah.gov>
Cc: "Abbott, Patrick" <pwabbott@eprod.com>
Lucia,
We do not have a better address for this site. We are good with what you have.
The 1,389 hp turbine was manufactured on April 10, 2007.
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Lucia Mason <lbmason@utah.gov>Mon, Jan 6, 2025 at 11:12 AM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Thanks.
Could you also provide the capacity of the flare?
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Abbott, Patrick <pwabbott@eprod.com>Mon, Jan 6, 2025 at 11:13 AM
To: Lucia Mason <lbmason@utah.gov>
Cc: "Abbott, Patrick" <pwabbott@eprod.com>
Lucia,
I am working with our permit engineer on that. I will send it over as soon as I have it.
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Lucia Mason <lbmason@utah.gov>Mon, Jan 6, 2025 at 11:14 AM
To: "Abbott, Patrick" <pwabbott@eprod.com>
1/16/25, 11:03 AM State of Utah Mail - Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2926572784282480233&simpl=msg-a:r-925593501570955897&simpl=msg-f:1818905584805939869&simpl=…4/5
Sounds good. Thank you!
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Abbott, Patrick <pwabbott@eprod.com>Mon, Jan 6, 2025 at 1:07 PM
To: Lucia Mason <lbmason@utah.gov>
Cc: "Havalda, Robert" <rmhavalda@eprod.com>, "Abbott, Patrick" <pwabbott@eprod.com>
Lucia,
Can you clarify what capacity you are looking for?
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Lucia Mason <lbmason@utah.gov>Mon, Jan 6, 2025 at 4:39 PM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Hi Patrick,
Ideally I'm looking for the maximum MMBtu/hr of natural gas that is burned in the flare. Let me know if you need more information.
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Lucia Mason <lbmason@utah.gov>Tue, Jan 7, 2025 at 5:17 PM
To: "Abbott, Patrick" <pwabbott@eprod.com>
Hey Patrick,
The DAQ can continue processing this 10-year review without the flare capacity. Apologies for the inconvenience.
Best,
Lucia
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1/16/25, 11:03 AM State of Utah Mail - Periodic Permit Updates (Division of Air Quality), 10264: Mid-America Pipeline Company- Moab Station
https://mail.google.com/mail/u/0/?ik=509389cc4c&view=pt&search=all&permthid=thread-a:r-2926572784282480233&simpl=msg-a:r-925593501570955897&simpl=msg-f:1818905584805939869&simpl=…5/5