COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Southwest Regional Office

Transcription

1 COMMONWEALTH OF PENNSYLVANA Department of Envronmental Protecton Southwest Regonal Offce TO FROM AQ Case Fle TV NoorNahar Ar Qualty Engneerng Specalst Ar Qualty Program THROUGH Thomas Joseph, P.E. Envronmental Engneer Manager Ar Qualty Program Mark Gorog, P.E. Program Manager Ar Qualty Program DATE May 23, 2016 RE Revew Memo of Ttle V Renewal Applcaton Domnon Transmsson, nc. (DT) Rochester Mlls Compressor Staton North Mahonng Townshp ndana County APS AUTH PF Background Domnon Transmsson, nc. (DT) s an nterstate gas transmsson subsdary of Domnon Energy, nc. and operates facltes n Pennsylvana for the producton, storage, and transmsson of natural gas. Rochester Mlls Compressor Staton (RM) supports Domnon's natural gas producton operatons and operates year round. The faclty s located n North Mahonng Townshp, ndana County. The current man sources of emssons at the faclty ncluded (2) 4- cycle, rch bum, 440 bhp naturally asprated ngersoll Rand Model #SVG-8AS engnes whch were nstalled between 1960 and The current ste source nventory from the prevous Ttle V operatng permt s as follows: 031 Dehydrator and stll (0.375 mmbtu/hr) 102 n g. Rand Comp. Engne 440 bhp 103 ng. Rand Comp. Engne 440 bhp 109 Tank F Gallon Dehydraton Wastewater (dstllate) 110 Fugtve/Tank VOC Emssons 111 Emergency Generator (240 hp)

2 COl Thermal Oxdzer There have been some small changes at the faclty snce the ssuance of the last TVOP whch was ssued on May 26, Engne #4 was last operated on May 14, The company submtted a Mantenance Plan for the engne on May 13, Source #106 Tank A-1 (5,000 gallon Lube Ol) was replaced wth a 3,000 gallon tank and moved to Mscellaneous Secton. Source #1 07 Tank E-1 (2,000 gallon waste Ol) was removed from ths ste and Source #108 Tank P-2 (2,000 gallon produced flud) has been renamed -1 and moved to Mscellaneous Secton. RM's Ttle V renewal permt expres on May 26, DT submtted a renewal applcaton on November 23, 2015 n accordance wth Secton B, Condton #004 ofthe permt whch requres a renewal applcaton be submtted at least sx months pror to permt expraton. The applcaton was deemed admnstratvely complete December 21, Regulatory Analyss Operaton of the equpment at RM results n the emsson of varous ar contamnants. As a result of the levels ofnox emtted, RM s a major statonary source as defned n Ttle, Part D of the Clean Ar Act Amendments. As such, the faclty s subject to the Ttle V permttng requrements adopted at 25 Pa. Code, Chapter 127, Subchapter G. All of the condtons derved from Ttle 25 of the Pennsylvana Code n the orgnal Ttle V permt have been ncluded n ths renewal. The applcable emsson lmtatons, montorng, recordkeepng, reportng and work practce standard requrements ofpa. Code Ttle 25 Sectons 123.1, 123.2, , , , , , , and have been ncluded n ths n ths renewal Ttle V permt. The tanks n ths ste are not subject to 25 Pa. Code and thus wll be lsted n Secton H, Mscellaneous as nsgnfcant emsson sources. The RACT 2 Rule was publshed fnal n the Pennsylvana Bulletn on Aprl23, The RACT 2 Regulatons (25 PA Code Secton ) are applcable to exstng (exstng before July 20, 2012) major sources ofnox and VOC, therefore f a faclty has a potental to emt (PTE) n excess of 100 tpy NOx or 50 tpy VOC, t s subject to the RACT 2 requrements. Facltes that became major after July 20, 2012 are also potentally subject to the regulaton. The regulaton does allow facltes that are currently major sources to cap emssons below major source thresholds and opt out ofract 2. The caps must be n place wthn one year of the effectve date of the regulaton. RACT 2 proposals or alternatve RACT 2 pettons need to be submtted to PADEP by October 24,2016 and facltes must be able to comply wth applcable RACT 2 requrements by January 1, Rochester Mlls Compressor Staton s subject to RACT 2 requrements and shall comply wth t by January 1, 2017.

