DAQ-2025-002497

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DAQC-457-25
Site ID 10259 (B1)

MEMORANDUM

TO: FILE – NORTHWEST PIPELINE CORPORATION – Cisco Compressor Station

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: May 14, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Grand County,
FRS ID# UT0000004901900016

DATE OF INSPECTION: May 6, 2025

SOURCE LOCATION: Cisco, Utah. Take I-70 east to the Cisco exit (204). Turn south and follow this
road about 3 miles to the highway 128 junction. Take highway 128 toward
Moab for approximately 1 mile. Plant is on the north side of the road.

COMPANY ADDRESS: Williams – Northwest Pipeline, LLC, 650 South Main Street Salt Lake City,
UT 84101

SOURCE CONTACT: Cecilia Diaz EHS Senior Engineer – Phone [phone]
Derek Forsberg, Environmental Specialist - Phone: [phone]

OPERATING STATUS: Engine 2 online. Engine 1 offline.

PROCESS DESCRIPTION: Northwest Pipeline (NWP) is a natural gas compressor station. Pipeline gas is
drawn by vacuum pressure to a feed pipe to one of two Solar T5502
compressors. The gas is compressed to build up pressure then routed back to
the main gas line to be processed or sold at other sites. The two compressor
turbines run on the pipeline gas which is fed through a bypass duct and
regulator. There is a Sellers steam boiler on site that is to provide steam for
comfort heat. The site also has a Cummins GTA 855 electrical generator for
backup power to the computer and control heads. The boiler and generator both
operate on pipeline quality gas only.

APPLICABLE
REGULATIONS: Title V Operating Permit 1900016006 dated March 18, 2024, revised March 18,
2024
40 CFR 60 Subpart A-General Provisions,
40 CFR 60 Subpart GG-Standards of Performance for Stationary Gas Turbines,
40 CFR 63 Subpart A-General Provisions, and
40 CFR 63 Subpart ZZZZ-National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE).

SOURCE INSPECTION EVALUATION:

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SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: This permit is not being modified, revoked, reopened, reissued, or terminated for cause at this
time. The permittee appeared to be operating in compliance with this permit. In compliance.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the director, within a reasonable time, any information that
the director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: The permittee appeared to be operating in compliance with this permit. In compliance.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

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I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit expires March 18, 2029.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: The permit expires March 18, 2029. The renewal application is due September 18, 2028.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: No portion of this permit is being challenged at this time.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: Emission fees have been paid as invoiced. In compliance.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

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I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: Access was granted to the source and records. No claims of confidentiality were made. In
compliance.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: All necessary forms and reports submitted during the prior 12-month period appeared to be
properly certified. In compliance.

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I.L Compliance Certification.

I.L.1 Permittee shall submit to the director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: The last annual compliance certification was received May 31, 2024, with a due date of June 1,
2024, (see source files for review memo). No deviations were reported. Company is aware of
due dates. In compliance.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

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I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(a)(xiii) and Section 19-2-
110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: This is a statement of fact and not an inspection item.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the director within two working
days of the time when emission limitations were exceeded due to the emergency.
This notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken. This notice fulfills the requirement of
Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

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I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: No emergency events were reported in the previous 12 months. In compliance.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is a statement of fact and not an inspection item.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is a statement of fact and not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

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I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

I.S.2.c The director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the director are to be sent to the following address or to such other
address as may be required by the director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

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For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch
(mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone].

Status: Six-month reports have been submitted in the past year. Company policy requires all
applicable reports to be submitted to EPA. In compliance.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: SLEIS shows the last emission inventory was submitted for calendar year 2023 on April 4,
2024. In compliance.

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I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 P001: Turbine #1
5,500 hp compressor turbine (nameplate ISO rating), fired on pipeline-quality natural gas only.

II.A.3 P002: Turbine #2
5,500 hp compressor turbine (nameplate ISO rating), fired on pipeline-quality natural gas only.

II.A.4 Turbines
Includes P001: Turbine #1 & P002: Turbine #2.

II.A.5 G001: Backup generator engine
350 hp 4 stroke rich burn engine fired on pipeline-quality natural gas only.

