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Home My WebLink AboutDAQ-2025-0024891 DAQC-446-25 Site ID 12428 (B1) MEMORANDUM TO: FILE – URBAN OIL AND GAS GROUP, LLC – Clawson Spring Central Production Facility THROUGH: Harold Burge, Major Source Compliance Section Manager FROM: Robert Haynes, Environmental Scientist DATE: May 12, 2025 SUBJECT: FULL COMPLIANCE EVALUATION, SM80, Carbon County, FRS# UT0000004900700068 INSPECTION DATE: May 8, 2025 SOURCE LOCATION: Remote location in Carbon County (two miles east of Hiawatha) SOURCE CONTACT: Kirt Rasmussen: Office: 435-636-2402, Cell: 435-820-9801 Office: 6825 South 5300 West, Price, Utah 84501 Mailing Address: Urban Oil and Gas Group LLC 1000 East 14th Street, Suite 300 Plano, TX 75074 OPERATING STATUS: Operating PROCESS DESCRIPTION: This is a natural gas compressor station. It was originally named a production facility because of proposed equipment. Natural gas is captured from Coal Bed Methane (CBM) wells and is gathered on-site through multiple pipelines. The gas is compressed by one of four natural gas compressors. A fifth electric motor compressor is also on-site. Operations may run 24 hours a day. The numbers of compressors in operation varies for reasons that include temperature changes, natural gas volume, and other factors. After the compressed gas is cooled it passes through an amine (Ucarsol AP) contactor unit to extract CO2 from the gas. Next, the gas passes through a Tri-Ethylene Glycol (TEG) contactor unit to remove the moisture from the gas. Once the gas has been processed, it is piped to a sales gas line. APPLICABLE REGULATIONS: Approval Order DAQE-AN12480010-22 dated September 28, 2022 NSPS (Part 60), A: General Provisions MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 2 SOURCE EVALUATION: 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] Not evaluated. This is a statement of fact and not an inspection item. I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] Status: In compliance. No limits were 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. No modifications have been requested. 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. All records were provided upon request. 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. The equipment appeared to be maintained and operated per this AO. No visible emissions were observed. Maintenance procedures are followed. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance. No reportable breakdowns have occurred in the past year. I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] Status: In compliance. Urban Oil submitted the 2023 inventory to the Oil and Gas Air Emissions Inventory Group (OGEI). This source’s data is not maintained in SLEIS, but in a separate database and validated by the OGEI. 3 SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Natural Gas Production Facility II.A.2 Four (4) Compressor Engines Fuel: Natural Gas Manufacturer: Caterpillar Controls: Lean Pre-mix Combustion Heat Input: 9,893,330 BTU/hr each Stack Dimensions: 12 inch diameter by 33 feet in height (modeling requirement) Production Capacity: 6 MMscf/day each II.A.3 Four (4) Electric Compressor Motors Production Capacity: 6 MMscf/day each *listed for informational purposes only II.A.4 Two (2) TEG Re-boilers Fuel: Natural Gas Heat Capacity: 1.5 MMBtu/hr each Type of Burner: 83 ppm NOx; 29 ppm CO Exhaust Stack Dimensions: 15 inch diameter by 20 feet in height Exhaust Temperature: 600 Fahrenheit Stack flow rate: 777 acfm at each stack II.A.5 Two (2) DEA Re-boilers Fuel: Natural Gas Heat Capacity: 8.5 MMBtu/hr each Type of Burner: 83 ppm NOx; 29 ppm CO Exhaust Stack Dimensions: Three each for each boiler, 24 inch diameter by 28.5 feet in height Exhaust Temperature: 600 Fahrenheit Stack flow rate: 1467 acfm at each stack II.A.6 One (1) Emergency Natural Gas Vent Stack Status: In compliance. No unapproved equipment was observed. Currently, only C-103 and C-104 (of II.A.3) are running. One DEA-Re-boiler (II.A.5) is idle. 4 SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Facility-Wide Requirements II.B.1.a The owner/operator shall not allow visible emission to exceed the following values: A. All emergency vent stacks - 0% opacity B. All boiler exhaust stacks - 10% opacity C. All compressor engine exhaust stacks - 10% opacity. [R307-401-8] Status: In compliance. No visible emissions were observed from any equipment at the facility during inspection. II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [40 CFR 60 Subpart A] Status: This is a statement of fact. Method 9 is used to complete opacity observations from the equipment listed in Condition II.B.1.a. II.B.1.b The