 Air Pollution Control
 Federal Title V Permit to Operate
 Statement of Basis (Update for Minor Permit Modification) -- Permit No. V-UO-000005-2018.03

                         Andeavor Field Services, LLC 
                              (Operated by MPLX)
                       Wonsits Valley Compressor Station
                        Uintah & Ouray Reservation
                              Uintah County, Utah

 Facility Information

 Location

 Andeavor Field Services, LLC's (Andeavor) Wonsits Valley Compressor Station (Wonsits Valley) is located on Indian country lands within the exterior boundaries of the Uintah and Ouray Indian Reservation (U&O Reservation), in Uintah County, Utah, approximately 38 miles south of the town of Vernal, Utah. Wonsits is located at Latitude 40.140792, Longitude -109.494322. The facility mailing address is:
 
 Andeavor Field Services, LLC
 1515 Arapahoe St. 
 Suite 1600
 Denver, CO  80202
  Contacts
 Facility Contact:
 Thomas Gibbons, HES Professional
 Andeavor Field Services, LLC
 1515 Arapahoe St. 
 Suite 1600
 Denver, CO  80202
 (303) 454-6685
 Email:  thgibbons@marathonpetroleum.com 

  Responsible Official:
 Darren Snow, North West Region Director 
 1611 E. Century Ave
 Suite 300
 Bismarck, ND  58503
 (701) 250-1960

 Tribal Contact:
 Mike Natchees, Director
 Air Quality Program
 Energy and Minerals Department 
 Ute Indian Tribe
 P.O. Box 70
 Fort Duchesne, Utah  84026
 (435) 725-4974
 Email: miken@utetribe.com  
 













































Table 1- Part 71 Permitting History
                                       
                                Date of Action
                                       
                                 Permit Number
                                       
                                Type of Action
                                       
                             Description of Action

September 10, 2013

V-UO-000005-2000.00

Initial Permit

N/A
May 13, 2020
NA
Environmental Appeals Board Petition by MPLX
CAA Appeal No. 20-01; MPLX petitioned that the combustor (C-2) is not subject to MACT HH.
September 2, 2020
NA
Order Denying Review
Petition by MPLX denied by Environmental Appeals Board.
September 16, 2020
V-UO-000005-2018.00
Renewal Permit
N/A
November 22, 2021
V-UO-000005-2018.01
Minor Permit Modification
Revised Title V permit to accurately describe and permit the correct engine test methods approved at the facility.
September 28, 2022
V-UO-000005-2022.01B
Minor Permit Modification
Revised Title V permit to reflect replacement of slop tank combustor (unit C-1) and removal of dehydrator backup combustor (unit C-2), update NSPS JJJJ and MACT ZZZZ reporting requirements, and add the option for alternative engine testing methods (FTIR) for performance testing. 
March 30, 2023
V-UO-000005-2018.03
Administrative Amendment
The EPA discovered and fixed a typographical error regarding condition V.C.1(b) numbering, fixed a material mistake regarding the Consent Decree (CD) requirements of condition V.C.1(b) indicating they had been met, and revised condition V.B.1(a) as requested in the initial application for the previous permit to align with section VIII (paragraph 69) of the draft 2022 CD. Additionally, the EPA has amended the Title V permit by removing requirements from the permit that were inadvertently added as flare requirements in sections III.E.3 and III.E.4. 

 Description of Operations

 Wonsits Valley gathers natural gas, natural gas condensate and produced water from surrounding well sites via a gathering pipeline system. The comingled stream enters the station and is routed to a slug catcher where the liquids and natural gas are separated. From the slug catcher, the liquids are routed to a 3-phase separator, where the natural gas, condensate and produced water are separated. 

 The condensate is routed to the station discharge and then off site to a gas plant. The produced water is temporarily stored in the slop tank (emissions unit T-1 in Table 2 below) and the emissions are controlled with the combustor unit (emissions unit C-1 in Table 2 below). Liquids from T-1 are gravity fed offsite. 
 
 The natural gas exits the slug catcher and 3-phase separator as mentioned in the first paragraph, where it is routed to an inlet scrubber; condensate and produced water that are removed during this process are also routed to T-1. 