II.A.6 B001: Boiler
Rated at 2.5 MMBtu/hr, fired on pipeline-quality natural gas only. No unit specific applicable
requirements.

II.A.7 Storage Tanks
One 4,200-gallon tank (TK-01) storing used oil and condensate/lube oil from the filter separator
and two tanks (TK-02, TK-03), 500 gallons each, storing lube oil. No unit specific applicable
requirements.

II.A.8 F001: Miscellaneous emission points
Includes fugitive VOC emissions from miscellaneous points, including blowdown vent stack. No
unit specific applicable requirements.

Status: No unapproved equipment was observed onsite. A NOI has been submitted for changes to
equipment but no AO has been issued, and no equipment has been replaced as of the inspection. In
compliance.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

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II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN102590004-23].
[R307-401-8, R307-201-3]

II.B.1.a.1 Monitoring:

In lieu of monitoring via visible emission observations, records required for this permit condition
will serve as monitoring.

II.B.1.a.2 Recordkeeping:

The permittee shall keep records of fuel bills, fuel meter readings, or other documentation that
demonstrate only pipeline quality natural gas is used as fuel. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

In addition to the reporting requirements specified in Section I of this permit, the permittee shall
certify in each annual certification report that only pipeline quality natural gas is used as fuel.

Status: NWP does certify compliance with this condition in the annual certification. The equipment is
designed to only operate on pipeline quality natural gas. No other fuels were observed on-site. In
compliance.

II.B.1.b Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, 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. [Origin: DAQE-AN102590004-23]. [40 CFR 60.11(d), R307-401-4, R307-401-8]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance. All
maintenance performed on permitted plant equipment shall be recorded. Records shall be
maintained in accordance with Provision I.S.1 of this permit.

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II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The source appeared to be maintained in a manner consistent with good air pollution control
practice for minimizing emissions. A source specific preventative maintenance plan is in place and
tracked through a computerized database (Maximo software). Maintenance is based on
manufacturer recommendations and additional Williams Companies, Inc. (parent company) best
practices. In compliance.

II.B.1.c Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle air
conditioners pursuant to 40 CFR 82 Subpart B - Servicing of Motor Vehicle Air Conditioners. [Origin: 40
CFR 82 Subpart B]. [40 CFR 82.30(b)]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82 Subpart B.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82 Subpart B shall be maintained consistent with the requirements
of Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82 Subpart B shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: The permittee certifies compliance with this condition in the annual compliance certification. All
maintenance is done by an outside contractor and facilities. In compliance.

II.B.1.d Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82 Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.d.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82 Subpart F.

II.B.1.d.2 Recordkeeping:

All records required in 40 CFR 82 Subpart F shall be maintained consistent with the requirements
of Provision I.S.1 of this permit.

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II.B.1.d.3 Reporting:

All reports required in 40 CFR 82 Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: The permittee certifies compliance with this condition in the annual compliance certification. All
maintenance is done by outside contractors. In compliance.

II.B.1.e Condition:

1) General requirements for prevention of emissions and use of good air pollution control practices.
(a) All crude oil, condensate, and intermediate hydrocarbon liquids collection, storage, processing
and handling operations, regardless of size, shall be designed, operated and maintained so as to
minimize emission of volatile organic compounds to the atmosphere to the extent reasonably
practicable.
(b) At all times, including periods of start-up, shutdown, and malfunction, the installation and air
pollution control equipment shall be maintained and operated in a manner consistent with good
air pollution control practices for minimizing emissions.
(c) Determination of whether or not 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, infrared camera images, opacity observations, review of operating and
maintenance procedures, and inspection of the source.
[Origin: R307-501-4]. [R307-501-4]

II.B.1.e.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.e.2 Recordkeeping:

The permittee shall keep manufacturer specifications or equivalent on file and shall document
activities performed to assure proper operation and maintenance. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The source appeared to be maintained in a manner consistent with good air pollution control
practice for minimizing emissions. A source specific preventative maintenance plan is in place and
tracked through a computerized database (Maximo software). Maintenance is based on
manufacturer recommendations and additional Williams Companies, Inc. (parent company) best
practices. All covers were in place and no potential emissions points were noted. In compliance.

