The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and Natural Gas Pipeline Company of America, LLC (“NGPL”) entered into a March 1st Consent Administrative Order (“CAO”) addressing alleged violations of an air permit. See LIS No. 22-017.
The CAO provides that Natural Gas Pipeline owns and operates a natural gas compressor station (“Station”) in Searcy, Arkansas.
The CAO refers two air permits to the Station that are operated or operated by them.
According to Station, the Station conducted emissions testing at the Worthington ML-14, 2-stroke Lean-burn Compressor Engine (SN-88) on March 16, 2020. The Station sent an email on March 17, 2020, to DEQ stating that SN-08 had exceeded the Carbon Monoxide (“CO”) emission rate limit during the test. It submitted an Upset Conditions Report. According to the Upset Condition Report, the average CO emissions rate recorded at SN08 during the emissions test was 30.8 lbs/hr.
This is alleged to be in violation of Specific Condition 5 on an air permit.
A retest was reported to have taken place on March 18, 2020. Test results were then submitted. According to the test report, SN-08 exceeded permissible emission rates limit during the test. The emissions test report also included the results of the failed test.
Natural Gas Pipeline is reported to have been informed by DEQ, in a letter dated May 1st 2020, that SN08 was in compliance with the allowed CO emission rate limit at the testing site on March 18, 2020.
On February 2, 2021, a DEQ compliance inspection was performed at the Station. The inspection was said to have covered the reporting periods of August 2019 through Dec 2020.
According to the Station, it failed to test for CO emissions on the remaining eight engines of the Facility after SN-08 exceeded its permitted CO emission limit on March 16, 2020.
This alleged failure is considered to be in violation of Plantwide Condition 8 and Permit 7 respectively.
The Station passed the emissions testing for SN-01 and SN-04. SN-09 was also passed. The Station will be retesting SN-8 in March 2020.
Natural Gas Pipeline provided the following information in response to a DEQ March 17, 2021 query:
- Respondent stated that in regard to the compliance issues mentioned in Paragraph 7 above: “During the stack test of March 16, 2020, SN-08 failed to pass the stack test for CO. To prove compliance with PWC 8 the test results will be extrapolated so that they correlate with 100% of permitted capacity. The extrapolated CO results came in at 30.8 lb/hr, exceeding the allowed limit of 30 lb/hr CO. SN-8 had to be shut down and fixed. SN-08 was retested and passed on March 18, 2020. NGPL contacted ADEQ after receiving preliminary test results from SN-88, which indicated that there was an excess of CO emissions. An Upset Condition Reporting form was submitted on March 17, 2020. A deviation was reported in the SemiAnnual Monitoring Report, and Annual Compliance Certification for that reporting period. Submission of the upset notification is required. The permit deviation must be included in the Annual Compliance Certification.
- Respondent stated that in relation to the compliance issues mentioned in Paragraph 11 above, Units SN-01 through SN07 were 3,080 HP Cooper Bessemer GMWH compressor engine. Unit SN08 is a 5,000HP Worthington ML-14 compression engine and Unit SN09 is a 9,063HP Cooper Bessemer 16W330 compressor engine. In March 2020, the five-year emissions testing was done on units SN-01 through SN-04 (representatives all Cooper Bessemer GMWH Units), SN-04 (representatives all Cooper Bessemer ML-14 compressor engines), SN08 (ML-14), SN-135, SN-09 (16W330) and SN-135. Because SN-8 is the only engine of its type and the CO results for GWMH units (SN-01 to SN-04, SN-04 and Cooper Bessemer 16W330 to SN-09 were within permissible limits, Respondent stated that it was reasonable to believe that additional testing was not required and respectfully disagreed with the Division’s claim that NGPL failed the permit requirement to test non-identical units due to the failure to test SN-8.
Natural Gas Pipeline stated that it would prepare a Title V permit modification application during a meeting on October 19, 2020. Natural Gas Pipeline also requested clarification from DEQ regarding the application of the requirement to retest all 8 units. Natural Gas Pipeline requested a written notification of DEQ’s decision regarding additional testing of the remaining four units.
DEQ was notified by Natural Gas Pipeline that they had submitted a permit modification request on October 28, 2021. This application was to modify Plantwide Condition 8. Additional language was also requested.
Natural Gas Pipeline denies or admits to the legal and factual allegations made in the CAO.
A civil penalty of $2.100 will be assessed.
Download a copy the CAO Here.