 The natural gas is then compressed from field pressure to approximately 1,200 pounds per square inch gauge (psig) from five reciprocating internal combustion engines (RICE) that are also located onsite. The compressed natural gas enters the dehydration unit, emissions unit D-1, and is bubbled up through lean triethylene glycol (TEG) in a process vessel called a contactor. During this process, water vapor is removed from the gas to a concentration determined by a sales contract. The pipeline quality natural gas then exits the contactor, is metered and then routed off site. Natural gas used to fuel equipment at Wonsits Valley is pulled from the discharge after the dehydrator where it is filtered and separated. 

 The rich TEG exits the contactor, is depressurized in a TEG flash tank, and is regenerated using heat in a vessel known as a reboiler (emissions unit R-1 in Table 2 below). The rich TEG is heated in R-1 to a set temperature that boils the impurities out of the TEG. The vapors from the reboiler are routed to the benzene, toluene, ethylbenzene and xylenes (BTEX) condenser to remove liquids that drain into the distillate tank. BTEX vapors from the distillate storage tank and flash gas from the flash tank are routed to the emission control device: a flare (emissions unit FL-1 in Table 2 below). The depressurized TEG is routed to a vessel called a glycol reboiler and regenerated using heat. The regenerated lean TEG is circulated back to the contactor.

 There are fugitive emissions associated with the potential seeping of gas from connections, seals, flanges and valves. Instrument air is used on site for energizing pneumatic equipment.
 

 Emissions Points

 Table 2 lists emissions units and emissions generating activities, including any air pollution control devices, that are operating at Wonsits Valley, according to the information provided in Andeavor's 40 CFR part 71 (Part 71) minor permit modification application. 
 
 
 
 The Title V Operating Permit Program at Part 71 allows the Permittee to separately list in the permit application units or activities that qualify as "insignificant" based on potential emissions below 2 tons per year (tpy) for all regulated pollutants that are not listed as hazardous air pollutants (HAP) under Clean Air Act (CAA) section 112(b) and below 1,000 lbs/year or the de minimis level established under CAA section 112(g), whichever is lower, for HAP. However, the application may not omit information needed to determine the applicability of, or to impose, any applicable requirement. Units and activities that qualify as "insignificant" for the purposes of the Part 71 application are in no way exempt from applicable requirements or any requirements of the Part 71 permit.
 
 Table 2. Emissions Units and Emissions Generating Activities


Unit I.D. 

Description

Control Equipment
                                     C202
                                       
                                       
                                       
                                     C203
                                       
                                       
                                       
                                     C204
                                       
                                       
Caterpillar G3612LE Compressor Engine; 3,406 hp*, 4SLB* RICE*,
Natural Gas-Fired

Serial No. 1YG00023		Installed: 9/2007
	                                           Manufactured: 10/21/2001
				Reconstructed: 9/2007

Serial No. 1YG00022		Installed: 9/2007
				Manufactured: 10/10/1991
				Reconstructed:9/2007

Serial No. 1YG00034		Installed: 9/2007
				Manufactured: 5/12/1993
				Reconstructed: 9/2007
                         Selective Catalytic Oxidation
                                     C206
                                       
                                       
Waukesha 12V-AT27GL Compressor Engine; 3,100 hp, 4SLB RICE,
Natural Gas-Fired

Serial No. C-13271/2		Installed: 3/2001
				Manufactured: 12/7/2000
				Reconstructed: 6/2007
                         Selective Catalytic Oxidation
                                     C207
                                       
Caterpillar G3616LE Compressor Engine; 4,554 hp, 4SLB RICE,
Natural Gas-Fired

Serial No. BLB00215		Installed: 6/2008
				Manufactured: 12/5/1993
                                                          Reconstructed: 1/2014
                         Selective Catalytic Oxidation
                                     
D-1
                                       
                                      R-1
                                       
100 MMscfd* Triethylene Glycol Dehydrator

1.0 MMBtu* Glycol Reboiler

                                 Flare (FL-1)
                                       
                                       
                                     None
                                     (IEU)
                                      T-1
500 bbl* Slop Tank, referred to as the Condensate Tank in the Consent Decree No. 2:08-CV-00167-TS-PMV 
21,900 bbls per year Annual Condensate Throughput
                                Combustor (C-1)
                                     (IEU)
                                       