II.B.1.f Condition:

If materials that may create fugitive dust are deposited on a public or private paved road, the permittee
shall clean the road promptly. [Origin: R307-205-6]. [R307-205-6]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.
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II.B.1.f.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained as described in
Provision I.S.1 of this permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The company has a protocol in place for operators to clear by shovel or broom (carried in trucks)
any tacked dirt. This site has a 300-yard dirt road from the paved road to the site gate. This access
road is additionally used by the general public to access OHV trails. In compliance.

II.B.2 Conditions on Turbines.

II.B.2.a Condition:

Emissions of NOx from each stationary gas turbine shall not be greater than the concentration calculated
by the equation:

STD = 0.0150 (14.4/Y) + F

where:
STD = allowable ISO corrected NOx emission concentration (percent by volume, at 15 percent oxygen
and on a dry basis);
Y = manufacturer's rated heat rate at manufacturer's rated peak load (kilojoules per watt hour), or
actual measured heat rate based on lower heating value of fuel as measured at actual peak load for
the facility. The value of Y shall not exceed 14.4 kilojoules per watt hour; and
F = NOx emission allowance for fuel-bound nitrogen as defined in 40 CFR 60.332(a)(4). The
permittee has accepted an F-value of zero in accordance with 40 CFR 60.332(a)(3).
[Origin: 40 CFR 60 Subpart GG]. [40 CFR 60.332(a)(2), 40 CFR 60.332(c)]

II.B.2.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. The source shall be tested at least once every five years based on the date of the
most recent stack test. The Director may require the permittee to perform a stack test at any
time. The permittee shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol
shall include the items contained in R307-165-3. The source shall attend a pretest conference
if determined necessary by the Director.
(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1 and 40 CFR 60.335(a). In addition, Occupational Safety and Health
Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved
access shall be provided to the test location.
(d) Methods
(1) 40 CFR 60, Appendix A, Method 20, the test methods specified in 40 CFR 60.335(a),
or other EPA-approved testing method, as acceptable to the Director, shall be used to
determine the nitrogen oxides.
15
(2) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine stack gas velocity and volumetric
flow rate;
(e) Calculations. For each run of the performance test, the mean nitrogen oxides emission
concentration (NOxo) corrected to 15 percent O2 shall be corrected to ISO standard
conditions using the following equation.

NOx = (NOxo)(Pr/Po)0.5e19(Ho-0.00633)(288 K/Ta)1.53

where:
NOx = emission concentration of NOx at 15 percent O2 and ISO standard ambient
conditions, ppm by volume, dry basis,
NOxo = mean observed NOx concentration, ppm by volume, dry basis, at 15 percent O2,
Pr = reference combustor inlet absolute pressure at 101.3 kilopascals ambient pressure.
Alternatively, 760 mm Hg (29.92 in Hg) may be used,
Po = observed combustor inlet absolute pressure at test, mm Hg. Alternatively, the
barometric pressure for the date of the test may be used,
Ho = observed humidity of ambient air, g H2O/g air,
e = transcendental constant, 2.718, and
Ta = ambient temperature, K.

The 3-run performance test shall be performed within +/- 5 percent at four evenly-spaced
load points in the normal operating range of the gas turbine, including the minimum point in
the operating range and 90-to-100 percent of peak load.

To determine mass emission rates (lb/hr, etc.), 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 Director to give the results in the specified
units of the emission limitation.
(f) Production Rate During Testing. The operational rate during all compliance testing shall be
no less than 90% of the maximum rate achieved in the previous three (3) years.

II.B.2.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision I.S.1 of this permit.

II.B.2.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status and shall
include validated results and supporting information. The annual compliance certification
required by Provision L in Section I of this permit shall use the most recent test results as a basis
for stating compliance status for this limitation.

