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Home My WebLink AboutDAQ-2025-0024901 DAQC-447-25 Site ID 11168 (B1) MEMORANDUM TO: FILE – URBAN OIL AND GAS GROUP, LLC – Helper Station (Help #1) Compressor Station 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 ID UT0000004900700049 INSPECTION DATE: May 8, 2025 SOURCE LOCATION: 3 miles northeast of Price, Helper, Utah in Carbon County. 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 LLC 1000 East 14th Street, Suite 300 Plano, TX 75074 OPERATING STATUS: Operating PROCESS DESCRIPTION: Natural gas compressor station. 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. Four electric motor compressors are 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 a Di-ethylamine (DEA) 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 (AO) DAQE-AN111680015-22, dated March 23, 2022 40 CFR 63 Subpart ZZZZ NESHAP for Stationary Reciprocating Internal Utah Administration Code (UAC) R307-501 O&G General Provisions UAC R307-502 O&G Pneumatic Controllers UAC R307-504 Tank Truck Loading 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] Status: 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. Limits set in this AO were not exceeded at time of the 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 to equipment or processes were observed during this inspection. 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 were provided during 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. The equipment appeared to be properly maintained and operated at time of the inspection. All records were provided upon request. I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] Status: In compliance. According to company personnel there have been no on-site breakdowns in the last 12-months. Preventative maintenance is used to help prevent breakdowns. See status of condition I.5. I.7 The owner/operator shall comply with UAC R307-150 Series. Inventories, Testing and Monitoring. [R307-150] Status: In compliance. Urban Oil is on a tri-annual report period. The emissions workbook for 2023 is summarized at the end of this document. 3 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. The new units 1972 and 1973 are installed and operating. Stack testing is being completed as scheduled (see status of II.B.1.d). Section II: SPECIAL PROVISIONS II.A THE APPROVED EQUIPMENT II.A.1 Helper Station Natural Gas Compressor Station II.A.2 Compressor Engines Four (4) Internal Combustion (IC) Compressor Engines Manufacturer Rated Horsepower: 1,340 derated to 1,206 Fuel Type: Natural Gas Stack Height (above ground): minimum 24 feet (modeling requirement) II.A.3 Tri-ethylene Glycol Unit One (1) Tri-ethylene Glycol Dehydration Unit with Natural Gas-fired Boiler Maximum Boiler Rating: 1.5 MMBTU/hr II.A.4 Di-ethylamine (DEA) Unit One (1) Di-ethylamine (DEA) Unit with Natural Gas-fired Boiler Maximum Boiler Rating: 4.4 MMBTU/hr II.A.5 Di-ethylamine (DEA) Unit One (1) Di-ethylamine (DEA) Unit with Natural Gas-fired Boiler Maximum Boiler Rating: 7.33 MMBTU/hr II.A.6 One (1) Emergency Vent (Not Flared) II.A.7 Electric Compressor One (1) Electrically Powered Natural Gas Compressor Note: Listed for informational purposes only and produces no emissions. Status: In compliance. No unapproved equipment was observed on-site. There are four RICE engines and one electric engine. RICE engine numbers: 1802, 1803, 1972, and 1973. This AO is for the replacement-in-kind for units 1972 and 1973. The TEG and DEAs are installed. One DEA (II.A.4) is currently idle. The emergency vent is not a flare, is blocked off, and not used. 4 II.B REQUIREMENTS AND LIMITATIONS II.B.1 The Helper CPF Natural Gas Fired Compressor Station shall be subject to the following: II.B.1.a The owner/operator shall not allow visible emissions from the following emission points to exceed the following values: A. All emergency vent stacks - 0% opacity B. All natural gas-fired compressors - 5% opacity C. All boiler exhaust stacks - 10% opacity D. All other points - 20% opacity [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Status: In compliance. No visible emissions were observed during this inspection. II.B.1.b The owner/operator shall use only pipeline-grade natural gas as fuel. [R307-401-8] Status: In compliance. All combustion gas comes from the post compression lines and is from the sales line only. II.B.1.c The owner/operator shall not vent more than 200 million scf of natural gas to the atmosphere per rolling 12-month period. The natural gas shall not be flared. [R307-401-8] II.B.1.c.1 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 production data to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep the records of natural gas venting for all periods the plant is in operation. [R307-401-8] Status: In compliance. Urban Oil has blocked off the emergency vent. The flow meter was reading 0.0. The 12 month rolling total of gas vented ending May 7, 2025, was 0.0. II.B.1.d The owner/operator shall not emit more than the following rates and concentrations from each 1206 hp IC Compressor Engine: Pollutant lb/hr g/bhp-hr NOx 5.32 2.00 CO 5.05 1.90 [R307-401-8] II.B.1.d.