                                       
                                      T-2
                                      T-3
                                      T-4
                                      T-5
                                      T-6
                                      T-7
                                      T-8
                                      T-9
Miscellaneous Chemical Storage Tanks

100 bbl New Glycol
100 bbl New Lube Oil
100 bbl Used Lube Oil
100 bbl Used Glycol
65 bbl Glycol
100 bbl Produced Water
100 bbl Dehydrator Drip Tank
100 bbl Dehydrator Drip Tank
                                  None 
(IEU)
                                      EL
Fugitive Equipment Leaks
                                     None
                                      PG
Pigging Operations
                                     None
                                     (IEU)
                                      ES
Engine Start-ups
                                     None
                                     (IEU)
                                      CB
Compressor Blowdowns 
                                     None
                                      ESD
Emergency Shutdowns
                                     None
                                     (IEU)
                                     FL-1
Elevated Open-Flame Flare
                               Dehydrator (D-1)
                                     (IEU)
                                      C-1
                                       
                                       
                                       
Cimarron 47" model AB-200 ECD*



                                Slop Tank (T-1)
                                     (IEU)
                                       
                                       
* 4SLB = 4 Stroke Lean Burn; RICE = Reciprocating Internal Combustion Engines; IEU = Insignificant Emission Unit (The Title V Operating Permit Program at Part 71 allows the Permittee to separately list in the permit application units or activities that qualify as "insignificant" based on potential emissions below 2 tons per year (tpy) for all regulated pollutants that are not listed as hazardous air pollutants (HAP) under Clean Air Act (CAA) section 112(b) and below 1,000 lbs/year or the de minimis level established under CAA section 112(g), whichever is lower, for HAP); hp = horsepower; bbl = barrel; MMscfd = million standard cubic feet per day; MMBtu/hr = million British thermal units per hour; ECD = Enclosed Combustors.

 Potential to Emit

 Pursuant to 40 CFR 52.21, potential to emit (PTE) is defined as the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its design if the limitation, or the effect it would have on emissions, is federally enforceable. Independently enforceable applicable requirements are considered enforceable to the extent that the source is in compliance with the standard. In addition, beneficial reductions in non-targeted pollutants resulting from compliance with an independently enforceable applicable requirement may be counted towards PTE provided the emissions reduction of the non-targeted pollutant is enforceable as a practical matter and compliance is being met. See the 1995 guidance memo signed by John Seitz, Director of the Office of Air Quality Planning and Standards titled, "Options for Limiting Potential to Emit of a Stationary Source under Section 112 and Title V of the Clean Air Act."
 
 Andeavor reported the controlled emission unit-specific PTE in their Part 71 minor permit modification application. The PTE in Table 3 are based on the applicable legally and practically enforceable requirements outlined in this permit, including a federal Consent Decree (See Section II.O. below). 
 
Table 3. Potential to Emit with Legally and Practically Enforceable Controls
	
                                       
                                    Unit ID

                                      NOX

                                       CO

                                      VOC

                                       PM

                                      SO2

                                      CH2O
 Total HAPs
                                      C202
                                      32.9
                                      32.9
  17.9 [a]
                                      1.1
                                      0.1
                                      1.64
                                      2.7
                                      C203
                                      32.9
                                      32.9
  17.9 [a]
                                      1.1
                                      0.1
                                      1.64
                                      2.7
                                      C204
                                      32.9
                                      32.9
  17.9 [a]
                                      1.1
                                      0.1
                                      1.64
                                      2.7
                                      C206
                                      38.9
                                      29.9
  11.0 [a]
                                      1.0
                                      0.1
                                      2.69
                                      3.6
                                      C207
                                      44.0
                                      44.0
                                    23.4[b]
                                      1.5
                                      0.1
                                      2.20
                                      3.6
                                       D-1
                                       -
                                       -
  15.3 [c]
                                       -
                                       -
                                       -
                                      6.12
                                       R-1
                                      0.39
                                      0.33
                                      0.02
                                      0.03
                                      0.00
                                       -
                                      0.01
                                       T-1
                                       -
                                       -
                                       .7
                                       -
                                       -
                                       -
                                      0.03
   T-2  -  T-9
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -
                                       EL
                                       -
                                       -
                                      4.8
                                       -
                                       -
                                       -
                                      0.4
                                       PG
                                       -
                                       -
                                      1.26
                                       -
                                       -
                                       -
                                      0.06
                                       ES
                                       -
                                       -
                                      0.22
                                       -
                                       -
                                       -
                                      0.01
                                       CB
                                       -
                                       -
                                      10.0
                                       -
                                       -
                                       -
                                      0.5
                                       ESD
                                       -
                                       -
                                      0.07
                                       -
                                       -
                                       -
                                     0.003
                                      FL-1
                                      0.7
                                      0.02
                                       -
                                       -
                                       -
                                       -
                                       -
                                       C-1
                                      0.4
                                      0.1
                                       -
                                       -
                                       -
                                       -
                                       -
                                       LO*
                                       -
                                       -
                                      1.57
                                       -
                                       -
                                       -
                                       -
                                     TOTAL
                                     181.6 
                                     172.6
                                     107.53
                                      5.9
                                      0.4
                                      9.81
                                     21.69
*NOX = nitrogen oxide; CO = carbon monoxide; VOC = volatile organic compound; PM = particulate matter; SO2 = sulfur dioxide; CH2O = formaldehyde; HAP = hazardous air pollutant; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = equivalent CO2; LO = truck loadout for condensate.

