EPA entered into an Administrative Consent Order (ACO) with Whiting Oil and Gas Corporation (Whiting) to address violations of the New Source Performance Standards, Subpart A (General Provisions) Subpart KKK (Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants), Subpart VV (Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry), the National Emissions Standards for Hazardous Air Pollutants, Subpart HH (Oil and Natural Gas Production Facilities), the Michigan State Implementation Plan, and Whiting?s Permits to Install, at its West Branch Gas Plant in West Branch, Michigan.
At its West Branch Gas Plant, Whiting failed to: conduct Method 21 (LDAR) inspections at required components; comply with its visible emissions limitations at its flare; keep records pertaining to the operation of its glycol dehydrator; and operate its facility in accordance with good air pollution control practices. EPA discovered the violations in part during an inspection at the facility on July 31, 2013, where Whiting was not operating its system to recover VOC emissions from storage vessels, and was sending all vapors to its flare, causing visible emissions at the flare and causing excessive leaks of VOC from a pressure relief device. EPA also obtained information on the recordkeeping and LDAR violations through a Section 114 request. EPA issued to Whiting a Notice and Finding of Violation on January 8,