3 There are several potentally applcable federal regulatory requrements whch have been promulgated snce the last tme RM's Ttle V permt was ssued. Ths ncludes both Natonal Emsson Standards for Hazardous Ar Pollutants (NESHAPs) and New Source Performance Standards (NSPS). These are dscussed below: NSPS NSPS requre new, modfed, or reconstructed sources to control emssons to the level achevable by the best demonstrated technology as specfed n the applcable provsons. Any source subject to an NSPS s also subject to the general provsons ofnsps Subpart A except where expressly noted. 40 CFR Subpart KKK- Standards of Performance for Equpment Leaks ofvoc From Onshore Natural Gas Processng Plants apples to affected facltes n onshore natural gas processng plants. Natural gas processng plant means any processng ste engaged n the extracton of natural gas lquds from feld gas, fractonaton of mxed natural gas lquds to natural gas products, or both. RM does not meet the defnton of natural gas processng plant and thus these requrements are not applcable. 40 CFR Subpart JJJJ- NSPS For Statonary Spark gnton nternal Combuston Engnes apples to manufacturers, owners, and operators of new statonary spark gnton nternal combuston engnes manufactured after July 1, Emergency generator engne s subject to NSPS Subpart JJJJ f manufactured on January 1, 2009 or later. Snce the engnes at ths faclty were made before July 1, 2007, ths regulaton s not applcable. NESHAPs NESHAPs are applcable to both major and area sources of hazardous ar pollutants (HAPs). Part 63 NESHAPs apply to sources n specfcally regulated ndustral source categores (CAA Secton 112( d)) or on a case-by-case bass (Secton 112(g)) for facltes not regulated as a specfc ndustral source type. Subpart HHH, Natural Gas Transmsson and Storage apples only to major sources of HAPs that transport or store natural gas pror to enterng the transmsson ppelne to end users as defned n 40 CFR RM s not a major source of HAPs. Thus, Subpart HHH s not applcable. Subpart HH does apply to area as well as major sources. The affected source s each trethylene glycol (TEG) dehydraton unt. However, 40 CFR (e)(1)() exempts unts from the most of the requrements of ths subpart fthe actual average emssons ofbenzene from the glycol dehydraton unt process vent to the atmosphere and are less than 0.90 megagram (approxmately 1.0 ton) per year as determned by the procedures specfed n 40 CFR (b)(2). Use of the model GR-GLYCalc, Verson 3.0 or hgher, and the procedures assocated n the GR-GLYCalc Techncal Reference Manual s an approved method to determne benzene emssons under (b)(2). Accordng to RM, actual average emssons ofbenzene from the unt wll be well below one-tenth of a ton. DT wll stll be requred to mantan approprate records of benzene emssons n accordance wth 40 CFR (d)(l).

4 Subpart ZZZZ, Recprocatng nternal Combuston Engnes apples to the owners/operators of new, reconstructed, and exstng statonary recprocatng nternal combuston engnes (RCE) at both major sources ofhaps and area sources ofhaps such as RM. On August 10, 2010 the US EPA revsed Subpart ZZZZ to establsh requrements for exstng statonary RCE. t was amended agan on January 30, The applcable requrements depend on numerous factors ncludng engne type (rch burn or lean burn), stroke (2 or 4), rated horsepower, fuel type, age (new, exstng, or reconstructed), and purpose (emergency or non-emergency). Exstng spark gnton engnes must comply wth the applcable emsson and operatng lmtatons of Subpart ZZZZ no later than October 19, CFR requres area sources to comply wth the applcable requrements n Table 2d of ths subpart and the applcable operatng lmtatons n Table 2b. For the compressor engnes at RM whch are 440 bhp non-emergency, non-black start, 2SLB, spark gnton statonary RCE unts, Table 2d requres ol and flter changes every 1,440 hours of operaton or annually, whchever comes frst, spark plug nspecton/replacement when necessary, and nspecton/replacement when necessary ofhoses and belts every 1440 hours of operaton or annually, whchever comes frst. For the emergency generator engne, Table 2d requres ol and flter changes every 500 hours, spark plug nspecton every 1,000 hours, and hoses/belts nspecton every 500 hours or annually, whchever comes frst. Table 2d also requres DT to mantan records of Subpart ZZZZ mantenance for a mnmum of fve years. 40 CFR requres complance wth emsson lmtatons, operatng lmtatons, and operaton n a manner consstent wth safety and good ar polluton control practces for mnmzng emssons at all tmes. 40 CFR (e) requres operaton and mantenance ofthe RCE accordng to manufacturer's emsson-related wrtten nstructons or development of specfc engne mantenance plans whch provde for operaton n a manner consstent wth good ar polluton control practce for mnmzng emssons. 40 CFR ( ) nstructs the permttee to nstall a non-resettable hour meter on exstng area source emergency generator engnes f one s not already nstalled. 40 CFR (h) states that an engne's tme spent at dle durng startup be mnmzed to a perod needed for approprate and safe loadng of the engne not to exceed 30 mnutes after whch all applcable emsson standards apply. 40 CFR ( ) dctates how the emergency generator engne must be operated n order for the engne to be consdered an emergency statonary RCE under ths subpart. 40 CFR covers notfcatons for affected sources whle 40 CFR contans recordkeepng provsons for conducted mantenance. Table 8 lsts all of the General Provsons of Part 63.1 through whch are applcable. All applcable requrements from 40 CFR Part 63, Subpart ZZZZ have been added to the proposed TVOP renewal. Addtonal Federal Requrements 40 CFR Part 64: Complance Assurance Montorng The Complance Assurance Montorng (CAM) requrements of 40 CFR have been evaluated for applcablty to RM. The CAM rule was promulgated by EPA n 1997 and t s ntended to provde a reasonable assurance of complance wth applcable requrements under the Clean Ar Act (CAA). n accordance wth 40 CFR 64.2(a), CAM apples to each pollutantspecfc emsson unt (PSEU) that:

