Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Rose Bud Natural Gas Compression System Enter into Consent Administrative Order

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and Orca Gathering Company, LLC (“Orca”) entered into an August 6th Consent Administrative Order (“CAO”) addressing an alleged violation of an air permit. See LIS No. 24-125.

The CAO provides that Orca operates a natural gas compression system denominated White Compressor Station (“Station”) in Rose Bud, Arkansas.

The Station is stated to be subject to the General Air Permit for Minor Source Natural Gas Compression Stations (“Permit”).

Orca is stated to have requested consideration in correspondence dated June 15, 2023, under DEQ’s Environmental-Self Disclosure Incentive Policy (“Policy”) for the disclosure of the failure to submit the stack test report for Unit 2 as required by 40 C.F.R. § 60.4245 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. The failure to submit the report is stated to have been found during a review of records from the stack test tracking database on June 14, 2023.

Orca provided the required stack test report for Unit 2 on June 15, 2023. It is stated to have provided that to track testing in engines, a stack test tracking database is maintained.

The company’s review of the stack test database is stated to have found that a stack test for Unit 2 was conducted on March 20, 2023. Subpart JJJJ requires that the stack test be submitted within 60 days following the stack test. The stack test was not submitted by the required due date, violating Special Condition 15 of the Permit.

DEQ informed Orca that its review of the self-disclosure determined that seven off the eight conditions of the Self-Disclosure Policy had been completed. As a result, DEQ stated it could mitigate up to 75% of the gravity-based component of a civil administrative penalty.

Orca neither admits nor denies the factual and legal allegations contained in the CAO.

A civil penalty of $300.00 is assessed.

A copy of the CAO can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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