Status: Test report for the two turbines was received on July 9, 2020. Testing was completed on May 18-19,
2020. The DAQ-calculated test results for NOx for Unit 1 ranged between 61.41 ppm and 69.95
ppm @ 15% O2; Unit 2 ranged between 54.49 ppm and 80.94 ppm @ 15% O2. Both engines were
tested at 4 loads. Calculated emission limit was 176 ppm @ 15% oxygen. Testing was being done on
both engines during this inspection and the following day. In compliance.

16
II.B.2.b Condition:

Emissions of CO from each turbine shall be no greater than 5.8 lbs/hour.
[Origin: DAQE-AN102590004-23]. [R307-401-8]

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified here:
(a) Frequency. The unit shall be tested at least once every five years based on the date of the
most recent stack test. The Director may require the permittee to perform a stack test at any
time. The permittee shall conduct testing according to the approved source test protocol and
according to the test conditions contained in R307-165-4.
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol
shall include the items contained in R307-165-3. The source shall attend a pretest conference
if determined necessary by the Director.
(c) Sample Point. The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1. In addition, OSHA- or MSHA-approved access shall be provided to
the test location.
(d) Methods.
(1) 40 CFR 60, Appendix A, Method 10, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2, or other EPA-approved testing method, as
acceptable to the Director, shall be used to determine stack gas velocity and volumetric
flow rate.
(e) Calculations. To determine mass emission rates (lb/hr, etc.) 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 Director to give the results in the
specified units of the emission limitation. In addition, values shall be corrected to 7% excess
oxygen as appropriate.
(f) Production Rate During Testing. The operational rate during all compliance testing shall be
no less than 90% of the maximum rate achieved in the previous three (3) years.

II.B.2.b.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated test
method and Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status and shall
include validated results and supporting information. The annual compliance certification
required by Provision L in Section I of this permit shall use the most recent test results as a basis
for stating compliance status for this limitation.

Status: Test report for the two turbines was received on July 9, 2020. Testing was completed on May 18-19,
2020. The DAQ-calculated test results for CO for Unit 1 ranged between 0.16 lbs/hr and 0.23
lbs/hr; Unit 2 ranged between 0.16 lbs/hr and 0.52 lbs/hr. Testing for each engine was done at 4
loads. Testing was being done on both engines during this inspection and the following day. In
compliance.

17
II.B.2.c Condition:

Emissions of NOx from each turbine shall be no greater than 17.9 lbs/hour.
[Origin: DAQE-AN102590004-23]. [R307-401-8]

II.B.2.c.1 Monitoring:

Compliance with the limitation shall be determined by calculating an average NOx emission rate
based on the total Btu value of the fuel combusted and the hours of operation for each affected
turbine as follows:

The quantity of natural gas combusted in the turbine shall be monitored. Each month, the total
amount of natural gas combusted in the turbine shall be calculated and multiplied by the average
Btu value of the fuel. The resulting Btu total shall be multiplied by the appropriate emission
factor to estimate the NOx emissions for that month. The emission total shall be divided by the
hours of operation for the turbine during the month to calculate an average lb/hr emission rate.

The emission factor used in this calculation shall be determined by dividing the average NOx
emission rate (lb/hr) at peak load calculated from the most recent stack test by the fuel flow rate
(Btu/hr) corresponding to peak load for each affected turbine.

The average NOx emission rate (lb/hr) calculated from the most recent stack test shall also be
used for determining compliance with this limitation.

II.B.2.c.2 Recordkeeping:

The following information shall be calculated and recorded within 15 days of the end of each
month:
a) The total amount of fuel combusted in the unit by volume (scf/month) and by heating value
(Btu/month);
b) the average heating value of the fuel (Btu/scf) combusted during the month;
c) the total hours of operation of the unit for the month;
d) the total NOx emissions calculated using the emissions factor; and
e) the average NOx emissions (lb/hr) for the month.

The records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The average NOX emission rate is calculated monthly and recorded on a spreadsheet. All five
recordkeeping requirements of II.B.2.c.2 have been recorded and were provided. Monthly
emissions were in compliance for the past year for both units. The most recent emission factors
were used. May 2024 was the high month for unit one, 11.594 lbs/hr, and May 2025 was high month
for unit two, 16.48 lb/hr. In compliance.