5 s located at a major source that s requred to obtan a Ttle V permt, s subject to an emsson lmtaton, Uses a control devce to meet that lmt, and Have pre-controlled emssons greater than the major source threshold. At the RM, control devces are not used to acheve complance wth emsson lmtatons. Therefore, CAM s not applcable to ths faclty. 40 CFR Part 68 Chemcal Accdent Preventon Provsons: Ths part sets forth the lst of regulated substances and thresholds and the requrements for owners or operators of statonary sources concernng the preventon of accdental releases. The substances and threshold quantty that are consdered a regulated substance under ths part are lsted n Tables 1, 2, 3, and 4 to 40 CFR DT does not store any of the lsted compounds at the Rochester Mlls Compressor Staton; therefore the requrements of ths subpart do not apply. 40 CFR Part 98 Mandatory Greenhouse Gas Reportng: Ths part was promulgated on October 30, n accordance wth 40 CFR 98.2(a), the Greenhouse Gas (GHG) reportng requrements and related montorng, recordkeepng, and reportng requrements of ths part apply to the owners and operators of any faclty that s located n the Unted States and that meets the requrements of ether paragraph 40 CFR 98.2 (a)(1), (a)(2), or (a)(3) of ths secton. However, publc comments to the Greenhouse Gas Mandatory Reportng Rule (GHG MRR) questoned the requrements of ths rule to meet current defntons of " applcable requrement" at 40 CFR 70.2 and The commentators requested that USEPA confrm ther nterpretaton of the regulatons. The EPA provded the followng response: "As current! y wrtten, the defnton of "applcable requrement" n 40 CFR 70.2 and 71.2 does not nclude a montorng rule such as today' s acton, whch s promulgated under CAA sectons 114(a)(l) and 208." The preamble of the fnal verson of the GHG MRR, located at 74 Fed Reg 209, pp , states that the GHG MRR s not consdered an "applcable requrement" under the Ttle V Operatng Permt program. Therefore, ths Subpart, whle t may be an oblgaton for ths faclty, s not consdered an applcable condton for ths Ttle V Operatng Permt. 40 CFR Parts 51 and 52 Greenhouse Gas Talorng Rule: Ths regulaton was ssued on May 13, Ths rule establshes a process for conductng Preventon of Sgnfcant Deteroraton (PSD) revews, ncludng Best Avalable Control Technology (BACT) determnatons for control of greenhouse gases (GHG) when a new source or a modfcaton to an exstng source results n emssons of GHGs n excess of certan thresholds. The applcablty of the Greenhouse Gas Talorng Rule was evaluated durng the revew of the Ttle V applcaton. New ndustral facltes that emt the equvalent of 100,000 tons of carbon doxde per year and modfed sources that ncrease ther emssons by 75,000 tons annually are requred to get PSD approvals for greenhouse gas emssons. Snce May 13,2010, there have not been any changes at ths ste, so GHG PSD has not been trggered. Equpment and Emssons:

6 The major sources of emssons at ths faclty are the two ngersoll Rand compressor engnes (Sources 101 and 102) each rated at 440 bhp. Table below shows the reported emssons for 2014 and 2015 and the permt lmts for each engne: Pollutant NOx co voc!! Permt Lmt lbs/hr tons/yr lbs/hr tons/yr lbs/hr tons/yr Source Amount reported on AMS report (TPY) Source Source Source Source Source ! ; n addton to the two compressor engnes, emergency generator, a dehydrator & steel, three storage tanks, a thermal oxdzer (control devce) and one source for fugtve emssons from the faclty. Table below shows the faclty wde reported emssons for 2014 and 2015 : Pollutant Amount selfreported on 2014 AMS report (TPY) Amount selfreported on 2015 AMS report (TPY) co NOx PMO PM SOx voc Total HAPs Formaldehyde Ammona C02 3, , Methane N There are no addtonal sources at the ste that are consdered trval or nsgnfcant actvtes

7 Conclusons and Recommendatons: Rochester Mlls Compressor Staton has met the regulatory requrements assocated wth ths applcaton submttal. The recent stack test was conducted on the enclosed flare on Aprl 19, The most recent nspecton was conducted on March 23, Reports ndcate that faclty s n complance wth all regulatory requrements. The attached proposed permt reflects terms and condtons as descrbed n ths permt applcaton. t s my recommendaton to ssue a Ttle V Operatng Permt renewal for ths faclty as proposed upon completon of the publc comment perod. Notce of ntent to ssue ths TVOP renewal wll be publshed n Pa Bulletn and local newspaper. EPA, the company and Ar Qualty nspector wll be provded wth ths proposed TVOP renewal.