a. Based on the enforceable emission limit of 1.0 g/hp-hr limit in the Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ). 
b. Based on the enforceable emission limit of 0.7 g/hp-hr limit in NSPS JJJJ. 
c. Based on the enforceable requirement of a 95% reduction of VOC emissions in National Emission Standards for 
Hazardous Air Pollutants from Oil and Natural Gas Production Facilities.
	
 Applicable Requirement Review

 The following sections discuss the information provided by Andeavor in their Part 71 permit application, certified to be true and accurate by the Responsible Official of this facility.

 40 CFR 52.21: Prevention of Significant Deterioration

 The Prevention of Significant Deterioration (PSD) Permit Program at 40 CFR part 52 (Part 52) is a preconstruction review requirement of the CAA that applies to proposed projects that are sufficiently large (in terms of emissions) to be a "major" stationary source or "major" modification of an existing stationary source. Source size is defined in terms of PTE, which is its capability at maximum design capacity to emit a pollutant, except as constrained by existing legally and practically enforceable conditions applicable to the source. 
 
 
 A new stationary source or a modification to an existing minor stationary source is major if the proposed project has the PTE for any pollutant regulated under Part 52 requirements in amounts equal to or exceeding specified major source thresholds, which are 100 tpy for 28 listed industrial source categories and 250 tpy for all other sources. The PSD Permit Program also applies to modifications at existing major sources that cause a "significant net emissions increase" at that source. Significance levels for each pollutant are defined in the PSD regulations at 40 CFR 52.21. 

 According to information provided by Andeavor in the Part 71 permit application, at the time of its construction, Wonsits was a minor source of emissions with respect to the PSD Permit Program as the PTE did not exceed the major source thresholds of any criteria pollutants regulated under the PSD Permit Program. Per 40 CFR 49.160(b)(1)(ii), sources that have a Part 71 permit are exempt from the existing true minor source registration program. As such, the source was not subject to preconstruction permitting requirements of the minor New Source Review (NSR) or PSD Permit Programs.

 40 CFR 49.166  -  Federal Major New Source Review Program for Nonattainment Areas in Indian Country 

 The Federal Major NSR Program for Nonattainment Areas in Indian Country (NNSR Permit Program) at 40 CFR 49.166 - 49.173 is a preconstruction review requirement of the CAA that applies to proposed projects that are sufficiently large (in terms of emissions) to be a "major" stationary source or "major modification" of an existing stationary source in an area that the EPA has designated nonattainment for a NAAQS (See 40 CFR 49.167). Similar to the PSD Permit Program, source size is defined in terms of PTE, but a new stationary source or a modification to an existing stationary source is major if the proposed project has the PTE for any pollutant regulated under the 40 CFR part 49 requirements in amounts equal to or exceeding specified major source thresholds defined in 40 CFR part 51, appendix S. 