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] 5 II.B.1.d.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.1.d.3 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, using methods 10 and 7E set forth in 40 CFR 60 Appendix A or within two years (2) of the most recent stack test of the emission unit using a portable analyzer. If methods 10 and 7E are used, test results shall be the average of three 30-minute test runs. Volumetric flow rate shall be determined stoichiometrically. The Director may require the owner/operator to perform a stack test at any time. [R307-165-2, R307-401-8] Status: In compliance. The source has been keeping up with testing requirements. Previous 2-year portable test were done October 12, 2023. Results were: Source NOx lb/hr CO lb/hr Source list C101 2.19 2.62 1801 C102 2.49 2.25 1802 C104 2.40 2.06 1972 C103 2.98 2.25 1973 Engines 1972 and 1973 were tested on September 21, 2022. Results were: Source Test Method Pollutant Result Limit 1972 RM7E/19 NOx 2.29 lb/hr 5.32 lb/hr 0.95 g/bhp-hr 2.00 g/bhp-hr RM10/19 CO 1.95 lb/hr 5.05 lb/hr 0.79 g/bhp-hr 1.90 g/bhp/hr 1973 RM7E/19 NOx 2.29 lb/hr 5.32 lb/hr 1.27 g/bhp-hr 2.00 g/bhp-hr RM10/19 CO 1.95 lb/hr 5.05 lb/hr 0.85 g/bhp-hr 1.90 g/bhp/hr II.B.2 Stack Testing Requirements II.B.2.a The owner/operator shall conduct any stack testing required by this AO according to the following conditions. [R307-401-8] II.B.2.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] II.B.2.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] II.B.2.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] 6 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 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.b.2 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.3 CO 40 CFR 60, Appendix A, Method 10 or other EPA-approved testing method as acceptable to the Director. [R307-401-8] II.B.2.b.4 Internal Combustion (IC) Engines Portable testing monitors may be used to test IC engines. If portable monitors are to be used, they shall be calibrated according to the manufacturer's recommendations prior to any test. Also, portable monitor's operation and testing time shall be in accordance with manufacturer's recommendations. [R307-401-8] Status: In compliance. Pretest protocols are submitted and approved with all requirements above met. All testing was performed and reviewed by DAQ staff. Records are in main source file. 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. MACT (Part 63), A: General Provisions MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 7 Part 63 NESHAP ZZZZ – National Emission standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines: Status: In compliance. As described in memo DAQC-846-15, the engines meet the definition of Table 2d, item 8 – non-emergency, non-black start 4SLB remote stationary RICE greater than 500 HP. Thus, inspection and maintenance are the only requirements. 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. 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 2000 (with exception of replacement in kind engines addressed above). The pneumatic controls operate on instrument air pressure. There are no natural gas controls. 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 2000. 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. EMISSION INVENTORY: This source is not listed in SLEIS. A 2023 CAIRS workbook includes the following emissions (in tons): PM10 1.209 PM2.5 1.209 SOX 0.071 VOC 27.06 NOX 91.22 CO 38.38 HPV STATUS: Not Applicable. PREVIOUS ENFORCEMENT ACTIONS: None in the past 5 years. COMPLIANCE ASSISTANCE: None. COMPLIANCE STATUS & RECOMMENDATIONS: Urban Oil, Helper #1 should be found to be in compliance with the conditions evaluated under the AO dated March 23, 2022, and 40 CFR 63 Subpart ZZZZ. RECOMMENDATION FOR NEXT INSPECTION: Contact company contact prior to conducting future inspections. Site is fenced with locked gate. Inspect as usual. ATTACHMENTS: VEO form.