II.B.2.d Condition:

Sulfur content of the fuel combusted shall be no greater than 0.8 percent by weight (8000 ppmw).
[Origin 40 CFR 60 Subpart GG]. [40 CFR 60.333(b)]

18
II.B.2.d.1 Monitoring:

In lieu of monitoring the total sulfur content of gaseous fuel combusted in the turbines, the
permittee shall demonstrate that the gaseous fuel meets the definition of natural gas in 40 CFR
60.331(u). To make the required demonstration, the permittee shall use the gas quality
characteristics in a current, valid purchase contract, tariff sheet or transportation contract for the
gaseous fuel, specifying that the maximum total sulfur content of the fuel is 20.0 grains/100 scf or
less. (40 CFR 60.334(h)(3)).

II.B.2.d.2 Recordkeeping:

The total sulfur limit in the gas tariff sheet shall be recorded and converted to percent sulfur by
weight to determine sulfur content. Results of monitoring shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.2.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Pipeline quality natural gas is the only fuel combusted at this station. NWP demonstrates
compliance by maintaining a tariff contract that requires pipeline gas to contain a sulfur content of
no more than 5 grains/100 scf. In compliance.

II.B.3 Conditions on G001: Backup Generator Engine

II.B.3.a Condition:

The permittee shall comply with the following operating limitations and other requirements at all times
for each emergency affected emission unit:
1. The permittee shall operate the affected emission unit according to the requirements in paragraphs 1.a
through 1.c. In order for the engine to be considered an emergency stationary RICE under 40 CFR 63
Subpart ZZZZ, any operation other than as described in 40 CFR 63.6640(f), is prohibited. If the
engine is not operated according to the requirements in 40 CFR 63.6640(f), it will not be considered
an emergency engine and shall meet all requirements for non-emergency engines.
a. There is no time limit on the use of emergency stationary RICE in emergency situations.
b. Emergency stationary RICE may be operated for the purpose specified in 40 CFR
63.6640(f)(2)(i) for a maximum of 100 hours per calendar year. Any operation for non-
emergency situations as allowed by 40 CFR 63.6640(f)(4) counts as part of the 100 hours per
calendar year allowed by this paragraph.
(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing,
provided that the tests are recommended by federal, state or local government, the
manufacturer, the vendor, the regional transmission organization or equivalent balancing
authority and transmission operator, or the insurance company associated with the engine. A
petition for approval of additional hours to be used for maintenance checks and readiness
testing is not required if the permittee maintains records indicating that federal, state, or
local standards require maintenance and testing of emergency RICE beyond 100 hours per
calendar year.
c. Emergency stationary RICE may operate up to 50 hours per calendar year in non-emergency
situations as specified in 40 CFR 63.6640(f)(4).
2. The permittee shall meet the following requirements at all times, except during periods of startup:
a. Change oil and filter every 500 hours of operation or annually, whichever comes first;
19
b. Inspect spark plugs every 1,000 hours of operation or annually, whichever comes first, and
replace as necessary; and
c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
During periods of startup, the permittee shall minimize the engine's time spent at idle and minimize
the engine's startup time to a period needed for appropriate and safe loading of the engine, not to
exceed 30 minutes, after which time the non-startup emission limitations apply.
3. The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.
[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63.6603(a), 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40
CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2d, 40 CFR 63 Subpart ZZZZ Table
8]

II.B.3.a.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the required schedule, or if
performing the management practice on the required schedule would otherwise pose an
unacceptable risk under federal, state, or local law, the management practice can be delayed until
the emergency is over or the unacceptable risk under federal, state, or local law has abated. The
management practice shall be performed as soon as practicable after the emergency has ended or
the unacceptable risk under federal, state, or local law has abated. [40 CFR 63 Subpart ZZZZ
Table 2d Footnote 2]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(j).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665].