 On April 30, 2018, the EPA designated portions of the Indian country lands within the U&O Reservation as marginal nonattainment for the 2015 ozone NAAQS effective on August 3, 2018. Wonsits is located within that marginal ozone nonattainment area. Appendix S lists the marginal ozone nonattainment major source threshold for VOC or NOX emissions as 100 tpy. As such, although at the time of construction, Wonsits was considered a minor source with respect to the PSD Permit Program, it is now considered an existing major source for ozone with respect to the NNSR Permit Program. The preconstruction review requirements of the NNSR Permit Program would apply to any future proposed modification at Wonsits that exceeds 40 tpy of VOC or NOX emissions. Wonsits remains a minor source with respect to PSD for all other criteria pollutants.

 Source Determination

 At 40 CFR 71.2, a major source is generally defined as any stationary source (or any group of stationary sources that are located on one or more contiguous or adjacent properties, are under common control of the same person (or persons under common control)) and belong to a single major industrial grouping. On June 3, 2016, the EPA published a final rule clarifying when oil and natural gas sector equipment and activities must be deemed a single source when determining whether major source permitting programs (PSD and NSR preconstruction permit programs and the Part 71 permit program) apply (81 FR 35622). 
 
 By clarifying the term "adjacent," the rule specifies that equipment and activities in the oil and natural gas sector that are under common control will be considered part of the same source if they are located on the same surface site or on individual surface sites that share equipment and are within (1/4) mile of each other. According to information provided by Andeavor, there are no surface sites with shared emissions equipment within (1/4) mile from the Wonsits facility.

 40 CFR Part 60, Subpart A: General Provisions

 This subpart applies to the owner or operator of any stationary source which contains an affected facility, the construction or modification of which is commenced after the date of applicability of any standard in 40 CFR part 60 (Part 60). The general provisions under subpart A apply to sources that are subject to the specific subparts of Part 60.

 As explained below, the engines C202, C203, C204, C206 and C207 operating at Wonsits are subject to 40 CFR part 60, subpart JJJJ; therefore, the General Provisions of Part 60 apply.


 40 CFR Part 60, Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After July 23, 1984
 
 	This subpart establishes requirements for controlling VOC emissions from storage vessels with a capacity greater than or equal to 75 cubic meters that are used to store volatile organic liquids for which construction, reconstruction, or modification commenced after July 23, 1984.
 
 According to the information provided by Andeavor in their Part 71 application, the condensate tank, T-1, at this facility is exempt from these requirements because it has a capacity of less than 75 cubic meters; therefore, the facility is not subject to this subpart.

 F. 	40 CFR Part 60, Subpart KKK: Standards of Performance for Equipment Leaks of VOC  from Onshore Natural Gas Processing Plants 
 
 This subpart establishes requirements for controlling fugitive VOC emissions from onshore natural gas processing plants. It applies to natural gas processing plants that commenced construction, reconstruction, or modification after January 20, 1984. 
 
 According to the information provided by Andeavor in their Part 71 application, Wonsits is not a natural gas processing plant; therefore, the facility is not subject to this subpart.

G. 	40 CFR Part 60, Subpart LLL: Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 
 
This subpart applies to sweetening units and sulfur recovery units at onshore natural gas processing facilities. As defined in this subpart, sweetening units are process devices that separate H2S and CO2 from a sour natural gas stream. Sulfur recovery units are defined as process devices that recover sulfur from the acid gas (H2S and CO2) removed by a sweetening unit. 


According to the information provided by Andeavor in their Part 71 application, neither sweetening nor sulfur recovery are performed at the Wonsits facility. Therefore, this facility is not subject to this subpart.

H.   40 CFR Part 60, Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

This subpart establishes emission standards and compliance requirements for the control of emissions from stationary spark ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006, and are manufactured on or after specified manufacture trigger dates. The manufacture trigger dates are based on the engine type, fuel used, and maximum engine horsepower.

According to the information provided by Andeavor in their Part 71 application, engines C202, C203, C204, C206 and C207 are subject to the requirements of this subpart because they have been
reconstructed after the applicable date.

I.   40 CFR Part 60, Subpart OOOO  -  Standards of Performance for Crude Oil and Natural Gas production, Transmission, and Distribution

This subpart establishes emission standards for the control of VOC and SO2 emissions from affected facilities that commence construction, modification, or reconstruction after August 23, 2011. Affected facilities include, but are not limited to natural gas wells, centrifugal compressors, reciprocating compressor, pneumatic controllers, storage vessels, dehydration units, sweetening units, underground storage vessels, field natural gas gathering systems and well completions.