owner/operator shall not vent more than 300 MMscf of natural gas to the atmosphere during emergency situations per rolling 12-month period. [R307-401-8] Status: In compliance. The 12-month rolling total ending May 7, 2025, was 0.0 MMscf. The emergency vents are blocked off. II.B.1.b.1 To determine compliance with the rolling 12-month total the owner/operator shall: A. Determine the amount of vented natural gas with the use of a flowmeter B. Record the amount of natural gas vented on a monthly basis C. Use the gas venting records to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep records of natural gas venting for all periods when the plant is in operation. [R307-401-8] Status: In compliance. No natural gas has been vented in the past 12 months. The emergency vents are blocked off. II.B.1.c The owner/operator shall use only natural gas as fuel in the four (4) natural gas compressor engines, two (2) TEG reboilers, and two (2) DEA reboilers. [R307-401-8] Status: In compliance. The source confirmed that only sales gas is used at this site. 5 II.B.2 Stack Testing Requirements II.B.2.a The owner/operator shall not emit more than the following rates and concentrations from each Natural Gas Fired Compressor Engine: Pollutant lb/hr g/hp-hr ppmdv NOx 5.15 1.74 282 CO 5.51 1.87 498 Concentration (ppmdv) is corrected to 7.9% 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 Test Frequency The owner/operator shall conduct a stack test on the emission unit within five years after the date of the most recent stack test of the emission unit if using methods 10 and 7E as set forth in 40 CFR 60 Appendix A, or every two years if using a portable analyzer. 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 conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.b.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.b.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.b.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.b.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.b.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] 6 II.B.2.c 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.c.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] II.B.2.c.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] II.B.2.c.3 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. Emissions testing is completed using a portable analyzer every two years. Engine C-102 is currently out of service. The most recent testing for engines C-101, C-103, and C-104 occurred on September 26, 2024 (DAQC-1205-24): Engine Pollutant lb/hr ppmvd g/hp-hr C-101 NOx 2.46 254 1.34 CO 2.87 488 1.56 C-103 NOx 2.06 220 1.10 CO 2.53 442 1.35 C-104 NOx 2.58 252 1.44 CO 2.39 383 1.33 40 CFR FEDERAL REGULATIONS EVALUATION Part 63 NESHAP ZZZZ – National Emission standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines: Status: In compliance – The on-site existing non-emergency stationary reciprocating internal combustion engines (RICE) met the definition of Remote Stationary RICE the remote engine. Urban Oil continues to meet the definition of remote stationary engines as defined in this regulation. The most recent remote status determination was completed on January 21, 2025. Maintenance is performed on schedule. 7 UTAH ADMINISTRATIVE CODE RULE EVALUATION UAC R307-501 – General Provisions: Status: In compliance. According to company personnel that compressor station has not been modified or reconstructed since it was constructed around 1999. There are no natural gas controls. All equipment appeared to be in operational order with no emissions noted from any source. UAC R307-502 – Pneumatic Controllers: Status: In compliance. According to company personnel that compressor station has not been modified or reconstructed since it was constructed around 1999. The pneumatic controls operate on instrument air pressure. There are no natural gas controls. UAC R307-503 – Flares/Combustors: Status: Not Applicable. There are no open or enclosed flares operating at the compressor station, only a natural gas vent. EMISSION INVENTORY: See Condition I.7 above. The 2023 inventory (in tons) is as follows: PM10 0.735 PM2.5 0.735 SOX 0.043 VOC 21.33 NOX 85.29 CO 23.33 HPV STATUS: Not Applicable. PREVIOUS ENFORCEMENT ACTIONS: None in the past five years. COMPLIANCE ASSISTANCE: None. COMPLIANCE STATUS & RECOMMENDATIONS: Urban Oil, Clawson Spring should be found to be in compliance with Approval Order DAQE-AN12480010-22 at the time of this inspection. No further action is recommended. RECOMMENDATION FOR NEXT INSPECTION: Contact company personnel prior to conducting future inspections as sites are not manned. Inspect as usual. ATTACHMENTS: VEO form.