II.B.3.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records of the hours of operation of the engine that are recorded through
the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours
are spent for non-emergency operation, and the date the engine was used. If the engine is used for
the purpose specified in 40 CFR 63.6640(f)(4)(ii), the permittee shall keep records of the
notification of the emergency situation, and the time the engine was operated for these purposes.
[40 CFR 63.6655(f), R307-401-8]

20
If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that federal, state, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per calendar year. [40 CFR 63.6640(f)(2)(i)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation [including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan]. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.3.a.3 Reporting:

The permittee shall report any failure to perform the management practice on the schedule
required and the federal, state or local law under which the risk was deemed unacceptable. [40
CFR 63 Subpart ZZZZ Table 2d Footnote 2]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665] The permittee shall also report
each instance in which it did not meet the applicable requirements in Table 8. [40 CFR
63.6640(e)]

There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: A non-resettable hour meter is installed. Maintenance records are maintained to confirm
compliance with this condition. Last maintenance was done on December 27, 2023, and
maintenance record shows all required items were completed per checklist. Hour logs are kept
confirming compliance with run hour limits with 12-month total of 17.3 hours used as May 2, 2025.
In compliance.

II.B.3.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ].
[40 CFR 63.6605(b)]

21
II.B.3.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)] The permittee shall document activities performed to assure proper operation
and maintenance. Records shall be maintained in accordance with 40 CFR 63.6660 and Provision
I.S.1 of this permit.

II.B.3.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: The source appeared to be well maintained in a manner consistent with good air pollution control
practices. In compliance.

II.B.3.c Condition:

The permittee shall not operate the emergency generator engine for non-emergency purposes before 8:00
am or after 6:00 pm each day. [Origin: DAQE-AN102590004-23]. [R307-401-8]

II.B.3.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.c.2 Recordkeeping:

For all periods when the emergency generator engine is in operation for non-emergency purposes,
the permittee shall record the time operations begin each day and the time operations end each
day. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: All maintenance firings are done during the day shift and maintenance logs show this requirement
is met.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.
II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

22
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. 40 CFR, Part 68 (Chemical Accident Prevention Provisions)

This regulation is not applicable to the Permitted Source for the following reason(s): no listed
substance is now stored at this source at levels above the threshold quantity; also, the pipeline and
associated compression equipment are regulated under 49 CFR 192 and so do not meet the
definition of stationary source for this part. [Last updated August 17, 2023]

III.B. 40 CFR 61 Subpart A (General Provisions)

This regulation is not applicable to the Permitted Source for the following reason(s): this source
does not handle any of the listed substances. [Last updated August 17, 2023]

III.C. 40 CFR 61 Subpart V (National Emission Standard for Equipment Leaks (Fugitive Emission
Sources))

This regulation is not applicable to the Permitted Source for the following reason(s): this source has
no equipment in volatile hazardous air pollutant (VHAP) service. [Last updated August 17, 2023]

III.D. 40 CFR 63 Subpart H (National Emission Standards for Organic HAPs for Equipment Leaks)

This regulation is not applicable to the Permitted Source for the following reason(s): this source has
no equipment in organic hazardous air pollutant (OHAP) service and is not subject to any subpart
that references this regulation. [Last updated August 17, 2023]

III.E. 40 CFR 63 Subpart B (Requirements for Control Technology Determinations for Major Sources)

This regulation is not applicable to the Permitted Source for the following reason(s): this source is
not a major source of hazardous air pollutants. [Last updated August 17, 2023]
SECTION IV: ACID RAIN PROVISIONS

This source is not subject to Title IV. This section is not applicable.

EMISSION INVENTORY: The following was taken from the DAQ’s 2023 emissions
inventory database (in tons/year):
Pollutant Tons/year
PM10 0.798
PM2.5 0.798
NOX 47.126
VOC 1.783
SOx 0.051
CO 6.046

23
PREVIOUS ENFORCEMENT
ACTIONS: None in the past five years

COMPLIANCE ASSISTANCE: None requested

COMPLIANCE STATUS &
RECOMMENDATIONS: Williams Northwest Pipeline, Cisco Compressor Station should
be found in compliance with the Title V permit at the time of this
inspection. No further action is recommended.

HPV STATUS: Not Applicable

RECOMMENDATION FOR
NEXT INSPECTION: Contact the company to schedule an inspection. This site may be
unmanned.

ATTACHMENT: VEO form