According to the information provided by Andeavor in their Part 71 application, the current equipment at Wonsits predates the applicability date for this subpart. Therefore, Wonsits is not subject
to this subpart.

J.   40 CFR Part 60, Subpart OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015

This subpart establishes emission standards for the control of VOC and SO2 emissions from affected facilities that commence construction, modification, or reconstruction on or after September 18, 2015. Affected facilities include, but are not limited to well completions, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage vessels and sweetening units.

According to the information provided by Andeavor in their Part 71 application, the current equipment at Wonsits predates the applicability date for this subpart. Therefore, Wonsits is not subject
to this subpart.

K.   40 CFR Part 63, Subpart A: National Emission Standards for Hazardous Air Pollutants for Source Categories, General Provisions

The requirements of 40 CFR part 63 (Part 63), subpart A apply to sources that are subject to the specific subparts of Part 63.

As explained below, the TEG dehydration unit (emissions unit D-1) is subject to 40 CFR part 63, subpart HH, and the five engines (emissions units C202, C203, C204, C206 and C207) operating at
Wonsits are subject to 40 CFR part 63, subpart ZZZZ; therefore, the General Provisions of Part 63 apply. 

L. 	40 CFR Part 63, Subpart HH: National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities 
 
This subpart establishes emission standards for the control of HAP emissions from affected units located at natural gas production facilities that process, upgrade, or store natural gas prior to the point of custody transfer, or that process, upgrade, or store natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user. The affected units are glycol dehydration units, storage vessels with the potential for flash emissions and natural gas throughput greater than 79,500 liters per day (660 bbls/day), and the group of ancillary equipment and compressors intended to operate in volatile HAP service which is located at natural gas processing plants.

According to the information provided by Andeavor in their Part 71 application, Wonsits is subject to the requirements of this subpart, based on the requirements of the Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraph 17 filed on July 3, 2012. The affected unit is the dehydration unit D-1 and control device FL-1 operating at the facility.

M. 	40 CFR Part 63, Subpart ZZZZ (MACT ZZZZ): National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 
 
This subpart establishes emission standards and operating limitations for the control of HAP emissions from reciprocating and compression ignition engines. 

According to the information provided by Andeavor in their Part 71 application, Wonsits is subject to the requirements of this subpart, based on the requirements of the Consent Decree Case No. 2:08-CV-00167-TS-PMV, Paragraphs 23, filed on July 3, 2012. The affected units are the reciprocating internal combustion engines C202, C203, C204, C206 and C207 operating at the Wonsits facility.

 N. 	40 CFR Part 64: Compliance Assurance Monitoring 
 
Pursuant to requirements concerning enhanced monitoring and compliance certification under the CAA, the EPA promulgated regulations to implement compliance assurance monitoring (CAM) for major stationary sources of air pollution, for purposes of Title V permitting that are required to obtain operating permits under Part 71. The rule requires owners or operators of such sources to conduct monitoring that provide a reasonable assurance of compliance with applicable requirements under the CAA. The effective date of this rule is November 21, 1997.

       CAM Applicability 
         
According to 40 CFR 64.2(a), CAM applies to each pollutant specific emission unit (PSEU) located at a major source that is required to obtain a Part 71 permit if the unit satisfies all of the following criteria:
 The unit is subject to an emission limitation or standard for the applicable regulated air pollutant other than an emissions limitation or standard that is exempt under 40 CFR 64.2(b)(1);
            
 The unit uses a control device to achieve compliance with any such limit or standard; and

      (c) 	The unit has potential pre-control device emissions of the applicable regulated pollutant that are equal to or greater than 100 percent of the amount, in tpy, required for a source to be classified as a major Title V source. 

        CAM Plan Submittal Deadlines 

      (a) 	Large pollutant-specific emissions units (PSEUs). A CAM plan submittal for all PSEUs with the PTE (taking into account control devices) of any one regulated air pollutant in an amount equal to or greater than 100% of the amount, in tpy, required for a source to be classified as a major source, is due at the following times: 

      (i) 	On or after April 20, 1998, if by that date, a Part 71 application has either: 

            (A) 	Not been filed; or 
                  (B) 	Not yet been determined to be complete. 

            (ii) 	On or after April 20, 1998, if a Part 71 permit application for a significant modification is submitted with respect to those PSEUs for which the requested permit revision is applicable; or 

            (iii) 	Upon application for a renewed Part 71 permit and a CAM plan has not yet been submitted with an initial or a significant modification application, as specified above. 

 Other PSEUs. A CAM Plan must be submitted for all PSEUs that are not large PSEUs, but are subject to this rule, upon application for a Part 71 renewal permit. According to the information provided by Andeavor in their Part 71 application, the compressor engine (emissions unit C207) and the glycol dehydration unit (emissions unit D-1) both have potential pre-control device emissions that are greater than 100 tpy for criteria pollutants or 10 tpy for HAP. However, both emissions units have compliance limitations that make them exempt to CAM per 40 CFR 64.2(b)(1)(i) and 64.2(b)(1)(vi). Therefore, Wonsits is not subject to CAM requirements.

O. 	40 CFR Part 68, Subpart A: Chemical Accident Prevention 

This subpart contains general requirements for sources that have more than a threshold quantity of a regulated substance in a process and the requirements for a Risk Management Plan (RMP). 

According to the information provided by Andeavor in their Part 71 permit application, the facility is not subject to 40 CFR part 68.

P. 	40 CFR Part 98: Mandatory Greenhouse Gas Reporting 

This rule requires sources above certain emission thresholds to calculate, monitor, and report greenhouse gas emissions. 
According to the definition of "applicable requirement" in 40 CFR 71.2, neither 40 CFR part 98 (Part 98), nor CAA §307(d)(1)(V), the CAA authority under which 40 CFR part 98 was promulgated, are listed as applicable requirements for the purpose of Title V permitting. Although the rule is not an applicable requirement under Part 71, the source is not relieved from the requirement to comply with the rule separately from compliance with their Part 71 operating permit. It is the responsibility of each source to determine applicability to Part 98 and to comply, if necessary.

 Q. 	Consent Decree Case No. 2:08-CV-00167-TS-PMV 
 
Wonsits is subject to the requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV (Consent Decree), filed on July 3, 2012 and terminated on June 4, 2014. The termination of the Consent Decree did not include certain requirements which were intended to continue to apply after the Consent Decree's termination, for the operational life of the subject emissions units. Those specific requirements, paragraphs 17, 19, 20 and 23 of the terminated Consent Decree, are included in the draft permit at Section V Requirements of Consent Decree Case No. 2:08-CV-00167-TS-PMV. The originally lodged Consent Decree (now terminated) has been included in its entirety in Appendix A of the draft permit.

III. 	EPA Authority 

Title V of the CAA requires that the EPA promulgate, administer and enforce a federal operating permit program when a state does not submit an approvable program within the time frame set by Title V or does not adequately administer and enforce its EPA approved program. On July 1, 1996 (61 FR 34202), the EPA adopted regulations codified at Part 71 setting forth the procedures and terms under which the Agency would administer a federal operating permit program. These regulations were updated on February 19, 1999 (64 FR 8247) to incorporate the EPA's approach for issuing federal operating permits to stationary sources in Indian country. 

As described in 40 CFR 71.4(a), the EPA will implement a Part 71 program in areas where a state, local, or tribal agency has not developed an approved 40 CFR part 70 program. Unlike states, tribes are not required to develop operating permits programs, though the EPA encourages tribes to do so. See, e.g., Indian Tribes: Air Quality Planning and Management (63 FR 7253, February 12, 1998) (also known as the "Tribal Authority Rule"). Therefore, within Indian country, the EPA will administer and enforce a Part 71 federal operating permit program for stationary sources until a tribe receives approval to administer their own operating permit program. As of the issuance of this draft permit, the Ute Indian Tribe have not applied for or received EPA approval to administer an operating permit program. 

IV. 	Use of All Credible Evidence 

Determinations of deviations, continuous or intermittent compliance status, or violations of the permit are not limited to the testing or monitoring methods required by the underlying regulations or this permit; other credible evidence (including any evidence admissible under the Federal Rules of Evidence) must be considered by the Permittee and the EPA in such determinations.
